HomeMy WebLinkAbout2 - PUBLIC COMMENT_GuerraNovember 9, 2020
Planning Commission Chair and Members
City Council Chamber
22 Civic Center Plaza
Santa Ana, CA 92701
RE: Item 2: Environmental Impact Report No. 2020-03 and General Plan Amendment No.
2020-06 For The Comprehensive Update To The Santa Ana General Plan
Dear Planning Commission Chair and Members,
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 which includes deep
affordable housing, parkland for active recreational use, and open green space.
As the Planning Commission reviews the General Plan Update (“GP Update”) and
finalized Environmental Impact Report (“EIR”), we ask the Commission to recommend
postponing the adoption of the GP Update. We believe that there are community concerns
that have not been properly or at all addressed by the GP Update which require more and better
community engagement. In this letter we will highlight these concerns, which we made known in
the public comment letter the Coalition submitted on October 5, 2020 response to the Santa
Ana GP Update Draft Program Environmental Impact Report (“DPEIR”).
Impact on Open Space
In our October 5th public comment letter, we stated that the City should 1) keep Willowick zoned
as Open Space due to the deficit of open space in the City, and 2) that there were
inconsistencies with the policies proposed in the Land Use Element and Open Space Element
that would make it hard for the City to achieve its General Plan goals of increasing open space.
In regards to our first concern, we commend the City for continuing to maintain Willowick zoned
as open space. Willowick is critical in addressing the parkspace deficit in the City given that
there is very little open space remaining in the City that could help address this deficit.
Our second concern was that the City’s proposed land use policies in the GP Update hindered
the City’s ability to meet its Open Space Element goal of increasing the amount of open space
in the City to 2 acres of open space per 1000 residents. The reason for this was that the 1
increase in open space will not be sufficient to keep pace with the anticipated increases in
residential density and population that will result from the development the GP Update
1 Santa Ana Open Space Element, Policy 1.3, p. 5. August, 2020.
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Received 11/9 at 5:33 p.m.
incentivizes. In fact, under the proposed GP Update, after the development and population
increases anticipated in the DPEIR are reached, the City would still have an open space need of
299.48 acres, increasing from a current need of 107.56 acres (DPEIR at 5.15-16).
We commend the City for trying to address this concern by proposing new policies that can
address the park space deficit more adequately. However, the Coalition believes that there is
still a lot of uncertainty around the policies proposed that the City needs to clarify before
determining if the policies are adequate and, thus, before the GP Update can be sent to
the City Council for adoption.
1.Open Space Element Policy 1.3 says 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. Our concern is that this policy does not address
prioritization for projects of fewer than 100 residential units as it should.
2.Implementation Action OS-1.15 calls for the City to “[a]mend the Residential
Development Fee in the Municipal Code (Chapter 35, Article IV) to reflect requirements
for Larger Residential Projects (100+ units, residential only or mixed-use) to provide two
acres of new public parkland concurrent with the completion of and within a 10-minute
walking radius of the new residential project.” Similarly, Implementation Action OS-1.8
calls for the City to update the Acquisition and Development Ordinance to increase
dedication and fee requirements and ensure that parkland is acquired near projects
creating demand. The Coalition believes these changes should apply to all new
market-rate projects, including those smaller than 100 units.
3.Implementation Action OS-1.16 says that the City should “[d]evelop an incentives
program that encourages private development and public agencies to provide park and
recreation facilities beyond the minimum requirements.” The issue is that the City does
not provide an explanation on how the incentives would work or be implemented.
4.Implementation Action OS-1.6 calls for the City to “[e]stablish land use provisions in the
Municipal Code that prevent a net loss of parkland in the city” and “[r]equire at least a 1:1
replacement if there is any loss of public parkland due to development.” Our first
concern is that there needs to be clarification on the definition of “parkland.” It is
unclear if this policy applies to sites like Willowick given that it is zoned as open space,
but it is not a public park but a golf course. Our second concern is that the policy
needs more detail to ensure it does not create barriers to projects that will provide
a combination of only parkland and affordable housing on golf courses. These
types of projects are not the same as market-rate housing and commercial development.
