Item 37 - EIR No. 2020-03 and GPA No.2020-06 Santa Ana General Plan Update

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Page 2 of 2 3) The General Plan does not propose policies that will effectively address the City's deep parkland deficit. The City currently has a parkland deficit of 154.44 acres, which means that for every 1,000 residents there are only 1.54 acres of parkland.3 The deficit is projected to increase to 346.41 acres by the year 2045 based on the development and population increases the City anticipates the Plan's proposed policies will facilitate, or to 1.20 acres per every 1,000 residents.' Parks provide important benefits including improving physical and mental health, improving air quality, and reducing heat levels. They are essential to creating healthy and thriving communities. To ensure that the intensification of development does not further exacerbate the City's parkland deficit, the City should consider adopting the No -Net -Loss of Open Space being proposed by community groups like the Rise Up Willowick Coalition. This policy would require that current open space in the City lost to the market -rate housing be replaced at a 1-to-1 ratio. This policy would preserve open space in the City that can be converted to publicly accessible parkland. 4) In addition to concerns over the General Plan not addressing the City's current and future parkland deficit and the need for affordable housing policies, there are other environmental justice (EJ) issues the City's General Plan does not adequately address. Community groups like Orange County Environmental Justice, Madison Park Neighborhood Association, Santa Ana Active Transportation, and Thrive Santa Ana have raised concerns over the fact that the General Plan policies will not solve issues over air quality, lead contamination of soil, mobility, and the need to prioritize community -led land use and development, like through community land trusts. The City says that it has done an adequate amount of community outreach over the last year and, thus, it is ready to adopt the General Plan. While there were multiple EJ forums and an EJ survey where residents and community groups raised the concerns mentioned in this letter, the City's General Plan does not adequately address them. True community engagement means that the City not only provides ample opportunities for community input, but that the City also addresses the input residents provide. The Commission requests that the Council not adopt the General Plan being proposed tonight and instead direct City staff to work with residents and community groups to develop policies that actually address community needs and concerns. The Commission looks forward to partnering with the City of Santa Ana to create opportunities to increase affordable homes for lower income households in the City. If you have any questions, please feel free to contact me at (949) 250-0909 or cesarc@kennedycommission.org. Sincerely, Cesar Covarrubias Executive Director 3 Final Recirculated Draft Program Environmental Impact Report, Table 5.15 4, October, 2021, p. 5.15-28, htt alwww. anta-ana.or / ite ldefauPtPfile l l l eneral- lanll�ovf"Elf 2021/Volurne'1o2021Ch 05...15 REC.ndf. 4 Ibid.