Attachment 1b - Development Review Committee Report - February 22, 2023 — Riverside City Council, November 28, 2023

ATTACHMENT 1

PUBLIC COMMENT LETTERS
From: Richard Block
To: Eguez, Judy
Cc: Norton, Brian; Leonard Nunney; Gurumantra; Kevin Dawson; [email protected]; Tinio, Maribeth; Taylor, Matthew Subject: RE: [External] FW: Mt Vernon Ave RC zone site proposalPR-2021-001108(DR, GE), APN 257-160-003 Date: Friday, February 10, 2023 4:45:51 PM
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Hello.

Thank you for providing the applicant response to the concerns expressed in our previous letter (both copied below), although we note that the applicant response is faulty and seriously deficient.

Friends of Riverside’s Hills and the University Neighborhood Association vehemently oppose approval of this project in its present (latest) form. Any approval of the project in that form, with the house and ADU practically on top of the immediately adjacent Box Springs Mountain Reserve (BSM Reserve), a core Western Riverside County Multiple Species Habitat Conservation Plan (MSHCP) Reserve and the premier wildlife sanctuary in or near Riverside, would be defective planning, and (absent appropriate environmental review) a violation of CEQA, as well as violating pertinent City codes and the City’s legal obligations regarding MSHCP, all as noted in detail below.

Before getting into the CEQA, fire danger and other issues, we note that in our previous letter, as shown below, we quoted sections of the Grading Code and pointed out that the project violated such sections. We now mention one further section of the Grading Code, Section 17.28.020:
“12. No grading shall be permitted on slopes exceeding 40 percent unless findings can be made by the Planning Commission that exceptional or special circumstances as set forth in Chapter 17.32 Conditional Exceptions apply.”
Note that it doesn’t say the slope of the entire site or of the entire graded area – it just says grading on slopes – that is, presumably on any substantial slope.

In her Thursday, September 15, 2022 3:42 PM email to me (copied below), then-Project planner Candice Assadzadeh said “The average existing slope of the entire parcel is 39.63% and the average existing slope of the area to be graded is 30%.”
The 30.63% figure is suspiciously close to 40% -- would the Average NATURAL slope (rather than average EXISTING slope) be over 40%, thus invoking another restriction? Of course the area to be graded includes the flatter house-ADU pad area, thus lowering the average slope of the area to be graded. As far as we are aware, no figure has been given for the existing slope of the area to be graded for the driveway. The present version of the grading plan differs from the previous one only with very minor changes along the driveway.

From the diagrams in the grading plan versions, one can see that for substantial portions, of substantial length, of the area proposed to be graded for the driveway, the slope appears to be about one to one, that is, a 100% slope, which far exceeds the 40% figure. Thus per the Grading Code, findings must be made by the PLANNING COMMISSION, that Is, the project is beyond the jurisdiction of the DRC , and until such
involvement of the Planning Commission, it is illegal and improper for the DRC to consider the project. It needs to be turned over now to the Planning Commission with them to make the decision regarding a Conditional Exception and the project as a whole.

NOT EXEMPT FROM CEQA

As stated in our previous letter, while CEQA may provide an exemption for construction of a single-family house and ADU under its Class 3 Exemptions, that exemption (as quoted from the law by us and by the applicant in his response copied below) is subject to the following provision of CEQA law:
“these classes are considered to apply in all instances, except where the project may impact on an environmental resource of hazardous or critical concern where designated, precisely mapped, and officially adopted pursuant to law by federal, state, or local agencies.”

It is important to note that for the exception to apply, the project site doesn’t have to be within the designated, mapped, adopted area – for a house and ADU it wouldn’t be when, as in the present case, such a designated area is publicly owned -- but merely that the project MAY impact on an environmental resource of critical concern (in this case, protection of native wildlife) for such a designated area.

The BSM Reserve, being a core MSHCP Reserve, with its wildlife protection, is indeed an environmental resource of critical concern, designated, precisely mapped, and officially adopted pursuant to law by Riverside County (and cities). As we had previously noted, the project site borders the BSMR borders all along the 427 feet of the site’s long eastern boundary, as shown on the RCA MSHCP information map (incorporated by reference) https://wrcrca.maps.arcgis.com/apps/webappviewer/index.html? id=2b9d4520bd5f4d35add35fb58808c1b7
(or on Google maps) with the BSM Reserve then continuing from there north, east and south.

Regarding the BSM’s native wildlife, there was a lengthy analysis of it by wildlife expert Dr. Smallwood – please see the City Council Dec. 6, 2022 agenda Item 11 Case PR-2021-000932, Attachment labeled 9/21/22 DRC Report (incorporated by reference) pp. 47-86 of that Report (full disclosure: we are now in litigation about that project, relying to an extent on Dr. Smallwood’s report). Dr. Smallwood’s report concerns BSM Reserve wildlife at what he states as very close (up to 1.5 miles) from the project he is commenting on. In his Table 2, Dr. Smallwood gives a list of scores of species of concern, some endangered, that are observed very close, and thus also very close (or at least nearby) to the present project site, evidence that the present project may impact the BSM Reserve’s wildlife.

The applicant response claims
“As per the biologist working on the project, "The Multiple Species Habitat Conservation Plan (MSHCP) for Riverside County does not consider the site of concern to wildlife." There will not be a long term effect on the area either. Instead of a negative long term effect the biologist stated," Once construction and landscaping is complete there could be a positive impact on the wild life in the area".

Those claims are false, even far-fetched. Regarding their MSHCP claim, it is true that, although it has a long border with the MSHCP-protected BSM Reserve, the project site itself is not in an MSHCP criteria cell.

However, contained in the MSHCP document
https://www.rctlma.org/Portals/0/mshcp/volume1/sec6.html (incorporated by reference) is its

Section 6.1.4 Guidelines Pertaining to the Urban/Wildlands Interface “The guidelines presented in this section are intended to address indirect effects associated with locating Development in proximity to the MSHCP Conservation Area, …

Lighting
Night lighting shall be directed away from the MSHCP Conservation Area to protect species within the MSHCP Conservation Area from direct night lighting. Shielding shall be incorporated in project designs to ensure ambient lighting in the MSHCP Conservation Area is not increased.

Noise
Proposed noise generating land uses affecting the MSHCP Conservation Area shall incorporate setbacks, berms or walls to minimize the effects of noise on MSHCP Conservation Area resources pursuant to applicable rules, regulations and guidelines related to land use noise standards. For planning purposes, wildlife within the MSHCP Conservation Area should not be subject to noise that would exceed residential noise standards.

... Barriers
Proposed land uses adjacent to the MSHCP Conservation Area shall incorporate barriers, where appropriate in individual project designs to minimize … domestic animal predation … in the MSHCP Conservation Area. …”

Regarding night lighting, with the house and ADU on top of a hill overlooking the BSM Reserve and only 60 and 54 feet away, there would be no practical way to ensure that light trespass from the house and ADU did not increase ambient lighting in the adjacent part of BSM Reserve, whereas if the house and ADU were located farther down near the west edge of the site then that very hill would effectively shield the BSM Reserve from such light trespass.

Regarding noise, construction noise is an issue. With construction for the house and ADU at the top of the hill, there would again be no practical way for wildlife so close in the adjacent part of the BSM Reserve not to be subject to construction noise exceeding residential noise standards, whereas again if the house and ADU were located farther down near the west edge of the site then that very hill would effectively shield the wildlife in the BSM Reserve from excessive noise.

Regarding barriers, residents’ pet dogs and especially cats can be devastating to nearby native wildlife. It is unrealistic to think that the City would enforce any kind of barrier regarding pets. Thus having the house and ADU at the hill overlooking BSM Reserve from very close would be much more of a threat to the native wildlife of the BSM Reserve that that from buildings near the project site’s western edge, thus much farther away from the reserve.

Thus, contradicting the applicant’s claim, the MSHCP does indeed in those ways consider the site of concern to wildlife, and the City is legally bound by the standards quoted above. These issues stemming from the proposed location of the buildings a mere stone’s throw from the BSM Reserve – light trespass, construction noise, potential cat predation – not only concern violation of MSHCP’s Guidelines Pertaining to the Urban/Wildlands Interface, but also show that the project MAY impact on an environmental resource – the BSM Reserve of critical concern, and thus that it is NOT exempt from CEQA, per the quote of CEQA law above.

DUMP TRUCKS

Another issue affecting the BSM Reserve is that the dump trucks involved in the export of dirt from the site will traverse over several hundred feet of east-west dirt road easement, part of the BSM Reserve, easterly of and joining Mt Vernon Ave (see Google maps). With the dirt export (per the project Grading Plans -- the applicant’s response fails to address the issue) estimated as over 6,500 cu yds, that would be about 500 dump truck loads (about 11 cu yds per 15-ton dump truck load), an extreme amount for a single lot, so 500 empty dump trucks in and 500 loaded dump trucks out, and yet another negative impact on a portion of the BSM Reserve, and a huge imposition on the residential neighborhood.

FIRE DANGER
The applicant claims
“Per the fire consulate [sic] and the fire the City Fire department the pad cannot be located in the bottom of the property because the structure would be within the 100ft defensible space. Having the property at the bottom corner of the hill would expose two sides of the buildings to less than 100 ft from the property line. Having two sides exposed to within 100 ft is not allowed per the city fire department.”
Again the applicant’s claims are false, even absurd as applied to the proposed location of the buildings a stone’s throw from the BSM Reserve, so with far less than 100 ft defensible space. It would be interesting to see in writing any such claims by the City Fire Department, and in particular any such dubious requirement of 100 ft defensible space pertaining to an existing individual residential lot, and any totally ignoring of the real fire danger of placing the buildings far less than 100 ft from the very flammable BSM Reserve. Regarding fire protection to the buildings from nearby fires and to nearby land from fires originating near the buildings, and a desirable 100 ft of defensible space, it is the location at the top of the hill that would be far more dangerous than a location below and much farther away from the BSM Reserve. The adjacent BSM Reserve land, outside the City and containing flammable brush that (in recognition of its status as a wildlife reserve) is not and must not be cleared, is the location of the real danger of nearby of fires – as has happened rather frequently in large parts of the BSM Reserve. Thus placing the house and ADU much closer than 100 ft from the BSM Reserve, and not being allowed to clear brush or plant there, poses two fire dangers: to the buildings from fire spreading from the BSM Reserve, and to the BSM Reserve from fire starting near the buildings or from their residents going into the BSM Reserve. Both of these dangers would be sharply reduced by locating the buildings down below near the west edge of the project site and thus much farther from the BSM Reserve.

GRADING EXCEPTION
We see that approval of this project involves granting of a Grading Exception, which requires certain findings. Please provide us with the written proposed justifications for those required findings. We note that one of the required findings is
“C. That the granting of a waiver will not be materially detrimental to the public welfare or injurious to the property or improvements in the zone or neighborhood in which the property is located.” But of course the Grading Exception is to allow the proposed driveway up the steep hill so that the house and ADU can be located there. As shown above and in our previous letter that would be injurious to the BSM Reserve property, and as the immediate neighbors will testify, it is injurious to their neighborhood.

Therefore the finding, and with it the Grading Exception, cannot be legally made.

ABOUT SITE NEAR BOTTOME OF HILL
In his responses, the applicant states
“The only feasible location for the pad, taking in consideration the defensible space, the location of the leech [sic] lines and following the grading ordinance is the top of the hill.”

We’ve shown above that the defensible (from fire) space issue goes the totally opposite way: the site near the bottom of the hill is the one that is defensible and has much less need for defense because it would be in much less fire danger.

Regarding a septic system, if leach line layout might be a problem, one could use one or more seepage pits.

The applicant has provided no report showing any problem with a septic system for building at the bottom of hill – he presumably hasn’t bothered to have soil tests done for seepage pits there.

And as for following the grading ordinance, it is the location at the top of the hill that is so problematic – serious violations of hillside/arroyo provision of the grading code as we had previously pointed out, and a need for a Grading Exception, while there has been no indication for any grading code problem at the lower elevation.

Please confirm receipt of this email, which is being sent prior to the close of the requested comment period.

We hope that the above considerations, as well as those in our previous letter, will be fully taken into account by the Planning Division.

Thanks
Richard
Richard Block for Friends of Riverside’s Hills and the University Neighborhood Association

Sent from Mail for Windows

From: Eguez, Judy
Sent: Monday, February 6, 2023 11:55 AM
To: Richard Block
Cc: Norton, Brian
Subject: RE: [External] FW: Mt Vernon Ave RC zone site proposalPR-2021-001108(DR, GE), APN 257-160-003

Good morning Mr. Block,

Below is the applicants responses to your letter. I’ve also provided a link to supporting documents that he provided.

With the exception of the grading exception to allow a 20-foot-wide driveway width where the grading code requires a 15-foot-wide driveway, staff had determined that the proposed single family residence and ADU meet the development standards. Further analysis will be provided in the staff report.

Thank you,Judy

Supporting Documents

Grading: Per the fire consulate and the fire the City Fire department the pad cannot be located in the bottom of the property because the structure would be within the 100ft defensible space. Having the property at the bottom corner of the hill would expose two sides of the buildings to less than 100 ft from the property line. Having two sides exposed to within 100 ft is not allowed per the city fire department. Also, per the soil engineer we cannot relocate the leech lines to another area of the property. We could not drill test holes on other sections of the property because of the topography of the site.

The pad cannot be built on the flat at the bottom corner of the property and moving the building pad halfway up the hill is not permitted either. Grading is not permitted on slopes exceeding 40%.

The only feasible location for the pad, taking in consideration the defensible space, the location of the leech lines and following the grading ordinance is the top of the hill.

The driveway curves around the hill side in order to keep the natural slope change to minimum. In addition, the driveway will be graded with gravel to blend with the landscape.

Regarding the view:

Blocking the view of a house does meet the threshold of significance. Citing Porterville Citizens for Responsible Hillside Development v. City of Porterville (2007) 157 Cal.App.4th 885. (2005) Also: Mira Mar Mobile Community v. City of Oceanside (2004)

Zoning:

As supported by the city staff, the civil engineer and the architect working on this project, the project is following all zoning guidelines. Examples below:
· The grading has been limited to just 37% of the total property · The driveway is limited to a 15% slope.
· The driveway curves around the hill side in order to keep the natural slope change to minimum. · The driveway will be graded with gravel to blend with the landscape General Plan Public Safety Element Violations: Fire Hazard

The project is following the state and city fire code by placing the pad on the top of the hill. In addition, a Fire Protection Plan (FPP) and Alternate Means and Method (AMMR) were created. The FPP and the AMMR were created to mitigate one side of the defensible space less than 100 ft.

The Environmental Impact Review (EIR) created for the city as part of the 2025 general plan states that construction in high fire severity hazards does not create a significant impact on the fire hazard. The report also clearly states that mitigation can be used to reduce any impact to less than significant. Please reference the EIR Section 5.7-36, Section 5.7-37 and section 5.7 -38.

