October 21, 2025 VIA EMAIL AND HAND DELIVERY Tamara Letourneau, City Manager City of Laguna Niguel 30111 Crown Valley Parkway Laguna Niguel, CA 92677 Subject: Vegetation Management Contract Awards Including Council Agenda Item #8 (October 21, 2025) Dear Ms. Letourneau, We are writing to you today to express our concern as local residents of Laguna Niguel and as environmental professionals serving the southern California region for over 30 years. We are asking for your review of staZ decisions regarding recent City contract awards for fuel modification and wildlands management, including an award under consideration tonight, as these do not appear to be in the best interest of the community or the best qualified low bid. A. 2023 Maintenance Services Agreement for Wetland and Habitat Areas was awarded to a standard landscape company, instead of the qualified habitat management company bidder, Natures Image as lowest qualified bidder. This has led to degradation of these important wetland resource. B. 2024 Citywide Weed Abatement contract was awarded to a standard landscape company with zero specialized fuel load abatement knowledge or specialized equipment to manage 44-acres of open space, and zero experience with goat grazing as an abatement management approach noted in the RFP . i. Although fire season is year-round, the selected vendor performed abatement only one time annually. In prior years, abatement was performed 2 – 3 times to protect life and property. ii. The vendor’s work was of poor quality within the last area – Phillips and Russel - completed in August – significantly missing the City and OCFA-mandated deadline of June. iii. The City had to suspend the vendor’s 2024 attempted goat grazing element because animals were running down the public streets and residents were calling animal control to rescue them.
City of Laguna Niguel Page 2 iv. We are unclear if the vendor was compensated the $43,000 “optional” grazing bid amount, as these services were not performed. v. The City’s website rightfully still features the City’s goat grazing initiative, (although current vendor is not able to perform this work). We support the City returning to this sustainable and cost-eZective method. https://cityoflagunaniguel.org/1486/Goat-Grazing-Initiative#:~:text=The%20City's%20Goat%20Grazing%20Initiative,of%20controlling%20fire%2Dprone%20vegetation. C. City Council October 21, 2025 Agenda Defensible Space and Vegetation Management Study staZ award recommendation to Dudek. We have several concerns regarding the award as outlined below. i. Dudek is currently assisting ENGIE and Compass Energy in their CEC data submittals for the BESS Facility in San Juan Capistrano, which is strongly opposed by the City of Laguna Niguel. Although we respect Dudek for their environmental compliance work in general, we and others have found significant errors in their CEC submittals. ii. We also find significant omissions in Dudek’s Defensible Space and Vegetation Management Study (VMP) proposal under award consideration tonight. We would like to bring to your attention: a. The Dudek proposal is silent on the following RFP topics which may expose the City to litigation if not addressed: b. existing geological issues c. soil erosion and slope stability/instability d. sensitive plant species No Dudek scope or resumes for geotechnical evaluation were submitted. No Dudek scope or resumes for sensitive species evaluation were submitted. Geological omissions may expose the City to potential litigation for any VMP-related land sluZing or sliding.
