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Response to Letter L12: Linda Genis, dated August 12, 2024 <br />Comment L12.1: This comment states that there are too many units for the site and there could easily be <br />more than 8,000 residents. <br />Response L12.1: The comment does not raise any specific environmental concern with the analysis within <br />the Draft SEIR. As discussed on page 5.10-8 of the Draft EIR, the Project would result in approximately <br />9,238 residents based on the Santa Ana GPU FEIR person per household generation rate. While the Draft <br />EIR's analysis relies on the person per household generation rate of 2.41 from the GPU FEIR, due to the <br />potential unit type which would be developed within the Related Bristol Specific Plan, the applicant has <br />commissioned a study that suggests buildout could result in a lower generation rate of 1.74 persons per <br />household (Concord, 2023). Based on 1.74 PPH, buildout of the Project would result in 6,725 residents <br />inclusive of senior units. This comment will be forwarded to City decision makers as part of the staff report <br />for the Project. <br />Comment L12.2: This comment states that the open space should be 3 to 5 acres per 1,000 people and <br />the Project would result in open space at 1.6 acres per 1,000 people. The comment states that Santa Ana <br />is already short of open space compared to neighboring cities and questions how open space was <br />calculated. <br />Response L12.2: The comment does not raise any specific environmental concern with the analysis within <br />the Draft SEIR. As discussed on page 5.1 2-8 of the Draft SEIR, while the proposed Project would provide <br />approximately 17.21 acres of public and private open space, inclusive of 13.1 acres of publicly <br />accessible open space and recreational facilities onsite, per the requirements of the Related Bristol Specific <br />Plan, the proposed Project's provision of parkland would not meet the City of Santa Ana's GPU <br />performance standard of 3 acres of parkland for every 1,000 residents, either on the site or cumulatively. <br />As the existing ratio of acreage of parks and recreational facilities to existing City population results in a <br />parkland deficiency of approximately 154.44 acres, development of the proposed Project would continue <br />to result in a deficiency in parkland throughout the City of Santa Ana. The Project proposes to provide <br />approximately 1.4 acres of publicly accessible open space per 1,000 residents, which exceeds the <br />approximately 1.2 acres per 1,000 residents currently existing within the City. <br />In order to comply with the GPU policy of 3 acres of parkland per 1,000 residents, the proposed Project <br />would require 27.7 acres of parkland or the dedication of approximately 67.3 percent of the Project site. <br />While the proposed Project would provide approximately 17.21 acres of public and private open space <br />onsite, inclusive of 13.1 acres of publicly accessible open space and facilities, and would comply with <br />applicable Municipal Code requirements, the proposed Project would not provide 27.7 acres of parkland <br />and recreation facilities onsite and would not meet the City of Santa Ana's performance standard for <br />parkland, either on the site or cumulatively through the availability of parks and recreation facilities <br />citywide. As discussed in the GPU FEIR, the City of Santa Ana is essentially fully built out and there is a <br />lack of available vacant land to develop substantial new parks or expand existing facilities. Therefore, <br />there would be no feasible mitigation measures that would be able to reduce the proposed Project's <br />contribution to significant impacts related to the City's unsatisfactory level of resident to parkland ratio. As <br />such, impacts would be significant and unavoidable, which is consistent with the findings of the GPU FEIR. <br />Comment L12.3: This comment states that too many mitigations are required. <br />Response L12.3: The comment does not raise any specific environmental concern with the analysis within <br />the Draft SEIR and presents the commenter's opinion. No further response is warranted, and this comment <br />will be forwarded to City decision makers as part of the Project's staff report. <br />Comment L12.4: This comment states that although State law has relaxed parking requirements for near <br />transportation lines, the City's parking requirements are too low and ignore the fact that most people use <br />26 <br />