CEQA:

The section used for reference by friends of the hills was misquoted.

Section 15300.2 (a) reads as follows:

As per the biologist working on the project, "The Multiple Species Habitat Conservation Plan (MSHCP) for Riverside County does not consider the site of concern to wildlife." There will not be a long term effect on the area either.

Instead of a negative long term effect the biologist stated," Once construction and landscaping is complete there could be a positive impact on the wild life in the area"

As per the soil engineer there will be no need for blasting. As stated in the soil report, the type of rocks in the area can be removed using other methods than blasting.

Lastly, using the current condition of the property as a baseline. (Taking into consideration the noise and dust from the neighbors and visitors hiking in the area ) will not significantly impact the area. The project meets the criteria for an Exception.

In conclusion, placing the house on top of the hill does not have an effect on the environment or wildlife. Placing the house anywhere else on the pad would cause unnecessary burden on myself (the owner) and violate several city ordinance and policies.

From: Richard Block <[email protected]>
Sent: Friday, February 3, 2023 3:34 PM
To: Eguez, Judy <[email protected]>
Subject: RE: [External] FW: Mt Vernon Ave RC zone site proposalPR-2021-001108 (DR, GE), APN 257-160-003

Hello, Judy.

I looked at the plans referenced in the link you sent, and don’t see any changes form the plans that we commented on in October. Have there been any changes, and if so what are they?

You say that the applicant has responded to the concerns we sent in October. Please email us a copy of any and all such applicant response(s) as well as any and all document(s) pertaining to how the staff has been, is, or will be, addressing those concerns.

Thanks,
Richard
Richard Block for Friends of Riverside’s Hills and the University Neighborhood Association

Sent from Mail
for Windows

From: Eguez, Judy
Sent: Friday, February 3, 2023 12:41 PM
To: Richard Block
Cc: Leonard Nunney; Gurumantra; Kevin Dawson; Arlee Montalvo; [email protected]; [email protected]; Norton, Brian
Subject: RE: [External] FW: Mt Vernon Ave RC zone site proposalPR-2021-001108 (DR, GE), APN 257-160-003

Good afternoon Mr. Block,

My sincerest apologies. I think this is the second time I do this to you and I was literally thinking about it yesterday afternoon. I do have your letter of concerns from October, which the applicant has responded to and I will be addressing your concerns in the staff report. I will make sure to provide you with the staff report before the DRC meeting (I promise!).

The plans being considered by the DRC can be found in the link below:

~Plans.pdf

Thank you,
Judy Egüez, Senior Planner
City of Riverside
Community & Economic Development, Planning Division
Main: 951.826.5371
Direct: 951.826.3969

From: Richard Block <[email protected]
>
Sent: Friday, February 3, 2023 11:56 AM
To: Eguez, Judy <[email protected]>
Cc: Assadzadeh, Candice <[email protected]>; Leonard Nunney <[email protected]>; Gurumantra <[email protected]>; Kevin Dawson <[email protected]>; Arlee Montalvo <[email protected]>; [email protected]; [email protected]
Subject: [External] FW: Mt Vernon Ave RC zone site proposal PR-2021-001108 (DR, GE), APN 257-160-003

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February 3, 2023
Hello, Judy

These comments are being submitted on behalf of Friends of Riverside’s Hills and the University Neighborhood Association. A letter, copied herein, was submitted to the then-project-planner Candice Assadzadeh, on behalf of both organizations on Oct. 27, 2022, so only several months ago, pointing out serious problems, including greatly excessive grading and impact on the Box Springs Mountain Reserve and the University neighborhood, with violations of the City’s grading code, zoning code, and general plan, and CEQA, pointed out. Unless the project has been very significantly changed, those concerns remain.

WE PROTEST THAT WE WERE NOT NOTIFIED OF THE NEW CONSIDERATION AND COMMENT PERIOD (extending to Feb. 10) FOR THE PROJECT, EVEN THOUGH WE HAD SPECIFICALLY ASKED IN THAT LETTER “ Please keep us
informed regarding any proposal for this site.”

Please inform us of any change from the proposal as it existed at the time of our October letter, and of any further consideration regarding it since that time, and in particular of any consideration of the issues raised in our October letter.

Please confirm receipt of this letter, and again we ask to please keep us informed regarding any proposal for this site.

Richard Block for Friends of Riverside’s Hills and the University Neighborhood Association Sent from Mail for Windows
From:

Richard Block
Sent: Thursday, October 27, 2022 4:55 PM
To: Assadzadeh, Candice
Cc: Kopaskie-Brown, Mary; Leonard Nunney; Gurumantra; Kevin Dawson; Arlee Montalvo Subject: Mt Vernon Ave RC zone site proposal
Hello, Candice.

Thank you for emailing (the latest on Sept. 15) material on this proposed project. We hope you are well now.

Does the project have a case number?
Friends of Riverside’s Hills strongly objects to the proposed plan for the house and driveway, and specifically the building location on the lot and extent of grading, at the parcel with APN 257-160-003 (formerly mislabeled 2292 Mt Vernon Ave although that is an existing long-developed neighboring property) in the RC zone and bordering the Box Springs Mountain Reserve. The site is colored green in the above exhibit.

Although western parts of the site (as shown on the proposed grading plan), including the start of the proposed driveway, are at an elevation of around 1,470 ft, the proposed building pad is at 1,540 ft, a 70 ft higher elevation only about 200 feet away, thus involving the proposed very long driveway to achieve the huge rise, and accompanying excessive grading including an estimated [per the developer’s grading plan— attachment MV grading] export of over 6,500 cu yds, or about 500 dump truck loads (about 11 cu yds per 15-ton dump truck load), an extreme amount for a single lot, over a nearly half-mile of dirt road easement, part of it on an easement over the Box Springs Mountain Reserve, between the site and Mt Vernon Ave.

Actually, per the developer’s grading plan in the Attachment labelled MV grading previous, the export would be even more: over 7,500 cu yds.

Grading Code Violations
The proposed project violates a number of provisions of the City’s Grading Code and Zoning Code that apply to RC-zoned lots that are focused on minimizing grading on hillsides. The circumstances showing these violations are that the proposed building pad, instead of being placed so high up a hill, could have been placed at a much lower elevation near the western side of the site with as a result a much shorter and less steep driveway [attachment MV grading – see also the other attachments, including aerial photos with comments] and consequently much less grading.

Thus the proposed grading is in serious violation of provisions of the City’s Grading Code, in particular the following ones of Grading Code section 17.28.020 - Hillside/arroyo grading:

A. Grading requirements. Where grading is proposed on any parcel having an average natural slope of ten percent or greater, or which is zoned Residential Conservation (RC), … grading must be confined per this chapter and limited to the minimum grading necessary to provide for an approved dwelling unit or units, driveway, garage and limited level yard. The ungraded terrain must be left in its natural form for the remainder of the site. All hillside/arroyo grading shall conform to the following general requirements:

1. The overall shape, height or grade of any cut or fill slopes shall be developed utilizing contour grading in concert with existing natural contours and the scale of the natural terrain of the site. …

6. The area of a site proposed to be graded shall be that which fits into the natural terrain and which allows for a minimal amount of grading. …

7. Structures shall be designed to fit with the contours of the hillside and relate to the overall form of the terrain. Structures shall be designed to fit into the hillside rather than altering the hillside to fit the structure.

As shown in the attached grading plan MV grading and in the other attachments, the proposed grading places the house pad at the top of a hillside with a very steep and wide winding driveway leading up to it, thus requiring a very large amount of grading and excessive export of dirt, instead of placing the house pad in the lower flatter part of the site, with a more appropriately located and shorter driveway.

Thus the proposed grading is far in excess of the minimum necessary, is not in concert with nor does it fit in with the existing natural terrain, and it alters the hillside, in particular removing rock outcroppings and excessively grading in order to have the driveway reach the top of the hillside. This is shown in the attached aerial photos and the comments marked on them.

Regarding any possible exception to the above quoted Grading Code requirements, the Findings required to justify any such exception include all the following:

A. That the strict application of the provisions of this title would result in practical difficulties or unnecessary hardships inconsistent with the general purpose and intent of this title; C. That the granting of a waiver will not be materially detrimental to the public welfare or injurious to the property or improvements in the zone or neighborhood in which the property is located.

As with variances, California Appellate and Supreme Court decisions constrain the justifications that can be used for such findings. Here, it is the developer who is choosing to place the building pad so far up the hill, thus necessitating the extremely large amount of grading for the driveway, a self-induced difficulty-hardship, and self-induced difficulties or hardships cannot be used in a legally adequate justification. And the developer’s chosen position for the building will degrade the view from the houses to the west and cause light trespass and noise on the bordering Box Springs Mountain Reserve thus degrading the habitat there, which is injurious to that property.

All of the above also applies to the developer’s requested variance for the driveway width.

Zoning Code Violations

In addition to violation of the above provisions of the Grading Code, the proposed grading violates the following provisions of the Zoning Code:

19.100.050 - Additional regulations for the RC Zone.

D. Grading.

1. No grading permit shall be issued for any grading in the RC Zone until grading plans and, if required, special drawings showing grading and topography as viewed from critical locations within the neighborhood or community, have been submitted to and approved by the designated Approving or Appeal Authority as set forth in Table 19.650.020 (Approving and Appeal Authority).

2. The Approving and/or Appeal Authority shall consider the following items of particular concern in the review of grading proposals in the RC Zone. Conditions may be applied in the approval of grading plans so as to achieve these objectives pursuant to adopted standards included in the City's Grading Ordinance (Title 17).
a. The maximum retention of vistas, natural plant communities and natural topographic features including ridgelines, hilltops, slopes, rock outcroppings, arroyos, ravines and canyons; b. The avoidance of excessive building padding or terracing and cut and fill slopes to reduce the scarring effects of grading;
c. The encouragement of sensitive grading to ensure optimum treatment of natural hillside and arroyo features; and
d. The encouragement of imaginative grading plans to soften the impact of grading on hillsides including rolled, sloping or split pads; rounded cut and fill slopes and post and beam construction techniques.

But instead of sensitive and imaginative grading to ensure optimum treatment and softening impact on natural hillsides, the proposal, with its extreme grading for the driveway, does the opposite. See in particular the Attachment MV slope diagram w comments.

General Plan Public Safety Element Violations: Fire Hazard

Per the City’s General Plan Public Safety Element, at p. 30, the project site is well within a Very High Fire Hazard Zone. Therefore in the planning process for the project, the following pertinent Public Safety Objective and Policies need to be taken account of:

Objective PS-6: Protect property in urbanized and nonurbanized areas from fire hazards.

Policy PS-6-3: Integrate fire safety considerations in the planning process.

Policy PS-6.4: Evaluate all new development to be located in or adjacent to wildland areas to assess its vulnerability to fire and its potential as a source of fire.

Policy PS-6.5: Mitigate existing fire hazards related to urban development or patterns of urban development …
Policy PS-6.6: Continue to implement stringent brush-clearance requirements in areas subject to wildland fire hazards
Policy PS-6.7: Continue to involve the City Fire Department in the development review process.

For this project, not only is the site well within a Very High Fire Hazard Zone, but it borders on its long 427 foot eastern side the Box Springs Mountain Reserve, a wildland area which is maintained as natural habitat not subject to brush clearance near any new buildings. That means that the required 100 feet brush clearance/plant-restriction zone around any newly planned building cannot intrude into the Reserve, and thus any planned house or ADU on the project site must be located at least 100 feet from the site’s eastern boundary. Placement of the house and ADU at a lower elevation in the western part of the site would accomplish that, but as shown on the Grading Plan, the location of the Proposed Main House (resp. Proposed ADU) is on top of a hill and only 61 feet (resp. 54 feet) from the Reserve, distances too short to accomplish the needed fire protection – protection of the Reserve and protection of the buildings, both in accord with the above quoted General Plan Objective and Policies.

Thus the project is violation of the General Plan Safety Element. In particular the City Fire Department needs to be involved in the review process, and we need to be informed of any consideration in regard to fire potential related to the proposal.

CEQA Violations

In addition to violations of City Codes and General Plan, there is the question of potential CEQA violations. In one of the project’s engineering plans [MV grading previous], it states “Planning Division – Environmental Review Not Required”. That is wrong.

While CEQA may provide an exemption for construction of a single-family house and ADU under its Class 3 Exemptions,

that exemption is “qualified by consideration of where the project is to be located. A project that would ordinarily be insignificant in its impact on the environment may, in a particularly sensitive or hazardous area, be significant. Therefore, these classes will not apply where the project may impact an area of special significance that has been designated, precisely mapped, and officially adopted pursuant to law by federal, state, or local agencies.”

In the present case, that area of special significance (so designated, precisely mapped and officially adopted by local agencies) is the County’s Box Springs Mountain Reserve (“Reserve”), a special habitat reserve under the Western Riverside County Multiple Species Habitat Conservation Plan, which the site (in green in the display above) borders all along the 427 feet of the site’s long eastern boundary.

The building location, as shown on the site’s grading plan, is on a hilltop overlooking the Reserve to its east from a rather close distance (54’ for the ADU, 61’ for the main house). Thus light trespass and noise into the Reserve will be a permanent impact to the wildlife there, in violation of the Reserve’s designation as a Sensitive Receptor. In addition there will be the construction noise and air quality impacts, including from the many hundreds of dump truck loads going over an easement on a portion of the Reserve, as noted above.

And with the project’s substantial excavation in rocky areas, it is important to know before any approval whether there will be any blasting.

The above quoted Municipal Code provisions and General Plan policies were all adopted in order to provide environmental protection, and thus potential violations of them are subject to CEQA consideration. In view of these potential impacts, there needs to be an Environmental Review of the project.

Because the project involves impingement on Box Springs Mountain, which is a primary amenity of the University Neighborhood, the University Neighborhood Associations joins in opposing the present version of the project.

Please keep us informed regarding any proposal for this site.

Thanks,
Richard
Richard Block for Friends of Riverside’s Hills and the University Neighborhood Association

From: Assadzadeh, Candice
Sent: Thursday, September 15, 2022 3:42 PM
To: Richard Block
Cc: Leonard Nunney; Kevin Dawson; Gurumantra; Arlee Montalvo; [email protected] Subject: RE: [External] 2292 Mt Vernon Ave project

Hi Richard,
Sorry for the delay in getting back to you, as I have been out of the office sick. I am not sure where the address in the email subject came from, but agree that it is incorrect. The APN for the subject parcel is 257-160-003. I was not able to open the email attachment, but have provided a PDF of the Aerial/Location Map indicating the location of the subject parcel, which is north of 2290 Mt. Vernon Avenue and east of 2292 Mt. Vernon Avenue. The north arrow on the PDF of the Grading Plan is inaccurate, as it should be pointing to the left. I hope that resolves the confusion.

The average existing slope of the entire parcel is 39.63% and the average existing slope of the area to be graded is 30%.

Thank you,

Candice Assadzadeh
City of Riverside
Community and Economic Development Department, Planning Division Main: 951-826-5371
Direct: 951-826-5667
RiversideCA.gov

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From: [email protected]
To: Eguez, Judy
Subject: [External] CASE # PR-2021-001108 (DR,GE)
Date: Friday, February 10, 2023 2:16:04 PM
Attachments: Mount Vernon Ave.cleaned.pdf
MOUNT VERNON 1.pdf
MOUNT VERNON 2.pdf
MOUNT VERNON 3.pdf
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Miss Jeguez,
Attached is a response to the above referenced case.

Can you send me an email confirming you received the information? Thanks
Brian
ATTACHMENT 2

APPLICANT PREPARED

RESPONSES
From: Guillermo Landeros
To: Eguez, Judy
Subject: Re: FW: [External] FW: Mt Vernon Ave RC zone site proposalPR-2021-001108(DR, GE), APN 257-160-003 Date: Wednesday, February 15, 2023 11:31:24 PM
Attachments: 8500E500725F4D7082C06036BC0DD61D.png
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33808.4 - Mr. Guillermo Landeros.cleaned.pdf
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Hi Judy,
Please see my response to the friends of the hills:

Regarding Grading:

This is absolute, the average natural slope does not exceed 40%. The same is true for the grading plan. The grading plan does not exceed 40% grading.

As written and stamped by the civil engineer,the grading plan and the natural slope of the site do not exceed 40%. Both the grading and the natural slope of the site are both lower than 40% that is a mathematical reality.

Regarding CEQA and The MSHCP:

As per the Western Riverside County Multiple Species Habitat Conservation Plan Volume 1 Section 6.1.1 Two Key Points:

The project is not of critical concern and meets the criteria for CEQA exemption. As stated in MSCHP section 6.1.1 development of property outside of the MSHCP Conservation Area (both within and outside of the Criteria Area) provided full mitigation under CEQA by paying the fee and compliance with the requirements in sections 6.

Deveploment of Single family homes are considered covered activity within the Criteria Area.

Additionally, the project is only subject to review solely in order determine location of the building (referencing Western Riverside County Multiple Species Habitat Conservation Plan Volume 1 Section

7.3.2)
Section 6.1.4 states where applicable. As outlined in the City of Riverside 2025 General Plan and the EIR Report prepared for the 2025 General Plan, there are already policies in place.

I repeat, the project is only subject to review solely in order determine location of the building (referencing Western Riverside County Multiple Species Habitat Conservation Plan Volume 1 Section 7.3.2) Single family homes are consider covered activity within the Criteria Area.

The biology report and letter prepared by the biologist were completed as additional documentation following section 6.1.1 of the MSHCP. No further reviews are required under the MSHCP.

As per the comments made above the is no violation of the MSHCP or CEQA.

Dump trucks:

The possible usage of dirt transportation by the dump truck over the easement at part of the development is a covered activity under the MSHCP. The easement is a road access, part of the development of the project, and is a covered activity under the MSHCP for single family homes. (See Section 7.3.2 above) Additionally under the City of Riverside EIR for the General Plan of 2025 the truck usage as part of construction will not pass the threshold of significant (Referencing Appenix G of CEQA). The daily threshold for construction is below:

Fire:

Mr. Block's statements are baseless and false. The FPP prepared by a licensed fire engineer shows the conditions at the bottom of the hill have increased fire risk. A "worse case" fire scenario computer simulated for the north side of the hill (location recommended by Mr. Richard Block) and the typical offshore (current proposed location) show the north has higher fire risk. The simulation shows the north side burns at a faster speed and with longer flames than the current proposed location.

As stated previously, per the fire consultant, and the city fire department, the pad cannot be located at the bottom section of the property. No adequate fire protection plan can be created with the house located at the bottom of the hill because of lack of defensible space. In summary, building at the bottom of the hill has a higher fire risk than building at the top of the hill.

For reference a fire protection with the home at the bottom of the hill could not be approved. However, a fire protection plan with the home at the top of the hill was submitted and approved by the city fire department.

See fire sumilation below, 379.5 rate of fire spread on the top of the hill versus 399.5 rate of fire spread. Flame lenght at the top of the hill 49.6 ' versus 50.8 ' at the North side Location of the house:

The comment made by Richard Block are false. The supporting document provided by Judy on February 6 contains a letter from the civil engineer with reasoning for the grading exemption. The WQMP, FPP and grading plan show there is no harm to the neighbor as determined by the city ordinance. In addition, per the city fire department, because of California Fire Code requirements a grading exemption would be required regardless of the location of the housing pad.

None of the points made by Mr. Richard Block are correct. The attach soil report show the bonderies of the test site as the bottom of hill. Testing at the top of the hill was not possible be of the topography of the site. The deeper testing site required for a well type sepic system could not be completed because of the geology of the site. Therefore per the geologist, the project requires a leech field and the leech field could only be constructed at the bottom of the hill. As reference in the MSHCP section 7.3.2 the leech field is a factor when 19 November 2022

Re: LANDEROS RESIDENCE APN 257160003

The property is rocky with senescent vegetation. Elevations range from approximately 1460 to 1560 feet. The subject property is currently a vacant rectangular shaped with no significant topographic features or vegetation, and it is currently undeveloped land. The Multiple Species Habitat Conservation Plan (MSHCP) for Riverside County lists the following:
• Not in a Cellgroup
• Not in a Criteria Cell
Conservation Description:
• Not in an amphibian survey area
• Burrowing owl area
• Not in a criteria area species survey area
• Not in a mammal survey area
• Not in a narrow endemic plant survey area

A burrowing owl survey was conducted; no signs of BUOW (tracks, whitewash, pellets, decorations, prey remains) were found. No burrowing owls (BUOW), a CDFW species of concern, or BUOW burrows were found within the site or 500 foot buffer. This is not an area that provides favorable habitat to BUOW. The rodent burrows that are present are not large enough to house a BUOW and the ground is not supportive of burrowing.

The Multiple Species Habitat Conservation Plan (MSHCP) for Riverside County does not consider this area a habitat of wildlife concern. Biologists surveyed the area and did not find any current evidence of burrowing owl presence or historical presence.

Construction will be of a relatively short duration. After construction is complete, and landscaping is complete, there is the possibility of creating shelter for wildlife within the landscaped area and could be a positive influence in the area.

Wildlife Biologist
Barrett’s Biological Surveys
760 427 7006

1 1411 Rimpau Ave, Ste 109
Corona, CA 92879
Phone: 714-606-3655
Email: [email protected]
Date: November 8, 2022
To: City of Riverside
P
lanning Department
3900 Main Street
Riverside, CA 92522
Re: LANDEROS RESIDENCE – APN: 257-160-003 – PLANNING
CASE P20-0427 (PLOT PLAN REVIEW)
Topic: PROPOSED PAD LOCATION AND GRADING DESIGN
T
o Whom Maybe Concerned:

The proposed single-family development lies along th e edge of the Box Springs Mountains which rise to the north and east of the site. This area descends at moderate gradients to the north, west, and south and rises quite steeply, offsite, to the east. Total project site is

2.47 acres and disturbed area is 0.92 acres (37% of the site). The area of the proposed residence lies atop a roughly east to west trending topographic within the center portion of the property. Large lot residential properties lie to the north and west of the site while the properties to the east and south of the site are vacant, natural land. The proposed access road alignment selected to avoid natural boulders and limited the required cut / fill slopes to the existing terrain and contours of the site. After discussion with City of Riverside staffs, the design team have come up with numerous ways to reduce the amount of grading and best fit the project for the lot.
- Pad Location
T
he proposed structures will be lies atop a roughly east to west trending topographic high within the center portion of the property. The location of the structures is placed in one of the flattest portions of the site (existing natural terrain range from 5% to 15%). The structures will be designed to fit with the contours of the hillside and relate to the overall form of the terrain. Structures will be designed to fit into the hillside rather than altering the hillside to fit the structure.

If the pad is placed at lower portion of the site, this creates a transition grading situation which requires cut and fill (see Figure 1). Typically, the building requires 3’ to 5’ overexacation over the existing surface and recompacted to 90% relative compaction.

The amount of grading is excessive. Alternatively, stepped building layout typically used to avoid excessive cut and fill (see Figure 2). However, the stepped building layout requires shoring walls and extensive amount of retaining wall which creates a financial burden to the owner. Therefore, in our opinion, the proposed pad location fits into the natural terrain and most economical to the owner.
2 1411 Rimpau Ave, Ste 109
Corona, CA 92879
Phone: 714-606-3655
Email: [email protected]
Figure 1: Transition Grading (Cut and Fill)

Figure 2: Stepped Building Concept

3 1411 Rimpau Ave, Ste 109
Corona, CA 92879
Phone: 714-606-3655
Email: [email protected]
- R
educe Amount of Grading
T
he area of a site proposed to be graded shall be that which fits into the natural terrain and which allows for a minimal amount of grading. The ungraded area must be left in its natural form for the remainder of the site. No native vegetation shall be removed and no non-native vegetation shall be introduced or allowed within hillside areas not included as part of the graded pad area. Most of the grading is due to the maximum slope of 15% and driveway width is required by Fire Department to increase to 20’ side. After discussion with Fire Department, the straight portion of the driveway can be reduced to 15’. This reduced approx. 3,000 sf of disturbed area and 2,325 cy less of export.

The proposed grading slope to be rounded and blend with natural hillside slope. The disturbed area mostly avoided where larger rocks located. If necessary, interference larger rocks will be relocated elsewhere of the site as a natural feature.

In conclusion, the proposed development meets City’s grading ordinance and best fit to the existing terrain. If you have any questions, do not hesitate to contact us.

Best Regards,
Yang Hu, PE
(714) 606-3655
[email protected]

FIREWISE2000, LLC

Mel Johnson, Owner
FIREWISE 2000, LLC
[email protected]
(760) 745-3947

6 August 2022

To: Planning Department City of Riverside

We often find the same comments on many of our projects, the Fire Protection Plan submitted to Fire provides details on expected fire behavior, required fuel modification distances, and mitigation measures.

CEQA Finding
Would the project expose people or structures to a significant risk of loss, injury or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands?

The wildland fire risk in the vicinity of the project site has been analyzed and it has been determined that wildfires may occur in wildland areas to the south, west, north and east of the project site, but would not be significantly increased in frequency, duration, or size with the approval of the Landeros Residence.

The types of potential ignition sources that currently exist in the area include vehicle and roadway, electrical transmission line, and machinery associated with various land uses in the vicinity, as well as from off-site developed parcels.

The project would introduce potential ignition sources, but would also include conversion of fuels to lower flammability landscape and include better access throughout, managed and maintained landscapes, higher site awareness/monitoring, and generally a reduction in the receptiveness of the areas landscape to ignition.

Fires from off-site would not have continuous fuels across this site and would therefore be expected to burn around and/or over the site via spotting. Burning vegetation embers may land on structures but are not likely to result in ignition based on types of non-combustible and ignition resistant materials that will be used.

The project does comply with ignition resistant fire and building codes, plus site-specific measures that will result in a project that is less susceptible to wildfire than surrounding landscapes and that would facilitate fire fighter and medical aid response.

Respectably

Monty Kalin
Associate Planner
Firewise2000, LLC
Monty.Kalin @firewise2000.com

1 PEARL CITY ENGINEERING, INC.
1411 Rimpau Ave, Ste 109 Corona, CA 92879 Phone: 714-606-3666 Email:

[email protected]

Re: LANDEROS RESIDENCE – APN: 257-160-003 – PLANNING CASE P20-0427 (PLOT PLAN REVIEW)

Descriptive Narrative for Project Meeting Hillside /Arroyo Grading Ordinance

Hillside / Arroyo Grading Ordinance Requirements:

The site lies along the edge of the Box Springs Mountains which rise to the north and east of the site. This area descends at moderate gradients to the north, west, and south and rises quite steeply, offsite, to the east. Total project site is 2.47 acres and disturbed area is 0.96 acres (39% of the site). The area of the proposed residence lies atop a roughly east to west trending topographic within the center portion of the property. Large lot residential properties lie to the north and west of the site while the properties to the east and south of the site are vacant, natural land. The proposed access road alignment selected to avoid natural boulders and limited the required cut / fill slopes to the existing terrain and contours of the site.

2. Where two cut or fill slopes intersect, the intersection shall be horizontally rounded and blended.

Refer to Appendix A for Grading Specification for details showing slopes blended with natural hillside. Also, added the notes to the Conceptual Grading Plan.

3. The tops of cut and fill slopes shall be rounded vertically with a constant tangent (T) of ten feet.

Refer to Appendix A for Grading Specification for how slope to be rounded and blend with natural hillside slope. Also, added the notes to the Conceptual Grading Plan.

2 PEARL CITY ENGINEERING, INC.
1411 Rimpau Ave, Ste 109 Corona, CA 92879 Phone: 714-606-3666 Email: [email protected]

4. Where any cut or fill slopes intersect the natural grade, the intersection of each slope shall be vertically and/or horizontally rounded and blended with the natural contours so as to present a natural slope appearance.

Refer to Appendix A for Grading Specification for how slope to be rounded and blend with natural hillside slope. Also, added the notes to the Conceptual Grading Plan.

5. Where any cut or fill slope exceeds 100 feet in horizontal length, the horizontal contours of the slope shall be developed in concert with existing natural contours.

R
efer to Appendix A for Grading Specification and details how landform graded slopes blended with natural contours. Also, added the notes to the Conceptual Grading Plan.

6. The area of a site proposed to be graded shall be that which fits into the natural terrain and which allows for a minimal amount of grading. The ungraded area must be left in its natural form for the remainder of the site. No native vegetation shall be removed and no non-native vegetation shall be introduced or allowed within hillside areas not included as part of the graded pad area. The Community & Economic Development Director shall be responsible to determine the precise boundaries of the non-graded area to be retained as natural open space and an open space easement shall be recorded over this area. Portions of the non-graded area may be excluded from the natural open space easement by the Community & Economic Development Director based on factors specific to each lot, including whether the area is isolated from a meaningful area of contiguous open space and the absence of unique topographical or geological features. The intent of this provision is to create significant areas of contiguous open space and not to create small, isolated areas of open space. No change to the boundaries of the area determined to be placed in natural open space by Community & Economic Development Director shall be made unless the Planning Commission determines that exceptional or special circumstances addressed in Chapter 17.32 Conditional Exceptions apply.

The proposed disturbed grading area well fits into the natural terrain and limited disturbance of the site. Total disturbed area is 39% of the total project area. All the native vegetation will remain. Added the note on Conceptual Grading Plan.