The Coalition still believes that Willowick should be developed primarily as open space
with a limited part developed as affordable housing in order to properly meet the
community’s needs. The project proposal submitted to the City of Garden Grove by The
Trust for Public Land, the California Coastal Conservancy, and Clifford Beers Housing
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can help achieve this. But proposals such as this one might be impacted if the proposed 2
policy is not refined.
Impact on Affordability of Proposed Development
In the Coalition's comment to the DPEIR in October, we stressed our concerns that the type of
development being facilitated by the GP Update land use policies will not be affordable to
existing residents and, instead, increase housing costs. The City’s response was that since
housing affordability is not considered an environmental issue under CEQA, the City did not
need to respond through the DPEIR. However, this continues to be a concern for residents.
The GP Update would increase the allowable density of residential development in the five
identified focus areas in the GP Update (DPEIR at 1-6, 1-7, H-a-7.). This will lead to increased
development by allowing projects to increase their density automatically without needing to
request approval from the City. The changes in the density requirements and land use
designations mentioned above facilitate development by eliminating approvals developers had
to request in the past. This has an adverse effect on the Housing Opportunity Ordinance’s
(HOO) ability to require developers to either include affordable units or pay an in-lieu fee when
requesting a density allowance. If higher densities are allowed, developers will not request
higher density permits, and thus, not trigger the HOO’s requirements resulting in more
market-rate development and less affordable housing.
In its response to our DPEIR comment, the City acknowledges the increase in residential
development, stating that the GP Update would convert what are currently 581 acres of
nonresidential land use to residential uses. However, the City does not mention an affordability
requirement on any of the 581 acres. As previously stated, if there is no explicit requirement of
affordability accompanying the proposed GP Update land use policies, and the HOO has been
amended in a way that reduces its effectiveness to produce affordable housing, then there is a
high probability that the residential unit increases the DPEIR anticipates, will be at the
market-rate level and not affordable. Given that 84% of residents are in occupations that pay
less than $53,500 per year, and the annual median income in Orange County starts at
$103,000, it is safe to say the majority of the new market-rate housing units will not be 3
accessible to the majority of residents in Santa Ana. We continue to ask the Planning
Commission and City staff to postpone the approval of the GP Update to address this
concern which has largely been ignored.
2 Willowick Community Park Proposal, Trust For Public Land, p. 17. 3CA HCD State Income Limits for 2020, April, 2020.
https://hcd.ca.gov/grants-funding/income-limits/state-and-federal-income-limits/docs/income-limits-2020.pdf
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SB1000 and Environmental Injustice
In our October letter, the Coalition raised concerns over the inadequate assessment of the
City’s environmental justice issues and the policies proposed to address them. The City
responded that it was not required under CEQA to address environmental justice concerns
through the DPEIR. However, residents are still waiting for policies that will effectively address
their environmental justice (“EJ”) issues. Community members, including the Coalition,
continuously raise concerns over the rushed implementation of SB1000, which mandates the
City to incorporate EJ principles into their GP Update due to the fact that almost half the City is
considered a disadvantaged community (“DAC”). A DAC is defined as a “ low-income area that 4
is disproportionately affected by environmental pollution and other hazards that can lead to
negative health effects, exposure, or environmental degradation.” The City began its 5
community outreach on EJ issues this year, after the Covid-19 pandemic began. Not only are
the few months of outreach insufficient, the outreach has not been as effective given that the
Covid-19 pandemic has severely limited the type of outreach conducted and accessibility to
residents. Given the importance of addressing EJ concerns, the Commission should
recommend the City postpone the approval of the GP update until improved community
outreach is possible that can then lead to better EJ policies.
Conclusion
We ask the Commission to recommend that the GP Update be postponed until 1) the new
open space policies are refined with consultation from the community 2) the City
addresses housing affordability and EJ concerns that have yet to be properly addressed,
and 3) better and increased community outreach is possible which the Covid-19
pandemic currently limits.
The Coalition looks forward to seeing how the City implements these community-informed
recommendations and improves its community engagement efforts. For any questions please
contact Cynthia Guerra at cguerra@riseupwillowick.org.
Thank you,
The Rise Up Willowick Coalition
4 CalEnviroScreen 3.0. California Office of Environmental Health and Hazard Assessment. June 2018.
https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-30
5 Government Code Section 65302. https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201520160SB1000
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