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City of Santa Ana Planning Commission <br /> November 9, 2020 <br /> Page 2 <br /> supports the prioritization of parkland dedication over parkland impact fee collection. <br /> However, the Open Space Element does not fully explain how prioritization would occur <br /> for projects of fewer than 100 residential units. Implementation Action OS-1.16 indicates <br /> that the City should "[d]evelop an incentives program that encourages private <br /> development and public agencies to provide park and recreation facilities beyond the <br /> minimum requirements." Rise Up Willowick supports the creation of such incentives. <br /> However, the Open Space Element does not explain how the incentives program might <br /> operate or provide criteria to guide its implementation. The Open Space Element should <br /> be revised to further clarify these measures. <br /> Implementation Action OS-1.6 calls for the City to "[e]stablish land use <br /> provisions in the Municipal Code that prevent a net loss of parkland in the city" and <br /> "[r]equire at least a 1:1 replacement if there is any loss of public parkland due to <br /> development." We support the City's adoption of a "no net loss of parkland" requirement <br /> in the Municipal Code. However, we urge the City to clearly define what constitutes <br /> "parkland" for purposes of this requirement. The "no net loss of parkland" requirement <br /> should not impede the redevelopment of golf courses to include a mix of public parkland <br /> and affordable housing. As outlined in our October 6 letter to the City, The Trust for <br /> Public Land, the California Coastal Conservancy, and Clifford Beers Housing have <br /> submitted a proposal to the City of Garden Grove to develop most of the Willowick Golf <br /> Course site into a public park and to construct affordable housing on the remainder. The <br /> "no net loss of parkland" policy should not create barriers to projects such as the <br /> Willowick proposal that would create affordable housing and other community benefits <br /> in addition to public parkland. <br /> Implementation Action OS-1.151 calls for the City to "[a]mend the <br /> Residential Development Fee in the Municipal Code (Chapter 35, Article IV) to reflect <br /> requirements for Larger Residential Projects (100+ units, residential only or mixed-use) <br /> to provide two acres of new public parkland concurrent with the completion of and within <br /> a 10-minute walking radius of the new residential project." It also calls for the City to <br /> work with "new development projects within the Focus Areas" to encourage developers <br /> to provide more parkland than the Code requires. Similarly, Implementation Action OS- <br /> 1.8 calls for the City to update the Acquisition and Development Ordinance to increase <br /> dedication and fee requirements and ensure that parkland is acquired near projects <br /> creating demand. Rise Up Willowick supports these changes, and urges the City to ensure <br /> 1 The City's responses to comments in the Final EIR label this action as OS-1.14, but the <br /> Open Space Element of the revised Update identifies this action as OS-1.15. <br /> 1I � M1 11AN <br />