3/29/23, 1:35 PM Manage Survey Statistics - Text Report https://www.portolavalley.net/Admin/Components/Form/Statistics/TextStatisticsDetail/?page=8&size=30&formId=67&itemID=93237&id=6960 2/3
11. Dear Council Members,
These recent storms have taught us just how devastating Mother Nature can be in our community. Flooding, landslides, roads buckling, power outages, falling trees - all threatening our safety. Please, let us use this learning as we move forward.
There has been a lot of good, hard work and many many hours dedicated to our State Mandated Housing Element. Thank you to Laura and staff, the Town Council, Planning Commission, the Ad Hoc Housing Element Committee and other volunteers. This is no easy task! And when one has given all that blood, sweat and tears, it is painful to think it still may fall short of a perfect plan.
What I would like the Town Council to agree on is that after we submit this round of the Housing Element, we also plan on submitting revisions that wil improve this plan, aligning it more with our community culture and ethos of our General Plan. Let’s plan on revising the Housing Element plan, and view it as an iterative process. And let’s rezone only when we absolutely must.
For example, as we receive more SB-9 applications, we could replace the Opt-In program with SB-9 units, and not deal with the uncertainty of what issues may arise with the Opt-In program. We don’t know what we don’t know. (Look at what happened with 4370 Alpine Rd. where folks visualized residential units atop commercial space, but the owner came back with a different plan.) If we end up on pace to surpass our ADU and JADU target, let’s decrease units elsewhere. I can’t imagine that units under 500 SF (JADUs or conversions of existing structures) would not be considered low-income housing. We must not overbuild.
You’ve probably heard about the new proposal from YIMBY and the Conservations……to stop urban sprawl due to the safety of WUI communities and wildfire risk - proposed legislation that makes sense. Let’s leverage bills such as this and push back a bit on the state.
Is it prudent to construct most of the new homes along our major evacuation route? With the affordable housing building laws, it appears that our Town could lose the 75’ setback that could be essential to our safety. We need wide roads for evacuation, but affordable housing developers get concessions we can't control...
Is it prudent to eliminate small businesses that provide work to lower-income employees, such as Glen Oaks? Is it prudent to not believe that a 20% increase in population would be insignificant to our infrastructure and public services? One example - We already have constant parking congestion at the Alpine Inn and Windy Hill, and at given times, at Ford Field, Alpine Hills and Town Center. These new developments will only make congestion more challenging.
What is prudent? Putting the safety of our residents first comes to the top of my list. Being willing to put in more work to improve the future of Portola Valley joins in as well. Let’s take the time to get things right, and continue to make improvements to our plan.
Thank you,
Karen Askey
Optional: You can upload a copy of your comments.
3/29/23, 1 :32 PM
Submitter DB ID
IP Address
Submission Recorded On
Time to Take the Survey
Pagel
1. First and Last Name
Bob Turcott
6959
03/29/2023 10:52 AM
7 minutes, 36 secs.
2. Email address ( will not be publicly displayed)
Manage Survey Statistics - Text Report
3. Organization ( Enter name of organization, business, or non profit if you are submitting conm1ents on their behalf.) Not answered
4. Street address ( will not be publicly displayed)
5. City
Portola Valley
6. State
CA
7. ZipCode
94028
8. Date of Meeting you ai·e submitting comment for.
03/29/2023
9. Agenda Item number or name
3a. Public Hearing
10. Conm1ent
Please distribute the attached letter to the Town Council and include in the public digest
11. Optional: You can upload a copy of your c01mnents.
TC Turcott ISMND 2022-03-28.pclf
https://www.portolavalley.neVAdmin/Components/Form/Statistics/TextStatisticsDetaiV?page=8&size=30&formld=67&itemlD=93237&id=6959 1/1 To: Town Council
Cc: Fire Marshal Bullard
From: Bob Turcott
Date: March 28, 2023
Re: The IS/MND ignores significant impacts on fire safety and cements in place fire hazard mitigations that are inadequate
Dear Council Member,
Among the changes to the General Plan that the IS/MND evaluates is elimination of the most rigorous of existing fire safety policies from 34-83% of Portola Valley’s area.
Despite this change, and numerous other hazardous changes, the IS/MND asserts that the proposed General Plan revisions would have no significant impacts that expose residents to the uncontrolled spread of wildfire, and, therefore, that no mitigation is required.
Would HCD, YIMBY Law, and developers welcome fire safety mitigations that are identified outside of the CEQA process and imposed to ensure safe development? Why would they? The Town Council would have just documented that there are “no significant impacts” requiring mitigation. These groups would cite the IS/MND as the basis for a legal challenge.
