24 (01)Date:3/21/2026 4:37:07 PM
From:"S R" shelly.n.robbins@gmail.com
To:"Ryan Balius" RBalius@anaheim.net, "Public Comment" publiccomment@anaheim.net
Cc:"City Clerk" cityclerk@anaheim.net
Subject:[EXTERNAL] Meeting 3-24-26 Agenda Items 24 & 25 – Anaheim Hills Festival Proje ct (DEV2023-00043) – Response to
Rehearing Denial and Related Actions
Warning: This email originated from outside the City of Anaheim. Do not click links or open attachme nts unle ss you recognize the
sender and are expecting the message.
Date: 3/21/26
Honorable Councilmember Ry an Balius,
Thank y ou for y our time and consideration of this matter. I rec ognize the complex ity of the issues befo re y o u and the responsibility inv olv ed
in balancing c ommunity needs, dev elopment, and public safety . This response is offered in good faith and is intentionally foc used o n a small
number of key proc edural and analy tical c onsiderations that remain unresolv ed in the rec ord and are important to ensuring a c omplete and
informed decision-making process.
1. I ncomplete Wildfire Evacuation Analysis
The City acknowledges that a comprehensiv e wildfire ev ac uation plan is currently in dev elo pment, y et the Projec t was appro v ed prio r to
c ompletion of that analy sis. This raises a fundamental conc ern under CEQA, which requires dec isio ns to be based o n the best av ailable
information—particularly where public safety is at stake.
The ev ac uation analy sis relied upon in the EI R does not appear to incorporate:
Updated regional traffic c onditions
Real-world human behav ior during emergenc y ev ac uations
Cumulativ e impacts across known bottlenecks and c onstrained ev acuation routes
Approv ing the Projec t while a City -initiated ev ac uation study remains incomplete c reates a disc onnec t between ac knowledged risk and the
c onclusions relied upon for approv al.
2. Procedural Limitations on Public Participation
The administrativ e record reflects that the public hearing was formally closed on January 1 3, 20 26, while deliberations and c onsideratio n of
the Projec t continued thereafter. Although general public c omment was permitted at subsequent meetings, this is no t equiv alent to
partic ipation within an open public hearing tied to ac tiv e deliberation.
This distinc tion matters. Meaningful partic ipation under CEQA is intended to occ ur within the dec ision-making framewo rk itself, where public
input c an direc tly inform the outc ome. The struc ture used here limited that opportunity .
3. Departure from Adopted Public Comment Procedures
The Project inv olv ed legislativ e c omponents, y et public comment was limited to three minutes per speaker without a c lear ex planation in the
record for dev iating from the City ’s standard fiv e-minute alloc ation for legislativ e matters.
Adherenc e to established proc edures is essential to maintaining consistenc y and public trust. Where dev iations o c c ur, the basis fo r tho se
decisions should be c learly doc umented.
4. I nconsistent Project Description – Parking Discrepancy
The administrativ e record contains conflic ting information regarding required parking:
Draft EIR: 1 ,07 5 spaces
Parking Study : 963 spaces
While this disc repancy has been acknowledged, it does not appear to hav e been fully reconc iled in the rec ord. A stable and internally
c onsistent projec t desc ription is foundational under CEQA , as it directly informs the analy sis and the findings relied upon fo r appro v al.
5. Access to I nformation and Transparency
Certain materials requested during the rev iew proc ess, including internal c ommunications and tec hnic al ev aluations, were not made av ailable.
These materials are relev ant to understanding how key analy ses—particularly those related to fire safety and ev ac uation—were ev aluated and
relied upon.
Ac cess to this information supports informed public participation and confidence in the dec isio n-making proc ess.
Conclusion
This response is not intended to restate the full appeal, but rather to highlight a set of focused c onsideratio ns that remain unresolv ed in the
administrativ e record. Taken together, these issues raise important questions about whether the Projec t was rev iewed and appro v ed based on
a c omplete and procedurally consistent framework.
