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21 (29) Susana Barrios From:Concerned Anaheim Residents <concernedanaheimresidents@gmail.com> Sent:Tuesday, August 25, 2026 1:44 PM To:Public Comment; City Clerk; Robert Fabela; Gregory Garcia; ProhousingPolicies@hcd.ca.gov; compliancereview@hcd.ca.gov Subject:\[EXTERNAL\] PUBLIC COMMENT - ITEM #21: Formal Opposition to Anaheim Pro- Housing Designation Application (Addressed to Mayor, City Council, and City Clerk) Attachments:History of Previously Submitted Public Comment Within Public Comment Period.pdf You don't often get email from concernedanaheimresidents@gmail.com. Learn why this is important 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 Mayor Ashleigh Aitken, Members of the Anaheim City Council, and City Clerk: The Concerned Anaheim Residents coalition is submitting this formal public comment for Tonight’s August 25, 2026, City Council Meeting, explicitly tied to Agenda Item #21. This comprehensive opposition was originally transmitted directly to City Clerk, Christine Nguyen, and the State HCD on June 11, 2026. Due to a documented failure by the City to respond or confirm receipt, we have attached our original, time-stamped June submissions to this email and are re-submitting this comment directly under tonight's agenda item to enforce our statutory right to civic participation. We demand this item be pulled or denied based on the city's failure to meet threshold transparency metrics. We maintain that the state must 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 record for Item #21 based on the following material merits:  Active CPRA Statutory Delinquency & Deficient Responses: As of May 22, 2026, the city entered a documented state of statutory non-compliance and systemic determination delinquency 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.  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.  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.  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. 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.  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.  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 regarding the Anaheim Hills Festival Development Project Approval (DEV2023-00043), neighborhood water contamination metrics, internal administrative communications, and critical investigative files from the 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 City Council pull this application tonight, and we request the HCD Review Board place an immediate administrative hold on Anaheim's designation. Please immediately confirm receipt of this message and confirm its inclusion in tonight's supplemental public comment packet for the Mayor and City Council. Respectfully submitted, The Stakeholder Audit Team 2 Concerned AnaheimResidents <concernedanaheimresidents@gmail.com> URGENT NOTICE: Re-Submission of Formal Opposition to Anaheim Pro-Housing (PDP) Application (Original Transmission: 6/11/26) 1 message Concerned Anaheim Residents <concernedanaheimresidents@gmail.com>Tue, Jun 23, 2026 at 3:45 PM To: cnguyen2@anaheim.net, publiccomment@anaheim.net, cityclerk@anaheim.net Cc: rfabela@anaheim.net, ggarcia@anaheim.net, prohousingpolicies@hcd.ca.gov, compliancereview@hcd.ca.gov, whistleblower@auditor.ca.gov, info@firstamendmentcoalition.org, norberto@voiceofoc.org 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 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. 8/25/26, 1:09 PM Gmail - URGENT NOTICE: Re-Submission of Formal Opposition to Anaheim Pro-Housing (PDP) Application (Original Transmission… https://mail.google.com/mail/u/0/?ik=bb7ab00bd6&view=pt&search=all&permthid=thread-a:r-3374563642578642215%7Cmsg-a:r-1692931829049448…1/4 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. 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). 8/25/26, 1:09 PM Gmail - URGENT NOTICE: Re-Submission of Formal Opposition to Anaheim Pro-Housing (PDP) Application (Original Transmission… https://mail.google.com/mail/u/0/?ik=bb7ab00bd6&view=pt&search=all&permthid=thread-a:r-3374563642578642215%7Cmsg-a:r-1692931829049448…2/4 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 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 8/25/26, 1:09 PM Gmail - URGENT NOTICE: Re-Submission of Formal Opposition to Anaheim Pro-Housing (PDP) Application (Original Transmission… https://mail.google.com/mail/u/0/?ik=bb7ab00bd6&view=pt&search=all&permthid=thread-a:r-3374563642578642215%7Cmsg-a:r-1692931829049448…3/4 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: 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. 