9.1. Agreements related to the restoration and future conveyance to the City of the approximately 67.7-acre former Sully-Miller property at 6145 E. Santiago Canyon Road for permanent public open space, and finding of California Environmental Quality Act exemption
I respectfully ask the City Council to defer approval of this agreement. Based on the Orange County Local Enforcement Agency's (LEA) August 19, 2026 response to Landify, I believe the proposal is premature and that the City does not yet have the regulatory information necessary to make an informed decision.The LEA's August 19 letter states that Landify's proposed IDEFO Operation Plan is "not complete and correct" under 14 CCR §18101. The LEA also states that certain aspects of the proposal remain "premature and speculative" because the Stipulated Notice and Order (SNO) remains effective.That is a significant statement from the agency responsible for regulating the solid-waste aspects of this property.The contaminated stockpiles have not been resolved The LEA's August 19 letter specifically identifies arsenic in Stockpiles F, G, H and I. The LEA states that affected portions must be removed and properly disposed of and that it cannot approve reuse of material from those stockpiles until Milan completes the Water Board-required work-plan activities.This creates a fundamental problem with moving forward with an IDEFO agreement now.The City would be committing to a future operation while the regulatory agencies are still determining what material must be removed, what material can remain, and what material may ultimately be processed or reused.The LEA also did not concur with the premise that the existing stockpiles could simply remain in place as engineered fill.
These are not issues that should be treated as resolved.The proposed project is substantial This is not simply a proposal to bring clean fill onto an otherwise vacant property.The proposed IDEFO involves approximately 971,000 cubic yards of imported fill, with proposed fill areas approximately 45 to 50 feet high, together with grading, processing and reuse of existing material, substantial truck traffic, and an eventual open-space end use.
CEQA Should also Be Addressed Before the City Acts I understand that the City is considering this IDEFO proposal to be CEQA-exempt.
I respectfully ask the Council to require the City to identify the specific CEQA exemption being relied upon and explain how that exemption applies to this particular project and site.This is especially important because the proposed action involves substantial changes to a property with a complicated environmental and regulatory history.The Rio Santiago site contains historically accumulated stockpiles from a prior disposal operation. Some of those stockpiles have been identified as containing contaminants. The property remains subject to the SNO, and the LEA has expressly stated that portions of the proposed IDEFO remain premature while that SNO remains effective.The City is now being asked to approve an agreement involving a proposed operation with nearly one million cubic yards of fill, significant changes in site elevation, processing and reuse of existing material, substantial truck traffic, and a proposed open-space end use.Those circumstances warrant a careful examination of whether the City's action is actually ministerial or discretionary and, if discretionary, whether a CEQA exemption is legally appropriate.Under 14 CCR §15268, a ministerial action is one in which the public agency does not have discretion to consider environmental consequences in deciding whether or how to approve the project.
Jarad Hildenbrand, City Manager
300 East Chapman Avenue
Orange, CA 92866
RE: City Council Agenda Item 9.1
As a 40-year resident of Orange and long-time property owner in East Orange, I am providing my comments in support of item 9.1.
This action moves the city forward in compliance with so many goals and policies of the General Plan. It is another positive sign that open space and implementing the Quimby Act do matter in Orange.
As I have been consistent in my call for proper, fair, and ethical land use decisions in Orange, the leading issue that remains a passion, is solving the citywide open space deficit that prior city leadership long ignored. It is great to see this issue no longer being kicked down the road. This agreement will go a long way in fixing it along with the 30-acre acquisition along Santiago Creek and the Chandler site.
To best memorialize the significance of this issue, I share this paragraph below from our 2010, General Plan’s Natural Resources Element on page 44, the last paragraph.
Because city residents will benefit from additional Parkland and recreation programming, Orange will work actively to acquire, build, and maintain additional Parkland and park facilities. Specifically, the city will pursue adding approximately 246 acres of additional parkland beyond the current inventory of current and planned facilities listed in table NR-2, in order to achieve a minimum park land ratio of 3 acres per thousand persons by 2030, working toward a desired ratio of 5 acres per thousand persons by 2050 (additional 450 acres). The city will evaluate progress toward achieving this goal in a report to the City Council and the community every five years.
While this and future City Council’s have more work to do in addressing our citywide parkland deficit ahead of the 2030 and 2050 deadlines, the approval of this action gets us well on our way.
