Maureen Moe Mendoza
April 7, 2026
Members of the City Council
13220 Central Avenue
Chino, CA 91710
Good evening Mayor and City Council Members of Clhino,
Over the past year, I have submitted multiple letters and public comments to this council raising serious concerns about ARC's care, resources, funding, medical needs, and oversight, including letters submitted in 2025 and 2026 .
I have raised concerns about whether ARC has adequate staffing, funding , space, and oversight , and proposed solutions such as aligning resources with intake, expanding spay and neuter services, strengthening foster and rescue partnerships, and ensuring transparency through regular public reporting .
To date, I have received only one written response despite these repeated submissions.
No acknowledgment, no timeline, no accountability . This lack of response is alarming when animal welfare and public trust are at stake.
Tonight, I'm asking again for action. I respectfully request that the City formally consider pursuing amendments to the ARC Joint Powers Agreement to allow shared staffing support, including member agency employees , event volunteers, and limited-duty personnel to assist with ARC operations and community outreach .
I'm also asking the Council to commit to transparency and oversight by:
• Implementing regular public reporting on ARC operations • Placing a quarterly ARC agenda item to publicly report intake, adoptions , return to owner, transfers , euthanas ia totals (and reason), and average length of stay, consistent with the Hayden Act.
• Ensuring meetings are posted, accessible , and recorded for the public • Request that City Council implement a practice of displaying two adoptable ARC animals, with brief introductions, on screen before and after each meeting to promote adoption
• I am requesting that the City of Chirro formally request, through the JPA, the establishment of an independent oversight committee to ensure that decisions impacting the welfare of animals are transparent and open to public review.
These steps are practical, achievable, and necessary to ensure humane care and responsible management of the animals in ARC's care. I respectfully request a written response to my prior submissions and to the concerns raised here tonight.
Thank you for your time and consideration,
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Maureen Moe Mendoza
Faster Advocate for Maverick
April 7, 2026
Members of the City Council
13220 Central Avenue
Chino, CA 91710
RE: Request for Consideration of JPA Amendment - Shared Staffing and Support for ARC
I am writing as a community advocate to respectfully request your consideration of pursuing an amendment to the Joint Powers Agreement, JPA, governing the Animal Resource Center of the Inland Empire, ARC, to include provisions allowing for the temporary sharing or assignment of staff between member agencies.
As you are aware, the ARC is not only a regional service provider but also a fac ility responsible for the daily care, housing, and wellbeing of animals for its member cities, including the City of Chino. The demands of maintaining kennel operations such as cleaning, feeding, medical support, and enrichment combined with staffing and budget limitations , can make it difficult to fully support both essential onsite animal care and participation in community events, particularly those hosted within member cities.
To help address this, I respectfully suggest that the JPA be expanded to allow for:
• Temporary assignment of employees from member agencies to assist ARC at city hosted events
• Utilization of approved event volunteers to support ARC related activities under appropriate supervision
• Opportunities for limited duty employees to assist with appropriate tasks that support animal care and outreach
These options would provide meaningful, flexible support while ensuring that ARC can maintain its core responsibilities , including animal care, enrichment, and community engagement.
Allowing this type of collaboration would be consistent with the cooperative intent of a JPA and would strengthen the partnership between ARC and its member cities, while directly benefiting the animals in ARC's care.
This correspondence is being submitted for inclusion in the public record. I respectfully request a written response regarding this matter and whether the City would be willing to explore this proposal and potentially bring it forward for discussion.
Thank you for your time and consideration.
Respectfully submitted,
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Maureen Moe Mendoza
Foster Advocate for Maverick
Outlook
[EXT EMAIL] Public Comments
From Robert Nig
Date Tue 4/7/2026 3:51 PM
To Gonzaga, Natalie <ngonzaga@cityofchino .org> ; Ulloa, Eunice <[email protected]>; Burton, Curtis <[email protected]> ; Flores, Christopher <[email protected]>; Comstock, Karen < [email protected] >; Lucio, Marc < [email protected] rg > Cc Reich, Linda < LReich@cityofchino .org >
(ID 1 attachment (527 KB)
Recap of Density Meeting 1.pdf;
Natalie Gonzaga, City Clerk
I plan on attending the April 7, 2026 Council Meeting tonight and due to the 5 minutes time limit for Public Comments, I request the attached PDF document be distributed to each council member to be included in the public record.