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 8/25/26, 1:09 PM Gmail - URGENT NOTICE: Re-Submission of Formal Opposition to Anaheim Pro-Housing (PDP) Application (Original Transmission… https://mail.google.com/mail/u/0/?ik=bb7ab00bd6&view=pt&search=all&permthid=thread-a:r-3374563642578642215%7Cmsg-a:r-1692931829049448…4/4 Susana Barrios From:Concerned Anaheim Residents <concernedanaheimresidents@gmail.com> Sent:Tuesday, August 25, 2026 2:57 PM To:Public Comment; City Clerk; Robert Fabela; Gregory Garcia; ProhousingPolicies@hcd.ca.gov; compliancereview@hcd.ca.gov Subject:\[EXTERNAL\] SUPPLEMENTAL PUBLIC COMMENT – ITEM #21 – Material Discrepancies in Anaheim Prohousing Application, Public Participation Certification, and Unresolved Wildfire-Evacuation Safety Issues You don't often get email from concernedanaheimresidents@gmail.com. Learn why this is important 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 Mayor Ashleigh Aitken, Members of the Anaheim City Council, City Clerk, Planning and Building Department, and California Department of Housing and Community Development: The Concerned Anaheim Residents coalition submits this supplemental opposition regarding Agenda Item #21 and the City of Anaheim’s proposed application for California Prohousing Designation. Following review of the City’s August 25 staff report, proposed resolution, Prohousing application, self- scoring materials, supporting Housing Element documents, public-comment attachment, and Anaheim’s still-draft Wildfire Evacuation Study, we have identified material issues that warrant postponement of City Council authorization and independent HCD review before Anaheim certifies this application as complete. This comment does not assert that Prohousing Designation eliminates CEQA, abolishes all public hearings, eliminates all parking requirements, or automatically approves any particular housing development. Those claims would overstate the program. Our concern is narrower and better documented: Anaheim is seeking State recognition and financial preference for an existing local policy framework expressly designed to increase density, expand residential use, eliminate certain discretionary hearings, accelerate housing approvals, reduce development costs, and subsidize housing production at the same time that Anaheim has not completed the wildfire-evacuation framework intended to evaluate the safety implications of future development in its most evacuation-constrained communities. The City’s own records establish that concern. 1. Anaheim’s application expressly claims credit for accelerated, ministerial, and hearing-free housing approvals. 1 The August 25 staff report describes the Prohousing program as incentivizing jurisdictions that implement policies and programs that accelerate housing production. Anaheim’s application claims a self-score of 61 points, more than double the 30-point threshold. Those points are not merely symbolic. Anaheim specifically seeks Prohousing credit for ministerial approval processes for multiple housing types; by-right multifamily development through the Residential Opportunities Overlay Zone; streamlined project-level development review; elimination of public hearings for qualifying projects consistent with zoning and the General Plan; priority processing or reduced plan-check times; zoning measures supporting increased housing density; allowing residential uses in nonresidential zones; development-cost reductions and fee programs; and financial subsidies and local housing-financing programs. The application further identifies a Housing Element inventory of 27,735 pipeline, ADU, and candidate- site units against a RHNA obligation of 17,453 units, or approximately 159% of that obligation. That figure should not be confused with actual construction or Anaheim’s ultimate housing obligation. It does, however, demonstrate the magnitude of development capacity already embedded in the City’s planning framework before additional Prohousing funding advantages are considered. We therefore reject the characterization that residents are reacting to a meaningless designation or an abstract label. Anaheim itself is asking HCD to reward concrete policies intended to accelerate housing production. 2. The final resolution contains an important public-safety safeguard — but the scope and implementation of that safeguard remain unresolved. The coalition acknowledges an important modification appearing in the proposed August 25 resolution. Paragraph 6 now recognizes Anaheim’s continuing authority and responsibility to protect public health, safety, public facilities and infrastructure, emergency access, and public property. That language responds to a legitimate concern raised during public review and should remain in any future resolution. However, its practical interaction with Paragraph 3 requires clarification. Paragraph 3 commits Anaheim to refrain from enacting laws, developing policies, or taking local governmental actions that may inhibit or constrain housing production. Anaheim’s draft Wildfire Evacuation Study is simultaneously developing a future project-review framework that may require precisely the kinds of restrictions that can constrain development: evacuation-capacity standards, emergency-access requirements, project-specific modeling, roadway improvements, mitigation measures, density or design modifications, fire-protection requirements, and potentially denial or redesign where significant impacts cannot be adequately mitigated. 