At minimum, the record reflects:
Approv al prior to com pletion of a c om prehensiv e ev acuation analy sis
Lim itations on m eaningful public participation during deliberation
I nc onsistenc ies in core projec t data
Dev iations from standard procedural practic es
For these reasons, I respectfully request that the Council grant the appeal, or at minimum, remand the matter fo r further analy sis and
proc edural c larific ation to ensure that the decision is based on a c omplete and consistent rec o rd.
This correspondenc e is submitted to ensure the administrativ e record ac curately reflec ts the pro c edural and analy tic al issues raised prior to
final action.
Respectfully Submitted,
Shelly Robbins
shelly.n.robbins@gmail.com
81 41 E. Kennedy Rd, Anaheim, CA
Date:3/21/2026 4:41:56 PM
From:"S R" shelly.n.robbins@gmail.com
To:"Carlos A. Leon" CLeon@anaheim.net, "Public Comment" publiccomment@anaheim.net
Cc:"citycityclerk@anaheim.net" citycityclerk@anaheim.net
Subject:[EXTERNAL] Meeting 3-24-26 Agenda Items 24 & 25 – Anaheim Hills Festival Proje ct (DEV2023-00043) – Response to
Rehearing Denial and Related Actions
Warning: This email originated from outside the City of Anaheim. Do not click links or open attachme nts unle ss you recognize the
sender and are expecting the message.
Dat e: 3/21 /26
Honorable Councilmember Carlos Leon,
Thank y ou for y our time and consideration of this matter. I rec ognize the complex ity of the issues befo re y o u and the responsibility inv olv ed
in balancing c ommunity needs, dev elopment, and public safety . This response is offered in good faith and is intentionally foc used o n a small
number of key proc edural and analy tical c onsiderations that remain unresolv ed in the rec ord and are important to ensuring a c omplete and
informed decision-making process.
1. I ncomplete Wildfire Evacuation Analysis
The City acknowledges that a comprehensiv e wildfire ev ac uation plan is currently in dev elo pment, y et the Projec t was appro v ed prio r to
c ompletion of that analy sis. This raises a fundamental conc ern under CEQA, which requires dec isio ns to be based o n the best av ailable
information—particularly where public safety is at stake.
The ev ac uation analy sis relied upon in the EI R does not appear to incorporate:
Updated regional traffic c onditions
Real-world human behav ior during emergenc y ev ac uations
Cumulativ e impacts across known bottlenecks and c onstrained ev acuation routes
Approv ing the Projec t while a City -initiated ev ac uation study remains incomplete c reates a disc onnec t between ac knowledged risk and the
c onclusions relied upon for approv al.
2. Procedural Limitations on Public Participation
The administrativ e record reflects that the public hearing was formally closed on January 1 3, 20 26, while deliberations and c onsideratio n of
the Projec t continued thereafter. Although general public c omment was permitted at subsequent meetings, this is no t equiv alent to
partic ipation within an open public hearing tied to ac tiv e deliberation.
This distinc tion matters. Meaningful partic ipation under CEQA is intended to occ ur within the dec ision-making framewo rk itself, where public
input c an direc tly inform the outc ome. The struc ture used here limited that opportunity .
3. Departure from Adopted Public Comment Procedures
The Project inv olv ed legislativ e c omponents, y et public comment was limited to three minutes per speaker without a c lear ex planation in the
record for dev iating from the City ’s standard fiv e-minute alloc ation for legislativ e matters.
Adherenc e to established proc edures is essential to maintaining consistenc y and public trust. Where dev iations o c c ur, the basis fo r tho se
decisions should be c learly doc umented.
4. I nconsistent Project Description – Parking Discrepancy
The administrativ e record contains conflic ting information regarding required parking:
Draft EIR: 1 ,07 5 spaces
Parking Study : 963 spaces
While this disc repancy has been acknowledged, it does not appear to hav e been fully reconc iled in the rec ord. A stable and internally
c onsistent projec t desc ription is foundational under CEQA , as it directly informs the analy sis and the findings relied upon fo r appro v al.
5. Access to I nformation and Transparency
Certain materials requested during the rev iew proc ess, including internal c ommunications and tec hnic al ev aluations, were not made av ailable.