Thank-you
Bob Nigg
EXTERNAL EMAIL: Please verify sender email. If unknown, DO NOT open links/attachments . NEVER give out your user ID or password for any reason!
Comments Concerning Zoning Revisions Meeting
of February 11, 2026
Density Issues
It has been nearly 15 months since the city council agreed to look into the topics of density, height and inclusion of storage facilities in the affordable housing overlay sites.
This extended time frame unjustifiably has and will allow future developments to be continued to be developed at unwarranted zoning requirements that are detrimental to the citizens of Chino. The horrible effects of the Eden development are being allowed to continue while the city council takes no meaningful action.
The density of units in the MU-OV districts was based upon a faulty feasibility study that was revised within a two week period. It is argued that the econometric feasibility study dated March 15, 2023 did not meet the standards of law under Gov. Code § 65850.01 (b) which required sufficient evidence be provided to HCD to adequately review the Housing Element (and Ordinance 2023-008) to determine the density study used would not constrain the production of housing in the two types of overlay districts (AFF-OV and MU-OV). It is asserted the lnclusionary Housing: Policy Recommendations prepared by Keyser Marston Associates, Inc., dated March 15, 2023 lacked the standards of § 65850.01 (b)(3). The study methodology did not follow best professional practices and was not sufficiently rigorous to allow an assessment of whether the rental inclusionary requirement, in combination with other factors (active commercial usage) that influence feasibility, was realistic and economically feasible. • Lack of professional practices - The March 15, 2023 study had material differences between the January 30, 2023 and March 15, 2023 feasibility studies prepared by Keyser. A professional and proficient study which followed best practices should not contain significant revisions in less than a 90 day period. A professional firm should not need to recalculate the cost of public permits and fees by 100% within a very short period of time.
• Insufficient Rigorous Analysis - The March 15 study did not conduct a rigorous analysis and did not provide analytical data to support that public permits and fees had doubled within an approximate 30 day period since the report dated January 30, 2023.
• Lack of Best Practices - Standard auditing principles should have been used to assure that the January 30, 2023 was using the most current analytical information to determine cost projections, including current public permits and fees. • Lack of Assessment of Other Factors in Mixed Use Overly Sites - Neither the January 30 or the March 15, 2023 report considered mixed use cost benefits, including how including commercial, retail, or office space in a mixed-use project can directly improve the financial feasibility of the residential component. These factors 1 Table 8
Projected RHNA Development in AFF-OV and MU-OV Distri cts (Feb. 2026) Buildable RHNA
Net Overlay Assumed Overlay Assumed Low Units RHNA
APN Acreage Zone Density Zone Density Projected Shortage 101551127 8.35 AFF-OV 25 207 207 0 207
10201110 1 4.02 AFF-OV 25 99 99 0 99
102103116 1.45 AFF-OV 25 36 36 0 36
Totals 13.82 342 342 0 342
Based upon the current planned and proposed developments in 8 RHNA sites, there is a probable remaining buffer of only 631 units before a "no net loss" would be expected to occur.
Table 9
Total
Tota l RHNA
RHNA Tota l RHNA Shortage
Lower Buffer Shortage in Total RHNA Percentage
Tota l Income in in Projected Shortage Remaining of RHNA Units Units Overlay Planned Low Planned & Buffer Actual to Available Required Districts Units Units Projected Units Required 4958 3397 1561 588 342 930 631 18.6%
Based upon the assumed capacity in all 91 RHNA sites documented in the Housing Element, a development trend of only 1.3% of planned and projected capacity is being developed to fulfill the city's RHNA lower income housing allocation. Of the RHNA goal of 3,397 only 35 lower income units have been planned to date within the planning period.
