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SHUT_ MIHALY- I N BERGERLLP 396 HAYES STREET, SAN FRANCISCO, CA 94102 GABRIEL M.B. ROSS T: (415) 552-7272 F: (415) 552-5816 Attorney www.smwiaw.com Ross@smwlaw.com November 9, 2020 Via Email City of Santa Ana Planning Commission 20 Civic Center Plaza Santa Ana, CA 92701 c/o Commission Secretary Sarah Bernal e a gsa o®a a,or . Re: Santa Ana General Plan Update EIR, Clearinghouse No. 2020020987 Dear Chair McLoughlin and Commissioners: On behalf of Rise Up Willowick, I write to comment on the proposed Santa Ana General Plan Update ("the Update") and its accompanying Environmental Impact Report("EIR"). In the Final EIR the City has proposed changes and additions to the Update's Open Space Element that seek to create new parkland and avoid loss of parkland. We commend the City for including these measures in response to feedback received on the Draft EIR. However, these General Plan measures are insufficient: they do not fully explain how increased creation of parkland will work, and are ambiguous as to what lands are included in a proposed prohibition on net loss of parkland. Moreover, the Open Space Element calls for several Municipal Code amendments to put these General Plan polices into effect, but would defer them until 2022. This will create a period of uncertainty until the measures are fully implemented. We urge the City to revise the Open Space Element to clarify these ambiguities, and to defer the Update so that it can be adopted concurrently with these code amendments. Moreover, the City should defer the Update so that it can be aligned with the City's new Housing Element and code amendments to strengthen the City's Housing Opportunity Ordinance (HOO). The revised Open Space Element Policy 1.3 indicates that the City should "prioritize the creation and dedication of new public parkland over the collection of impact fees" for new residential development in Focus Areas. Rise Up Willowick