20 (54)
Susana Barrios
From:Concerned Anaheim Residents <concernedanaheimresidents@gmail.com>
Sent:Tuesday, June 23, 2026 3:46 PM
To:Christine Nguyen; Public Comment; City Clerk
Cc:Robert Fabela; Gregory Garcia; prohousingpolicies@hcd.ca.gov;
compliancereview@hcd.ca.gov; whistleblower@auditor.ca.gov;
info@firstamendmentcoalition.org; norberto@voiceofoc.org
Subject:\[EXTERNAL\] URGENT NOTICE: Re-Submission of Formal Opposition to Anaheim Pro-
Housing (PDP) Application (Original Transmission: 6/11/26)
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Warning: This email originated from outside the City of Anaheim. Do not click links or open
attachments unless you recognize the sender and are expecting the message.
To Christine Nguyen, the Anaheim City Clerk, Members of the Anaheim City Council, and the State
HCD Review Board:
The Concerned Anaheim Residents coalition is re-submitting this formal written comment, originally
transmitted on 6-11-26, before the 5:00 p.m. public deadline to state our strict opposition to the City of
Anaheim’s California Pro-Housing Designation Program (PDP) application. Due to lack of confirmation
of our previous correspondence, this email is being re-submitted to ensure that it is included in the
list of public comments received for the HCD Review Board.
We demand that the state deny Anaheim's self-certified sixty-one (61) local transparency points.
Under the oversight of City Attorney Robert Fabela, the city is maintaining an active, server-wide
public records blackout to shield special interests, directly violating state grant requirements.
We enter our formal opposition onto the permanent public and state record based on the following
material merits:
1. Active CPRA Statutory Default & Deficient Responses: As of May 22, 2026, the city entered a
documented state of statutory non-compliance and systematic determination delinquency
per California Public Records Act (CPRA) guidelines. The administration has actively
suppressed raw backend lobbyist portal metadata logs and intentionally misfiled urgent 24-
hour statutory Delinquency Notices into standard slow queues to run out public clocks.
2. Systemic Lobbyist Disclosure Fraud & Shadow Lobbying: A completed registry audit of Curt
Pringle & Associates (2023–2026) exposes a coordinated pattern of wide-scale, retroactive
quarterly disclosure modifications executed right alongside major Planning Commission and
City Council vote dates. Furthermore, visual evidence captures unregistered shadow lobbyists
operating inside council chambers to manipulate project outcomes, utilizing unrecorded back-
channel access to sitting Councilmembers.
3. Calendar Omissions & Shielding of Unsubmitted Pipelines: The city is utilizing this records
default to advance multiple unsubmitted, adjacent high-density land-use pipelines under total
zero-disclosure thresholds. Official municipal public calendars maintain "flat-zero" disclosures
and flat-zero listed developer meetings, actively erasing and failing to record developer
1
coordination sessions even while physical project signage is being actively installed on-site in
the community.
4. Muzzling Public Participation (Pre-empting the "Modernization" Defense): To insulate city
executives from public scrutiny regarding these hidden developments, the City Council voted
on May 12, 2026, to codify restrictive new meeting rules.
Regardless of whether these rules are actively enforced at every session, the mere codification
of a discretionary 1-minute speech cap and a 90-minute meeting cutoff creates an
immediate structural barrier and a documented chilling effect on civic participation. By vesting
the power to arbitrarily muzzle resident testimony into the subtext of city policy, the council has
built a legal mechanism designed to restrict evidence-heavy oversight. Under state HCD
guidelines, it is the structural existence of these restrictive barriers, not the city's promises of
benevolence, that violates the threshold requirements for open community engagement and
state AFFH mandates.
1. Dais Collusion & Evidence Suppression: Time-stamped visual data captures a synchronized
pattern of sitting Councilmembers utilizing devices behind the dais immediately adjacent to
developer lobbying team communications during active, live project deliberations. To shield
this back-channel collusion from public review, the city has actively suppressed public records
requests for the corresponding backend communication metadata logs and has failed to
produce the public hall camera footage capturing these sequences.
2. Audit of Open, Suppressed, and Deficient Datasets: The city currently maintains an extensive
backlog of unanswered or deficient Public Records Act (PRA) requests across multiple
districts, systematically shielding municipal and developer liability. This includes:
Stonewalled PRAs Concealing Municipal & Lobbyist Misconduct: The city has gone
completely radio silent on outstanding PRA requests regarding city official and lobbyist
conduct for the Anaheim Hills Festival Development Project Approval (DEV2023-
00043); deliberately withholding records that substantiate allegations of shadow lobbying,
unregistered influence, and altered disclosure timelines.
Procedural Deficiencies and Due Process Evasion: Municipal administration failed to
acknowledge multiple formal delinquency notices, omitted critical evidence submissions, and
ignored a valid Brown Act Cure & Correct demand. This includes an entirely inadequate
administrative review of the project's appeal, where the city restricted public opposition to a
token 10-page response against an 870-page structural appeal packet.
Open, deficient PRAs regarding local neighborhood water contamination metrics.
Suppressed City Council administrative records, unredacted internal communications, and
deliberately unrecorded or altered lobbyist disclosure timelines.
Withholding critical investigative files and body-worn camera footage from the grieving family
of Albert Arzola.
A municipality cannot legally pocket millions in state infrastructure funds under the guise of "local
transparency" while actively operating a state of records default on its own servers to muzzle its
residents and shield developer liabilities. We request that the HCD Review Board place an immediate
administrative hold on Anaheim's designation.
2
The itemized evidentiary files, including time-stamped visual data of unregistered shadow lobbying and
metadata audit logs, are currently being finalized for investigative integrity and will be transmitted
directly to the HCD Review Board and state enforcement agencies under separate cover.