Table 10
RHNA
Capacity Percentage
Tota l RHNA Tota l Tota l Lower of RHNA
Units Lower Buffer Planned Income Low
Available Income in and Planned Income
with Units Overlay Planned Projected Projected & Actual to Buffer Required Districts Capacity Capacity Capacity Projected Required 4,958 3,397 1,561 623 342 965 35 1.03%
5 Key reasons for this shift included:
• Preventing "Paper Capacity": Historically, cities identified sites that were technically zoned for housing but had zero real-world chance of development (e.g., a high performing grocery store or a site with long-term leases). • Data-Driven Accuracy: HCD now requires cities to look at recent development trends. If developers only build just less than 50% of the maximum allowed density in mixed use sites, the city can only claim 50% capacity for its future sites. • Enforcing Housing Targets: By requiring a realistic "expected yield," HCD ensures that the RHNA targets represent actual homes that can be delivered during the 8- year planning period.
• Mixed-Use Likelihood: For sites zoned for both commercial and residential use, cities must now prove the likelihood of residential development occurring instead of just more commercial space.
The recent Redondo Beach appellant court decision further restricted the possible "paper capacity" developments in mixed use overlay sites. The City of Chino could be a "poster child" for the abuses of mixed use overlays.
Furthermore, there is a false assumption that the shortfalls in the city's RHNA lower income capacity would be met by having virtually all of the assumed RHNA LowNery Low Income capacity be developed. There are 91 overlay sites (44 AFF-OV and 47 MU OV sites) the city used to fulfill its RHNA allocations. Under Table B-6 of the Housing Element, the "Net Capacity" total is identical to the RHNA "LowNery Low" capacity total for each of the 91 RHNA site. Wherein the city has a 146% buffer assumption to satisfy its RHNA lower income allocation requirements with 4,958 units, the city passed an ordinance requiring only 9% of the units in the 91 overlay sites are required to be for lower income units. This results in a projected short of 4,512 lower income unit during the assumed 6th Cycle period. This creates a highly probable "no net loss" scenario that cannot be realistic achieved.
Table 12
No Net Loss Chart
Site
RHNA Inventor y Realistic Net
Lower Site Tota l at 9% RHNA Lower
Income Buffer Inventor y Low Income Income Units
Capacity Assumpt ion Tota l Inclusion Shortage
3,397 146% 4,958 446 4,512
7 Under Gov. Code § 65583.2(g)(1) the city shall specify for nonvacant site the additional development potential for each site within the planning period and shall provide an explanation of the methodology used to determine the development potential. • Existing Uses: an analysis of any known existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, and could include other market conditions that would encourage redevelopment of the property. For example, an analysis might describe an identified site as being developed with a 1960's strip commercial center with few tenants and expiring leases and, therefore, a good candidate for redevelopment, versus a site containing a newly opened retail center, an active Home Depot, the only grocery store in the city, etc. that is unlikely to be available for residential development within the planning period. An existing use shall be presumed to impede additional residential development, absent findings based on substantial evidence that the use is likely to be discontinued during the planning period. • Development Trends: The inventory analysis should describe development and/or redevelopment trends in the community as it relates to nonvacant sites, i.e., the rate at which similar sites have been redeveloped. This could include a description of the local government's track record and specific role in encouraging and facilitating redevelopment, adaptive reuse, or recycling to residential or more intensive residential uses. If the local government does not have any examples of recent recycling or redevelopment, the housing element should describe current or planned efforts (via new programs) to encourage and facilitate this type of development (e.g., providing incentives to encourage lot consolidation or assemblage to facilitate increased residential-development capacity).
There are a corrected 72 nonvacant sites listed in the Housing Element (and only 19 vacant sites, 26 less 7 misclassified equal 19 sites). Many of the 72 nonvacant sites have active retail/commercial sales in strip malls, large shopping centers, or no verified realistic potential to be developed under the 6th Cycle Housing Element planning period.
Additionally, there is a lack of documented evidence that retail/commercial sites have been redeveloped in the city for residential housing in the recent past. The extent of the existing uses or development trends as required under Gov. Code 65583.2(g)(1) for these 47 sites could impede the development of lower income housing.
A more accurate analysis of these 72 nonvacant sites could determine a large portion should be removed from the assume RHNA capacity they would fail to realistically fulfill the 3,397 lower income units during the 6th Cycle (2021-2029) planning period. 8 Vacant - Nonvacant Sites
Per Gov. Code 65583.(g)(2), if a housing element relies on nonvacant sites to accommodate 50 percent or more of its RHNA for lower income households, the nonvacant site's existing use is presumed to impede additional residential development.
Under HCD letters of October 2, 2019 (No Net Loss Law Government, Code Section 65863) and June 10, 2020 (Housing Element Site Inventory Guidebook Government Code Section 65583.2), a city must track and determine if it will fulfill its RHNA lower income allocations during the 8 year planning period. Based upon recent trends and the large use utilization of nonvacant sites, it is very dubious that the city can or will meet its RHNA allocations.
The City of Chino 6th Cycle Housing Element appears to have inaccurately and under reported percentages of nonvacant sites to determine if it meets the 50% required under §65583.2(c)(2). Without supporting documentation the city claimed 1,861 RHNA lower income units. However, an analytical review of Tables 8-6 and 8-7 of the Housing Element, only identified 1,591 units in the declared vacant sites. Errors and material omissions were also identified in that 704 housing units claimed in seven vacant sites should have been correctly classified as nonvacant. HCD defines a vacant site as a site without any houses, offices, buildings, or other significant improvements on it.
Improvements are generally defined as development of the land (such as a paved parking lot, or income production improvements such as crops, high voltage power lines, oil-wells, etc.) or structures on a property that are permanent and add significantly to the value of the property. Examples of Vacant Sites:
• No improvement on the site (other than being a finished lot).• • No existing uses, including parking lots.
• Underutilized sites are not vacant sites. (agriculture and prison property are considered underutilized)
• Sites with blighted improvements are not vacant sites. • Sites with abandoned or unoccupied uses are not vacant sites.
In Chino's Housing Element, under Table B-2, Sites Capacity on Vacant Sites, the city listed a capacity of 1,861 units, declaring it had 55% of the RHNA need of 3,397 units.
However the 1,861 units could not be supported with any analytical documentation. An analysis of Table 8-6 , Sites to Accommodate Chino 2021-2029 RHNA, determined there are 26 vacant sites listed. These 26 vacant sites totaled 1,591 in RHNA lower income units, resulting in only a 46.8% of the units being vacant. Additionally, the city misclassified at least seven sites as being vacant, when under the criteria used by HCD, 9 • There is a development agreement that exists to develop the site within the planning period,
• The entity operating the existing use has agreed to move to another location early enough within the planning period to allow residential development within the planning period.
• The property owner provides a letter stating its intention to develop the property with residences during the planning period.
Based upon a determination if the city had misrepresented the factual nonvacant sites capacity in the Housing Element, HOC should require the city to resubmit a revised 6th Cycle Housing Element with corrected and accurate data.
Based upon the new information, there is a false assumption of the realistic capacity to ensure the City of Chino is planning for housing that will realistically be built during the 6th Cycle planning period, rather than just a theoretically possibility on paper.
It is assumed that the city has inflated the realistic capacity of the nonvacant sites and will thus fail to meet its RHNA lower income housing of 3,397 units during the 6th Cycle planning period ending in 2029. It is anticipated that credibly factual evidence will determine that the City of Chino may already be at, or very near, a "no net loss" violation and be subject to the conditions of SB 166 as codified in Gov. Code § 65863.