The proposed structures will be lies atop a roughly east to west trending topographic high within the center portion of the property. The location of the structures is placed in one of the flattest portions of the site (existing natural terrain range from 5% to 20%). 3 PEARL CITY ENGINEERING, INC.
1411 Rimpau Ave, Ste 109 Corona, CA 92879 Phone: 714-606-3666 Email:

[email protected]

8. Streets shall be designed to generally follow the natural contours and land form in order to minimize cut and fill.

Not applicable. No street is proposed for the development.

9. Pad sizes for single family residential development shall be limited as follows:

• Thirty percent to 40 percent average natural slope within the area to be graded - 18,000 square feet.

Based on average natural slope calculation, S = 30% and allowable pad size is 18,000 sf. The proposed project with an 8,000-sf pad is well below the allowable pad size.

10. Slopes having a ratio of 3.9:1 or steeper shall not exceed 20 feet in vertical height. Slopes having a 4:1 or flatter ratio may be up to 25 feet in vertical height. The Community & Economic Development Director shall have the authority to increase vertical slope height by up to 25 percent without a grading exception depending on the sensitivity of the site.

Sensitivity shall be determined by such factors as the slope's visibility from the public right-of-way, its location on a ridge line, the presence of habitat for sensitive species including rare, threatened, or endangered species, or the presence of unique topographic features such as knolls, valleys, rock outcroppings or other features or views capes. (Level padded area defined as area that is at a slope ratio of 5:1 or flatter.)

As shown on the Conceptual Grading Plan, vertical height throughout the site ranges from 11’ to 19’. The proposed grading mostly avoided existing Boulders.

11. Slopes requiring benches shall not normally be permitted.

No slope with benches proposed for the project.

12. No grading shall be permitted on slopes exceeding 40 percent unless findings can be made by the Planning Commission that exceptional or special circumstances as set forth in Chapter 17.32 Conditional Exceptions apply

The proposed grading will be on the northwest of the project site which is generally flatter than Remainer of the site. The disturbed area mostly between 5% to 40%.

13. Driveway grading:
a. Shall not exceed 15 feet in width.
b. Shall not exceed a 15 percent finished grade unl ess otherwise approved by the Fire Department and Community & Economic Development Director. c. Driveway cut and fill slopes shall be subject to the same restrictions as identified in Chapter 17.28.
d. Driveway grading required to provide access to t he level building pad area is not included as part of the total permitted level pad area. 4 PEARL CITY ENGINEERING, INC.
1411 Rimpau Ave, Ste 109 Corona, CA 92879 Phone: 714-606-3666 Email:

[email protected]
The maximum slope is 15% and driveway width is required by Fire Department to increase to 20’ side.

14. Arroyo grading.

a. No development or grading of any kind shall be p ermitted within 50 feet of the limits of the Mockingbird Canyon, Woodcrest, Prenda, Alessandro, Tequesquite, or Springbrook Arroyos and associated tributaries as shown on Exhibits A-F. The Community & Economic Development Director shall have the authority to administratively allow grading within designated arroyo tributaries depending on the sensitively of the area. Sensitivity shall be determined by such factors as the presence of riparian vegetation, habitat for rare or endangered species, significant rock outcroppings or other unique topographic features on the property proposed to be graded or in nearby segments of the same tributary.
b. The limits of these arroyos shall include all th at land within the watercourse area, the adjacent slopes having an average natural slope of 30 percent or greater, and all other areas within the boundaries shown on Exhibits A-F. c. No grading for private crossings of these arroyo s shall be permitted. Grading for public street crossings must be limited to the minimum necessary for access and emergency access.
d. No native vegetation shall be removed and no non -native vegetation shall be introduced within the boundaries of theses arroyos in areas that cannot be graded. e. All land within the boundaries of these arroyos shall be included as an open space easement on final tract and parcel maps.
f. Where drainage structures enter these arroyos, t he structure must be blended into the natural terrain, and where necessary, lined with natural or quarried rock or other material as approved by the Community & Economic Development Director and Public Works Director.
g. Where possible, other arroyos, shall be preserve d as natural drainage courses.

Significant natural features within these arroyos shall be preserved including riparian vegetation, boulders, rock outcroppings, milling features and deeply incised channels.

These features shall be shown on the grading plans submitted for review. To insure that these areas are adequately preserved, an appropriate setback for development and grading may be applied.
h. Development or grading within blue line streams shall be limited to the minimum necessary for access or drainage structures. Any disturbance will require permits from the U.S. Corps of Engineers and the State Department of Fish and Wildlife.

The project is not within Arroyo Hillside boundary.

Please contact me with any questions. Thank you,
Yang Hu, PE
(714) 606-3655
[email protected]

GENERAL EARTHWORK ANDGRADING SPECIFICATIONSSHEET 1

TRANSITION LOT DETAIL
GENERAL EARTHWORK ANDGRADING SPECIFICATIONSSHEET 2TYPICAL BUTTRESS FILL DETAIL

DIAGRAMS FOR DESIGN STANDARDS

DIAGRAM II-1

FILL SLOPES BLENDED WITH NATURAL STEEP HILLSIDE

DIAGRAM II-2: LANDFORM GRADED SLOPES

DIAGRAM II-6

LONG DRIVEWAYS

DIAGRAM II-7

STRUCTURES THAT FIT NATURAL CONTOURS

DIAGRAM II-9

STRUCTURE LOCATED IN FRONT OF MANUFACTURED SLOPE

DIAGRAM II-10: STEPPED BUILDING

DIAGRAM II-11: BUILDING SET INTO STEEP HILLSIDE

DIAGRAM II-13

NATURAL HILLSIDES RETAINED

BETWEEN DEVELOPMENT AREAS

DIAGRAM II-15

RETAINED AREAS OF UNDISTURBED

HILLSIDES WITHIN DEVELOPMENT

DIAGRAM II-16

SPLIT-LEVEL STREET

DIAGRAM II-17

USE OF RETAINING WALLS IN HILLSIDE DEVELOPMENTS

- 37 -

DIAGRAM II-18

VARIED LOT SIZE AND SHAPE

DIAGRAM II-19

BLENDED MANUFACTURED SLOPES

DIAGRAM II-20

DEVELOPMENT LOCATED ON LEAST STEEP AREAS

DIAGRAM II-21

BUILDING LOCATED NEAR RIDGELINE

DIAGRAM II-22

SINGLE LOADED STREETS

DIAGRAM II-23

STEPPED PADS

- 39 -

DIAGRAM II-24

PARKING FOR HILLSIDE STRUCTURES

DIAGRAM II-25

PARKING LOTS NEAR STEEP HILLSIDES

- 40 -

SLOPE MAINTENANCE GUIDELINES

SLOPE MAINTENANCE GUIDELINES
Hillside lots in general, and hillside slopes in particular, need maintenance to continue to function and retain their value. Many homeowners are unaware of this and allow deterioration of their property. In addition to his own property, the homeowner may be subject to liability for damage occurring to neighboring properties as a result of his negligence. It is therefore important to familiarize homeowners with some guidelines for maintenance of their properties and make them aware of the importance of maintenance.

Nature slowly wears away land, but human activities such as construction increase the rate of erosion 200, even 2,000 times that amount. When we remove vegetation or other objects that hold soil in place, we expose it to the action of wind and water, and increase its chance of eroding.

The following guidelines are provided for the protection of the homeowner’s investment, and should be employed throughout the year.
(a) Care should be taken that slopes, terraces, berms (ridges at crown of slopes), a nd proper lot drainage are not disturbed.

Surface drainage should be conducted from the rear yard to the street by a graded swale through the sideyard, or alternative approved devices.
(b) In general, roof and yard runoff should be conducted to either the str eet or storm drain by nonerosive devices such as sidewalks, drainage pipes, ground gutters, and driveways.

Drainage systems should not be altered without expert
consultation.
(c) All drains should be kept cleaned and unclogged, including gutters and downspout s. Terrace drains or gunite ditches should be kept free of debris to allow proper drainage. During heavy rain periods, performance of the drainage system should be inspected. Problems, such as gullying and ponding, if observed, should be corrected as soon as possible.
(d) Any leakage from pools, waterlines, etc. or bypassing of drains should be repaired as soon as possible.
(e) Animal burrows should be filled since they may cause diversion of surface runoff, promote accelerated erosion, and even trigger shallow soil failures.
(f) Slopes should not be altered without expert consultation.

Whenever a homeowner plans a significant topographic
modification of the lot or slope, a qualified geotechnical consultant should be contacted.
(g) If plans for modification of cut, fill , or natural slopes within a property are considered, an engineering geologist should be consulted. Any oversteepening may result in a need for expensive retaining devices. Undercutting of the bottom of a slope might possibly lead to slope instability or failure and should not be undertaken without expert consultation.
(h) If unusual racking, settling, or earth slippage occurs on the property, the homeowner should consult a qualified soil engineer or an engineering geologist immediately.
(i) The most common caus es of slope erosion and shallow slope failures are as follows:
❖ Gross negligent of the care and maintenance of the slopes and drainage devices.
❖ Inadequate and/or improper planting. (Barren areas should be replanted as soon as possible.)
❖ Excessive or insufficient irrigation or diversion of runoff over the slope.
❖ Foot traffic on slopes destroying vegetation and exposing soil to erosion potential.
(j) Homeowners should not let conditions on their property create a problem for their neighbors. Cooperation with nei ghbors could prevent problems; also increase the aesthetic attractiveness of the property.

WINTER ALERT
It is especially important to “winterize” your property by mid - September. Don’t wait until spring to put in landscaping. You need winter protection. Final landscaping can be done later. Inexpensive measures installed by mid-September will give you protection quickly that will last all during the wet season.
❖ Check before storms to see that drains, gutters, downspouts, and ditches are not clogged by leaves and rubble.
❖ Check after major storms to be sure drains are clear and vegetation is holding on slopes. Repair as necessary.
❖ Spot seed any bare areas. Broadcast seeds or use a
mechanical seeder. A typical slope or bare areas can be don e in less than an hour.
❖ Give seeds a boost with fertilizer.
❖ Mulch if you can, with grass clippings and leaves, bark chips or straw.
❖ Use netting to hold soil and seeds on steep slopes.
❖ Check with your landscape architect or local nursery for advice. ❖ Prepare berms and ditches to drain surface runoff water away from problem areas such as steep, bare slopes.
❖ Prepare base areas on slopes for seeding by raking the surface to loosen and roughen soil so it will hold seeds.

CONSTRUCTION
❖ Plan construction act ivities during spring and summer, so that erosion control measures can be in place when the rain comes. ❖ Examine your site carefully before building. Be aware of the slope, drainage patterns and soil types. Proper site design will help you avoid expensive stabilization work.
❖ Preserve existing vegetation as much as possible. Vegetation will naturally curb erosion, improve the appearance and value of your property, and reduce the cost of landscaping later. ❖ Use fencing to protect plants from fill material and traffic. If you have to pave near trees, do so with permeable asphalt or porous paving blocks.
❖ Minimize the length and steepness of slopes by benching, terracing, or constructing diversion structures. Landscape benched areas to stabilize th e slope and improve its
appearance.
❖ As soon as possible after grading a site, plant vegetation on all areas that are not to be paved or otherwise covered.

TEMPORARY MEASURES TO STABILIZE THE SOIL
Grass provides the cheapest and most effective short -term erosion control. It grows quickly and covers the ground completely. To find the best seed mixtures and plants for your area, check with your local landscape architect, local nursery, or the U.S. Department of Agriculture Soil Conservation Service. Mulc hes hold soil moisture and provide ground protection from rain drainage. They also provide a favorable environment for starting and growing plants. Easy -to- obtain mulches are grass clippings, leaves, sawdust, bark chips, and straw.

Straw mulch is nearly 100 percent effective when held in place by spraying with an organic glue or wood fiber (tackifiers), by punching it into the soil with a shovel or roller, or by tacking a netting over it.

Commercial applications of wood fibers combined with various seeds and fertilizers (hydraulic mulching) are effective in stabilizing sloped areas. Hydraulic mulching with a tackifier should be done in two separate applications; the first composed of seed fertilizer and half the mulch, the second composed of the remaini ng mulch and tackifier. Commercial hydraulic mulch applicators – who also provide other erosion control services – are listed under “landscaping” in the phone book.

Mats of excelsior, jute netting, and plastic sheets can be effective temporary covers, bu t they must be in contact with the soil and fastened securely to work effectively.

Roof drainage can be collected in barrels or storage containers or touted into lawns, planter boxes, and gardens. Be sure to cover stored water so you don’t collect mosqui toes. Excessive runoff should be directed away from your house. Too much water can damage tress and make foundations unstable.

STRUCTURAL RUNOFF CONTROLS
Even with proper timing and planting, you may need to protect disturbed areas from rainfall until the plants have time to establish themselves. Or you may need permanent ways to transport water across your property so that it doesn’t cause erosion.

To keep water from carrying soil from your site and dumping it into nearby lots, streets, streams and channels, you need ways to reduce its volume and speed. Some examples of what you might use are:
❖ Riprap (rock lining) – to protect channel banks from erosive water flow.
❖ Sediment trap – to stop runoff carrying sediment and trap the sediment.
❖ Storm drain outlet protection – to reduce the speed of water flowing from a pipe onto open ground or into a natural channel. ❖ Diversion dike or perimeter dike – to divert excess water to places where it can be disposed of properly.
❖ Straw bale dike – to stop and detain sediment from small - unprotected areas (a short-term measure).
❖ Perimeter swale – to divert runoff from a disturbed area or to contain runoff within a disturbed area.
❖ Grade stabilization structure – to carry concentrated runoff down a slope.

ATTACHMENT 3

APPROVED FIRE PROTECTION PLAN
F
ire Protection Plan
L
anderos Residence
APN 257-160-003
Riverside, California
20 November 2022
Prepared for:

G
uillermo Landeros
3391
Spruce Street Unit C
R
iverside, CA 92501
CITY OF RIVERSIDE FIRE DEPT.

This is to certif y that plans have been
approved by the Fire Of f icial and no change or
deviation theref rom shall be permitted. However,
this approval does not authorize violation or
cancellation of any law of the city nor does it
prevent requiring correction of any error on the
plans. This is not an approval of any work requiring
a separate permit under the laws of the city.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC
FPP_
Landeros Residence
V3_IncAM&M Page | 1
Landeros Residence
Fire Protection Plan
Table of Contents

Subject

Page

1.0 GENERAL DESCRIPTION
3 1.1 General Information
4 2.0

WILDLAND FIRE HAZARD AND RISK ASSESSMENT
6 2.1
Weather Review and Assessment
6 2.2 Off-
Site Fire Hazard and Risk Assessment
8 2.3 On-
Site Fire Hazard and Risk Assessment
10 2.4 Fire History
10 3.0

PREDICTING WILDLAND FIRE BEHAVIOR
11 3.1
Wildland Fire Behavior Calculations for the Adjacent Hazardous

Vegetative Fuels
11 4.0

ASSESSING STRUCTURE IGNITIONS IN THE

WILDLAND/URBAN INTERFACE
16 4.1 Firebrands
16 4.2 Radiant Heat/Direct Flame Impingement
17 4.3 Fire Resistant Plant Palette
18 5.0

FIRE DEPARTMENT RESPONSE TIMES
18 6.0 FUEL

MODIFICATION

ZONE DESCRIPTIONS AND

REQUIRED TREATMENTS
19 6.1 Irrigated Zone 1
19 6.2 Vegetation
Management
Non Irrigated
Zone 2 20

7.0 CONSTRUCTION

STANDARDS
22 7.1
Conditions to be Met
22 7.2 Additional Construction Requirements
22 7.3
Application for Alternate materials and methods. (AMMR) 22 Proposed mitigation measures and mandatory requirement.

8.0 OWNER,

OCCUPANT,

AND EMPLOYEE

EDUCATION
23 9.0

INFRASTRUCTURE
24 9.1 Water Supply 24

9.2 Access Roads/Driveways and Gates
24 10.0

FIRE PROTECTION PLAN
MAP 24

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIREWI
SE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 2
A

PPENDICES
P
rohibited Plant Li
st APPENDIX ‘A’
De
fensible Space Landscaping
APPENDIX ‘B’
L
iterature Referen
ced APPENDIX ‘C’
I
gnition Resistant Construction
Requirements
APPENDIX ‘D’
A
M&M Application
APPENDIX ‘E’
F
uel Treatment Exhibit with Ac
cess Plan APPENDIX ‘F’
CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 3

Fire Protection Plan
Landeros Residence
APN 257-160-003
Riverside, California

1.0 GENERAL DESCRIPTION
The proposed Landeros Project,
construction
of a SFR of
approximately
3,154sqft, and
construction of an ADU of approximately
971sqft
The parcel is

2.47 acres of undeveloped vacant land. Residences are
found to the west and north;
vacant lots to the south and east. The City o
f Riverside boundary is on the east side of the property.

The property is rocky with sparse vegetation. Elevations range from approximately 1460 to 1560 feet.

Figure 2 Topo image
The subject property is currently a vacant rectangular shaped with no significant topographic features or vegetation, and it is currently undeveloped land.

The proposed Project is located within a high fire hazard zone in the City of Riverside Figure 1 Very High Fire Hazard Severity Zone (VHFHSZ)).

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIREWI
SE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 4
Th
e project is mostly bounded by undeveloped land to the n orth, east and south. (Fi
gure 2).

P
rior to any land development within this proposed pr
oject, a F
ire Protection Plan (
FPP) must be
su
bmitted to and approved by the City of R
iverside F
ire Department (R
CFD). The FPP assesses
t
he overall (on-si
te and off-si
te) wildland fire hazards and risks that may threaten life and property a
ssociated with the proposed residential development
.

In addition, thi
s FPP est
ablishes both short
a
nd long-t
erm fuel modifications t
o minimize any projected fire hazard and r
isk and a
ssigns annual
m
aintenance responsibilities for each of the recommended fuel modification actions. 1 .1 G
eneral Information
De
veloper/Applicant: G
uillermo Landeros
3391
Spruce Street Unit C
R
iverside, CA 92501
Appr
oving Departments: C
ity of Riverside Planning De
partment
F
ire Authority:

City of Riverside Fire Department
P
repared By:

Monty Kalin
F
irewise2000, LLC
A
ssociate Planner
C
ITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIREWI
SE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 5
Th
e project does not
provide for 100 feet of Fuel Treatment and defensible space on east side of t
he proposed structure. Fi
gure 3
The purpose of this FPP is to provide Veget
ation M
anagement Z
one treatment and con
struction f
eature
d
irection for developers,
architects, builders, a
nd the individual lot owner. Th
e document will be used i
n
ma
king the structures in the proposed project
safe from future wild
fires.

R
equirements of this FPP are based upon requirements listed in the 2019 California Fire Code, Chapter 49.

Pu
blic Resources Code, Sections 4201 through 4204, and Gov ernment C
ode, Sections 51175 through
5 1189, or other areas designated by the en
forcing agency to be at a significant risk from wildfires.

L
ocal A
mendments a
s required; Chapter 7A-California Building Code; 2019 California R esidential C
ode
se
ctions R337; National Fire Protection Association Standards (NFPA) 13-D, 2019 Edition.
t
he Ci
ty of Riverside Weed Abatement, Decla
ration of Nuisance 6.1

5.020, and supporting guidelines.

H
azardous v
egetation a
nd fuels around all applicable bu
ildings a
nd s
tructures s
hall be ma
intained
by
the following laws and/or regulations:

Pu
blic Resources Code, Section 4291. California Code of R egulations, T
itle 14, Division 1.5, Chapter 7,
Subchapter 3, Section 1299 (see guidance for i
mplementation "
General Guideline to Create Def
ensible
S
pace"). Ca
lifornia Gov
ernment C
ode, S
ection 51182. C
alifornia Code of R
egulations, T
itle 19, Division
1 , Chapter 7, Subchapter 1, Section 3.07. R
iverside County Ordinances; 787.7 and 460.151.

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi

FIREWI
SE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 6
2 .0 W

ILDLAND FIRE HAZARD AND RISK ASSESSMENT
T
he proposed site is located within an area classified by the RCFD as a Very High Fire Hazard Area. Wildland fire may impact the project as there are wildland fuels within 1000 feet of the project on all sides. The
greatest threat comes from the adjacent u
ndeveloped properties a
nd steep
terrain. Th
ere is potential for wildfire to enter the project sit
e from any direction. Al
l the structures
w
ithin t
he site would be s
ubject to embers showers.

2.1 Weather Review and Assessment
T
he typical prevailing summer time
wind pattern is out of the w
est/southwe
st and normally
i
s of a much lower velocity (5-10 MPH with occasional gusts to 30 MPH) and is associated wi
th relative humidity readings ranging between 20% and occasionally more than 70% due to t
he sites proximity to the ocean. All other (northwest, southeast and south) wind directions m
ay be occasionally strong and gusty; however, they are generally associated with cooler moist a
ir and have higher relative humidity (>40%). They are considered a serious wildland fire we
ather condition when win
d speeds reach >20-M
PH.

The most cr
itical weather pattern to the project area i
s a
hot, dry offshore wind, typically called
a S
anta Ana. Such wind conditions are usually associated with strong (>50 MPH), hot, dry wi
nds with very low (<15%) r
elative humidity.

Santa Ana winds originate over the dry desert
l
and and can occur anytime of the year; however, they generally occur in the late fall (September through November). This is also when non-irrigated vegetation is at its lowest moisture content.

Th
e following i
llustrations d
epict the the worst case weather that FI
REWI
SE 2000 LLC c
ould
verify over the last 10 years. Note that when very low humidity occurs simu ltaneously w
ith
st
rong winds that f
ire behavior can be p
rofoundly affected.

F
igure 4 Wind Gust highest found oer the past several years.

Recorded at 65 mph.

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 7

Figure 5 note predominate wind out of the west.

2.2 Off-
Site Fire Hazard and Risk Assessment
Figure 6 shows areas that potentially put the structure at risk.

There is considerable
open space
fuel in all directions.

The Fire Behavior Analysis was performed in all directions from the proposed pad.

Noted is that the site is very rocky, the lack of fuel means the models results are over predicted.

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIREWI
SE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 8
Hist
orically, wildland fires h
ave burned i
n the City of R
iverside during mode
rate west to
sou
thwest winds. This moderately strong, dry wind condition that occurs during these fires u
sually develops in the late afternoon or early evenings.

These winds occur d
uring the normal
s
ummer a
nd early fall (J
une through O
ctober) months.

These winds m
ay blow from 2
0-30 MPH.

Th
e most significant wind pattern t
hat will impact the project i
s a Sa
nta Ana wind w
hich
t
ypically occur in September thru N
ovember and i
n the range of 50-60
MPH within this portion
of
Riverside County.

Th
e current vegetative cover best
resembles a SCAL 18 BEHAVE Model. M
oderate Load, Dry
Cl
imate Shrub
T
he required irrigated fire-resistant landscape surrounding the structure combined with ignition resistant construction requirements, will be more than sufficient to mitigate any threats from wi
ldfire and embers coming from the east.

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 9

Site Photos

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIREWI
SE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 10
CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 11

The greatest threat will be from embers from a wildfire occurring to the east in the undeveloped
open space.

2.3 On-
site Fire Hazard and
Risk Assessment
All
the interior fuels
will be removed during
grading; therefore, there
are
no wildland fire hazards
anticipated within the development once all the fuel
modifications
are developed as described in
Section 6.0
Fuel Modification Zone Descrip
tions & Required Treatments
.

2.4 Fire History
Historical wildland fire activity was also considered in developing this FPP .

On the following page
is a map showing historical large fire activity on and around the project over the past 100 years.

The data for this map was obtained from CalFire.

Smaller fires of under 100
ac
are seldom maped
unless they caused significant damage or loss of life.

Fire History is not signaficiant as both the major fires occred in 1981.

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 12

3.0 Predicting Wildland Fire Behavior
The BEHAVE Plus 5.0.5 Fire Behavior Prediction and Fuel Modeling System developed by USDA–Forest Service research scientists Patricia L. Andrews and Collin D. Bevins at the Intermountain
Forest Fire
Laboratory,
Missoula, Montana, is one of the best systematic methods for predicting wildland fire behavior.

The BEHAVE Plus fire behavior computer modeling system
is utilized by wildland fire experts n
ationwide.

Wildland fire managers use the BEHAVE Plus modeling system to project the expected fire intensity, rate-of-spread and flame lengths with a reasonable degree of certainty for use in Fire Protection Planning purposes. FIREWISE 2000 LLC. used the BEHAVE Plus 5.0.5 Fire Behavior Prediction Model to make the fire

behavior assessments for the
project
discussed below.

3.1 Wildland Fire Behavior Calculations for the
Adjacent
Hazardous Vegetative Fuels
Wildland fire behavior calculations have been projected for t he hazardous vegetative fuels
in the
undeveloped
lands located east of the the proposed project. These projections are based on scenarios that are “worst case” Riverside County fire weather assumptions in the vicinty of the project area.

The following i
mages provide

the fire behaviour for

a fire start in each directiion from the pad.

They displays the expected Rate of Fire Spread (expressed in feet/minute), Fireline Intensity (expressed in
btu/ft/s
) and Flame Length (expressed in feet)
.

The Behave
calculation inputs follow
each run,
and include
source
inputs used in the BEHAVE
Plus program which were obtained from project site
observations
and fuel moisture levels
typically observed during the local fire season.

The flame lengths are over predicted because the model does not take into account the non-
vegatated areas (rock out crops.)

or areas that are dirt.

In estimatiion of the effect would be to evaluate the cover and deduct the percentage.

This is not scientific, however will be very close.

If cover represent a 30% reduction caused by a lack of vegatation then it would reduce the flame lengths for the off shore run from 49 to 35 feet. 30% would be less than what my observations were, I guessed around 50% .

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 13

Image 1 Typical Off
Shore
BehavePlus 5.0.5 (Build 307)
Off Shore Wind Event East Side
Wed, Jun 29, 2022 at 15:19:48

Input Worksheet
Inputs: SURFACE
Input Variables
Units
Input Value(s)
Fuel/Vegetation, Surface/Understory
Fuel Model SCAL18
Fuel Moisture
1-h Moisture % 2
10-h Moisture % 3
100-h Moisture % 5

Live Herbaceous Moisture
% 30

Live Woody Moisture
% 50
Weather
20-
ft Wind Speed
mi/h 65

Wind Adjustment Factor
.5
CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 14

Wind Direction (from north)
deg 45
Terrain
Slope Steepness % 12
Aspect deg 270
Image 2 Fire Behavior from the North
BehavePlus 5.0.5 (Build 307)
North Run
Wed, Jun 29, 2022 at 15:29:48

Input Worksheet
Inputs: SURFACE
Input Variables
Units
Input Value(s)
Fuel/Vegetation,
Surface/Understory
Fuel Model SCAL18
Fuel Moisture
1-h Moisture % 2
10-h Moisture % 3
CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 15

100-h Moisture % 5

Live Herbaceous Moisture
% 30

Live Woody Moisture
% 50
Weather
20-
ft Wind Speed
mi/h 65

Wind Adjustment Factor
.5

Wind Direction (from north)
deg 0
Terrain

Slope Steepness
% 47
Aspect deg 0
Notes
Image 3 Fire
Behavior from the
South

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 16

BehavePlus 5.0.5 (Build 307)
South Run
Wed, Jun 29, 2022
at 15:43:16

Input Worksheet
Inputs: SURFACE
Input Variables
Units
Input Value(s)
Fuel/Vegetation, Surface/Understory
Fuel Model SCAL18
Fuel Moisture
1-h Moisture % 2
10-h Moisture % 3
100-h Moisture % 5

Live Herbaceous
Moisture % 30

Live Woody Moisture
% 50
Weather
20-
ft Wind Speed
mi/h 30

Wind Adjustment Factor
.5

Wind Direction (from north)
deg 180
Terrain

Slope Steepness
% 43
Aspect deg 180
Image 4 Fire
Behavior from the
West
CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIREWI
SE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 17
B
ehavePlus 5.0.5 (Build 307)
West Run
Wed
, Jun 29, 2022 at 15:51:27
I
nput Worksheet
I
nputs: SURFACE
I
nput Variables Units I
nput Value(s)
F
uel/Vegetation, Surface/Understory
Fu
el Model S CAL18
F
uel Moisture
1-h
Moisture % 2
10-h M
oisture % 3
100-h
Moisture % 5
Li
ve Herbaceous Moisture % 30
Li
ve Woody Moisture % 50
W
eather
20-f
t Wind Speed m
i/h 30
Wi
nd Adjustment Factor .5
Wi
nd Direction (from north) d
eg 2 70
T
errain
Sl
ope Steepness % 52
A
spect deg 2 70

4.0 Assessing St
ructure Ignitions in the Wildland/Urban Interface
St
ructure ignitions from wildland wildfires basically come from three sources of heat: convective f
irebrands (flying embers), direct flame impingement, and radiant heat. The Behave Plus Fire Behavior Modeling Program does not address wind blown embers or firebrands from a structure ignition perspective. However, even though ignition resistant exterior building materials will be required in the construction,
t
hey are not garnateed to prevent ignition from w
ind driven embers,
these i
ssues are addressed in this FPP.

4.1 Firebrands
Fi
rebrands are pieces of burning materials that detach from a burning fuel due to the strong convection drafts in the flaming zone. Firebrands may also be referred to as embers. Firebrands can be carried a long distance (one mile or more) by fire drafts and strong winds. Severe wi
ldland/urban i
nterface fires can produce heavy showers of firebrands. The chance of these f
irebrands igniting a structure will depend on the n
umber and siz
e of the firebrands,
how long they
b
urn after contact and the type of building materials, building design, and con struction f
eatures
i
ncorporated into t
he structure.

Firebrands landing on combustible roofing and decks are common sou
rces for structure ignition. They can also enter a structure through unscreened or poorly screened
v
ents, chimneys, unprot
ected skylights, and w
indows.

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 18

Even with non
-
combustible roofing, firebrands landing on leaves, needles, and other combustibles located on a roof (due to a
lack of maintenance) can cause structure ignition. Any open windows, doors, or other types of unscreened openings are sources for embers to enter a structure during a wildland fire. If these maintenance issues are addressed on a regular basis, firebrands should not be a concern.
4 .2 Radiant Heat/Direct Flame Impingement
Radiation and convection involve the transfer of heat directly from the flame to any exposed surface.

Unlike radiation heat transfer, convection requires that the flames or heat column
contact
the structure. An ignition from radiation (given an exposed flammable surface) heat transfer depends on two aspects of the flame:
1) the radiant heat flux to a combustible surface and, 2) the duration (length of time) of the radiant flux.

The radiant heat flux depends on the flame zone size,
flame-
structure distance, and how mu
ch the combustible material of the structure is exposed to the flame.

While the flame from a wildfire may approach 1,800 degrees Fahrenheit, it is the duration of heat that is more critical.

For an example, a blow torch flame typically approaches 2,100 d egrees
Fahrenheit,
yet a person can easily pass their hand through the flame.

Heat duration only becomes
critical to a home with a wood exterior surface if the heat is allowed to remain for 30 -90 seconds.

Research scientist Jack Cohen of the United States Forest Service has found that a home's or structures
characteristics
(it
s exterior materials and design

in relation to the immediate area around
a home within 100 feet) principally determine the home’s ignition potential. He calls the home and its
immediate surroundings the
‘
home ignition zone
’.

In a study of ignition of wood wallboard,
tests by a USDA Forest Service research team described in the Proceedings, 1st International Fire and Materials Conference showed that flame
impingement
for sufficient length of time
(approximately 1 min
.
) ignites a typical hardboard siding ma
terial.

Fire agencies consider
fuel treatment

as a principal approach to wildland fire hazard reduct
ion.

Whenever the flame length
is equal to or more than the separation of c
ombustible vegetation
from a combustible structure
for 1-
2 minutes in duration or more
, there is a high probability of
structure ignition. Contact with a fire's convection heat column also may cause ignition but the temperature of the column’s gases is generally not hot enough or long enough in duration
to sustain the ignition of the structure.

Comparing the expected
wildland fire behavior projections
for all boundary areas against the
required fuel modifica
tion zones
, and mitigation measures

outlined in

Section 6
.0, demonstrates
substantial reductions in the expected fla
me length
in treated fuels
.

By requiring the structures
exposed to the threat of wildfire to incorporate the following guidelines, those structures will be provided with the most effective treatment for minimizing losses from flame impingement
and associated radiant heat intensities.
• The
structure is constructed of ignition resistant building materials .
• The area surrounding structure contains an Irrigated Zone (defensible space) and a Thinning Zone (low fuel volume buffer strip) between the Irrigated Z
one and the untreated
fuels.

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 19

The property owner shall be required (see Section 6.0) to maintain the properties to Zone 1 / Zone 2 Fuel Modification
standards and shall keep the roof and any rain gutters free of leaves, needles and other combustible debris.

All combustible materials must be properly stored away from each structure so that burning embers falling on or near the structure have no suitab
le host.

By requiring the structure
s to be
constructed of non-combustible roofing, ignition resistant building materials, and the implementation
of required fuel modification will be the most effective treatment for minimizing structure losses due to the projected flame lengths and associated radiant heat intensities.

4.3 Fire Resistant Plant Palette
W
ildland fire research has shown that some types of plants, including

many natives, are more fire
resistant than others.

T
hese low fuel volume, non
-
oily, non
-
resinous plants
are
commonly refered
to as “fire resistant”. This term comes with the proviso that each year these plants are pruned, all dead wood is removed and all grasses or other plant material are removed from beneath the circumference
of their canopies. Some native species are not considered “undesirable” from a wildfire risk management perspective provided they are properly maintained year round.

Refer to
APPENDIX ‘A’ for a list of prohibited plant species and APPENDIX ‘B’ for Defensible Space Landscaping
.

5.0 Fire Department Response Times
The project is within the Riverside City Fire Department’s (RCFD) response area. The closest Fire apparatus
is RCFD
Riverside City Fire Station 4,
from
1496 W Linden St
(2.8 miles away).

Would likely
be the first engine to arrive
on scene at to the structure.

Additional agencies such as Riverside County and nearby cities would also likely respond equipment should all
of Riverside City Resources be
unavailable.

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 20

Although the RCFD Fire Station #4 engine
may be generally
8 m
inutes away, there is

no assurance
that any of the engine companies will be in their stations when a wildfire threatens. Engines may respond from other stations located further away or from other incidents. On high/extreme
fire
danger days there often may be multiple fire starts and engine companies may be already deployed on other incidents.

•
This is why planned projects u
se “
defensible space
”, ‘
Ignition Resistant
’
building features,
and key fuel treatment strategies that enable
residents
to substantially increase their ability
to survive a wildfire on their own and without the loss of any structure. The goal of this FPP
, therefore, is to make the
future residences and its owners
,
as safe as possible and able
to survive on their own until firefighting equipment arrives and/or the occupants can be safely evacuated.

6.0 VEGETATION MANAGEMENT ZONE DESCRIPTIONS & REQUIRED

TREATMENTS

• Note: Landscaping elements will be coordinated with the Case Planner through “Landscape and Irrigation Design Review”.

Below are the descriptions and required treatments for the Vegetation Management Zones.

All distances
in this report are measured horizontall
y.

These distances are depicted on the attached Fire Protection Plan Exhibit.

Zones 1 and 2 encompasses 100 feet which will ensure no radiant heat will reach the structure.

Properties
to the
west required fuel treatment areas
will
tie into proposed Zones in that area. This will offer some buffer from on shore wind relate fire eve
nts.

As note prior the extremely
rocky
landscape will
assist in
breaking up the fuel bed into more compartmentalized fuel areas.

Below are the descriptions and required treatments for
the Fuel
Modification Zones.

All distances
in this report are measured horizontally from the exterior of each structure. These distances are depicted on the
enclosed
Fire Protection Plan
Map.

Fuel treatment
areas are a mix of irrigate areas
and dry thinning areas.

The owner

will be
responsible for maintaining Fuel M
odific
ation Zone.

In the event
of
repossession,
the person/unit/agency holding title to the
project

will be responsible for the maintenance.

All
highly
flammable
plant
species
identified
in
Appendix
A shall be
permanently
removed
from the

Irrigated

Zone 1 and T
hinning
Zone 2
due to their susceptibility to wildland fire.

6.1 Irrigated Zone 1 -
Vegetation
Management
Zone 0/1 Irrigated -

HOMEOWNER

MAINTAINED
50 feet
Zone 0
Homeowner
maintained
Irrigated - An area starting at the structure envelope extending 5 feet outward. This
zone includes
the area under and around all attached decks, and
requires the most
stringent
wildfire fuel reduction. This area shall be kept clear of combustibles,
landscaping
mulch, and any large
shrubs and trees. It may have limited plants that are low growing, nonwoody,
properly watered and
maintained.

Combustible fencing material shall not be attached to the structure.

Defined
Irrigated Zone 1 is commonly called the defensible space zone and shall be free of all combustible construction
and materials.

It includes the entire
area around the structure (front,
back and side) and that is located within the parcel. It is measured from the exterior wall of each s
tructure or from the most distal

point of a combustible projection, an attached accessory CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 21

structure, or an accessory structure within 10 feet of
a s
tructure. It provides the best protection
against the high radiant heat produced by wildfire. It also provides a generally open area in which fire suppression forces can operate during wildfire events. This zone includes a level or
level-gr
aded area around
each structure
, primarily used for parking
.

Required Landscaping
•
Plants in this zone
shall
be fire resistant and shall not include any pyrophytes that are high in oils and resins such as pines, eucalyptus, cedar, cypress or juniper species. Thick, succulent or leathery leaf species with high moisture content are the most ‘fire resistant’.

Refer to APPENDIX ‘A’ for the Prohibited Plant list.
•
Zone 1
shall
be cleared of all
fire prone and
prohibited
plant species
(see APPENDIX ‘A’).
• Landscape
designs using
hardscape features
such as
driveways, swimming pools,
concrete,
rock, pavers, and similar non
-
combustible features
to break u
p fuel continuity within Zone
1 are encouraged
.
•
All Landscaping will be fire resistive.

Landscaping elements will b
e coordinated with the
Case Planner through Landscape and Irrigation Design Review.

Required Maintenance
•
Maintenance
shall be year round by the
owner
as required by this
FPP or the RCFD.
•
Remove and replace any dead or dying plant material monthly. •
Native annual and perennial grasses will be allowed to grow and produce seed during the winter and spring. As grasses begin to cure (dry out), they shall be cut to four inches or less in height.
• Trees shall be maintained to a minimum of six feet of vertical separation from low growing, irrigated vegetation beneath the canopy of each tree.

All trees must be maintained to the current ANSI A300 standards [Tree, Shrub, and Other Woody Plant
Maintenance
—Standard Practices (Pruning)] (see
(
http://tcia.org/business/ansi
-a300-standards).

6.2 Vegetation
Management
Non Irrigated
–

MAINTAINED
by OWNER
Defined

THINNING ZONE
, is an area
following Zone 1
and
extends outward to 100 feet or the PL.

Distances
is less than 100feet on east side of project site
.

The first 20 feet
closest to Zone 1
shall be kept clear of
any shrub plantings and trees
,
maintained
as grass land
weed whipped or mowed to 4 inches
.

The
area following this 20
-foot
band may include single or small clusters of trimmed fire resistance native plants up to
36 inches in height
where 50% of the vegetation is removed.

Selected native plant
clusters must be separated by at least 1 1/2 times th
e mature height of the retained plants.

The ground
cover and grasses
shall be weed whipped and maintained to 4" or less in stubble height.

Required Maintenance
• Fuel
Modification
area shall be maintained year, as required by this FPP.

Inspections
and
compliance shall be by
Riverside City.
•
Shrubs shall be kept trimmed to ensure spacing is maintianed. •
Grasses shall be maintained weed whipped to 4 inches.
•
The area shall be maintained free of invasive plants and any volunteer native shru bs.
•
All plantings should be installed with at maturity growth in mind.

CITY OF RIVERSIDE FIRE DEPT.

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FPP_ Landeros ResidenceV2.5_29Aug22 Page | 22

• The image below provides a best practice spacing guide for construction
and long-term
maintenance.

Figure 9 Plant Spacing

CITY OF RIVERSIDE FIRE DEPT.

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7 .0 Con
struction Standards
T
he Landeros Residence and ADU sh
all be considered t
o be within a Ver
y High Fire Hazard
Sev
erity Zone (VHFHSZ) a
nd shall be
designed and b
uilt-in a
ccordance with Chapter 7A
(Ma
terials and Construction Methods for Exterior Wildfire Exposure) of the 2019 California B
uilding Code. To
include loca
l code amendments. F
or a description of the current construction
r
equirements as of the date of this report see APPENDIX ‘D’. • Al
l construction and ignition resistant requirements shall m eet the 2019 version of the
Ca
lifornia Fir
e Code,
including amendments, a
nd r
elated Ordinances.

The fire protection
f
eatures described herein shall be maintained to t
heir equivalent or
greater ignition
r
esistance in perpetuity.

Con
struction o
r building permits shall not be issued until the fire code official inspects and a
pproves required fire apparatus access and water supply for the construction site. 7 .1 Conditions To Be Met
Pr
ior to the delivery of combustible building co
nstruction m
aterials to the project site the
f
ollowing conditions shall be completed to the satisifaction of the R CFD:
• Water and power utilities shall be installed and approved by the appropriate inspecting dep
artment or agency.
• Z
one 1 sh
all be cleared of all vegetation prior to construction and subsequently planted to t
he r
equirments stated in Section 6.1 a
fter construction is completed.
7 .2 A
dditional Construction Requirements
Ad
equate irrigated space exists to provide a level of safety i n regard to radiant heat.

An automatic fire sprinkler system is required by City Ordinance 16.32.080. Under separate cover, submit plans for the automatic fire sprinkler system(s) and obtain approval from the F
ire Department prior to installation.
7 .3 A
pplication for Alternate Ma
terials and Me
thods. (AMMR) and Proposed mitigation
m
easures and mandatory requirement.

Th
ese measures are formally captured in the
AM&M Application Appendix E.
1) 6- f
t tall masonry wall as designated on the attached exhibit along the ea stern PL to
protect the
structures from, convected/radiant heat and blowing ground embers. 2 ) A 2- h
our exterior rated wall assembly for those surfaces facing the reduced Fuel M
odif
ication Area
C
ITY OF RIVERSIDE FIRE DEPT.

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FPP_ Landeros ResidenceV2.5_29Aug22 Page | 24

8.0 O
wner, Occupant/Employee Education
The owner should prepare, that in the event of a wildland fire, they should always relocate to a safe area well beyond the path of the threatening wildland fire. If relocation is not possible and egress is cut-off by the fire, they
sh
ould seek shelter within t
hier structure until the wildland fire
passes through their area. The ignition resistant buildings will have a ‘defensible space’ area around each structure for firefighters to make their stand in the protection of each structure. In the event firefighting forces are not readily available, the defensible space will substantially i
ncrease the probability of ‘st
ructure survivability’.

S
hould r
elocation be the the chosen option a
nd time is available, t
hey should ensure that all doors
a
nd windows are closed to prevent embers
from entering their structure.

Doors should be unlocked
t
o allow emergency personnel unimpeded access.

Both inside and outside lights should be placed
on
to allow emergency personnel to know that a s
tructure i
s present when smoke or
darkness m
ay
otherwi
se obscure visibility. I
n addition,
combustible materials
shall not be stored within 10 f
eet
of
any structure.

T
he owner sh
all be aware of the herein described fire protection measures by reviewing this FPP o
f the types of non-combustible con
struction a
nd plant materials that are allowed within the the
designated fuel treatment zones. A copy of this plan shall be provided to a future owner during escrow procedures. Of particular importance are
APP
ENDICES ‘A
’, ‘B’, and ‘D’ of this plan
which provide guidance in the types of plants that allowed to be est ablished i
n landscaped areas
CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi

FIRE
WISE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 25

and
appropriate
construction materials within fuel
modification
zones. Plant selection is critical
as embers often travel over a mile during Santa Ana wind events.

Where this
FPP
requires specific construction features, these features shall not be changed without the approval of the
RFD.

These features are required to maintain reasonable fire safety. 9 .0 Infrastructure
Below is a review and discussion of water sup
ply and access roads/driveways and gates that are to
be utilized in the development.

9.1 Water Supply
The water supply will be provided by Riverside Public Utilities. An approved permanent water supply capable of supplying the required fire flow will be designed and installed prior to beginning construction.

Water supplies for fire protection and hydrants shall be in accordance with the 2019 California
Fire Code
as amended by the City
of Riverside.

Hydrant
installation shall conform to City of
Riverside
INFORMATION BULLETIN: D
-19-
005 and the 2019 NFPA 14, Fi
re hydrants shall be tested, accepted and placed in service prior to the delivery of any combustible materials

to the project site
.

9.2 Access Roads/Driveways and Gates
There shall be one access into the project. Access will be via Mt Vernon Ave, with a fire department turnaround on property.

D
riveways and access roads within the
development

shall be termed
‘
Fire Access Roads
’
within this document.

All fire access roads shall meet the

requirements of the
R
iverside City
Fire Depaertment
, and shall be all weather surface capable of supporting loads of 80,000 lbs
gross vehicle weight.

Unless otherwise approved by the
RCFD
Fire Marshal, the grade of a fire apparatus access
road shall not exceed 16 percent and the cross slope shall not exce ed 2.5 percent.

Access to all
exterior portions of
each structure
must be within 1
5 0 feet of the available fire
depart
ment access.

The required turning radius of a fire apparatus access road shall be in
accordance with Information Bulletin B
-19-001, 28 f
eet inside radius and 48 feet outside
radius.
in accordance with Information Bulletin B
-19-001
unless otherwise approved by the
fire code official
.

Fire lanes shall be marked in accordance with the guidelines in Information Bulletin B
-19-003.

Any
gates to be installe
d shall meet
RCFD Standards
and shall be approved by the
RCFD prior
to fabrication and installation.

A Knox override key switch or similar device must be installed outside the gate in
an approved, readily visible, and unobstructed loca
tion at or near the gate
to provide emergency access. Gates accessing major roadways shall also be equipped with approved emergency traffic control
-
activating strobe light sensor(s), or other devices approved by the Fire
Chief, which will activate the gat
e on the approach of emergency apparatus with a
battery back-up or manual mechanical disconnect in case of power failure. All gates shall always be equipped to allow for automatic egress
.

CITY OF RIVERSIDE FIRE DEPT.

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SE2000, LLC
FPP_ Landeros ResidenceV2.5_29Aug22 Page | 26

10.0 F
ire Protection Plan M
ap
Attached in a separate file is the Fire Protection Plan Map depicting the location of all proposed fuel treatment l
ocations as well as fire access roads, and development bundaries.

PPENDICES
P
rohibited Plant List
APPENDIX ‘A’
De
fensible Spa
ce Landscaping
APPENDIX ‘B’
L
iterature Referenced
APPENDIX ‘C’
I
gnition Resistant Construction Requirements
APPENDIX ‘D’
A
M&M Application
APPENDIX ‘E’
F
uel Treatment Exhibit with Access Plan
APPENDIX ‘F’
CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIREWI
SE2000, LLC A

PPENDIX

PAGE LEFT I

NTENTIONALLY B
LANK
CITY OF RIVERSIDE FIRE DEPT.

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PPENDIX
APPENDIX ‘A’
P
rohibited Plant List
C
ITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC

APPENDIX

APPENDIX ‘A’
Prohibited (&
Fire Prone) Plant Species List
For Fuel Modification Zones in High & Very High Hazard Areas Botanical Name
Common Name
Plant Form

1. Acacia species
• Acacia Shrub/Tree

2. Adenostema fasciculatum
Chamise Shrub

3. Adenostema sparsifolium
Red Shank Shrub/Tree

4. Artemisia californica
California Sagebrush
Shrub

5. Anthemis cotula
Mayweed Weed

6. Arundo donax
Giant reed Grass/weed

7. Brassica nigra
Black Mustard
Weed

8. Brassica ropa
Yellow Mustard
Weed

9. Cedrus species
Cedar Tree

10. Cirsim vulgare
Wild Artichoke
Weed

11. Conyza canadensis
Horseweed Weed

12. Cortaderia selloana
Pampas Grass
Tall Grass

13. Cupressus species
Cypress Tree

14. Eriogonum fasciculatum
Common Buckwheat
Shrub

15. Eucalyptus species
Eucalyptus Shrub/Tree

16. Heterotheca grandiflora
Telegraph plant
Weed/shrub

17. Juniperus species
Junipers Succulent

18. Lactuca serriola
Prickly lettuce
Weed

19. Nicotiana bigelevil
Indian tobacco
Shrub

20. Nicotiana glauca
Tree tobacco
Shrub

21. Pennisetum species
Fountain Grass
Ground cover

22. Pinus species Pines Tree

23. Rosmarinus species
Rosemary Shrub

24. Salvia species
• • Sage Shrub

25. Silybum marianum
Milk thistle Weed

26. Urtica urens
Burning nettle
Weed
• Except:

Acacia redolens desert carpet (Desert Carpet ground cover) • • Except:

Salvia columbariae (chia)

Salvia sonomensis (Creeping Sage)
CITY OF RIVERSIDE FIRE DEPT.

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SE2000, LLC A

PPENDIX
A
dditionally, all of the following plants shall be removed from f
uel treatment zones in order to not only reduce fuel loading but a
lso eliminate invasive plants that are identified in the Multiple S
pecies Habitat Conservation Plan for Riverside County
(
MSHCP).

T
ABLE 6-2
P

LANTS THAT SHOULD BE AVOIDED
A

DJACENT TO THE MSHCP CONSERVATION AREA
BO

TANICAL NAME C OMMON NAME
A
cacia spp. (all species) a cacia
A
chillea millefolium v ar. millefolium common yarrow
A
ilanthus altissima t ree of heaven
A
ptenia cordifolia r ed apple
A
rctotheca calendula c ape weed
A
rctotis spp. (all species & hybrids) A frican daisy
A
rundo donax g iant reed or arundo grass
A
sphodelus fistulosus a sphodel
A
triplex glauca w hite saltbush
A
triplex semibaccata A ustralian saltbush
C
arex spp. (all species*) s edge
C
arpobrotus chilensis i ce plant
C
arpobrotus edulis s ea fig
C
entranthus ruber r ed valerian
C
hrysanthemum coronarium a nnual chrysanthemum
C
istus ladanifer ( incl. hybrids/varieties) gum
r
ockrose
C
ortaderia jubata [syn.C.

A
tacamensis] j ubata grass, pampas grass
C
ortaderia dioica [syn. C.
s
ellowana] p ampas grass
C
otoneaster spp. (all species) c otoneaster
C
ynodon dactylon ( incl. hybrids varieties) Bermuda
g
rass
C
yperus spp. (all species*) n utsedge, umbrella plant
C
ytisus spp. (all species) br oom
CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC

APPENDIX

Delosperma ‘ Alba' white trailing ice plant
Dimorphotheca spp. (all species) African daisy, Cape marigold Drosanthemum floribundum rosea ice plant
Drosanthemum hispidum purple ice plant
Eichhornia crassipes water hyacinth
Elaegnus angustifolia Russian olive
Eucalyptus spp. (all species) eucalyptus or gum tree
Eupatorium coelestinum [syn.

Ageratina sp.] mist flower
Festuca arundinacea tall fescue
Festuca rubra creeping red fescue
Foeniculum vulgare sweet fennel
Fraxinus uhdei (and cultivars) evergreen ash,
shamel ash
Gaura (spp.) (all species) gaura
Gazania spp. (all species & hybrids) gazania
Genista spp. (all species) broom
Hedera canariensis Algerian ivy
Hedera helix English ivy
Hypericum spp. (all species) St. John's Wort
Ipomoea acuminata Mexican morning glory
Lampranthus spectabilis trailing ice plant
Lantana camara common garden lantana
Lantana montevidensis [syn. L.
sellowiana] lantana
Limonium perezii sea lavender
Linaria bipartita toadflax
Lolium multiflorum Italian ryegrass
Lolium perenne perennial ryegrass
Lonicera japonica (incl. ‘Halliana') Japanese
honeysuckle
Lotus corniculatus birdsfoot trefoil
Lupinus arboreus yellow bush lupine
Lupinus texanus Texas blue bonnets
CITY OF RIVERSIDE FIRE DEPT.

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SE2000, LLC A

PPENDIX
M
alephora crocea i ce plant
M
alephora luteola i ce plant
M
esembryanthemum nodiflorum l ittle ice plant
M
yoporum laetum m yoporum
M
yoporum pacificum s hiny myoproum
M
yoporum parvifolium ( incl. ‘Prostratum') ground cover
m
yoporum
O
enothera berlandieri Me xican evening primrose
O
lea europea E uropean olive tree
O
puntia ficus-indica I ndian fig
O
steospermum spp. (all species) t railing African daisy, African d
aisy,
O
xalis pes-caprae Be rmuda buttercup
P
arkinsonia aculeata Me xican palo verde
P
ennisetum clandestinum K ikuyu grass
P
ennisetum setaceum f ountain grass
P
hoenix canariensis C anary Island date palm
P
hoenix dactylifera d ate palm
P
lumbago auriculata c ape plumbago
P
olygonum spp. (all species) k notweed
P
opulus nigra ‘ italica ' Lombardy poplar
P
rosopis spp. (all species*) m esquite
R
icinus communis c astorbean
R
obinia pseudoacacia bl ack locust
R
ubus procerus Hi malayan blackberry
S
apium sebiferum C hinese tallow tree
S
aponaria officinalis bo uncing bet, soapwart
S
chinus molle P eruvian pepper tree, California
p
epper
S
chinus terebinthifolius Br azilian pepper tree
S
partium junceum Sp anish broom
T
amarix spp. (all species) t amarisk, salt cedar
T
rifolium tragiferum s trawberry clover
T
ropaelolum majus g arden nasturtium
CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC

APPENDIX

Ulex europaeus prickly broom
Vinca major periwinkle
Yucca gloriosa Spanish dagger
An asterisk (*) indicates some native species of the genera exist that may be appropriate.

Sources: California Exotic Pest Plant Council, United States Department of Agriculture-Division
of Plant Health and Pest Prevention Services, California Native Plant Society,
Fremontia Vol. 26 No. 4, October 1998, The Jepson Manual; Higher Plants of California,
and County of San Diego-Department of Agriculture.

CITY OF RIVERSIDE FIRE DEPT.

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APPENDIX

APPENDIX ‘B’
Defensible Space Landscaping

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APPENDIX

CITY OF RIVERSIDE FIRE DEPT.

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PPENDIX
CITY OF RIVERSIDE FIRE DEPT.

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PPENDIX
CITY OF RIVERSIDE FIRE DEPT.

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APPENDIX

CITY OF RIVERSIDE FIRE DEPT.

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APPENDIX

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APPENDIX

CITY OF RIVERSIDE FIRE DEPT.

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APPENDIX

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC

APPENDIX

APPENDIX ‘C’
Literature References
Literature References

1. Standard Fire Behavior Fuel Models: A Comprehensive Set f or Use with Rothermel’s Surf ace Fire Spread Model,
General Technical Report RMRS
-GTR-153. June 2005.

Joe H. Scott, Robert E. Burgan, United
States
Department of Agriculture
-
Forest Service, Rocky Mountain Research Station, Missoula, Montana.

2. BEHAVEPlus: Fire Modeling System, version 5.0.5: Variables.

General Technical Report RMRS
-GTR-
213WWW Revised.

September 2009.

Patricia L. Andrews, United St
ates Department of Agriculture
-
Forest Service, Rocky Mountain Research Station, Missoula, Montana.

3. BEHAVEPlus Fire Modeling System, Version 5.0.0

General Technical Report RMRS
-GRT-106WWW
Revised. June 2008. Patricia L. Andrews, Collin D. Bevins and Robe rt C. Seli.

United States Department of
Agriculture -
Forest Service, Rocky Mountain Research Station, Missoula, Montana.

4. BEHAV EPlus Fire Modeling System, V ersion 5.0 User’s Guide.

General Technical Report RMRS
-GRT-
106WWW Revised. July, 2009. Patricia
L. Andrews, Collin D. Bevins, Robert C. Seli.

United States
Department of Agriculture
-
Forest Service, Rocky Mountain Research Station, Missoula, Montana.

5. The 2019
California Fire Code
Chapter 49

6. The 2019
California Fire Code
with Local Amendments

7. The 2019
California Residential Code, Section R337.

8. Chapter 7A-
California of the 201
9 Building Code

9. National Fire Protection Association
-
NFPA 13 Standard for the Installation of Sprinkler Systems in One –
and Two-
Family Dwellings and
Manufactured Homes, 13
-R &13-D, 2019 Editions

10. National Fire Protection Association
- NFPA 1144
Standard for Reducing Structure Ignition Hazards from
Wildfire (2018).

11. National Fire Protection Association
-
NFPA 1142, 2012 Edition.

Table C.11 (b) Time
-Distance Table
Using an Average Speed of 35 mph

12. The California State and Local Responsibility Area Fire Hazard Severity Zone Map –
Fire and Resource
Assessment Program of CAL FIRE
15 . Western Region Climate Center.

Historic Climate Data from
Remote Automated Weather Stations.

RAWS
USA Climate Archive.

Reno, NV.

Data for all Remote Automated Weather Stations
is available at:
http://www.raws.dri.edu/index.html
CITY OF RIVERSIDE FIRE DEPT.

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SE2000, LLC A

PPENDIX
APPENDIX ‘D’
I
gnition Resistant Construction
V
inyl windows and other Architectural features must meet California Building Code chapter 7 A requirement and must be approved by Ci
ty of Riverside Bu
ilding and Safety plan check
e
ngineer
Th
e following is a summary of the current requirements for ignition r esistant construction for high
f
ire hazard areas under Chapter 7A of the California Building Code (CBC) 2019 edition. H owever
t
he requirements listed below are not all inclusive and all exterior building construction including r
oofs, eaves, exterior walls, d
oors, windows, decks, and other attachments m
ust meet the current
CBC Chapter 7A ignition resistance r
equirements, t
he California Fire Code, and any additional
County and/or City codes in effect at the time of building permit application. See the currrent a
pplicable codes for a detailed description of these requirements and any exceptions.

1. A
ll structures will be built with a Class A Roof Assembly and shall comply with the r
equirements of C
hapter 7A and Chapter 15 of
the California Fire Code. Roofs shall have
a r
oofing assembly installed in accordance with its listing and the manufacturer’s i
nstallation instructions.
2 . R
oof valley flashings sh
all be not less than 0.019-i
nch (0.48 mm) No. 26 gage galvanized
sh
eet corrosion-r
esistant metal installed over not less than one layer of minimum 72 pound (3

2.4 kg) mineral-su
rfaced nonperforated cap sheet complying with ASTM D3909, at least 36-i
nch-wide (9
14 mm) running the full length of the valley.

3. A
ttic or foundation ventilation louvers or ventilation openings in vertical walls shall be covered with a minimum of 1/16-inch and shall not exceed 1/8-inch mesh corrosion- r
esistant metal screening or other a
pproved material that offers equivalent protection.

4. Where the roof profile allows a space between the roof covering and roof decking, t
he spaces sh
all be constructed to resist the intrusion of flames and embers, be firestopped with approved materials or have one layer of a minimum 72 pound (32.4 kg) mineral- s
urfaced nonperforated cap sheet complying with ASTM D3909 installed over the com
bustible decking.

5. E
nclosed roof eaves and roof eave soffits with a horizontal underside, sloping rafter tails wi
th an exterior covering applied to the under-si
de of the rafter tails, shall be pro
tected by
on
e of the following:
• n
oncombustible m
aterial
• Ignition-r
esistant material
• O
ne layer of 5/8-i
nch Type X gypsum sheathing applied behind an e
xterior
covering on
the underside of the rafter tails or soffit
• Th
e exterior portion of a 1-h
our fire resistive e
xterior wall a
ssembly applied to the
u
nderside of the rafter tails or soffit including assemblies using the C
ITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC

APPENDIX

gypsum panel
and sheathing products listed in the Gypsum Association Fire
Resistance
Design Manual
• Boxed-in
roof eave soffit

assemblies with a horizontal underside that meet the
performance criteria in Section
707A.10
when tested in accordance with the test
procedures set forth in ASTM E2957.
• Boxed-in
roof eave soffit

assemblies with a horizontal underside that meet the
performance criteria in accordance with the test procedures set forth in SFM Standard 12-7A-3.

Exceptions
: The following materials do not require protection:

1. Gable end overhangs and roof assembly projections beyond an exterior wall other than at the lower end of the rafter tails.

2. Fascia and other architectural trim boards.

6. The exposed roof deck on
the underside of unenclosed roof eaves shall consist of one of the following:
•
Noncombustible material, or
• Ignition-
resistant material, or
•
One layer of 5/8
-
inch Type X gypsum sheathing applied behind an exterior covering on the underside exterior of the roo
f deck, or
•
The exterior portion of a 1
-
hour fire resistive exterior wall assembly applied to the underside of the roof deck designed for exterior fire exposure including assemblies using the gypsum panel and sheathing products listed in the Gypsum Associat
ion fire Resistance Design Manual.

Exceptions
: The following materials do not require protection:

1. Solid wood rafter tails on the exposed underside of open roof eaves having a minimum nominal dimension of 2 inch (50.8 mm).

2. Solid wood blocking installe
d between rafter tails on the exposed underside of
open roof eaves having a minimum nominal dimension of 2 inch (50.8 mm).

3. Gable end overhangs and roof assembly projections beyond an exterior wall other than at the lower end of the rafter tails.

4. Fasc
ia and other architectural trim boards.

7. Vents - ventilation openings for enclosed attics, enclosed eave soffit spaces, enclosed rafter spaces
formed where ceilings are applied directly to the underside of roof rafters, and underfloor ventilation openings shall be fully covered with metal wire mesh, vents, other materials or other devices that meet one of the following requirements:

Vents listed to ASTM E2886 and complying with all the following:
i.

There shall be no flaming ignition of the cotton material during the Ember Intrusion Test.
ii.

There shall be no flaming ignition during the Integrity Test portion of the Flame Intrusion Test.
iii. T
he maximum temperature of the unexposed side of the vent shall not exceed 662°F (350°C).

Vents shall comply with all of the following:
i. The dimensions
of the openings therein shall be a minimum of
1/16-inch (1.6
mm) and shall not exceed
1/8-
inch (3.2 mm).
ii.

The materials used shall be

noncombustible
.

Exception:

Vents located under the
roof covering
, along the ridge of roofs,
CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIREWI
SE2000, LLC A

PPENDIX
wi
th the exposed surface of the vent covered by n
oncombustible w
ire mesh,
m
ay be of combustible materials.
i
ii. Th
e materials used shall be cor
rosion resistant.
8 . Ven
ts shall not be installed on the underside of eaves and cornices.

E
xceptions:

1. Ven
ts listed to ASTM E2886 and complying with all the following:
• Th
ere shall be no flaming ignition of the cotton material during the Ember I
ntrusion Test.
• Th
ere shall be no flaming ignition during the Integrity Test portion of the Flame I
ntrusion Test.
• Th
e maximum temperature of the unexposed side of the vent shall not exceed 662°F
(350°C).
2 . Th
e enforcing agency shall be permitted to accept or approv e special eave and cornice
v
ents that resist the intrusion of flame and burning embers.

3. V
ents complying with the r
equirements o
f Section 706A.2 shall be permitted to be
installed on the underside of eaves and cornices in accordance with either one of the f
ollowing conditions:
3 .1. The attic space being ventilated is fully protected by an automatic sprinkler system installed in accordance with Section 903.3.1.1 or, 3 .2. The exterior wall covering a
nd exposed underside of the eave are of
n
oncombustible materials, or ignition-r
esistant materials, as determined in accordance
wi
th SFM Standard 12-7
A-5 Ignition-R
esistant Material and the requirements

9. A
ll chimney, flue or stovepipe openings that will burn solid wood will have an approved spark arrester. An approved spark arrester is defined as a device constructed of n
onflammable m
aterials, having a heat and corrosion resistance equivalent to 12-gauge wire, 19-game galvanized steel or 24-gage stainless steel. or other material found sa
tisfactory by the Fire Protection District, having ½-i
nch perforations for arresting burning
ca
rbon or sparks nor block spheres having a diameter less than 3/8 inch (9.55 mm).

It shall
b
e installed to be visible for the purposes of inspection and m aintenance a
nd removeable
t
o allow for cleaning of the chimney flue.

10.A
ll residential structures will have automatic interior fire sprinklers i nstalled according to
t
he National Fire Protection Association (NFPA) 13D 2019 edition - Standard for the Installation of Sprinkler Sys
tems in One and Two-family Dwellings and M
anufactured
Homes. F
ire sprinklers are not required in unattached non-h
abitable structures greater than
5 0 feet from the residence.
11 .The exterior wall covering or wall assembly shall comply with one of the following r
equirements:
• Non
combustible material, or
• I
gnition resistant material, or
• Hea
vy timber exterior wall assembly, or
• Log
wall construction assembly, or
• W
all assemblies that have been tested in a
ccordance w
ith the test p
rocedures f
or a 10-
mi
nute direct flame contact expose test set forth in ASTM E2707 with the conditions of a
cceptance shown in Section 707A.3.1 of the California Building Code, or C
ITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC

APPENDIX

• Wall assemblies that meet the
performance
criteria in accordance with the test
procedures for a 10
-
minute direct flame contact exposure test set forth in SFM Standard 12-7A-1.

Exception: Any of the following shall be deemed to meet the assembly performance criteria and intent of this section including;
• One layer of 5/8-inch Type X gypsum sheathing applied behind the exterior covering or cladding on the exterior side of the framing, or • The exterior portion of a 1-hour fire resistive exterior wall assembly designed for exterior fire exposure including assemblies using the gypsum panel and sheathing products listed in the Gypsum Associate Fire Resistance Design Manual.

12. Exterior walls shall e
xtend from the top of the foundation to the roof and terminate at 2 -inch
nominal solid blocking between rafters at all roof overhangs, or in the case of enclosed eaves, terminate at the enclosure.

13. Gutters shall be provided with the means to prevent the accumulation of leaf litter and debris within the gutter that contribute to roof edge ignition.

14. No attic ventilation openings or ventilation louvers shall be permitted in soffits, in eave overhangs, between rafters at eaves, or in other overhanging areas.

15. All projections (exterior balconies, decks, patio covers, unenclosed roofs and floors, and similar
architectural
appendages and projections) or structures less than five feet from a building shall be of non-combustible material, one-hour fire resistive construction on the underside, heavy timber construction or pressure
-
treated exterior fire
-
retardant wood. When
such appendages and projections are attached to exterior fire-resistive walls, they shall be constructed to maintain same fire
-
resistant standards
as the exterior walls of the structure.

16. Deck Surfaces shall be constructed with one of the following materials:
•
Material that complies with the performance requirements of Section
709A.4
when tested in accordance with both ASTM

E2632 and ASTM E2726, or
• Ignition-
resistant material

that complies with the performance req
uirements
of 704A.3
when tested in accordance with ASTM E84 or UL 723, or
•
Material that complies with the performance requirements of both SFM Standard 12-7A-
4 and SFM Standard 12
-7A-5, or
•
Exterior fire retardant
treated wood, or
•
Noncombustible
material, or
• Any material that complies with the performance
requirements
of SFM Standard 12-
7A-4A when the attached exterior wall covering is also composed of
noncombustible
or ignition-
resistant material
.

17. A
ccessory structures attached to b
uildings with habitable spaces and projections shall be in accordance with the Building Code. When the attached structure is located and constructed so that the structure or any portion thereof projects over a descending slope surface greater than 10 perce
nt, the area below the structure shall have all underfloor areas and exterior wall construction in accordance with Chapter 7A of the Building Code.

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC

APPENDIX

18. Exterior windows, skylights and exterior glazed door assemblies shall comply with one of
the following req
uirements:
•
Be constructed of multiplane glazing with a minimum of one tempered pane meeting the requirements of Section 2406 Safety Glazing, or
•
Be constructed of glass block units, or
• Have a fire-
resistance rating

of not less than 20 minutes when tested according to
NFPA 257, or
•
Be tested to meet the performance requirements of SFM Standard 12 -7A-2.

19. All eaves, fascia and soffits will be enclosed (boxed) with non -
combustible materials. This
shall apply to the entire perimeter of each structure. Eaves of heavy timber construction are not required to be enclosed as long as attic venting is not installed in the eaves. For the purposes of this section, heavy timber construction shall consist of a minimum of 4x6 rafter ties and 2x decking.

20. Detached accessory buildings that are less than 120 square feet in floor area and are located more than 30 feet but less than 50 feet from an applicable building shall be constructed of
noncombustible
materials or of ignition-resistant materials as described in Section 704A.2
of the California
Building Code.

Exception: Accessory structures less than 120 square feet in floor area located at least 30 feet from a building containing a habitable space.

21. All rain gutters, down spouts and gutter hardware shall be constructed from metal or other noncombustible material to prevent wildfire ignition along eave assemblie s.

22. All side yard fence and gate assemblies (fences, gate and gate posts) when attached to the home shall be of non-
combustable
material. The first five feet of fences and other items attached to a structure shall be of non
-
combustible material.

23. Exterior garage doors shall resist the intrusion of embers from entering by preventing gaps between doors and door
openings, at
the bottom, sides and tops
of doors, from exceeding
1/8 inch. Gaps between doors and door openings shall be controlled by one of

the methods
listed in this section.
• Weather-
stripping products made of materials that:
(a) have been tested for tensile strength in accordance with ASTM D638 (Standard Test Method for Tensile Properties of Plastics) after exposure to ASTM G155 (Standard
Practice for Operating Xenon Arc Light Apparatus for Exposure of Non -
Metallic Materials) for a period of 2,000 hours, where the maximum allowable difference in tensile strength values between exposed and non -
exposed samples does
not exceed 10%; and (b) exh
ibit a V-
2 or better flammability rating when tested to
UL 94, Standard for Tests for Flammability of Plastic Materials for Parts in Devices and Appliances.
•
Door overlaps onto jambs and headers.
•
Garage door jambs and headers covered with metal flashing.

24. E
xterior doors shall comply with one of the following:

1. The exterior surface or cladding shall be of noncombustible material or,

2. The exterior surface or cladding shall be of ignition -
resistant material or,
CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIREWI
SE2000, LLC A

PPENDIX

3. The exterior door shall be constructed of sol
id core wood that complies with the
f
ollowing requirements:
3 .1. Stiles and rails shall not be less than 1-3
/8 inches thick.
3 .2. Panels shall not be less than 1-1
/4 inches thick, except for the exterior perimeter
of
the panel that shall be permitted to t
aper to a tongue not less than 3/8 inch thick.

4. The exterior door assembly shall have a fire-r
esistance rating of not less than 20
m
inutes when tested according to NFPA 252 or,

5. The exterior surface or cladding shall be tested to meet the performance r equirements
of
Section 707A.3.1 when tested in accordance with ASTM E2707 or,

6. The exterior surface or cladding shall be tested to meet the performance requirements of SF
M Standard 12-7A-1.

C
ITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIRE
WISE2000, LLC

APPENDIX

APPENDIX ‘E’

AM&M APPLICATION

CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi CITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi FIREWI
SE2000, LLC A

PPENDIX
APPENDIX ‘F’
Si
te Plan and Fuel Treatment Exhibit
C
ITY OF RIVERSIDE FIRE DEPT.

Engineer________________ Date_________12/07/22Smith Choi ATTACHMENT 4

APPLICANT PREPARED GRADING

EXCEPTION JUSTIFICATIONS

1. Will the strict application of the provisions of this title result in practical difficulties or unnecessary ha
rdships inconsistent with the general purpose and intent of Title 17 of the Riverside Municipal Code (Grading)?
Yes
, the fire code requires the driveway to be at least 20ft wide. The maximum allowable width of the driveway using title 17 is 15ft. Without the exemption the project does not pass the fire code requirements.

2. A
re there exceptional circumstances or conditions applicable to the property involved or the intended use or development of the property that do not apply generally to other properties in the same zone or neighborhood?
Yes, this project must meet additional fire code and city regulation because it is in a very high fire hazard zone. There are other properties that surround the proposed project, do not follow the same fire code or city regulations. The other properties are in the same zone, but do not require additional regulation because they are older units. Example, one of the neighboring properties is two stories building which is not allowed under Title 17. Some of the older properties do not require sprinkler systems, but this project will require sprinkler systems and additional actions.

3. W
ill the granting of a waiver be materially detrimental to the public welfare or injurious to the property or improvements in the some of neighborhood in which the property is located? No, if granted the project will not be materially detrimental to the public welfare of the neighborhood.

The project will not be injurious to the property or improvements of the neighborhood in which the property is located.

Riverside City CouncilNovember 28, 2023

Riverside City Council
November 28, 2023