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Memo to City of Santa Ana Planning Commission September 15, 2021 Page 5 The City's parkland standard is also less than the standard set out in the Quimby Act, Government Code section 66477, which allows cities to require that subdivisions dedicate parkland sufficient to provide up to three acres of park area per 1,000 subdivision residents. Moreover, Policy OS-1.3 has been weakened from the version included in the 2020 draft Update. While the previous draft policy called for the City to "achieve" a park ratio of two acres per 1,000 people (2020 Draft Open Space Element at 5; Final Environmental Impact Report at 2-17), the new draft merely says the City will "strive to attain" that standard. Open Space Element at 5. Given the importance of addressing the City's park deficiency, the policy's language should be mandatory. We therefore propose revising Policy OS-1.3 to read as follows: Policy OS-1.3: Park Standard. Establish and maintain public open space and recreation requirements for new residential and nonresidential development to provide sufficient opportunities for Santa Ana residents and visitors. Stfive to attain The City shall achieve a minimum citywide park ratio of two hree acres of pafk4apA-per 1,000 residents in the City. For new residential development in Focus Areas, the Ci . shall prioritize the creation and dedication of new public parkland over the collection of impact fees. We also propose that the Update include an additional implementation action calling for the City to amend the Municipal Code to reflect this standard: Implementation Action OS-1.16. Park Standard. Amend Municipal Code Chapter 35, Article IV to require that the City achieve a minimum citywide park ratio of three acres per 1,000 residents. 5. Proposed Changes to the Open Space Element's Policies on Parkland Creation and Distribution The Open Space Element currently includes the following policies relating to parkland creation and distribution: Policy OS-1.4. Park Distribution. Ensure the City residents have access to public or private parks, recreation facilities, or trails within a 10 minute walking and biking distance of home. Prioritize park provision, programs, and partnerships in park deficient an[d] environmental justice areas.