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nM <br /> � . wIF` <br /> 396 HAYES STREET, SAN FRANCISCO, CA 94102 GABRIEL M.B. ROSS <br /> T: (415) 552-7272 F: (415) 552-5816 Attorney <br /> www.smwlaw.com Ross@smwlaw.com <br /> October 6, 2020 <br /> Verny Carvajal <br /> Principal Planner <br /> City of Santa Ana Planning and Building <br /> Agency <br /> 20 Civic Center Plaza <br /> P.O. Box 1988 (M-20) <br /> Santa Ana, CA 92702 <br /> vcarvajal@santa-ana.org <br /> Re: Comments on Santa Ana General Plan Update DPEIR, <br /> Clearinghouse No. 2020020987 <br /> Dear Mr. Carvajal: <br /> On behalf of Rise Up Willowick, I write to provide comments on the proposed <br /> Santa Ana General Plan Update ("the Update") and its accompanying Draft Program <br /> Environmental Impact Report ("the DPEIR"). The Update will guide the development of <br /> Santa Ana, including the Willowick Golf Course site, for many years, and the California <br /> Environmental Quality Act ("CEQA"), Public Resources Code § 21000 et seq., requires <br /> that the DPEIR thoroughly assess the Update and its environmental impacts. As set forth <br /> in the following comments, we urge the City to (1) continue to designate the Willowick <br /> site as open space, (2) provide for more affordable housing under the Update and avoid <br /> undermining the Housing Element and the City's Housing Opportunity Ordinance (the <br /> "HOO"), and (3) revise the DPEIR to fully analyze the Update's environmental impacts, <br /> especially those related to displacement and environmental justice. <br /> L The bulk of the Willowick site should continue to be designated as open space. <br /> The Willowick Golf Course site lies within the West Santa Ana Boulevard Focus <br /> Area, one of the focus areas slated for new development under the Update. DPEIR at 4-6. <br /> The Willowick site is currently designated as open space, and the Update proposes to <br /> maintain that designation. DPEIR at D-6 to D-8. Rise Up Willowick supports this <br /> designation until and unless there is a proposal for developing part of the site with <br /> affordable housing. The Trust for Public Land, the California Coastal Conservancy, and <br />