Please immediately confirm receipt of this message. Any failure by the City to acknowledge and log
this formal opposition will be reported directly to the California Department of Housing and
Community Development (HCD) as a structural failure of local transparency and a deliberate
attempt to obscure public opposition to the Pro-Housing Designation Program (PDP Funding).
Respectfully submitted,
The Stakeholder Audit Team
---------- Forwarded message ---------
From: Concerned Anaheim Residents <concernedanaheimresidents@gmail.com>
Date: Thu, Jun 11, 2026 at 3:29 PM
Subject: Formal OPPOSITION & Public Comment: California Pro-Housing Designation Program (PDP)
Application – Material Transparency Defaults
To: <publiccomment@anaheim.net>, <cnguyen2@anaheim.net>
Cc: <ProhousingPolicies@hcd.ca.gov>, <prohousingincentive@hcd.ca.gov>
To Christine Nguyen, the Anaheim City Clerk, Members of the Anaheim City Council, and the State
HCD Review Board:
The Concerned Anaheim Residents coalition is submitting this formal written comment ahead of today's
5:00 p.m. public deadline to state our strict opposition to the City of Anaheim’s California Pro-Housing
Designation Program (PDP) application.
We demand that the state deny Anaheim's self-certified sixty-one (61) local transparency points.
Under the oversight of City Attorney Robert Fabela, the city is maintaining an active, server-wide
public records blackout to shield special interests, directly violating state grant requirements.
We enter our formal opposition onto the permanent public and state record based on the following
material merits:
1. Active CPRA Statutory Default & Deficient Responses: As of May 22, 2026, the city entered an
unconditional state of Statutory Default under the California Public Records Act (CPRA). The
administration has actively suppressed raw backend lobbyist portal metadata logs and
intentionally misfiled urgent 24-hour statutory Delinquency Notices into standard slow queues
to run out public clocks.
2. Systemic Lobbyist Disclosure Fraud & Shadow Lobbying: A completed registry audit of Curt
Pringle & Associates (2023–2026) exposes a coordinated pattern of wide-scale, retroactive
quarterly disclosure modifications executed right alongside major Planning Commission and
City Council vote dates. Furthermore, visual evidence captures unregistered shadow lobbyists
operating inside council chambers to manipulate project outcomes, utilizing unrecorded back-
channel access to sitting Councilmembers.
3. Calendar Omissions & Shielding of Unsubmitted Pipelines: The city is utilizing this records
default to advance multiple unsubmitted, adjacent high-density land-use pipelines under total
zero-disclosure thresholds. Official municipal public calendars maintain "flat-zero" disclosures
and flat-zero listed developer meetings, actively erasing and failing to record developer
3
coordination sessions even while physical project signage is being actively installed on-site in
the community.
4. Muzzling Public Participation (Pre-empting the "Modernization" Defense): To insulate city
executives from public scrutiny regarding these hidden developments, the City Council voted
on May 12, 2026, to codify restrictive new meeting rules.
Regardless of whether these rules are actively enforced at every session, the mere codification
of a discretionary 1-minute speech cap and a 90-minute meeting cutoff creates an immediate
structural barrier and a documented chilling effect on civic participation. By vesting the power
to arbitrarily muzzle resident testimony into the subtext of city policy, the council has built a
legal mechanism designed to restrict evidence-heavy oversight. Under state HCD guidelines, it
is the structural existence of these restrictive barriers, not the city's promises of benevolence,
that violates the threshold requirements for open community engagement.
1. Dais Collusion & Evidence Suppression: Time-stamped visual data captures a synchronized
pattern of sitting Councilmembers utilizing devices behind the dais immediately adjacent to
developer lobbying team communications during active, live project deliberations. To shield
this back-channel collusion from public review, the city has actively suppressed public records
requests for the corresponding backend communication metadata logs and has failed to
produce the public hall camera footage capturing these sequences.
2. Audit of Open, Suppressed, and Deficient Datasets: The city currently maintains an extensive
backlog of unanswered or deficient Public Records Act (PRA) requests across multiple
districts, systematically shielding municipal and developer liability. This includes:
o Stonewalled PRAs Concealing Municipal & Lobbyist Misconduct: The city has gone
completely radio silent on outstanding PRA requests regarding city official and lobbyist
conduct for the Anaheim Hills Festival Development Project Approval (DEV2023-
00043); deliberately withholding records that substantiate allegations of shadow
lobbying, unregistered influence, and altered disclosure timelines.
o Procedural Deficiencies and Due Process Evasion: Municipal administration failed to
acknowledge multiple formal delinquency notices, omitted critical evidence
submissions, and ignored a valid Brown Act Cure & Correct demand. This includes an
entirely inadequate administrative review of the project's appeal, where the city
restricted public opposition to a token 10-page response against an 870-page structural
appeal packet.
o Open, deficient PRAs regarding local neighborhood water contamination metrics.
o Suppressed City Council administrative records, unredacted internal communications,
and deliberately unrecorded or altered lobbyist disclosure timelines.
o Withholding critical investigative files and body-worn camera footage from the grieving
family of Albert Arzola.
A municipality cannot legally pocket millions in state infrastructure funds under the guise of "local
transparency" while actively operating a state of records default on its own servers to muzzle its
residents and shield developer liabilities. We request that the HCD Review Board place an immediate
administrative hold on Anaheim's designation.
4
The full, itemized evidentiary files, including time-stamped visual data of unregistered shadow lobbyists
and metadata audit logs, are being transmitted directly to the HCD Review Board and state enforcement
agencies under separate cover to preserve investigative integrity.
Respectfully submitted,
The Stakeholder Audit Team
5