2 We therefore request that Anaheim and HCD confirm in writing that objective wildfire-evacuation and public-safety requirements will never be treated as impermissible housing constraints merely because they delay, redesign, reduce, condition, or prevent development in a location where substantial evidence establishes an unacceptable safety risk. 3. Residents have consistently requested that safety and infrastructure deficits be addressed before additional development is layered onto the same constrained network. For years, East Anaheim and Anaheim Hills residents have raised substantially the same concern: development should occur only after the City demonstrates that existing infrastructure, roadway capacity, emergency access, and evacuation systems can safely accommodate both current residents and foreseeable cumulative growth. That concern appears again in the City’s own Prohousing public-comment packet. Residents specifically asked Anaheim to evaluate cumulative traffic and evacuation impacts, demonstrate consistency with wildfire planning policies, assess infrastructure capacity, and avoid treating projects individually when residents experience the resulting traffic and evacuation demand collectively. The City’s own Wildfire Evacuation Study outreach likewise records residents reporting that streets are already crowded, objecting to additional high-density development before evacuation concerns are addressed, and requesting analysis of road closures affecting access to the 91 and 55 freeways. This history matters because residents are not asking Anaheim to abandon housing production. They are repeatedly asking for a sequence of planning that places infrastructure capacity and demonstrable life safety before additional loading of constrained evacuation corridors. The Prohousing application instead rewards faster approval, greater development capacity, ministerial processing, fewer hearings for qualifying projects, lower development barriers, and financial incentives for additional housing production. The City therefore should explain how those acceleration policies will be reconciled with longstanding resident requests that infrastructure deficits first be identified, funded, implemented, and demonstrated effective. 4. The Know Your Way program should not be treated as proof of evacuation capacity. Anaheim’s Know Your Way program was created after the 2017 Canyon II Fire, when a rapidly moving wildfire caused large-scale evacuation, resident confusion concerning routes and road closures, and expansion of evacuation zones. The City’s draft study itself identifies those evacuation difficulties as the reason the program was created. The coalition recognizes the value of public education, evacuation zones, signage, preparedness information, and advance planning. But an evacuation plan is not the same thing as evacuation capacity. 3 Know Your Way identifies zones and routes and assists emergency managers in communicating evacuation instructions. It does not, by itself, add roadway capacity, eliminate existing bottlenecks, prevent commuter or through-traffic from occupying evacuation corridors, guarantee freeway acceptance capacity, guarantee that every designated route remains open, or establish that residents can physically clear threatened areas before fire reaches them. Indeed, Anaheim’s own draft study demonstrates why this distinction matters. Even with modeled evacuation management, area-specific scenarios produce maximum modeled clearance times ranging from approximately 4 hours 28 minutes to 7 hours 14 minutes, while catastrophic existing-condition scenarios reach approximately 10 hours 5 minutes and 12 hours 16 minutes. The study also acknowledges constrained roadways, downstream congestion, limited access points, and signal operations as factors capable of materially affecting evacuation clearance. Residents have repeatedly been advised in public discussions that wildfire evacuation is dynamic and that routing may change depending on the location and behavior of a fire. If the City considers Know Your Way an adaptable operational framework rather than a fixed route guarantee, then it should not simultaneously cite that framework as evidence that additional development can safely be absorbed by the existing transportation network. Those are different propositions. The City should therefore distinguish clearly between preparedness guidance, which tells residents what officials intend them to do, and demonstrated evacuation capacity, which establishes whether the transportation network can actually accomplish it under credible emergency conditions. 5. Anaheim’s own draft Wildfire Evacuation Study documents severe existing and cumulative evacuation constraints. Anaheim’s June 2026 Draft Wildfire Evacuation Study does not establish that Anaheim Hills has abundant evacuation capacity. It documents the opposite. Its modeled maximum clearance times include approximately 10 hours 5 minutes under one catastrophic existing-condition scenario; 12 hours 16 minutes under another catastrophic existing- condition scenario; 7 hours 14 minutes under the SR-241 wildfire scenario; 5 hours 38 minutes under the East Nohl Ranch Road wildfire scenario; 4 hours 28 minutes under the Deer Canyon existing-condition wildfire scenario; and 6 hours 2 minutes under the Deer Canyon cumulative-growth scenario. The study further reports that cumulative growth increases modeled evacuation time in some locations, including an approximately 2-hour 4-minute increase in Zone 8 between the Deer Canyon existing and cumulative conditions. The same draft fire modeling indicates that some structures may experience wildfire exposure in approximately 15 minutes under modeled conditions. 