City of Laguna Niguel Page 3 Sensitive species omissions have been successfully litigated by environmental non-profits for VMP-related habitat degradation: CA CHAPARRAL INSTITUTE v BOARD OF FORESTRY https://climatecasechart.com/case/california-chaparral-institute-v-board-of-forestry-fire-protection/#:~:text=Reversing%20a%20California%20Superior%20Court,challengers%20in%20their%20original%20petition.&text=Notice%20of%20appeal%20lodged/received,Institute%20and%20Endangered%20Habitats%20League). CHAPARRAL WISDOM https://chaparralwisdom.org/2025/05/31/appellate-court-to-cal-fire-youre-making-the-landscape-more-flammable/#:~:text=Appellate%20Court%20to%20Cal%20Fire%20%E2%80%93%20You're%20Making%20the%20Landscape,steadfast%20support%20throughout%20it%20all. WATER EDUCATION https://www.watereducation.org/aquafornia-news/appellate-court-rules-against-cal-fire-plan-clear-chaparral#:~:text=%E2%80%A6,so%20was%20its%20target%20acreage. HILLS FOR EVERYONE https://www.hillsforeveryone.org/major-lawsuit-against-calfire-won/#:~:text=A%20California%20appellate%20court%20has,proper%20environmental%20reviews%20are%20completed. iii. The Dudek proposal does not recognize the City’s Strategic Plan Goals 1 and 3 as mentioned in the RFP nor include scope elements to forward those goals, such as: Goal 1 – Safety a. Leverage GIS tools to enhance public safety b. Update website, flyers, etc. to include Open Space information similar to and in conjunction with Trails information c. Conducted “What’s in your Pack” trail safety campaign at various City trailheads Goal 3 – Open Space and Environmental Preservation a. Continue to enhance wildfire awareness prevention City of Laguna Niguel Page 4 These omissions are a missed opportunity to forward the City’s Strategic Plan Goals. iv. The Dudek proposal is silent on possible CEQA processing exemptions, such as: a. Assembly Bill 623 which exempts qualifying fuel modification and fuel reduction projects b. Including specific project design features (PDFs) to avoid and minimize potential impacts upfront, such as biological monitoring during the nesting bird season, identification and avoidance of native vegetation and waterways etc. Both items represent a significant cost savings to the City for VMP approval and implementation phases. v. The Dudek proposal is silent on possible grant opportunities represent a significant cost savings to the City for VMP management and implementation phases such as: a. Grant funding (California Natural Resources Agency, State Coastal Conservancy, Wildlife Conservation Board, Coastal Conservancy, Natural Communities Coalition b. City mitigation banking opportunities (TCA, OCTA, USFWS & CDFW) Both of these items represent a significant cost savings to the City for VMP approval and implementation phases. vi. Let’s look at resumes: How qualified is Dudek? Let’s compare resumes: a. Dudek resumes v SAGE Team - FIREWISE2000 resumes DUDEK – The Project Lead for the VMP preparation has a total of nine years of experience, primarily not related to VMP preparation.
City of Laguna Niguel Page 5 FIREWISE2000 has been in business as Wildland/Urban Interface Fire Protection Consultants since 1997 (17 years of VMP preparation experience. FIREWISE2000 works on average 50-60 fire protection plans per year and has developed Fuel Modification and Fire Protection Plans for hundreds of residential and commercial projects including developments with Lennar Homes, KB HOMES, KHOV , Pulte Homes, Granite Homes, DR Horton, Centex Homes, Foremost Communities, Montage Resorts, individual custom homes, US National Park Service, and the US Navy. Clearly, FIREWISE provides greater depth and breadth of VMP preparation expertise. b. Dudek v. Laguna Canyon Foundation resumes DUDEK is silent on fuel modification area management capabilities. LAGUNA CANYON FOUNDATION has a proven track record in vegetation management programing with 10+ years of successful management of the Laguna Beach Fire Department’s fuel modification zones, while also protecting the many endemic plants present in those areas. In 2022, Coastal Commission Executive Director Jack Ainsworth called their approach “…the most sensibly designed fuel modification plan I’ve ever seen.” and said that “It should be used as a model across the state.” Clearly, LAGUNA CANYON FOUNDATION provides greater depth and breadth of VMP preparation expertise. Based on the information present herein, we would like to suggest the current award before Council today be withdrawn and that appropriate evaluation of all successfully-submitted proposals be conducted by qualified sta: with oversight from interested City Council and legal Counsel. We appreciate the City staZ’s dedication to quality, transparency, and integrity of service. We commend the City Council’s forward-looking efforts to address fire fuel load within City-owned, designated high fire open space.
City of Laguna Niguel Page 6 Thank you for your time and consideration. Respectfully, SAGE ENVIRONMENTAL GROUP Alissa Cope, Principal 24040 Camino del Avion, #A77 Monarch Beach, CA 92629 (949) 243-2282 cell [email protected] cc: council@cityoflagunaniguel.org Mayor Ray Gennawey Mayor Pro Tem Gene Johns Council Member Kelly Jennings Council Member Stephanie Oddo Council Member Stephanie Winstead Assistant to the City Manager, Kevin O’Connor Parks and Landscape Maintenance Superintendent, Scott Frame