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NA10P LEGISLATIVE COMMERCIAL REAL ESTATE DEVELOPMENT ASSOCIATION AFFAIRS SoCAL CHAPTER April 15, 2025 The Honorable Valerie Amezcua Mayor,City of Santa Ana 20 Civic Center Plaza Santa Ana, CA 92701 Re:Agenda Item #26—Opposition to a final extension of a moratorium on the approval,commencement, establishment,relocation,or expansion of industrial uses in Specific Development No.84 for up to one year. Honorable Mayor Amezcua and Councilmembers: My name is Mihran Toumajan, and I serve as Government Relations Manager for NAIOP SoCal,headquartered in the City of Santa Ana's historic Lacy neighborhood. Representing over 1,300 Members across Orange and Los Angeles counties, NAIOP SoCal is the leading nonprofit association for professionals in commercial real estate,including developers,owners, general contractors, architects, engineers, finance professionals, and other service providers focused on the development and redevelopment of office, industrial, retail,mixed-use residential, data center, and hospitality asset classes. We value our solid, working relationship with City staff and have actively participated in discussions around the Transit Zoning Code update for Specific Development No. 84. While we support thoughtful planning,we respectfully oppose the proposed urgency ordinance to extend the industrial use moratorium in SD-84 for up to one year. Under Government Code § 65858, such an extension requires new and specific findings of a current and immediate threat to public health, safety, or welfare. Unfortunately, the City's report offers no substantial new evidence - only repeated concerns previously cited. Generalized data on emergency calls and administrative compliance issues lack a direct, causal link to existing industrial uses and are therefore speculative. The proposed moratorium's economic impact is significant: It affects over 100 responsible businesses and potentially jeopardizes more than 1,000 local jobs.In its staff report,the City has not presented evidence showing that SD-84 businesses are directly causing immediate harm to public health, safety, or welfare. Rather than extending a broad and indiscriminate moratorium, we urge the City to pursue targeted code enforcement, while simultaneously focusing on the Transit Zoning Code update, scheduled for Council consideration on May 6. Such an approach will allow responsible businesses to continue operating while addressing specific concerns through existing regulations. Given that the zoning code update is imminent, an additional year-long moratorium is unnecessary and unjustified. In conclusion,the proposed extension lacks legal justification and risks harming our local economy.NAIOP SoCal supports balanced land use policies,but these must be grounded in current facts, economic realities, and compliance with State law. Thank you for your time and consideration. Sincerely, -Vrhran Toumajan Submitted at the City Council Meeting Mihran Toumajan Of 5 Item No. Manager of Government Relations,NAIOP SoCal By .(1_1 �( - `�-