4 These clearance times are model outputs under specified assumptions, not predictions that every resident would remain trapped for those durations. But neither are they findings that the system is categorically safe. That distinction matters enormously. 6. The wildfire study’s proposed statistical threshold appears to measure detectability against model variation; not an independent life-safety standard. One of the most consequential unresolved methodological issues is the study’s proposed project significance threshold. The draft states that a project’s modeled evacuation impact becomes quantitatively significant when the with-project average falls outside the without-project 95% confidence interval. The accompanying scoping form makes that confidence-interval methodology the required threshold unless the City and Anaheim Fire and Rescue concur otherwise. This methodology may provide a useful measure for determining whether a modeled project-related change exceeds normal simulation variability. But that is not the same question as: How much evacuation delay is safe? Nor does statistical overlap with a baseline confidence interval establish that an already-constrained baseline is acceptable. An unsafe or marginal existing condition does not become safe merely because a new project’s incremental effect falls within the statistical variability of that baseline. A statistical threshold designed to determine whether an average project-related change exceeds ordinary model variation is not itself a life-safety threshold. For a life-safety analysis, the City must evaluate not merely mean outcomes and statistical separation, but whether residents can clear threatened areas before fire, smoke, embers, road blockage, emergency operations, or loss of route tenability make evacuation dangerous or impossible. 7. Rare catastrophic outcomes require explicit treatment because life-safety failure often occurs in the tails, not at the average. The draft study performs repeated simulation runs and includes catastrophic scenarios. Those are useful analytical tools. The unresolved concern is how the City proposes to translate those simulations into future development approvals. 5 Wildfire evacuation is fundamentally a tail-risk problem. Catastrophic harm often arises from low- frequency combinations of adverse conditions rather than average conditions. A life-safety framework should therefore test credible combinations such as a primary evacuation route becoming unavailable; freeway or arterial spillback reducing downstream discharge capacity; traffic signals losing power or communications; emergency vehicles competing for constrained roadway space; stronger Santa Ana wind conditions; ember transport creating secondary ignitions or spot fires ahead of the principal fire front; smoke or reduced visibility compromising route usability; changing wind direction; more extensive shadow evacuation than assumed; school pickup or family-reunification traffic; disabled, elderly, or medically vulnerable residents requiring additional evacuation assistance; and simultaneous failures occurring while evacuation demand is near its peak. The City’s fire-progression analysis itself uses a fixed 33 mph wind condition and does not model detailed ember transport, structure-to-structure spread, changing weather, suppression activity, or traffic within the fire model. Those limitations do not invalidate the study. They mean the City should not convert one model’s statistical confidence interval into a proxy for safety without separately demonstrating that credible adverse conditions leave sufficient time and viable routes for evacuation. 8. The City’s planned transportation improvements should not be credited as current evacuation capacity before they exist and are tested. Anaheim’s draft study recommends a combination of signal interconnectivity, CCTV monitoring, coordinated outbound signal timing or “flush” strategies, communications improvements, roadway and intersection improvements, and other operational measures. When modeled, some of these interventions produce substantial improvements — in some zones, reductions ranging from tens of minutes to several hours. That result demonstrates their potential value. It also demonstrates that current evacuation performance is highly dependent upon improvements that must actually be funded, installed, maintained, staffed, activated, and functional during the emergency. Future development should therefore not receive the benefit of a modeled mitigation until the City identifies which improvements already exist; which remain proposed; funding sources; responsible agencies; completion schedules; backup power and communications; operational staffing requirements; implementation triggers; and measurable performance criteria demonstrating that the improvement works under evacuation conditions. The same principle applies to major freeway improvements. Regional freeway expansion may eventually improve downstream traffic movement, but future capacity should not be counted as existing capacity while construction remains incomplete. 6 Even a completed freeway improvement addresses downstream freeway movement; it does not automatically resolve neighborhood-level bottlenecks between homes and freeway access points. The City should separately model neighborhood-to-arterial, arterial-to-interchange, and interchange- to-freeway evacuation capacity rather than treating regional freeway capacity as interchangeable with local evacuation capacity. 