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a April 19, 2022 RE: Comment on No-Net-Loss Policy in the Santa Ana General Plan Update Dear Santa Ana Mayor, Councilmembers and Staff, The Rise Up Willowick Coalition ("the Coalition")is comprised of residents from the City of Santa Ana ("the City"), the City of Garden Grove, and neighboring Orange County cities as well as local organizations whose goal is to ensure that the Willowick Golf Course site ("Willowick") is developed to meet the needs of current local residents and their vision-- especially the most vulnerable such as, but not limited to, low income individuals, youth, and immigrant residents -- which includes deep affordable housing, parkland for active recreational use, and green space. The Coalition appreciates the City's efforts to address the community's environmental justice concerns through the General Plan Update. While the City has made necessary revisions to the draft General Plan, we believe there is still more the City can do to make sure the draft General Plan adequately addresses environmental injustice in Santa Ana. The proposed General Plan update includes Implementation Action OS 1.4: "No-net-loss of parkland. Establish land use provisions in the Municipal Code that prevent a net loss of public parkland in the city. Require at least a 1:1 replacement if there is any loss of public parkland due to public or private development." In our letters of October 6, 2021 and December 7, 2021, Rise Up Willowick has proposed extending this policy to all open space, including privately-owned areas like Willowick Golf Course. The City has declined to consider whether the proposal would benefit the community, instead raising concerns that it would constitute a taking of property. RUW believes these concerns are overblown. The City could easily craft a policy to avoid any unconstitutional effect. Policies very similar to the proposed no-net-loss of open space already exist throughout California. Many cities and counties have mitigation policies that require the replacement of land—such as agricultural land or habitat for endangered species--impacted by development. These policies apply to private land, and do precisely what the proposed open space policy would do. These widespread mitigation policies are constitutional. As just one example, Stanislaus County has adopted a Farmland Mitigation Program aimed at"mitigating the loss of farmland resulting from residential development in the unincorporated areas of Stanislaus County by requiring the permanent protection of farmland based on a 1:1 ratio to the amount of farmland converted." See Stanislaus County General Plan,Agriculture Element, Appx B. The Court of Appeal upheld this Page 1 of 2