How can the elimination of existing fire safety policies from such broad swaths of our most hazardous areas not have a significant negative impact on the uncontrolled spread of wildfire? Staff and Town consultants avoided answering this question at the March 22, 2023 Town Council meeting.
More generally, the rationale given for the finding of “Less Than Significant Impact” does not stand up to scrutiny:
• It invokes “self-mitigation,” in which existing policies are cited as providing sufficient mitigation for the proposed changes. In this circular reasoning the policies that would be eliminated are cited as providing sufficient mitigation for the proposed changes — including the elimination of those very policies.
• It cites Portola Valley’s building standards as adequate mitigation while providing no basis for concluding that such mitigation is sufficient.
• It ignores the fact that we have not yet complied with Cal Fire regulations for Very High Fire Hazard Severity Zones (eg minimum setbacks, road widths, and water flow), the National Fire Protection Association’s Standard for Wildland Fire Protection, or other best practices defined by authoritative national bodies such as National Institute of Science and Technology.
• It cites the requirement for home hardening in low and moderate risk areas as sufficient mitigation for the elimination of fire safety policies from High and Highest Hazard areas.
Finally, the replacement of our current Fire Map as the basis for our fire safety policies with a map the Fire District calls unsafe and inaccurate was never considered as an agendized item before any public committee, including the Housing Element Committee. The rationale for this change remains unexplained despite 9 months of persistent resident requests for clarification.
I urge you to delay voting on the IS/MND until the proposed changes to our General Plan that affect fire safety are considered as an agendized item at a Town Council meeting in which:
• It is confirmed that our current Fire Map (2008 Moritz) will continue to serve as the basis for our fire safety policies and official reference for fire hazard in our town until a superior assessment becomes available. Or, an adequate justification is provided for replacing it with the 2008 Cal Fire map as currently proposed.
• The justification for and adequacy of “self-mitigation” is clearly provided. • It is clarified whether Portola Valley presently has in place the basic mitigation measures defined by Cal Fire regulations for Very High Fire Hazard Severity Zones, NFPA Standards, and NIST-defined best practices and, if not, when they will be adopted.
Our lives and the lives of future residents depend on it.
Thank you,
Bob Turcott
IS/MND found no significant impacts on fire safety
The IS/MND deems that there are no significant impacts that expose residents to the uncontrolled spread of wildfire. (Section T. Wildfire, page 280, Initial Study and Mitigated Negative Declaration, page 280)
place measures that provide the mitigation that’s needed. So they … because they’re already adopted policies and codes by the Town, you don’t need to include them as mitigation measures.”
Existing Fire Safety Policies are defined in terms of Moritz’s High and Highest Hazard areas3
3 Safety Element, page 22
Proposed changes to the Safety Element would base fire safety policies on the 2008 Cal Fire map. The most restrictive policies would be removed from 34-83% of Portola 4 Valley’s area and would be limited to just 6% of our area.
Town of Portola Valley Safety Element Update, Public Review Draft, Oct 2022, page 37 and following. 4 https://www.portolavalley.net/home/showdocument?id=16654&t=638010066844115237 The proposed Safety Element changes would base safety policies on the 2008 Cal Fire map, rather than the current basis for fire safety policies — the 2008 Moritz map5 Town of Portola Valley Safety Element Update, Public Review Draft, Oct 2022, page 33. https:// 5 www.portolavalley.net/home/showdocument?id=16654&t=638010066844115237 The Fire District views the 2008 Cal Fire map as inaccurate, unsafe, and not suitable for adoption6
https://drive.google.com/file/d/1RuFbba6e2WwnLz4T3ZgwkOR0MvU7kUfk/view?usp=share_link 6 Safety Element Comparison - Fire Safety Policies
2010 Policy
Number (pg
22)
Policy Applies to PV
Area
2023 Policy
Number
(pg 37)
Policy Applies to PV
Area
1 Do not construct buildings for human occupancy,
critical facilities and high value structures in areas
classified as having the highest fire risk unless it is demonstrated that mitigation measures will be taken
to reduce the fire risk to an acceptable level.
Moritz Highest
Hazard area
40% P-37 Promote new development outside of the Very High Fire Hazard Severity Zone. If development is proposed in the Very High Fire Hazard Severity Zone, require fire safe design and compliance with fire safe regulations contained in Title 14 of the California Code of Regulations. If vegetation management hazard mitigations are required as a condition of building permit approval, the developer shall sign a maintenance agreement or provide a funding source for future maintenance of the required mitigations.
Cal Fire
VHFHSZ
6%
P-39 Ensure new public/critical facilities (schools, hospitals, fire stations, etc.), are not located in High and Very High Fire Hazard Severity Zones, to the greatest extent feasible. If located in these areas, ensure full compliance with fire safe regulations and adequate fire response and evacuation
capabilities.