9. The draft’s cumulative analysis demonstrates a growth effect, but it does not answer every future-development question now facing East Anaheim. Scenario 6 models cumulative land-use growth using the same phasing and operational assumptions as the existing Deer Canyon scenario and expressly seeks to isolate the effect of future growth. The resulting Zone 8 increase of more than two hours is therefore especially relevant. But Anaheim itself says future projects require project-specific analysis incorporating the actual project, affected zones, vehicle demand, cumulative projects, road network, routes, signal controls, and fire scenario. That becomes increasingly important because East Anaheim residents are confronting multiple development possibilities at different stages. These include the recently approved Festival Center apartment project, a renewed Deer Canyon development effort, the approximately 25-home Renaissance Partners proposal, and other potential or not-yet-filed properties residents are monitoring, including possible residential interest affecting additional East Anaheim parcels. We intentionally distinguish here between approved projects, known proposals, and unconfirmed future-development possibilities. The latter should not be represented as approved projects. But that uncertainty is itself one reason the cumulative-capacity question cannot be treated as closed. The relevant public-safety question is not whether each project can be made to appear acceptable in isolation. It is whether the entire shared evacuation network remains viable as approved, pending, foreseeable, and later development adds vehicles to the same constrained corridors. 10. Anaheim’s Housing Element itself recognizes substantial candidate-site capacity and the use of land-use changes to facilitate housing. Anaheim’s Housing Element identifies candidate sites that may require overlay zoning, General Plan amendments, zoning changes, or other actions to permit or streamline housing development. It also documents a longstanding pattern of converting nonresidential sites to residential uses and expressly discusses redevelopment of commercial and industrial parcels. 7 This is relevant because the City’s Prohousing application claims additional points for allowing residential development in nonresidential zones and for zoning and land-use measures that accelerate housing production. Again, none of this proves that any particular unannounced parcel will be developed. It demonstrates why residents are reasonably asking the City to establish infrastructure and evacuation capacity first, rather than assuring residents project-by-project after additional development applications arrive. 11. The strongest procedural discrepancy concerns Anaheim’s certification of public participation. Anaheim’s own Appendix 6 states that applicants must demonstrate a “Diligent Public Participation Process” and must attach and reference comments received. Anaheim then checks “YES” beside its representation that comments were documented and considered; that all comments were reviewed, summarized, and provided to decision-makers; that comments were incorporated where appropriate; and that, for comments not incorporated, the City provided explanations to ensure transparency and accountability. Anaheim’s staff report separately states that all public correspondence received by Planning staff through preparation of the report is included as Attachment 3. The Concerned Anaheim Residents coalition submitted its original written opposition on June 11, 2026 at 3:29 p.m., during the City’s formal May 12–June 11 public review period. After receiving no confirmation, the coalition retransmitted that same opposition on June 23, expressly asking that it be included in the public-comment record. The coalition’s submitted history preserves the June 11 transmission itself. Yet the coalition’s comment is not identifiable in Attachment 3 of the materials presently before Council. That creates a direct and material question concerning Anaheim’s proposed certification that all comments were documented, reviewed, summarized, provided to decision-makers, and either incorporated or explained. We are not asking HCD to infer motive from this discrepancy. We are asking HCD to verify the administrative record. Until Anaheim identifies when the June 11 correspondence was received; where it was logged; who reviewed it; whether it was provided to decision-makers; why it was omitted from Attachment 3; which portions were incorporated; which portions were rejected; and what explanation was provided for those portions not incorporated, Anaheim should not certify the public-participation section as complete. 12. Reliance on older Housing Element outreach raises an additional diligence question. 