These materials are relev ant to understanding how key analy ses—particularly those related to fire safety and ev ac uation—were ev aluated and
relied upon.
Ac cess to this information supports informed public participation and confidence in the dec isio n-making proc ess.
Conclusion
This response is not intended to restate the full appeal, but rather to highlight a set of focused c onsideratio ns that remain unresolv ed in the
administrativ e record. Taken together, these issues raise important questions about whether the Projec t was rev iewed and appro v ed based on
a c omplete and procedurally consistent framework.
At minimum, the record reflects:
Approv al prior to com pletion of a c om prehensiv e ev acuation analy sis
Lim itations on m eaningful public participation during deliberation
I nc onsistenc ies in core projec t data
Dev iations from standard procedural practic es
For these reasons, I respectfully request that the Council grant the appeal, or at minimum, remand the matter fo r further analy sis and
proc edural c larific ation to ensure that the decision is based on a c omplete and consistent rec o rd.
This correspondenc e is submitted to ensure the administrativ e record ac curately reflec ts the pro c edural and analy tic al issues raised prior to
final action.
Respectfully Submitted,
Shelly Robbins
shelly.n.robbins@gmail.com
81 41 E. Kennedy Rd, Anaheim, CA
Date:3/21/2026 4:44:55 PM
From:"S R" shelly.n.robbins@gmail.com
To:"Ashleigh Aitken" AAitken@anaheim.net, "Public Comment" publiccomme nt@anahe im.ne t
Cc:"City Clerk" cityclerk@anaheim.net
Subject:[EXTERNAL] Meeting 3-24-26 Agenda Items 24 & 25 – Anaheim Hills Festival Proje ct (DEV2023-00043) – Response to
Rehearing Denial and Related Actions
Warning: This email originated from outside the City of Anaheim. Do not click links or open attachme nts unle ss you recognize the
sender and are expecting the message.
Dat e: 3/21 /26
Honorable May or A itken,
Thank y ou for y our c ontinued leadership and thoughtful engagement on this matter. I apprec iate the c are and c o nsideration y o u hav e already
brought to ev aluating the Anaheim Hills Festiv al Project. As the Counc il c onsiders A genda Items 24–25 , I am o ffering this foc used response in
good faith to highlight sev eral procedural and analy tic al considerations that remain relev ant to ensuring a c o mplete and well-suppo rted
decision-making process.
1. I ncomplete Wildfire Evacuation Analysis
The City acknowledges that a comprehensiv e wildfire ev ac uation plan is currently in dev elo pment, y et the Projec t was appro v ed prio r to
c ompletion of that analy sis. This raises a fundamental conc ern under CEQA, which requires dec isio ns to be based o n the best av ailable
information—particularly where public safety is at stake.
The ev ac uation analy sis relied upon in the EI R does not appear to incorporate:
Updated regional traffic c onditions
Real-world human behav ior during emergenc y ev ac uations
Cumulativ e impacts across known bottlenecks and c onstrained ev acuation routes
Approv ing the Projec t while a City -initiated ev ac uation study remains incomplete c reates a disc onnec t between ac knowledged risk and the
c onclusions relied upon for approv al.
2. Procedural Limitations on Public Participation
The administrativ e record reflects that the public hearing was formally closed on January 1 3, 20 26, while deliberations and c onsideratio n of
the Projec t continued thereafter. Although general public c omment was permitted at subsequent meetings, this is no t equiv alent to
partic ipation within an open public hearing tied to ac tiv e deliberation.
This distinc tion matters. Meaningful partic ipation under CEQA is intended to occ ur within the dec ision-making framewo rk itself, where public
input c an direc tly inform the outc ome. The struc ture used here limited that opportunity .
3. Departure from Adopted Public Comment Procedures
The Project inv olv ed legislativ e c omponents, y et public comment was limited to three minutes per speaker without a c lear ex planation in the
record for dev iating from the City ’s standard fiv e-minute alloc ation for legislativ e matters.
Adherenc e to established proc edures is essential to maintaining consistenc y and public trust. Where dev iations o c c ur, the basis fo r tho se
decisions should be c learly doc umented.