Under Gov. Code § 65583.2(g)(2), in addition to the analysis required in paragraph (1 ), when a city or county is relying on nonvacant sites described in paragraph (3) of subdivision (b) to accommodate 50 percent or more of its housing need for lower income households, the methodology used to determine additional development potential shall demonstrate that the existing use identified pursuant to paragraph (3) of subdivision (b) does not constitute an impediment to additional residential development during the period covered by the housing element. An existing use shall be presumed to impede additional residential development, absent findings based on substantial evidence that the use is likely to be discontinued during the planning period.
Such existing use of commercial/retail on a RHNA site would be a factual impediment to meeting the city's RHNA goal of 3,397 lower income units. The city's calculation for realistic capacity should be the developable portion of the site rather than its total acreage.
Under the enhanced and rigorous requirements of § 65583.2(g)(2), the city should provide specific findings based on substantial evidence that commercial or engaged use is likely to be discontinued during the planning period.
Numerous nonvacant sites identified would need additional factual evidence to justify that residential development will likely occur in the 6th Cycle planning period. Probable 12 deficiencies have been identified during a perfunctory review of only a few of the 72 nonvacant site. Examples are:
1. APN 101910105, located at 4117 Riverside was reported on Table B-6 as being
7.19 acres as having 142 RHNA lower housing capacity. However the San Bernardino County Assessor office reports the lot acres as being only 4.93. This parcel per the notes in Table B-6 contains three retail structures having active commercial usage. It is estimated that only half of the parcel is developable for residential usage There is no evidence the commercial area will be removed or adjusted to allow for development on other than the estimated 2.47 east portion of the lot. There is no evidence that the leases for the commercial usage will expire during the current planning period. There is no evidence the developer has submitted a development agreement to revise or remove the commercial development. There is no evidence the owner has provided a letter stating its intention to develop the property with residences during the planning period . A realistic shortage of RHNA lower income units would range from 93 to 142 units
2. APN 101460119 located at 5402 Philadelphia was reported on Table B-6 as having a RHNA lower income capacity of 120 units. The parcel was described as currently having gym and strip mall with a large surface parking lot (local experience is the parking lot consistently has limited available parking and there are a very thriving and active commercial usage on the property. There is no evidence the leases will expire during the current planning period. There is no evidence the developer has submitted a development agreement to revise or remove the commercial development.
A realistic shortage of RHNA lower income 120 units exists.
3. APN 101506107 located at 5459 Philadelphia Ave, was reported on Table B-6 has having a RHNA lower income capacity of 180 units. Table B-6 lists the acreage as
9.05 acres; however, the San Bernardino County Assessor's office report the parcel has
6.2 acres. The only occupant on the parcel is Curacao, a large format retail chain that is currently active and uses the large parking lot. There may be a small portion of the parking lot that is being underutilized. A parcel being deemed as underutilized, would not qualify under the enhanced and rigorous significant evidence needed under Gov.
Code § 65583.2(g)(2); AB 1397; and HCD Housing Element Site Inventory Guidebook dated June 10, 2020. There is no evidence that the leases for the commercial usage will expire during the current planning period. There is no evidence the developer has submitted a development agreement to revise or remove the commercial development.
There is no evidence the owner has provided a letter stating its intention to develop the property with residences during the planning period. A realistic shortage of RHNA lower income 180 units exists.
13 4. APN 101945117 located at 13375 Ramona Ave, was reported on Table B-6 as
4.61 acres and having a RHNA lower income capacity of 115 units (AFF-OV). The only occupant on the parcel is currently a storage facility. There is no evidence that the leases for the commercial usage will expire during the current planning period. There is no evidence the developer has submitted a development agreement to revise or remove the commercial development. There is no evidence the owner has provided a letter stating its intention to develop the property with residences during the planning period. A realistic shortage of RHNA lower income 115 units exists.
5. APN 101951105 located at 13355 Ramona Ave, was reported on Table B-6 as
4.39 acres and having a RHNA lower income capacity of 109 units (AFF-OV). The only occupant on the parcel is currently a storage facility. There is no evidence that the leases for the commercial usage will expire during the current planning period. There is no evidence the developer has submitted a development agreement to revise or remove the commercial development. There is no evidence the owner has provided a letter stating its intention to develop the property with residences during the planning period. A realistic shortage of RHNA lower income 109 units exists.