8 Anaheim’s Prohousing application relies heavily on outreach conducted during the Sixth Cycle Housing Element and Environmental Justice processes as the foundation for its present Prohousing public- participation showing. There is value in that earlier outreach. But a 2021 Housing Element workshop asking residents generally about future housing needs is not necessarily equivalent to asking residents in 2026 whether Anaheim should seek a designation rewarding ministerial approval, eliminated hearings for certain projects, development-cost reductions, additional funding advantages, and accelerated production. Anaheim’s own historical outreach materials record stakeholder recommendations in favor of higher- density and mixed-use development, easier developer site selection, and reducing barriers created by community opposition. Residents were entitled to meaningful opportunity to evaluate those concepts in the context of this specific Prohousing application. Residents also raised specific questions during the review period regarding how many comments were received on the Prohousing application itself, who was directly notified, whether residents in wildfire-risk and evacuation-constrained areas were specifically contacted, how the application changed in response to public input, and whether supporting materials were consistently accessible. Those questions remain relevant to Anaheim’s certification that it conducted a diligent and meaningful public-participation process. 13. “Diligent Public Participation” requires more than publishing information where already-engaged residents know to look. Anaheim’s Prohousing application represents that it used multiple outreach methods and languages to ensure broad public awareness and participation and specifically certifies that the process provided opportunities for public input. The coalition requests that HCD and the City evaluate that claim quantitatively. Anaheim Hills encompasses large portions of ZIP Codes 92807 and 92808, with a combined population numbering in the tens of thousands. The question is not simply how many people live there. The appropriate public-participation questions are:  How many residents were directly notified of the Prohousing application?  What percentage of households in areas potentially affected by future Housing Element development received direct notice?  What methods were used — mailed notice, email subscription lists, social media, website posting, utility billing, community facilities, direct mail, or some combination?  Were residents required to already belong to a City email list in order to receive notice?  Were residents of Very High Fire Hazard Severity Zones or constrained evacuation areas specifically notified? 9  How were residents without reliable internet access reached?  How were older residents who are not regular users of social media or City websites reached?  What accessible formats were provided for residents with visual, hearing, cognitive, mobility, or other disabilities?  Were materials translated into languages reflecting Anaheim’s actual population?  How many residents opened or interacted with electronic notices?  How many comments were received specifically on the Prohousing Designation rather than imported from years-old Housing Element outreach? A resident’s participation in a 2021 discussion about housing needs cannot automatically be treated as informed consent to a 2026 application rewarding ministerial approvals, eliminated hearings for qualifying projects, development-cost reductions, and accelerated housing production. 14. Physical accessibility at public meetings should also be part of Anaheim’s participation analysis. The coalition also requests review of the physical accessibility of public-comment procedures. At a recent in-person City meeting, a wheelchair user attempting to provide multi-page public testimony was required to use a handheld microphone while simultaneously handling her written materials. Residents observed that the arrangement consumed part of her limited speaking time and interfered with her ability to deliver the comment. When the timer was stopped, other attendees had to request that the remaining speaking time be restored before she was permitted to complete her testimony. Regardless of intent, a public-comment format should not impose additional physical burdens on a speaker because the speaker uses a wheelchair or another mobility device. The coalition requests that Anaheim provide an accessible public-comment station for every public meeting, including an adjustable or wheelchair-accessible podium or table, a fixed or hands-free microphone, adequate space for written materials or electronic devices, and a procedure ensuring that time lost because of accessibility setup or accommodation is not charged against the speaker’s allotted public-comment time. This issue is especially relevant where Anaheim asks HCD to credit the City with a Diligent Public Participation Process. The relevant question is not simply whether public comment was technically available, but whether residents — including residents with disabilities — could participate on meaningfully equal terms. 15. The City’s financial incentive should be transparent but should not substitute for completing safety review. The staff report identifies a substantial financial consequence associated with Prohousing status. Anaheim states that future eligibility for $6.7 million in HHAP Round 7 homelessness funding is contingent upon obtaining Prohousing Designation. 10 The coalition recognizes the importance of homelessness funding and does not suggest that seeking such funding is improper. But the financial incentive also creates urgency that should not displace unresolved public-participation and life-safety review. A funding deadline is not a substitute for a complete administrative record. 