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
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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.
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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.
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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?
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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.
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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.
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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
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