6. APN 105327109 located at 6950 Edison, was reported on Table B-6 as 3.94 (adjusted) and having a RHNA lower income capacity of 97 units (AFF-OV). The property is currently occupied by a church. Per the narrative on page B-19 of the Housing Element, while the occupant (Crosspoint Church) could not commit to future plans, they weren't in disagreement over the application of the affordable housing overlay at this property. Such a stipulation would not quality under the enhanced and rigorous significant evidence needed under Gov. Code § 65583.2(g)(2); AB 1397; and HCD Housing Element Site Inventory Guidebook dated June 10, 2020. A realistic shortage of RHNA lower income 97 units exists.
7. APN 101555301 located at 5832 Riverside, was reported on Table B-6 as 2.77 acres and having a RHNA lower income capacity of 55 units. Th property is currently occupied by a strip mall with active tenets. While there may be some underutilized parking spaces at the east end, such unsupported evidence would not qualify under the enhanced and rigorous significant evidence needed under Gov. Code § 65583.2(g)(2); AB 1397; and HCD Housing Element Site Inventory Guidebook dated June 10, 2020. A realistic shortage of RHNA lower income 55 units exists.
8. APN 101504107 located at 12266 Central Ave, was reported on Table B-6 as 1.8 acres having a RHNA lower income capacity of 35 units. The parcel is currently a Motel 6 with a large surface parking lot. There is no evidence that the leases for the commercial usage will expire during the current planning period. There is no evidence 14 15
the developer has submitted a development agreement to revise or remove the commercial development. There is no evidence the owner has provided a letter stating its intention to develop the property with residences during the planning period. A realistic shortage of RHNA lower income 35 units exists.
9. APN 101460120 located at 5440 Philadelphia, was reported on Table B-6 as 3.1 0acres having a RHNA lower income capacity of 61 units. It was reported that parcel is currently a strip mall with a large surface parking lot. These businesses are active and utilized the parking area. There is no evidence that the leases for the commercial usage will expire during the current planning period. There is no evidence the developer has submitted a development agreement to revise or remove the commercial development.
There is no evidence the owner has provided a letter stating its intention to develop the property with residences during the planning period. A realistic shortage of RHNA lower income 61 units exists.
10. APN 105325102 at located at 6622 Edison, was reported on Table B-6 as 2.92 acres having a RHNA lower income capacity of 72 units. This property is adjacent to APN 105325103 at 6566 Edison on 2.12 acres having a RHNA lower income capacity of 52 units. Both parcels have single family detached residence in the southern portion of the parcels and the northern portion of the parcels are under SCE power lines making most of the property undevelopable. Both parcels are occupied by established ownership with no indication of near term development of high density housing. There is no evidence the developer has submitted a development agreement to revise or remove the detached housing units. There is no evidence the owners have provided a letter stating its intention to develop the property with residences during the planning period. A realistic shortage of RHNA lower income 124 units exists.
The reliance on the nonvacant sites to meet the realistic RHNA goals is not supported by substantial factual evidence and needs to be rectified.
In Summary
A jurisdiction must report in the jurisdiction's Annual Progress Report (APR) any sites that have been identified or rezoned to accommodate the resulting shortfall due to the approval of a development at a lower density. APRs are required to be sent to the Department by all jurisdictions by April 1, pursuant to Government Code section 65400.
There is sufficient evidence to necessitate that revisions to the 6th Cycle Housing Element are required and should be addressed in the Annual Progress Report due to the HCD by April 1, 2026. Based upon the factual data driven analysis of this submission, the City of Chino faces a specific potential of being in violation of the "No Net Loss" Law. It is recommended that immediate corrective action be taken to resolve the issues cited above.
Please advise me promptly if there is any disputes to the accuracy of the analysis cited in this submission. Feel free to contact me if you have any questions or concerns.
Sincerely
Robert Nigg
18