26 (01)
Susana Barrios
From:Liz Gonzales <liz@balancebpr.com>
Sent:Tuesday, October 28, 2025 9:22 AM
To:Public Comment
Subject:\[EXTERNAL\] Public Comment Submission – Balance Public Relations Letter
re: ATID Reforms (October 28 Council Meeting)
Attachments:Final Ltr Balance to Anaheim Council Oct 28 Meeting.pdf
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Dear City Clerk and Honorable Council Members,
On behalf of Dean Florez and Elaine Howle, Principals of Balance Public Relations, please find the attached
public comment letter regarding the proposed amendments to AMC § 2.14 and the Anaheim Tourism
Improvement District (ATID) Management Plan, scheduled for Council consideration at the October 28,
2025 meeting.
Given Balance’s role assisting the Anaheim Chamber during the 2023 State Audit, the letter offers
recommendations intended to strengthen transparency, prevent duplicative assessments, and ensure
compliance with the Brown Act. We respectfully request that this correspondence be entered into the public
record and distributed to the Mayor and City Council prior to deliberation.
We believe this letter meets the 1:30p.m PDT deadline for public comment.
Respectfully,
Liz
_________________________________________
Liz Gonzales | Relationship Director | Executive Assistant to Senator Dean Florez, Ret
Balance Public Relations, Inc.
(dl) 916.800.9710 | (
Email: liz@balancebpr.com
1
October 28, 2025
Mayor Ashleigh Aitken
Mayor Pro Tem Natalie Meeks
Members of the Anaheim City Council
City of Anaheim
200 S. Anaheim Blvd., 7th Floor
Anaheim, CA 92805
RE: Public Comment on Proposed Amendments to AMC § 2.14 and the ATID Management Plan
Dear Mayor Aitken and Honorable Members of the City Council,
We submit this letter jointly as Dean Florez, former Majority Leader of the California State Senate and
President of Balance Public Relations, and Elaine M. Howle, former California State Auditor and
senior advisor to Balance Public Relations, in response to the proposed amendments to AMC § 2.14
and the associated reforms to the Anaheim Tourism Improvement District (ATID) Management Plan.
As you know, Balance Public Relations previously assisted the Anaheim Chamber of Commerce
during the 2023 State Audit (Audit #2023-133), which addressed significant deficiencies in the City’s
contractual oversight of Visit Anaheim, particularly around the handling of ATID funds. The State
Auditor’s report identified key concerns—several of which remain “pending”—including lack of
performance metrics, inadequate fund segregation, and deficient subcontractor oversight . These
findings were not abstract: they reflected patterns that raise constitutional and statutory red flags
across California’s network of Tourism Improvement Districts.
We write today to express our support for many of the reform elements proposed in the October 28
draft correspondence prepared by the Chamber, particularly the elimination of double-billing
practices, mandatory Brown Act compliance, and statutory recognition of assessed hotel members
as dues-exempt participants in any public-funded service or benefit. It is critical that the Council
consider adopting stronger language around:
1. Prohibiting duplicate assessments for transportation services where mitigation or private
contributions already satisfy obligations. No assessed business should ever be required to
pay twice for the same service—once through a public assessment and again through private
dues. This practice is inconsistent with Article XIII C of the California Constitution, which bars
duplicative levies for identical public benefits. Anaheim must codify a clear prohibition against
any “double dip” in both the ordinance and management plan. Such language not only protects
hotel operators from inequitable treatment but also shields the City from future audit findings
and potential legal challenge under California’s Unfair Competition Law.
2. Ensuring all ATID-funded services are equally available to assessed entities, regardless of
whether they pay additional private dues to the Contracting Entity. Every business paying the
ATID assessment is entitled to the full and fair benefit of those funds —without condition,
favoritism, or additional payment. We strongly recommend adding explicit language recognizing
all assessed entities as members in good standing of the contracting entity and barring any
requirement for additional dues or sponsorship fees. This simple reform will align Anaheim with
statewide standards for public-benefit districts and prevent the perception that access to
City-subsidized programs can be privately purchased.
3. Requiring formal approval of all ATID component fund budgets in publicly noticed meetings,
with full Brown Act compliance across marketing, housing, and transportation committees.
While recent amendments add public transparency for the Transportation and Housing
components, the Marketing Component remains insulated from open-meeting requirements.
This omission contradicts both the spirit and the letter of the Ralph M. Brown Act, which applies
to any body entrusted with the expenditure of public funds. The City should require that all ATID
component budgets—Marketing, Housing, and Transportation—be publicly noticed,
deliberated, and approved in open session. Anything less perpetuates the opacity the State
Auditor explicitly warned against.
As former public ogicials with direct oversight experience in both legislative and auditing capacities,
we respectfully urge the Council to view this moment not as a routine contract update, but as an
opportunity to set a statewide standard for tourism district accountability. Anaheim has the chance
to lead—not follow—in advancing public integrity and restoring trust in how millions in assessments
are levied, managed, and disclosed.
Anaheim now stands at a crossroads. The City can either reagirm the integrity of its public finance
system or risk repeating the same governance failures that drew statewide scrutiny in 2023. The
proposed reforms, if strengthened as recommended above, would elevate Anaheim as a model for
lawful, transparent, and equitable district management—one that both the public and the tourism
industry can trust.
We appreciate the Council’s attention to these issues and remain available to provide any further
technical assistance or clarification regarding the audit findings or statutory framework.
We are available to provide additional clarification or technical support if needed. Thank you for your
attention to these serious and timely issues.
Respectfully,
Dean Florez
President, Balance Public Relations
Former Senate Majority Leader, California State Senate
Elaine M. Howle
Strategic Advisor, Balance Public Relations
California State Auditor (Retired)