4. I nconsistent Project Description – Parking Discrepancy
The administrativ e record contains conflic ting information regarding required parking:
Draft EIR: 1 ,07 5 spaces
Parking Study : 963 spaces
While this disc repancy has been acknowledged, it does not appear to hav e been fully reconc iled in the rec ord. A stable and internally
c onsistent projec t desc ription is foundational under CEQA , as it directly informs the analy sis and the findings relied upon fo r appro v al.
5. Access to I nformation and Transparency
Certain materials requested during the rev iew proc ess, including internal c ommunications and tec hnic al ev aluations, were not made av ailable.
These materials are relev ant to understanding how key analy ses—particularly those related to fire safety and ev ac uation—were ev aluated and
relied upon.
Ac cess to this information supports informed public participation and confidence in the dec isio n-making proc ess.
Conclusion
This response is not intended to restate the full appeal, but rather to highlight a set of focused c onsideratio ns that remain unresolv ed in the
administrativ e record. Taken together, these issues raise important questions about whether the Projec t was rev iewed and appro v ed based on
a c omplete and procedurally consistent framework.
At minimum, the record reflects:
Approv al prior to com pletion of a c om prehensiv e ev acuation analy sis
Lim itations on m eaningful public participation during deliberation
I nc onsistenc ies in core projec t data
Dev iations from standard procedural practic es
For these reasons, I respectfully request that the Council grant the appeal, or at minimum, remand the matter fo r further analy sis and
proc edural c larific ation to ensure that the decision is based on a c omplete and consistent rec o rd.
This correspondenc e is submitted to ensure the administrativ e record ac curately reflec ts the pro c edural and analy tic al issues raised prior to
final action.
Respectfully Submitted,
Shelly Robbins
shelly.n.robbins@gmail.com
81 41 E. Kennedy Rd, Anaheim, CA
Date:3/21/2026 4:47:58 PM
From:"S R" shelly.n.robbins@gmail.com
To:"Kristen Maahs" KMaahs@anaheim.net, "Public Comment" publiccomment@anaheim.net
Cc:"City Clerk" cityclerk@anaheim.net
Subject:[EXTERNAL] Meeting 3-24-26 Agenda Items 24 & 25 – Anaheim Hills Festival Proje ct (DEV2023-00043) – Response to
Rehearing Denial and Related Actions
Warning: This email originated from outside the City of Anaheim. Do not click links or open attachme nts unle ss you recognize the
sender and are expecting the message.
Date: 3/21/26
Honorable Councilmember Kristen Maahs,
Thank y ou for y our time and careful consideration of this matter. I appreciate the thoughtful appro ac h y ou hav e taken in ev aluating the
Anaheim Hills Festiv al Project. As the Counc il c onsiders A genda Items 24–25 for the City Counc il Meeting o n 3-24-26, I am submitting this
foc used response in good faith to highlight sev eral proc edural and analy tical c onsiderations that remain impo rtant to ensuring a c o mplete and
c onsistent rec ord.
1. I ncomplete Wildfire Evacuation Analysis
The City acknowledges that a comprehensiv e wildfire ev ac uation plan is currently in dev elo pment, y et the Projec t was appro v ed prio r to
c ompletion of that analy sis. This raises a fundamental conc ern under CEQA, which requires dec isio ns to be based o n the best av ailable
information—particularly where public safety is at stake.
The ev ac uation analy sis relied upon in the EI R does not appear to incorporate:
Updated regional traffic c onditions
Real-world human behav ior during emergenc y ev ac uations
Cumulativ e impacts across known bottlenecks and c onstrained ev acuation routes
Approv ing the Projec t while a City -initiated ev ac uation study remains incomplete c reates a disc onnec t between ac knowledged risk and the
c onclusions relied upon for approv al.
2. Procedural Limitations on Public Participation
The administrativ e record reflects that the public hearing was formally closed on January 1 3, 20 26, while deliberations and c onsideratio n of
the Projec t continued thereafter. Although general public c omment was permitted at subsequent meetings, this is no t equiv alent to
partic ipation within an open public hearing tied to ac tiv e deliberation.
