Apartment Association
1601 E. Orangewood Avenue, Suite 125
OF ORANGE COUNTY Anaheim, CA 92805
714) 245- 9500
May 11, 2026
Mayor Dan Slater & City Council Members
City of Orange
300 E. Chapman Avenue
Orange, CA 92866
RE: Opposition to Proposed Vacant Property Tax and Registry Dear Mayor Slater and Council Members,
The Apartment Association of Orange County ( AAOC) is the professional trade association that represents approximately 2,000 rental housing professionals who own, operate, and service more than 125,000 apartment and single-family rental units and employ more than 10,000 people in Orange and Riverside Counties. AAOC is committed to ensuring a safe, secure, and growing real estate market for all participants in the multifamily rental industry — and their residents.
We are writing to express strong opposition to the proposed Vacant Property Tax identified in Item 9. 1 of the May 12, 2026 city council agenda. The notion of taxing vacant properties — meaning units that are non- revenue generating — is perplexing. Further, creating a registration program to identify vacant units stands to diminish the safety of everyone' s neighborhoods. We strongly urge you to reject these proposals.
VACANT PROPERTY REGISTRY
The staff report indicates an intention to bring forward a vacant unit registry program in the coming weeks. Rental registries have repeatedly proven to be expensive to administer, unnecessary for city operations, and risky due to the creation of safety concerns that the city must then address:
Such registries are subject to Public Record Act requests.
Units that are exposed become potential targets for squatters or criminal enterprises.
Squatters, once established, become problematic for neighbors and the neighborhood.
Squatters take viable rental units off the market until they can be evicted — often taking 6- 9 months in California.
Squatters don' t pay rent and create hardships for the property owner on upkeep and security.
Registries are time- consuming and expensive for both the city and the property owner to maintain — and they take financial resources away from the units and the residents, as well.
Registries are typically funded by placing an additional fee on each unit — for which at least some of the cost is passed on to the tenants, making housing even less affordable.
This proposed registry is an expensive, unnecessary, and problematic endeavor that other Orange County cities have rejected as they learn about the liabilities, problems, and affordability concerns they bring.
www. AAOC. com
Apartment Association of Orange County
Opposition to Proposed Vacant Property Tax & Registry
2/ 3
VACANT PROPERTY TAX
The fact that the city of Oakland is the model being used for this proposal should be reason enough why the Orange City Council should not consider pursuing this policy. What right thinking city would ever say, " We should be more like Oakland." Outside of that glaringly obvious shortfall in this policy, there are other obvious issues that should be addressed:
The proposal is to tax properties that aren't "occupied" according to an arbitrary definition, nearly impossible oversight, and zero ability to enforce the policy.
The proposal fails to answer some very basic scenarios:
o What about people who move away for long-term assignments? o What about properties going through probate?
o What about people who are holding on to family properties? o What about properties whose future use is being considered? Additionally, the stated purpose of such a tax would be:
1) " Discourage long- term vacancies" — it's the property owner' s right to use the property as they see fit for their purposes — so long as the property does not become a nuisance. 2) " Promote productive use of land and buildings" - if property taxes are being paid, then it is a productive use of the land and buildings.
3) " Reduce neighborhood blight" - cities already have a mechanism to address this through code enforcement. An additional tax won' t make that any more viable. 4) " Encourage economic activity and housing availability" - again, this inserts the city in between the property owner and their free and legal use of their own property.
If the city' s goal is to keep up the look of the community — then empower code enforcement.
The city should also look to other cities beyond Oakland that have recently addressed similar proposals:
In 2023, the city of Adelanto put forth a similar proposal — the voters rejected it by a 2: 1 margin.
In 2024, the city of South Lake Tahoe put forth a similar proposal — the voters rejected it by a similar margin.
Currently, the city of San Diego is considering a similar proposal — and is pitting property owners against the public employee unions in a ballot initiative fight that will end up costing tens of millions of dollars.
