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Final Extension of Moratorium on the Approval, Commencement, Establishment, <br />Relocation, or Expansion of Industrial Uses in Specific Development No. 84 (Transit <br />Zoning Code) <br />April 15, 2025 <br />Page 5 <br />4 <br />9 <br />7 <br />1 <br />The City of Santa Ana Code Enforcement Division is currently addressing 21 open code <br />enforcement violations or compliance reviews specifically involving industrial businesses <br />within the TZC area. This activity demonstrates the City’s direct involvement in overseeing <br />these businesses to mitigate potential environmental and public health risks. <br />Review of Records and Activities of External Agencies <br />To broaden the analysis beyond the City's local land use impacts, City staff have <br />received public records requested of compliance status, violation records, and violation <br />status of outside regulatory agencies, and have contacted staff from external regulatory <br />agencies such as the South Coast Air Quality Monitoring District (SCAQMD), Santa Ana <br />Regional Quality Water Control Board (SARQWCB), the Department of Toxic <br />Substances Control (DTSC), Certified Unified Program Agencies (CUPA), California <br />Environmental Reporting System (CERS), and others responsible for issuing regulatory <br />permits for industrial uses in the TZC. Specifically, these agencies are responsible for <br />permit issuance, compliance activities, and/or monitoring hazardous clean-up sites, or <br />other industrial facility-related activities and have received current data requests for <br />sites located within the TZC zoning district. <br />Data from outside regulatory agencies assist City staff in further understanding activities <br />between external regulatory agencies and industrial businesses that may place additional <br />impacts on public health, safety, and welfare in affected neighborhoods adjacent to <br />industrial businesses in the TZC. This information would enable City staff to understand <br />the correlation and environmental burdens that may be attributed to permitted activities for <br />industrial businesses in historically environmentally disadvantaged communities, <br />specifically the Logan and Lacy neighborhoods. <br />Records show SCAQMD issued two notices to comply with one industrial business on <br />August 2023 and April 2024 for failure to maintain records, such as temperature graphs, <br />poundage logs, and source test data. SCAQMD issued several permits to construct and to <br />operate to the new operator of this same facility, which is currently in compliance with <br />SCAQMD. Two notices of violation were issued to one industrial business for operating a <br />paint spray booth without a valid permit to operate from SCAQMD. <br />The report from the SARWQCB from 2024 shows three (3) active industrial business in the <br />TZC in violation of their permit for providing a late report or incomplete and/or insufficient <br />information for their Stormwater Pollution Prevention Plan (SPPP). In March 2025, one of <br />the three businesses with active violations concluded a financial settlement directly with <br />the SARWQCB agency. <br />Public records from the CUPA for Orange County, spanning 2022-2024, reveal a <br />pattern of non-compliance with environmental and hazardous materials regulations