Cal Fire High
and VHFHSZ
6%
2 Prior to the approval of any subdivision of lands in
an area of high fire risk, the planning commission
should review the results of a study that includes at
least the following topics:
a) A description of the risk and the factors
contributing to the risk.
b) Actions that should be taken to reduce the risk to
an acceptable level.
c) The costs and means of providing fire protection
to the subdivision.
d) An indication of who pays for the costs involved,
and who receives the benefits.
Moritz High and
Highest Hazard
area
89% P-38 Prior to the approval of any subdivision of lands in a Very High Fire Hazard Severity Zone, the Planning Commission should review the results of a study that includes at least the following topics:
o A description of the risk and the factors contributing to the risk.
o Actions that should be taken to reduce the risk to an acceptable level.
o The costs and means of providing fire protection to the subdivision.
o The costs and means of providing ongoing vegetation
management for the subdivision.
o An indication of who pays for the costs involved, and who receives the benefits.
o If a proposed building site requires access to adjoining parcels to maintain 100 feet of defensible space from the primary structure, an easement or other legal agreement for access should be required as permitted by law.
Cal Fire
VHFHSZ
6%
3 Homeowners should provide adequate clearance
around structures to prevent spread of fire by direct
exposure and to assure adequate access in times of
emergency and for the suppression of fire.
All 100% P-43 Provide adequate clearance around structures to prevent spread of fire by direct exposure and to assure adequate access in times of emergency and for the suppression of fire.
All 100%
4 Adopt a town program to reduce fire hazards along
the town’s public roads.
All 100%
5 Establish a public information program regarding fire hazards and how property owners can reduce such
hazards. Utilize the Moritz report in this effort.
All 100%
1 6 In locations identified as presenting high fire hazard, require special protective measures to control
spread of fire and provide safety to occupants,
including but not limited to types of construction and
use of appropriate materials.
Moritz High and
Highest Hazard
area
89% P-40 Continue to require new development to incorporate design measures that enhance fire protection in High and Very High Fire Hazard Severity Zones. This shall include but is not limited to incorporation of fire-resistant structural design, use of fireresistant landscaping, and fuel modification around the perimeter of structures.
Cal Fire High
and VHFHSZ
6%
7 When reasonable and needed, make privately
owned sources of water, such as swimming pools, in
or adjacent to high fire risk areas, accessible to fire trucks for use for on-site fire protection.
Moritz High and
Highest Hazard
areas
89% P-49 Ensure access to privately owned sources of water, such as swimming pools, in or adjacent to high fire risk areas, for onsite fire protection use, if necessary.
Cal Fire High
and VHFHSZ
6%
8 Establish street naming and numbering systems to
avoid potential confusion for emergency response
vehicles.
All 100%
9 Design and maintain all private roads to permit
unrestricted access for all Woodside Fire Protection
District equipment.
All 100%
10 Apply Chapter 7A of the California Building Code to
the entire town to increase the resistance of
buildings to fire ignition, and when reviewing
developments under Chapter 7A, attempt to choose
those materials and colors that are consistent with
the visual aspects of the town.
All 100% P-40 Continue to require new development to incorporate design measures that enhance fire protection in High and Very High Fire Hazard Severity Zones. This shall include but is not limited to incorporation of fire-resistant structural design, use of fireresistant landscaping, and fuel modification around the perimeter of structures.
Cal Fire High
and VHFHSZ
6%
P-60 Require compliance with Chapter 7A requirements of the California Building Code and the Town’s Home Hardening
Code for all new development and substantial additions.
All 100%
P-62 Require non-combustible roofs and exterior siding in all fire hazard areas.
All 100%
P-66 Expand home hardening throughout the Town to reduce fire hazard vulnerability
All 100%
11 When undertaking actions to reduce fire risk by
removing or thinning vegetation, homeowners
should try to remove the most hazardous material
while leaving some native vegetaton to reduce risks
of erosion, habitat loss and introduction of
potentially dangerous invasive weeds.
All 100% P-44 Vegetation management conducted by homeowners should remove the most hazardous plant materials while leaving adequate vegetation to reduce risks of erosion, habitat loss, and reduce the potential for invasive species introduction.
All 100%
P-41 Require fire protection plans for new development and major remodels in areas designated as High and Very High Fire Severity Hazard Zones by the California Department of
Forestry and Fire Protection or equivalent hazard designation in Local Responsibility Areas.
Cal Fire High
and VHFHSZ
6%
P-42 Require vegetation management plans in all new
developments and major remodels.
