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Memo to City of Santa Ana Planning Commission September 15, 2021 Page 3 Although the Open Space Element already includes a"no net loss of parkland" implementation action (discussed below), the "no net loss" concept is so important and fundamental that it should be articulated as a policy as well. Moreover, given the shortage of both parks and open space in the City, this policy should apply to all open space, not merely to parkland. The City already has a "parkland deficiency" of 118.14 acres, which is expected to increase to 299.48 acres under the Update unless new parks are built. RDPEIR at 5.15-28. Non-park open space provides an important supplemental recreational resource, and can potentially be developed into parkland in the future. The City cannot afford to lose any of its existing parkland or open space acreage. 3. Proposed Changes to the Update's "No Net Loss" Implementation Action The draft Open Space Element currently includes this provision: Implementation Action [OS-]1.4: No-net-loss of parkland. Establish land use provisions in the Municipal Code that prevent a net loss of public parkland in the city. Require at least a 1:1 replacement if there is any loss of public parkland due to public or private development. City of Santa Ana Draft General Plan Update, Open Space Element, at 16. The City proposes to enact the no-net-loss ordinance in 2022; the City's Parks, Recreation and Community Services Agency (PRCSA) would be responsible. We commend the City for including this "no net loss" implementation action in the Update. However, as explained above, this provision should apply to all open space, not only to parkland. The implementation action should specify that net loss of open space will be avoided by prohibiting development that causes such a net loss. Moreover, the provision should clarify that replacement parks and open space must be located within 0.5 miles of the lost parks and open space, to ensure that the replacements serve the same communities. Finally, the implementation action should require that development of replacement parks and open space occur before the closure of the lost parks or open space. This will ensure that there is not a lag or"gap" in time where communities lose park or open space access if the replacement process is delayed. We propose modifying Open Space Element Implementation Action OS-1.4 to read as follows: Implementation Action OS-1.4: No Net Loss of park!+nd Open Space. Establish land use provisions in the Municipal Code that pfevent-prohibit development that causes a net loss of r„blie pafk aP Open Space in the city, including City parks as well as other public and private land designated as Open Space under the General Plan or the zoning code, but excluding an. acreageof a golf course that is