This distinc tion matters. Meaningful partic ipation under CEQA is intended to occ ur within the dec ision-making framewo rk itself, where public
input c an direc tly inform the outc ome. The struc ture used here limited that opportunity .
3. Departure from Adopted Public Comment Procedures
The Project inv olv ed legislativ e c omponents, y et public comment was limited to three minutes per speaker without a c lear ex planation in the
record for dev iating from the City ’s standard fiv e-minute alloc ation for legislativ e matters.
Adherenc e to established proc edures is essential to maintaining consistenc y and public trust. Where dev iations o c c ur, the basis fo r tho se
decisions should be c learly doc umented.
4. I nconsistent Project Description – Parking Discrepancy
The administrativ e record contains conflic ting information regarding required parking:
Draft EIR: 1 ,07 5 spaces
Parking Study : 963 spaces
While this disc repancy has been acknowledged, it does not appear to hav e been fully reconc iled in the rec ord. A stable and internally
c onsistent projec t desc ription is foundational under CEQA , as it directly informs the analy sis and the findings relied upon fo r appro v al.
5. Access to I nformation and Transparency
Certain materials requested during the rev iew proc ess, including internal c ommunications and tec hnic al ev aluations, were not made av ailable.
These materials are relev ant to understanding how key analy ses—particularly those related to fire safety and ev ac uation—were ev aluated and
relied upon.
Ac cess to this information supports informed public participation and confidence in the dec isio n-making proc ess.
Conclusion
This response is not intended to restate the full appeal, but rather to highlight a set of focused c onsideratio ns that remain unresolv ed in the
administrativ e record. Taken together, these issues raise important questions about whether the Projec t was rev iewed and appro v ed based on
a c omplete and procedurally consistent framework.
At minimum, the record reflects:
Approv al prior to com pletion of a c om prehensiv e ev acuation analy sis
Lim itations on m eaningful public participation during deliberation
I nc onsistenc ies in core projec t data
Dev iations from standard procedural practic es
For these reasons, I respectfully request that the Council grant the appeal, or at minimum, remand the matter fo r further analy sis and
proc edural c larific ation to ensure that the decision is based on a c omplete and consistent rec o rd.
This correspondenc e is submitted to ensure the administrativ e record ac curately reflec ts the pro c edural and analy tic al issues raised prior to
final action.
Respectfully Submitted,
Shelly Robbins
shelly.n.robbins@gmail.com
81 41 E. Kennedy Rd, Anaheim, CA
Date:3/21/2026 4:50:09 PM
From:"S R" shelly.n.robbins@gmail.com
To:"Natalie Rubalcava" NRubalcava@anaheim.net, "Public Comment" publiccomme nt@anahe im.ne t
Cc:"City Clerk" cityclerk@anaheim.net
Subject:[EXTERNAL] Meeting 3-24-26 Agenda Items 24 & 25 – Anaheim Hills Festival Proje ct (DEV2023-00043) – Response to
Rehearing Denial and Related Actions
Warning: This email originated from outside the City of Anaheim. Do not click links or open attachme nts unle ss you recognize the
sender and are expecting the message.
Dat e: 3/21 /26
Honorable Councilmember Rubalcav a,
Thank y ou for y our c ontinued time and attention to this matter. I rec ognize the complex ity of the c o nsiderations before y ou and the many
perspec tiv es inv olv ed. This response is offered in good faith and is intended to highlight a small number of pro c edural and analy tic al
c onsiderations that may benefit from further clarification to support a fully informed decisio n.
1. I ncomplete Wildfire Evacuation Analysis
The City acknowledges that a comprehensiv e wildfire ev ac uation plan is currently in dev elo pment, y et the Projec t was appro v ed prio r to
c ompletion of that analy sis. This raises a fundamental conc ern under CEQA, which requires dec isio ns to be based o n the best av ailable
information—particularly where public safety is at stake.
