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Michael A. Freedman 1008 & 1012 N. Fuller Street Santa Ana, CA 92703 May 6,2025 City Council City of Santa Ana 22 Civic Center Plaza Santa Ana, CA 92701 RE: Written Comment—Opposition to Agenda Item No. 21 (Proposed Zoning Ordinance Amendments for SD-84 Area) Dear Honorable Mayor and Councilmembers: I submit this letter in strong opposition to Agenda Item No. 21, which proposes permanent zoning ordinance changes to the SD-84 area that will significantly affect long-standing industrial properties like mine. Through my family trust, I own two industrial buildings at 1008 and 1012 N. Fuller Street. These buildings were constructed in 1980 and have been used continuously for warehouse and storage purposes ever since. My properties are M2-zoned, low-impact industrial sites with no history of code enforcement issues,violations, or complaints. We are not high-impact users and have operated responsibly for decades. Yet the City's actions have repeatedly impacted our ability to use and lease these properties. I am very concerned that the proposed zoning amendments effectively make permanent a moratorium that the Council itself declined to extend just three weeks ago. On April 15, 2025, the Council allowed the industrial moratorium to expire, implicitly recognizing that it could not lawfully make the findings required under Government Code Section 65858. If the City cannot justify a temporary moratorium under state law, it should not attempt to codify those same restrictions through permanent zoning legislation. In addition to these legal concerns, the proposed ordinance raises serious questions under the California Environmental Quality Act(CEQA). These zoning changes represent a significant shift in land use policy across a large portion of the City's industrial base. CEQA requires that cities evaluate the full environmental consequences of such policy decisions before adoption, particularly where the new regulations may lead to the displacement of industrial uses, intensification of other uses, or substantial changes in traffic, air quality, or land use patterns. It is not clear that the City has prepared or certified adequate environmental documentation for this action. I am also concerned about the fairness and consistency of the City's process. Throughout the moratorium period, City staff applied the restrictions so broadly that even business license applications for new tenants—proposing no change in use whatsoever—were delayed or denied. That experience has made it nearly impossible to lease my buildings. This kind of overreach is