Thanks to all parties involved for getting this important work done and moving the city forward in ending this deficit.
August 24, 2026
Sent via email to: JHildenbrand@cityoforange.org
Jarad Hildenbrand
City Manager
300 East Chapman Avenue
Orange, CA, 92866
Re: Support Agenda Item 9.1 (File: 26-0482) Agreements related to the restoration and future
conveyance to the City of 67.7-acre of the former Sully-Miller property for permanent public
open space.
Dear Mr. Hildenbrand:
Orange Park Association is a non-profit organization formed in 1960 to protect the rural
equestrian area known as Orange Park Acres (OPA) that was established in 1928.
The Orange Park Acres Specific Plan was adopted by the City of Orange in 1973. A significant
portion of OPA is encompassed in the Santiago Creek Greenbelt Plan, which was adopted by the
city in 1971. A major portion of the Sully-Miller site, located along Santiago Creek, is within
Orange Park Acres and included in the Greenbelt Plan.
The OPA Plan promotes (1) The Santiago Creek Greenbelt Plan (2) the phasing-out of gravel pit
operations along Santiago Creek and the restoration of natural amenities within the area, and
(3) the preservation of Santiago Creek as a balanced ecological system and riparian area,
maintaining the diversity of plant and vertebrate species while allowing for light recreational
use such as equestrian, hiking trails and agriculture.
The agreements before the City Council are in alignment with the OPA Plan. This effort is a
remarkable opportunity to fulfill the long-term open space vision for the Santiago Creek
corridor, trails, natural resources, and adds tremendous value to the rural character of the
surrounding area.
Orange Park Association supports the recommended actions and urges the City Council to
approve them.
We appreciate the work that has been done by the various parties to create the pathway to
transform the Sully Miller property for open-space use and ultimately transferred to the City for
permanent public ownership.
Thank you for the opportunity to comment on this matter. Please include OPA in any future
correspondence or notices.
Sincerely,
Sherry Panttaja
Sherry Panttaja
President, Orange Park Association
I support this agreement and the eventual conversion of this land to open-space. I would only caution how soil remediation will be addressed and funded.
I respectfully ask the City Council to defer approval of this agreement. Based on the Orange County Local Enforcement Agency's (LEA) August 19, 2026 response to Landify, I believe the proposal is premature and that the City does not yet have the regulatory information necessary to make an informed decision.The LEA's August 19 letter states that Landify's proposed IDEFO Operation Plan is "not complete and correct" under 14 CCR §18101. The LEA also states that certain aspects of the proposal remain "premature and speculative" because the Stipulated Notice and Order (SNO) remains effective.That is a significant statement from the agency responsible for regulating the solid-waste aspects of this property.The contaminated stockpiles have not been resolved The LEA's August 19 letter specifically identifies arsenic in Stockpiles F, G, H and I. The LEA states that affected portions must be removed and properly disposed of and that it cannot approve reuse of material from those stockpiles until Milan completes the Water Board-required work-plan activities.This creates a fundamental problem with moving forward with an IDEFO agreement now.The City would be committing to a future operation while the regulatory agencies are still determining what material must be removed, what material can remain, and what material may ultimately be processed or reused.The LEA also did not concur with the premise that the existing stockpiles could simply remain in place as engineered fill.
These are not issues that should be treated as resolved.The proposed project is substantial This is not simply a proposal to bring clean fill onto an otherwise vacant property.The proposed IDEFO involves approximately 971,000 cubic yards of imported fill, with proposed fill areas approximately 45 to 50 feet high, together with grading, processing and reuse of existing material, substantial truck traffic, and an eventual open-space end use.
CEQA Should also Be Addressed Before the City Acts I understand that the City is considering this IDEFO proposal to be CEQA-exempt.
I respectfully ask the Council to require the City to identify the specific CEQA exemption being relied upon and explain how that exemption applies to this particular project and site.This is especially important because the proposed action involves substantial changes to a property with a complicated environmental and regulatory history.The Rio Santiago site contains historically accumulated stockpiles from a prior disposal operation. Some of those stockpiles have been identified as containing contaminants. The property remains subject to the SNO, and the LEA has expressly stated that portions of the proposed IDEFO remain premature while that SNO remains effective.The City is now being asked to approve an agreement involving a proposed operation with nearly one million cubic yards of fill, significant changes in site elevation, processing and reuse of existing material, substantial truck traffic, and a proposed open-space end use.Those circumstances warrant a careful examination of whether the City's action is actually ministerial or discretionary and, if discretionary, whether a CEQA exemption is legally appropriate.Under 14 CCR §15268, a ministerial action is one in which the public agency does not have discretion to consider environmental consequences in deciding whether or how to approve the project.