The ev ac uation analy sis relied upon in the EI R does not appear to incorporate:
Updated regional traffic c onditions
Real-world human behav ior during emergenc y ev ac uations
Cumulativ e impacts across known bottlenecks and c onstrained ev acuation routes
Approv ing the Projec t while a City -initiated ev ac uation study remains incomplete c reates a disc onnec t between ac knowledged risk and the
c onclusions relied upon for approv al.
2. Procedural Limitations on Public Participation
The administrativ e record reflects that the public hearing was formally closed on January 1 3, 20 26, while deliberations and c onsideratio n of
the Projec t continued thereafter. Although general public c omment was permitted at subsequent meetings, this is no t equiv alent to
partic ipation within an open public hearing tied to ac tiv e deliberation.
This distinc tion matters. Meaningful partic ipation under CEQA is intended to occ ur within the dec ision-making framewo rk itself, where public
input c an direc tly inform the outc ome. The struc ture used here limited that opportunity .
3. Departure from Adopted Public Comment Procedures
The Project inv olv ed legislativ e c omponents, y et public comment was limited to three minutes per speaker without a c lear ex planation in the
record for dev iating from the City ’s standard fiv e-minute alloc ation for legislativ e matters.
Adherenc e to established proc edures is essential to maintaining consistenc y and public trust. Where dev iations o c c ur, the basis fo r tho se
decisions should be c learly doc umented.
4. I nconsistent Project Description – Parking Discrepancy
The administrativ e record contains conflic ting information regarding required parking:
Draft EIR: 1 ,07 5 spaces
Parking Study : 963 spaces
While this disc repancy has been acknowledged, it does not appear to hav e been fully reconc iled in the rec ord. A stable and internally
c onsistent projec t desc ription is foundational under CEQA , as it directly informs the analy sis and the findings relied upon fo r appro v al.
5. Access to I nformation and Transparency
Certain materials requested during the rev iew proc ess, including internal c ommunications and tec hnic al ev aluations, were not made av ailable.
These materials are relev ant to understanding how key analy ses—particularly those related to fire safety and ev ac uation—were ev aluated and
relied upon.
Ac cess to this information supports informed public participation and confidence in the dec isio n-making proc ess.
Conclusion
This response is not intended to restate the full appeal, but rather to highlight a set of focused c onsideratio ns that remain unresolv ed in the
administrativ e record. Taken together, these issues raise important questions about whether the Projec t was rev iewed and appro v ed based on
a c omplete and procedurally consistent framework.
At minimum, the record reflects:
Approv al prior to com pletion of a c om prehensiv e ev acuation analy sis
Lim itations on m eaningful public participation during deliberation
I nc onsistenc ies in core projec t data
Dev iations from standard procedural practic es
For these reasons, I respectfully request that the Council grant the appeal, or at minimum, remand the matter fo r further analy sis and
proc edural c larific ation to ensure that the decision is based on a c omplete and consistent rec o rd.
This correspondenc e is submitted to ensure the administrativ e record ac curately reflec ts the pro c edural and analy tic al issues raised prior to
final action.
Respectfully Submitted,
Shelly Robbins
shelly.n.robbins@gmail.com
81 41 E. Kennedy Rd, Anaheim, CA
Date:3/21/2026 4:52:48 PM
From:"S R" shelly.n.robbins@gmail.com
To:"Norma C. Kurtz" NKurtz@anaheim.net, "Public Comment" publiccomment@anahe im.ne t
Cc:"City Clerk" cityclerk@anaheim.net
Subject:[EXTERNAL] Meeting 3-24-26 Agenda Items 24 & 25 – Anaheim Hills Festival Proje ct (DEV2023-00043) – Response to
Rehearing Denial and Related Actions
Warning: This email originated from outside the City of Anaheim. Do not click links or open attachme nts unle ss you recognize the
sender and are expecting the message.
Dat e: 3/21 /26
Honorable Councilmember Campos Kurtz,
Thank y ou for y our time and thoughtful consideration of this matter. Giv en the importanc e of ensuring a c o mplete and c onsistent
record, particularly on issues related to public safety . This response is offered in good faith to highlight a few key proc edural and analy tic al
c onsiderations that remain relev ant to the decision before y ou.
