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® WOODRUFF, SPRADLIN G SMART THOMAS F. NIXON DIRECT DIAL: (714) 415 -1012 DIRECT FAX: (714) 415 -1192 E-MAIL: TNIXON ®WSS- LAW.COM September 12, 2014 VIA E -MAIL Honorable Mayor and Members of the City Council City of Santa Ana 20 Civic Center Plaza Santa Ana, CA 92701 Re: Environmental Impact Report No. 2014 -01 General Plan Amendment No. 2014 -02 Zoning Ordinance Amendment No. 2014 -01 Amendment Application No. 2014 -02 for the Harbor Mixed Use Transit Corridor Specific Plan Honorable Mayor and Members of the City Council: This firm serves as City Attorney to the City of Garden Grove ( "Garden Grove "). Garden Grove owns the property presently comprised of the Willowick Golf Course (the "Property"). The purpose of this letter is to formally register Garden Grove's concerns regarding the effect on the Property of the above - referenced proposed land use actions. Garden Grove purchased the Property in 1964. Although the Property has continued to be operated as a golf course since that time, the City of Santa Ana has long permitted and planned for the potential development of a more intense commercial recreational use on the Property. The 1982 North Harbor Redevelopment Plan designated the Property for parks, recreational and open spaces with Commercial/Industrial designations cited for alternative uses (see North Harbor Specific Plan, Appendix, pg. 16)., and since 1994, the zoning applicable to the Property has conditionally permitted "commercial recreational facilities." In 1974, Garden Grove granted the City of Santa Ana a 25 -year open space easement over the Property; however, this open space easement was never extended and expired pursuant to its own terms in 1999. The City of Santa Ana adopted the North Harbor Specific Plan ( "NHSP ") in 1994. The NHSP established land use and zoning regulations for an approximately 424.6 acre area that includes the Property. According to its text, the NHSP was "written as a regulatory tool to promote, not disallow changes," and "[i]ts intent is to provide a regulatory mechanism that is flexible in its enforcement and responsive to future changes and needs." The Property is designated as "Open Space" under the NHSP, but the NHSP expressly recognizes that " Willowick Golf Course ... [does] not play a major role as open space in the community." (NHSP, Appendix, pg. 5). 555 ANTON BOULEVARD,SVITE 1200 ■ COSTA MESA, CA 92626 -7670 ■ (714)558 -7000 ■ FAX (714)835-7282 WWW.WSS-LAW.COM CCM 09/16/2014 1028652.1 75B