16. We request postponement rather than an unsupported finding that housing and wildfire safety are mutually exclusive. California needs housing. Anaheim also has an obligation to protect residents already living in wildfire- and evacuation-constrained areas. Those objectives do not inherently conflict. The conflict arises only if speed itself becomes the measure of success before the City has defined the public-safety limits within which that speed may safely operate. That is precisely what residents are requesting Anaheim resolve before moving further. Accordingly, Concerned Anaheim Residents asks the City Council to continue or deny Item #21 tonight rather than authorize submission of the present application, and requests that HCD place Anaheim’s application on administrative hold if transmitted before the following issues are resolved: 1. Correct the public-comment record and account for the coalition’s timely June 11 submission and June 23 retransmission. 2. Revise the Diligent Public Participation certification to accurately reflect what comments were received, considered, incorporated, rejected, and answered. 3. Preserve Paragraph 6’s public-health, safety, infrastructure, and emergency-access protections. 4. Add explicit clarification that objective wildfire, evacuation, fire-code, traffic, emergency-access, infrastructure, and CEQA requirements are not prohibited housing constraints when supported by substantial evidence. 5. Complete and publicly respond to substantive comments on the Draft Wildfire Evacuation Study before relying on that framework to evaluate substantial new growth in evacuation-constrained areas. 6. Resolve the statistical significance-threshold issue so model variability is not treated as synonymous with life safety. 7. Evaluate credible tail-risk conditions, stronger-wind sensitivity, ember/spot-fire behavior, route failure, signal or power failure, smoke and route tenability, downstream congestion, and emergency-response interactions. 8. Establish implementation, funding, staffing, redundancy, and performance requirements for signal control, outbound flush strategies, communications, and other modeled operational improvements. 9. Separately analyze neighborhood-to-arterial, arterial-to-interchange, and interchange-to-freeway evacuation capacity. 11 10. Conduct project-specific and cumulative analysis as actual approved, pending, and reasonably foreseeable developments become known. 11. Quantify who was actually notified of the Prohousing application, what percentage of affected communities received notice, and how older, disabled, non-English-speaking, and non- technologically connected residents were reached. 12. Provide accessible public-comment facilities and procedures that do not consume a disabled speaker’s limited speaking time simply because an accommodation is required. 13. Provide HCD and the public with a complete, auditable record supporting Anaheim’s claimed 61- point self-score and its threshold public-participation certification. Anaheim should not be forced to choose between housing and wildfire safety. Nor should residents be asked to choose between them. The responsible sequence is straightforward: Establish the safety constraints. Prove the evacuation system can function within them. Fix known infrastructure deficits. Preserve those constraints as non-negotiable life-safety requirements. Then determine where and how additional housing can safely be accommodated. Until that work is complete, Anaheim should not seek State recognition for accelerating housing production while asking residents to trust that unresolved evacuation constraints will be addressed later. Source Documents: The City records referenced in this comment are incorporated by reference from the City of Anaheim’s publicly posted August 25, 2026 Agenda Item #21 materials, Prohousing Designation Application webpage, Housing Element materials, and June 2026 Draft Wildfire Evacuation Study. These include the City Council Agenda Report, proposed Resolution, Prohousing Designation Program Application and appendices, Public Correspondence/Attachment 3, Housing Element Appendix B, Housing Element Appendix C, and the Draft Wildfire Evacuation Study. Because these are City- generated records already maintained and publicly posted by Anaheim, they are not redundantly attached to this submission. Prior Submission Incorporated by Reference: Concerned Anaheim Residents previously transmitted documentation in this same email thread preserving the coalition’s June 11 and June 23, 2026 Prohousing public-comment submissions. That documentation is incorporated by reference into this supplemental comment and is not redundantly reattached. Please confirm receipt of this supplemental public comment, include it in tonight’s Item #21 record and supplemental public-comment packet, and ensure that this comment and the previously transmitted submission-history documentation accompany any subsequent Anaheim Prohousing Designation application transmitted to the California Department of Housing and Community Development. Respectfully submitted, Concerned Anaheim Residents Stakeholder Audit Team 12