1. I ncomplete Wildfire Evacuation Analysis
The City acknowledges that a comprehensiv e wildfire ev ac uation plan is currently in dev elo pment, y et the Projec t was appro v ed prio r to
c ompletion of that analy sis. This raises a fundamental conc ern under CEQA, which requires dec isio ns to be based o n the best av ailable
information—particularly where public safety is at stake.
The ev ac uation analy sis relied upon in the EI R does not appear to incorporate:
Updated regional traffic c onditions
Real-world human behav ior during emergenc y ev ac uations
Cumulativ e impacts across known bottlenecks and c onstrained ev acuation routes
Approv ing the Projec t while a City -initiated ev ac uation study remains incomplete c reates a disc onnec t between ac knowledged risk and the
c onclusions relied upon for approv al.
2. Procedural Limitations on Public Participation
The administrativ e record reflects that the public hearing was formally closed on January 1 3, 20 26, while deliberations and c onsideratio n of
the Projec t continued thereafter. Although general public c omment was permitted at subsequent meetings, this is no t equiv alent to
partic ipation within an open public hearing tied to ac tiv e deliberation.
This distinc tion matters. Meaningful partic ipation under CEQA is intended to occ ur within the dec ision-making framewo rk itself, where public
input c an direc tly inform the outc ome. The struc ture used here limited that opportunity .
3. Departure from Adopted Public Comment Procedures
The Project inv olv ed legislativ e c omponents, y et public comment was limited to three minutes per speaker without a c lear ex planation in the
record for dev iating from the City ’s standard fiv e-minute alloc ation for legislativ e matters.
Adherenc e to established proc edures is essential to maintaining consistenc y and public trust. Where dev iations o c c ur, the basis fo r tho se
decisions should be c learly doc umented.
4. I nconsistent Project Description – Parking Discrepancy
The administrativ e record contains conflic ting information regarding required parking:
Draft EIR: 1 ,07 5 spaces
Parking Study : 963 spaces
While this disc repancy has been acknowledged, it does not appear to hav e been fully reconc iled in the rec ord. A stable and internally
c onsistent projec t desc ription is foundational under CEQA , as it directly informs the analy sis and the findings relied upon fo r appro v al.
5. Access to I nformation and Transparency
Certain materials requested during the rev iew proc ess, including internal c ommunications and tec hnic al ev aluations, were not made av ailable.
These materials are relev ant to understanding how key analy ses—particularly those related to fire safety and ev ac uation—were ev aluated and
relied upon.
Ac cess to this information supports informed public participation and confidence in the dec isio n-making proc ess.
Conclusion
This response is not intended to restate the full appeal, but rather to highlight a set of focused c onsideratio ns that remain unresolv ed in the
administrativ e record. Taken together, these issues raise important questions about whether the Projec t was rev iewed and appro v ed based on
a c omplete and procedurally consistent framework.
At minimum, the record reflects:
Approv al prior to com pletion of a c om prehensiv e ev acuation analy sis
Lim itations on m eaningful public participation during deliberation
I nc onsistenc ies in core projec t data
Dev iations from standard procedural practic es
For these reasons, I respectfully request that the Council grant the appeal, or at minimum, remand the matter fo r further analy sis and
proc edural c larific ation to ensure that the decision is based on a c omplete and consistent rec o rd.
This correspondenc e is submitted to ensure the administrativ e record ac curately reflec ts the pro c edural and analy tic al issues raised prior to
final action.
Respectfully Submitted,
Shelly Robbins
shelly.n.robbins@gmail.com
81 41 E. Kennedy Rd, Anaheim, CA
Date:3/21/2026 4:54:50 PM
From:"S R" shelly.n.robbins@gmail.com
To:"Natalie Meeks" NMeeks@anaheim.net, "Public Comment" publiccomme nt@anahe im.ne t
Cc:"City Clerk" cityclerk@anaheim.net
Subject:[EXTERNAL] Meeting 3-24-26 Agenda Items 24 & 25 – Anaheim Hills Festival Proje ct (DEV2023-00043) – Response to
Rehearing Denial and Related Actions
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Dat e: 3/21 /26
Honorable Councilmember Meeks,
Thank y ou for y our time and continued engagement on this matter. I recognize the lev el of c ommunity interest and the respo nsibility inv o lv ed
in weighing complex decisions that affect both c urrent and future residents. This response is o ffered in good faith to highlight sev eral foc used
c onsiderations that may support a clear and well-supported path forward.
