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Verny Carvajal October 6, 2020 Page 2 Clifford Beers Housing have submitted a proposal to the City of Garden Grove pursuant to the Surplus Land Act, Government Code sections 54220 et seq., to develop the majority of the site into a community park, with affordable housing on the remainder. See Willowick Community Park Proposal, attached as Exhibit A. This public green space will further the goals and policies of the General Plan's Open Space Element, which call for the preservation of existing open space areas and the creation of new public parks. DPEIR at 5.15-13, 5.15-14 (Open Space Element, Goals 1-3). Designation of the majority of the Willowick site as public open space will help meet the growing demand for parks in the City. The Update's proposed increase in residential density in many areas of the City would lead to increased demand for parks and open space. DPEIR at 5.15-15, 5.15-17. The DPEIR projects that the proposed land use changes would result in construction of an estimated 36,261 dwelling units across the City (DPEIR at H-b-5), and a population increase of 96,855 people (DPEIR at 5.15-16). However, park acreage under the Update would increase by only 1.84 acres. Id. Open Space Element Policy 1.3 calls for the City to achieve a minimum park standard of two acres of parkland per 1,000 residents. The City currently does not meet this per-resident standard, and under the Update the shortfall is projected to increase further: the total "parkland deficiency" would increase from 107.56 acres to 299.48 acres at build-out unless additional parks are provided. DPEIR at 5.15-16. The DPEIR calculates that the City currently has 561.94 acres of parkland, but it includes other kinds of open space in this total, such as sports facilities and school recreational facilities. DPEIR at 5.15-10. Although the DPEIR does not fully explain the basis for this parkland calculation, it appears that it may inappropriately count golf courses and cemeteries towards the parkland total. Golf courses, including the Willowick golf course, are classified as "open space." DPEIR at 5.15-10. A golf course, only usable by a small segment of the population and even then for a fee, is not the kind of public space that meets the community's needs. Cemeteries are also classified as "open space," although they are not available for recreational uses. DPEIR at 3-15. Thus, if the DPEIR counts these areas as parkland, the current park deficit is actually greater than the City claims. Despite the admitted deficit, the DPEIR concludes that the Update will have less than significant impacts related to park demand. DPEIR at 5.15-15 to 5.15-17 (Impact 5.15-1). It reasons that"[p]rovision of parks under implementation of the GPU, which will occur over time, is expected to keep pace with the increase in population growth related to the plan and would not result in a significant impact."Id. at 5.15-16. The DPEIR assumes that the City will develop significantly more open space than the 1.84 acres of future parks designated in the Update, funded via in-lieu impact fees collected