While we understand the difficult and challenging financial position that the city of Orange presently finds itself, it seems imprudent to create a whole new bureaucracy and implement a tax on property usage under the guise of" reducing neighborhood blight" when there are already ample opportunities for the city to address these problems under existing systems. www. AAOC. com
Apartment Association of Orange County
Opposition to Proposed Vacant Property Tax & Registry
3/ 3
We strongly encourage the city council to reject this proposal and focus on revenue streams that do not necessitate the creation of a new bureaucratic process or burden its residents and businesses with funding it.
Thank you for your attention to this matter.
Sincerely,
dr---oer-
David J. ordero
Executive Director
www. AAO C. com
Orange City Council
Meeting Time: 05-12-26 18:00
eComments Report
Meetings Meeting
Time
Agenda
Items
Comments Support Oppose Neutral
Orange City Council 05-12-26
18:00
52 2 1 0 1
Orange City Council
05-12-26 18:00
Agenda Name Comments Support Oppose Neutral
2. PUBLIC COMMENTS
At this time, members of the public may address the Council on matters not listed on the agenda within the subject matter jurisdiction of the City Council, provided that NO action may be taken on off-agenda items unless authorized by law. Public Comments are limited to three (3) minutes per speaker unless a different time limit is announced. 1 1 0 0
8.3. Public Hearing to discuss and consider a draft City Charter 1 0 0 1
Agenda Item: eComments for 2. PUBLIC COMMENTS
At this time, members of the public may address the Council on matters not listed on the agenda within the subject matter jurisdiction of the City Council, provided that NO action may be taken on off-agenda items unless authorized by law. Public Comments are limited to three (3) minutes per speaker unless a different time limit is announced.
Overall Sentiment
Adrienne Gladson
Location:
Submitted At: 10:33pm 05-11-26
Costco is open to new ideas too. I read all about this project last summer. But its opening is scheduled for late June/July. I share this not to suggest Council or staff isn't aware of it. In fact, MV will be the home to the gas station while Lake Forest is getting the warehouse. Both cities get the benefits. Very smart. But its timely as you discuss the long-term economic needs to ensure our future tonight. Sharing the links to various media outlets that covered the story in March. As a Costco gas buyer (buying mainly in Fullerton and Tustin-El Camino locations, having a stand alone station in Orange is a goal we could achieve. It needs so much less land than a warehouse and a gas station (17 acres) does. I suggest all property sites that fit this size is worth considering for this purpose. Sharing these links below:
https://kfiam640.iheart.com/content/2026-03-19-costcos-first-standalone-gas-station-coming-to-mission-viejo/ According to Supermarket News, the station will be located at 25732 El Paseo in Mission Viejo, roughly 49 miles southeast of Los Angeles. City spokesman Robert Schick confirmed Costco plans to open the location to the public by the end of July 2026.
The facility will span more than 17,000 square feet and feature 40 (20 pumps) fueling positions, making it Costco's largest fuel facility to date. Like all Costco fuel locations, the station will be available to members only.
The gas station will occupy 3.28 acres.
Adrienne J. Gladson, AICP
What does Orange want to be?
Agenda Item: eComments for 8.3. Public Hearing to discuss and consider a draft City Charter Overall Sentiment
Adrienne Gladson
Location:
Submitted At: 10:39am 05-12-26
I am open to learning about this idea. But to rush it thru for this election cycle isn't wise. If we do it, it needs a broad, independent committee to do the non-political work on this. It's very complex and needs to be understood by everyone. The draft charter terms are a starting point for consideration but it needs in depth study. For example, I support a lifetime band. I do not support changing the size of the Council or existence of the city being in 6 districts. We cannot return to voters be deluded by the powerful and connected. In fact, I would make the band retroactive to include all the total years of service on the Council ever. It means none of you would be eligible run in Mayor or Council in 2028 or beyond. Recycling would end and new voices would join the Council.
It's best to not have Council decide this because of how it looks. If this is a good idea, which I am open to consider, it has to be done without any of you receiving it benefits. Plus, I recommend the better path is to work through appointed non-political commission/ad hoc committee toward placing this on the 2028 ballot so all voters to participate.