All 100%
2010 Policy
Number (pg
22)
Policy Applies to PV
Area
2023 Policy
Number
(pg 37)
Policy Applies to PV
Area
2 P-45 Ensure open space brush areas, susceptible to wildfire risk, are adequately maintained in accordance with WFPD and
applicable state requirements.
All 100%
P-46 Encourage the use of fire-resistant vegetation for landscaping, especially in high fire hazard areas.
All 100%
P-47 Require vegetation clearance and maintenance for all private roads and properties in the high and very high fire hazard severity zones.
Cal Fire High
and VHFHSZ
6%
P-48 Maintain and adequately fund fuel breaks and other fire defense improvements on public property and require similar measures for private property in compliance with fire safe regulations where possible.
Public - All
Private - Cal
Fire VHFHSZ
100%
6%
P-50 Ensure that landscaping, lighting, building siting and design, water pressure and peak load water storage capacity, and building construction materials meet current fire safe
regulations.[1]
Cal Fire
VHFHSZ
6%
P-51 Prioritize development in areas with sufficient water supply infrastructure and roadway capacity to ensure adequate
evacuation and emergency equipment access.
All 100%
P-52 Maintain and enhance water supply infrastructure to ensure adequate supplies for existing and future daily demands and firefighting suppression requirements.
All 100%
P-53 Educate residents and property owners on proper water shut off procedures during a hazard incident or evacuation order.
All 100%
P-54 Collaborate with WFPD to promote public awareness of fire hazards and safety measures, including outreach to at-risk populations, and identification of low-risk areas for temporary shelter and refuge during wildfire events
All 100%
P-55 Ensure adequate fire suppression resources in the local responsibility areas, and coordinate with WFPD and Cal Fire to meet current and future fire suppression needs.
All 100%
P-56 Identify fire defense zones where firefighters can control wildfires without undue risks to their lives, and areas where firefighter safety prohibits ground attack firefighting.
All 100%
P-57 Pursue funding for fire prevention and suppression (State grant funds, hazard mitigation funds, etc.).
All 100%
P-58 Become a Fire Risk Reduction Community through the State Board of Forestry and Fire Protection.
All 100%
P-59 Building upon CAL FIRE’s Fire Hazard Severity Zone maps, use local knowledge of wildfire hazard, landscape, housing, and infrastructure to develop a wildfire overlay or other similar regulatory tool for corresponding policies.
All 100%
2010 Policy
Number (pg
22)
Policy Applies to PV
Area
2023 Policy
Number
(pg 37)
Policy Applies to PV
Area
3 P-61 Require new developments and major remodels or renovations to comply with the California Building Code, Fire Code, and local ordinances for construction and adequacy of water flow and pressure, ingress/egress, and other measures for fire protection. Require endowments or HOA-type assessments to fund long-term maintenance of wildfire mitigations.
All 100%
P-63 Work with WFPD to enforce regulations related to fire resistant construction, sprinkler systems, and early warning fire detection system installation and/or sirens.
All 100%
P-64 All developments shall comply with the WFPD Fire Code and incorporate recommendations from the Santa Cruz County - San Mateo County Community Wildfire Protection Plan, where applicable.
All 100%
P-65 New developments in fire-prone hillside areas, shall comply with statewide Fire Safe Regulations (see CCR, Title 14, Sections 1270 et seq.).
All 100%
P-67 Incorporate updated WFPD fire hazard and risk assessment findings into the Safety Element.
All 100%
P-68 Monitor new State laws that increase minimum building standards and expand the requirements to more areas within the Town, including high and moderate areas.
All 100%
P-69 Upon the completion of the Structure Separation Experiments being carried out by National Institute of Standards and Technology (NIST), the Insurance Institute for Business and Home Safety, and Cal Fire on structure-to-structure ignition, consider science-backed approaches to addressing narrow setbacks. The Town may wait for State or WFPD guidance, implement findings into local building codes or provide voluntary guidance to residents.
All 100%
P-70 Develop, monitor, and regularly update a program to educate and inform the public on local and state fire code, and fire safe regulations. Ensure that this program provides the latest information as provided by the Town, County, and the State.
Use community-appropriate languages to ensure greater
understanding by residents and visitors.
All 100%
P-71 Support increased enforcement mechanisms and processes by WFPD to incentivize fire risk reduction activities and abatement.
All 100%
[1] Per P-37, Cal Fire’s Fire Safe Regulations apply only to the 6% of Portola Valley’s area that Cal Fire identified as VHFHSZ. Does P-50 apply throughout PV, or is it restricted to the area in which Fire Safe Regulations apply?
2010 Policy
Number (pg
22)
Policy Applies to PV
Area
2023 Policy
Number
(pg 37)
Policy Applies to PV
Area
4