Kim Plehn
Sent via email to: jhildenbrand@cityoforange.org
Date: August 24, 2026
Jarad Hildenbrand, City Manager
300 East Chapman Avenue
Orange, CA 92866
RE: City Council Agenda Item 9.1
As a 40-year resident of Orange and long-time property owner in East Orange, I am providing my comments in support of item 9.1.
This action moves the city forward in compliance with so many goals and policies of the General Plan. It is another positive sign that open space and implementing the Quimby Act do matter in Orange.
As I have been consistent in my call for proper, fair, and ethical land use decisions in Orange, the leading issue that remains a passion, is solving the citywide open space deficit that prior city leadership long ignored. It is great to see this issue no longer being kicked down the road. This agreement will go a long way in fixing it along with the 30-acre acquisition along Santiago Creek and the Chandler site.
To best memorialize the significance of this issue, I share this paragraph below from our 2010, General Plan’s Natural Resources Element on page 44, the last paragraph.
Because city residents will benefit from additional Parkland and recreation programming, Orange will work actively to acquire, build, and maintain additional Parkland and park facilities. Specifically, the city will pursue adding approximately 246 acres of additional parkland beyond the current inventory of current and planned facilities listed in table NR-2, in order to achieve a minimum park land ratio of 3 acres per thousand persons by 2030, working toward a desired ratio of 5 acres per thousand persons by 2050 (additional 450 acres). The city will evaluate progress toward achieving this goal in a report to the City Council and the community every five years.
While this and future City Council’s have more work to do in addressing our citywide parkland deficit ahead of the 2030 and 2050 deadlines, the approval of this action gets us well on our way.
Thanks to all parties involved for getting this important work done and moving the city forward in ending this deficit.
I say Vote Yes,
Adrienne J. Gladson
Adrienne Gladson, AICP
August 24, 2026
Sent via email to: JHildenbrand@cityoforange.org
Jarad Hildenbrand
City Manager
300 East Chapman Avenue
Orange, CA, 92866
Re: Support Agenda Item 9.1 (File: 26-0482) Agreements related to the restoration and future
conveyance to the City of 67.7-acre of the former Sully-Miller property for permanent public
open space.
Dear Mr. Hildenbrand:
Orange Park Association is a non-profit organization formed in 1960 to protect the rural
equestrian area known as Orange Park Acres (OPA) that was established in 1928.
The Orange Park Acres Specific Plan was adopted by the City of Orange in 1973. A significant
portion of OPA is encompassed in the Santiago Creek Greenbelt Plan, which was adopted by the
city in 1971. A major portion of the Sully-Miller site, located along Santiago Creek, is within
Orange Park Acres and included in the Greenbelt Plan.
The OPA Plan promotes (1) The Santiago Creek Greenbelt Plan (2) the phasing-out of gravel pit
operations along Santiago Creek and the restoration of natural amenities within the area, and
(3) the preservation of Santiago Creek as a balanced ecological system and riparian area,
maintaining the diversity of plant and vertebrate species while allowing for light recreational
use such as equestrian, hiking trails and agriculture.
The agreements before the City Council are in alignment with the OPA Plan. This effort is a
remarkable opportunity to fulfill the long-term open space vision for the Santiago Creek
corridor, trails, natural resources, and adds tremendous value to the rural character of the
surrounding area.
Orange Park Association supports the recommended actions and urges the City Council to
approve them.
We appreciate the work that has been done by the various parties to create the pathway to
transform the Sully Miller property for open-space use and ultimately transferred to the City for
permanent public ownership.
Thank you for the opportunity to comment on this matter. Please include OPA in any future
correspondence or notices.
Sincerely,
Sherry Panttaja
Sherry Panttaja
President, Orange Park Association
I support this agreement and the eventual conversion of this land to open-space. I would only caution how soil remediation will be addressed and funded.