Letter of Justification
To: Amanda Laufer
City of Anaheim – Senior Planner
From: Shea Properties: Sean McEachern
Copy: Elaine Thienprasiddhi
City of Anaheim – Principal Planner
Date: September 23, 2025
Re: Anaheim Hills Festival Project – Letter of Justification Th
e purpose of this correspondence is to provide additional justification for the deviations proposed under the Anaheim Hills Festival Project (DEV2023-00043). The items described in this letter represent deviations to the existing Code requirements, and are proposed through the Specific Plan Amendment to the Zoning and Development Standards in Chapter 18. 108 (SP 90-1).
1 Bedroom – Minimum Square Footage:
Anaheim Code requires a minimum square footage of 700 SF for a 1 Bedroom unit. The proposed project would allow for one-bedroom units in DA 5 to be a minimum of 580 SF. There are 36 units (unit type “AO”), representing less than 10% of the total units. These units are intentionally designed to provide a more attainable entry point for young professionals, particularly recent college graduates, in a high-demand Orange County market such as Anaheim. Additionally, all of these units have private open space with balconies of approximately 50 SF, which expands the usable living space and enhances natural light and ventilation. Units of this size and configuration are typically among the first to lease during initial lease-up.
1 Bedroom - Minimum Parking Requirement:
Anaheim Code requires a minimum of 2.0 spaces for 1 Bedroom units. The proposed project would require a minimum of 1.75 spaces for the 1 Bedroom units in DA 5. The SPA would require a Parking Demand Study for mixed-use developments to analyze the overall parking needs. A detailed Parking Demand Study was completed and confirmed that the project’s overall parking count is sufficient.
The Study utilized current examples of very similar Shea owned and managed projects in Orange County as well as the Urban Land Institute’s industry standard recommendations. The analysis demonstrates actual parking demand is lower than standard Code minimums and that the project’s parking supply will exceed anticipated demand across all unit types.
It is also important to note that there are over 2,000 parking spaces on the lower level, which includes a surplus of more than 300 spaces compared to Anaheim Code requirements. Parking within the Festival shopping center is shared throughout DA 1, DA2, DA3, and DA5. This adjustment reflects real-world demand, prevents oversupply of underutilized parking, and ensures that adequate parking is available for both residents and visitors, consistent with the Code’s intent to provide sufficient but efficient parking.
Maximum Wall Sign Square Footage for In Line Shops:
The existing Anaheim Hills Festival Specific Plan states certain requirements for tenant wall signage, which differ from the general Sign Code requirements and have caused confusion for implementation with tenants and City staff. The proposed Specific Plan Amendment would modify the sign requirements in Chapter 18.108 to refer back to the general sign requirements in Chapter 18.44, with the exception that tenants with 38-feet of frontage or less will be able to have 1.25 square feet of signage per lineal foot of frontage. The existing signage requirements in the Specific Plan could have allowed more than 1 SF of signage for tenant frontages, which could cause non-conforming conditions.
This request is intended to maintain the sizing that has been in place since the center was constructed and to ensure fairness for new tenants as spaces turn over. Visibility is especially critical for smaller in- line shop spaces, where signage has a direct impact on tenant visibility. The modest increase is narrowly tailored, applying only to tenants with limited frontage, and ensures consistency with existing tenant signage, compatibility with the scale of the center, and the Code’s intent to provide effective but orderly business identification. Tenants with these smaller frontages are primarily located interior to the center and are not as directly visible from the main street frontages along Santa Ana Canyon Road or Festival Drive.
Additional Monument Signs:
The existing Specific Plan includes regulations and locations for monument signage throughout the Anaheim Hills Festival shopping center. The proposed project would amend the monument sign requirements to increase the number of “Major Tenant Identification Sign- Low Monument” and “Project Identification” signs, specifically indicate where directional monument signs will be located throughout the center, and update monument sign dimension allowances based on the current condition of monument signs that are already built. The project also proposes to change the “Theater Marque Sign” along Santa Ana Canyon Road to a “Major Tenant Identification Sign”, which would be designed and constructed the same as the other monument signs along the street frontage.
The Anaheim Hills Festival is a large regional shopping center spread out over approximately 61 acres.
The area has significant topography, including a separation into a lower deck and upper deck separated by approximately 30 feet (depending on location of measurement). Additionally, there are significant distances from the public streets surrounding the center to the large tenants and the in line small shops within the center. To address these physical constraints, the proposed sign program offers a variety of signage options designed to ensure adequate visibility from surrounding public roadways and to support tenant identification across the center. The number and location of monument signs along the Santa Ana Canyon Road street frontage will not be modified, and all other newly proposed monument signs serve to better direct customers and the public to areas in the center where specific tenants are located.
The Specific Plan Amendment includes specific requirements for the monument signs to be located outside of the required visions clearance area to ensure pedestrian and vehicular safety, and do not overwhelm the street frontages surrounding the center.