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<br /> <br /> <br />November 9, 2020 <br />Via Email <br /> <br />City of Santa Ana Planning Commission <br />20 Civic Center Plaza <br />Santa Ana, CA 92701 <br />c/o Commission Secretary Sarah Bernal <br />SBernal@santa-ana.org. <br /> <br />Re: Santa Ana General Plan Update EIR, Clearinghouse No. <br />2020020987 <br /> <br />Dear Chair McLoughlin and Commissioners: <br />On behalf of Rise Up Willowick, I write to comment on the proposed Santa <br />Ana General Plan Update (“the Update”) and its accompanying Environmental Impact <br />Report (“EIR”). <br />In the Final EIR the City has proposed changes and additions to the <br />Update’s Open Space Element that seek to create new parkland and avoid loss of <br />parkland. We commend the City for including these measures in response to feedback <br />received on the Draft EIR. However, these General Plan measures are insufficient: they <br />do not fully explain how increased creation of parkland will work, and are ambiguous as <br />to what lands are included in a proposed prohibition on net loss of parkland. Moreover, <br />the Open Space Element calls for several Municipal Code amendments to put these <br />General Plan polices into effect, but would defer them until 2022. This will create a <br />period of uncertainty until the measures are fully implemented. We urge the City to <br />revise the Open Space Element to clarify these ambiguities, and to defer the Update so <br />that it can be adopted concurrently with these code amendments. Moreover, the City <br />should defer the Update so that it can be aligned with the City’s new Housing Element <br />and code amendments to strengthen the City’s Housing Opportunity Ordinance (HOO). <br />The revised Open Space Element Policy 1.3 indicates that the City should <br />“prioritize the creation and dedication of new public parkland over the collection of <br />impact fees” for new residential development in Focus Areas. Rise Up Willowick