1. I ncomplete Wildfire Evacuation Analysis
The City acknowledges that a comprehensiv e wildfire ev ac uation plan is currently in dev elo pment, y et the Projec t was appro v ed prio r to
c ompletion of that analy sis. This raises a fundamental conc ern under CEQA, which requires dec isio ns to be based o n the best av ailable
information—particularly where public safety is at stake.
The ev ac uation analy sis relied upon in the EI R does not appear to incorporate:
Updated regional traffic c onditions
Real-world human behav ior during emergenc y ev ac uations
Cumulativ e impacts across known bottlenecks and c onstrained ev acuation routes
Approv ing the Projec t while a City -initiated ev ac uation study remains incomplete c reates a disc onnec t between ac knowledged risk and the
c onclusions relied upon for approv al.
2. Procedural Limitations on Public Participation
The administrativ e record reflects that the public hearing was formally closed on January 1 3, 20 26, while deliberations and c onsideratio n of
the Projec t continued thereafter. Although general public c omment was permitted at subsequent meetings, this is no t equiv alent to
partic ipation within an open public hearing tied to ac tiv e deliberation.
This distinc tion matters. Meaningful partic ipation under CEQA is intended to occ ur within the dec ision-making framewo rk itself, where public
input c an direc tly inform the outc ome. The struc ture used here limited that opportunity .
3. Departure from Adopted Public Comment Procedures
The Project inv olv ed legislativ e c omponents, y et public comment was limited to three minutes per speaker without a c lear ex planation in the
record for dev iating from the City ’s standard fiv e-minute alloc ation for legislativ e matters.
Adherenc e to established proc edures is essential to maintaining consistenc y and public trust. Where dev iations o c c ur, the basis fo r tho se
decisions should be c learly doc umented.
4. I nconsistent Project Description – Parking Discrepancy
The administrativ e record contains conflic ting information regarding required parking:
Draft EIR: 1 ,07 5 spaces
Parking Study : 963 spaces
While this disc repancy has been acknowledged, it does not appear to hav e been fully reconc iled in the rec ord. A stable and internally
c onsistent projec t desc ription is foundational under CEQA , as it directly informs the analy sis and the findings relied upon fo r appro v al.
5. Access to I nformation and Transparency
Certain materials requested during the rev iew proc ess, including internal c ommunications and tec hnic al ev aluations, were not made av ailable.
These materials are relev ant to understanding how key analy ses—particularly those related to fire safety and ev ac uation—were ev aluated and
relied upon.
Ac cess to this information supports informed public participation and confidence in the dec isio n-making proc ess.
Conclusion
This response is not intended to restate the full appeal, but rather to highlight a set of focused c onsideratio ns that remain unresolv ed in the
administrativ e record. Taken together, these issues raise important questions about whether the Projec t was rev iewed and appro v ed based on
a c omplete and procedurally consistent framework.
At minimum, the record reflects:
Approv al prior to com pletion of a c om prehensiv e ev acuation analy sis
Lim itations on m eaningful public participation during deliberation
I nc onsistenc ies in core projec t data
Dev iations from standard procedural practic es
For these reasons, I respectfully request that the Council grant the appeal, or at minimum, remand the matter fo r further analy sis and
proc edural c larific ation to ensure that the decision is based on a c omplete and consistent rec o rd.
This correspondenc e is submitted to ensure the administrativ e record ac curately reflec ts the pro c edural and analy tic al issues raised prior to
final action.
Respectfully Submitted,
Shelly Robbins
shelly.n.robbins@gmail.com
81 41 E. Kennedy Rd, Anaheim, CA