June 2019

1.    Nothing has changed since the city denied a project on the same property in 2014

2.    The project does not reflect the goals and policies of the Orange General Plan

3.    The project violates the Orange Park Acres Specific Plan

4.    The project violates the East Orange General Plan


5.    The project does not honor the Santiago Creek Greenbelt Plan (1971)


6.    The project does not honor the Santiago Creek Implementation Plan (1976)

7.    The site is in a floodplain, below two earthen dams

8.    The site is next to a landfill that emits methane gas

9.    The Canyon 2 Fire exposed the property as a high-risk fire trap to homeowners

10.    Liquefaction poses serious threats to the area, which lies in an earthquake fault zone

11.    The property is undermined with silt ponds

12.    There are no reclamation plans to restore the former mining area for alternate use

13.    The site is still designated an area of regional significance (aggregates) by the state

14.    The Draft Environmental Impact Report is inadequate, failing to address agency and community concerns


15.    The Draft Environmental Impact Report relies on outdated studies to support its findings

16.    The Draft Environmental Impact Report ignored the site’s history

17.    Construction traffic will create significant noise and air pollution for several years

18.    The project infringes on the rights of neighboring homeowners

19.    There are generations of toxic mining residue buried on the site

20.    The city (and taxpayers) will be liable for future homeowners’ health or property loss


21.    There is no agreement between the landowner and anyone else to manage the creek once it’s conveyed

22.    The builder plans to build 128 houses, but amended zoning will permit 240

23.    The public benefits are backloaded with strings attached

24.    Designated open space will be lost forever

25.    Some of the identified “negative impacts” cannot be mitigated


26.    No one has stepped up to accept the liability or maintenance of the “gift” of unbuildable land

27.    Viable alternatives have not been addressed

28.    Forces impacts of development onto rural neighborhoods

29.    Investors are not entitled to build here; the city is not obligated to approve the project

30.    Clean-up costs will eventually be borne by taxpayers . . .

As Orange weighs approval of a housing

tract on the Sully-Miller property, there

are a few points worth pondering: