DRAFT
Preliminary Fire Protection Plan
University Hills
JULY 2025
Prepared for:
ENCORE UNIVERSITY HILLS LLC
3333 Michelson Drive, #620
Irvine, California 92612
Contact: David Hardy,
Director of Forward Planning and Entitlements
Prepared by:
3600 Lime Street
Building 2
Riverside, California 92501
Printed on 30% post-consumer recycled material.
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Table of Contents
SECTION PAGE NO.
Acronyms and Abbreviations ............................................................................................................................................. v Executive Summary ......................................................................................................................................................... vii 1 Introduction .......................................................................................................................................................... 1
1.1 Intent ....................................................................................................................................................... 2
1.2 Applicable Codes and Existing Regulations .......................................................................................... 2
1.3 Project Summary .................................................................................................................................... 3
1.3.1 Location ..................................................................................................................................... 3
1.3.2 Project Description ................................................................................................................... 4 2 Project Site Risk Analysis .................................................................................................................................. 11
2.1 Field Assessment ................................................................................................................................ 11
2.2 Project Site Characteristics and Fire Environment ............................................................................ 11
2.2.1 Topography ............................................................................................................................. 12
2.2.2 Climate ................................................................................................................................... 12
2.2.3 Vegetation .............................................................................................................................. 13
2.2.4 Fire History ............................................................................................................................. 13
2.3 Analysis of Wildfire Risk from Adding New Development ................................................................. 14
2.4 Off-site Wildfire Impacts ...................................................................................................................... 19
2.4.1 Vegetation Management ....................................................................................................... 20
2.4.2 Firefighter Response ............................................................................................................. 21
2.4.3 Ignition Resistant and Noncombustible Construction ......................................................... 21
2.4.4 Shelter in Place Capability ..................................................................................................... 22
2.4.5 Wildfire Risk Awareness Education ...................................................................................... 24 3 Anticipated Fire Behavior ................................................................................................................................. 27
3.1 Fire Behavior Modeling ....................................................................................................................... 27
3.2 Fire Behavior Modeling Analysis ......................................................................................................... 27
3.3 Fire Behavior Modeling Results .......................................................................................................... 29
3.3.1 Existing Conditions................................................................................................................. 30
3.3.2 Post-Development Conditions ............................................................................................... 30
3.4 Project Area Fire Risk Assessment ..................................................................................................... 32 4 Emergency Response and Service ................................................................................................................... 35
4.1 Emergency Response Fire Facilities ................................................................................................... 35
4.1.1 Emergency Response Travel Time Coverage ....................................................................... 36
4.2 Estimated Calls and Demand for Service from the Project .............................................................. 38
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5 Fire Safety Requirements-Infrastructure, Building Ignition Resistance, and Defensible Space .................. 43
5.1 Fire Apparatus Access ......................................................................................................................... 43
5.1.1 Roads ...................................................................................................................................... 44
5.1.2 Gates ...................................................................................................................................... 46
5.1.3 Premises Identification .......................................................................................................... 47
5.1.4 Ongoing Infrastructure Maintenance.................................................................................... 48
5.1.5 Pre-Construction Requirements ............................................................................................ 48
5.2 Infrastructure and Fire Protection Systems ....................................................................................... 48
5.2.1 Water Supply .......................................................................................................................... 48
5.2.2 Hydrants ................................................................................................................................. 48
5.2.3 Automatic Fire Sprinkler Systems ......................................................................................... 48
5.3 Ignition Resistant Construction and Fire Protection Systems .......................................................... 49
5.4 Defensible Space and Vegetation Management ............................................................................... 50
5.4.1 San Bernardino County Fuel Modification Zone Standards and Defensible Space .......... 51
5.4.2 San Bernardino County Fuel Modification Zones ................................................................ 51
5.4.3 Ongoing Infrastructure and FMZ Maintenance .................................................................... 54
5.4.4 Construction Phase Vegetation Management ..................................................................... 54
5.5 Pre-Construction Defensible Space Requirements ........................................................................... 55 6 Wildfire Education Program .............................................................................................................................. 67
6.1 Recognition for Fire Safety and Maintaining Fire Insurance ............................................................ 67 7 Conclusion ......................................................................................................................................................... 69 8 List of Preparers ................................................................................................................................................ 73 9 References ........................................................................................................................................................ 75 TABLES
1 Fuel Models Used for Fire Behavior Modeling ................................................................................................ 28 2A Fuel Moisture and Wind Inputs ........................................................................................................................ 28 2B Fuel Moisture and Wind Inputs ........................................................................................................................ 28 3 Modeling Results for Existing Conditions ........................................................................................................ 30 4 Modeling Results for Post-Project Conditions ................................................................................................. 31 5 Fire Suppression Interpretation ....................................................................................................................... 32 6 Closest Responding SBCFPD Fire Station Summary ...................................................................................... 36 7 Project Emergency Response Analysis using Speed Limit Formula .............................................................. 37 8 Project Emergency Response Analysis using ISO Formula ............................................................................. 37 9 Calculated Call Volume (Conceptual Based on 1,050 residents) for Project Site ........................................ 39
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EXHIBITS
1 Example of “higher density” development. ..................................................................................................... 16 2 Example of “moderate density” development. ................................................................................................ 17 3 Example of “lower density” development. ....................................................................................................... 18
FIGURES
1 Fire Hazard Severity Zone .................................................................................................................................... 5 2 Project Location ................................................................................................................................................... 7 3 Proposed Site Plan ............................................................................................................................................... 9 4 BehavePlus Analysis Map ................................................................................................................................. 33 5 SBCFPD Fire Stations Map ............................................................................................................................... 41 6 View 1 Fuel Modification Plan — Parcel 1 ........................................................................................................ 57 6 View 2 Fuel Modification Plan — Parcel 1 ........................................................................................................ 59 6 View 3 Fuel Modification Plan — Parcel 1 ........................................................................................................ 61 6 View 4 Fuel Modification Plan — Parcel 1 ........................................................................................................ 63 6 View 5 Fuel Modification Plan — Parcel 1 ........................................................................................................ 65
APPENDICES
A Representative Photo Log
B Fire History Map
C BehavePlus Fire Behavior Modeling Summary
D Ignition-Resistant Construction Requirements
E Prohibited Plant List
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Acronyms and Abbreviations
Acronym and Abbreviation Definition
AMR American Medical Response
AMSL above mean sea level
APN Assessor’s Parcel Number
BOA Bill of Assurance
BTU British Thermal Unit
CAL FIRE California Department of Forestry and Fire Protection CBC California Building Code
CDI California Department of Insurance
CC&R Covenants, Conditions and Restrictions
CFC California Fire Code
CRC California Residential Code
SBCMWD San Bernardino County Municipal Water District
FAHJ Fire Authority Having Jurisdiction
FHSZ Fire Hazard Severity Zone
FMZ Fuel Modification Zone
FPP Fire Protection Plan
FRA Federal Responsibility Area
FRAP Fire and Resource Assessment Program
FS Fire Station
HOA Homeowners Association (HOA)
IBC International Building Code
ICEMA Inland Counties Emergency Medical Agency
IFC International Fire Code
IRC International Residential Code
I-215 Interstate 215
LRA Local Responsibility Area
MPH miles per hour
NFPA National Fire Protection Association
PRC Public Resources Code
Project University Hills
SBCFPD San Bernardino County Fire Protection District
SRA State Responsibility Area
VHFHSZ Very High Fire Hazard Severity Zone
WUI Wildland Urban Interface
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Executive Summary
This Preliminary Fire Protection Plan (FPP) has been prepared for the University Hills (Project) single-family detached residential units located north of California State University San Bernardino campus on the opposite side of Badger Hill in the County of San Bernardino, California. The Project is proposed construction of three-hundred and twenty- seven (327) single-family detached residential units; to include related on-site improvements that encompasses a span of 338.80 acres total gross area . This FPP provides measures for fire protection that meet the applicable portions of San Bernardino County Fire Protection District (SBCFPD) standards and further evaluates and identifies the potential fire risk associated with the Project’s land uses and identifies requirements for water supply, fuel modification and defensible space, access, building ignition and fire resistance, and fire protection systems, among other pertinent fire protection criteria. The purpose of this plan is to generate and memorialize the fire safety requirements and standards of the SBCFPD along with project -specific measures based on the site, its intended use, and its fire environment.
This document provides analysis of the site’s fire environment and its potential impact on the Project as well as the Project’s potential impact on the existing fire protection service. Tasks completed in preparation of this FPP include data review, code review, site fire risk analysis, land use plan review, fire behavior modeling, and site -specific recommendations. Requirements and recommendations herein are based on site-specific fire environment analysis and Project characteristics and incorporates area fire planning documents, site risk analysis, and standard principles of fire protection planning.
As determined during the analysis of this site and its fire environment, the Project, in its current condition, may include characteristics that, under favorable weather conditions, could have the potential to facilitate fire spread.
Under extreme conditions, wind -driven wildfires from the north and/or east co uld cast embers onto the property.
Once the Project site is developed, the on-site fire potential will be much lower than its current condition due to conversion of wildland fuels to building footprints, parking areas, managed landscapes, fuel modification areas, improved accessibility for fire personnel, and structures built to the latest ignition and ember resistant fire codes.
It is important to note that the fire safety requirements that will be implemented on this site, including ignition resistant construction standards, along with requirements for water supply, fire apparatus access, fuel modification and defensible space, the installation of National Fire Protection Association ( NFPA) 13D automatic interior fire sprinkler systems within each of the residential buildings, and fire response travel times were integrated into the code requirements and internal guidelines based o n results of post -fire assessments, similar to the After Action Reports that are now prepared after large fire events. When it became clear that specifics of how structures were built, how fire and embers contributed to ignition of structures, what effects fuel modification had on structure ignition, how fast firefighters could respond, and how much (and how reliable) water was available, were critically important to structure survivability, the Fire and Building codes were revised appropriately. San Bernardino County now boasts some of the most restrictive codes for building within Wildland Urban Interface (WUI) areas that focus on preventing structure ignition from heat, flame, and burning embers.
The proposed Project of three-hundred twenty-seven (327) single-family detached residential units encompass a span of 338.80 acres total gross area. The Project represents an amendment to the previously approved University Hills Specific Plan, incorporating 36.46 acres for residential uses , 20.64 acres for streets , alongside 46.86 acres dedicated to open space and parks. Additionally, 234.84 acres are deemed as a designated remainder . This area has been identified as a Hazardous Fire Area in the City of San Bernardino. The entire site has been designed with
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fire protection as a key objective. The site improvements are designed to facilitate emergency apparatus and personnel access throughout the site. Driveway and road improvements with fire engine turnouts and turnarounds provide access to within 150 feet of the structures. Water availability and flow will be consistent with requirements including fire flow and hydrant distribution required by local and state codes. These features along with the ignition resistance of all structures, NFPA 13D automatic interior fire sprinkler systems, and the pre-planning, training and awareness will assist responding firefighters through prevention, protection, and suppression capabilities.
As detailed in this FPP, the Project’s fire protection systems will include a redundant layering of protection methods that have been proven to reduce overall fire risk. The fire safety measures included herein, both required and recommended, are performance based and site –specific, considering the Project’s unique characteristics rather than a prescriptive, one-size-fits-all approach. The fire protection systems are designed to increase building safety, as well as the safety of those occupying the structure, reduce the fire risk on site, minimize risks associated with typical uses, and aid the responding firefighters during an emergency. No singular measure is intended to be relied upon for the site’s fire protection, but rather, a system of fire protection measures, methods, and features combine to result in enhanced fire safety, reduced fire potential, and improved safety in the development.
Based on the results of this FPP’s analysis and findings, the following FPP implementation measures will be provided as part of the proposed development plan. Based on the analysis conducted herein, the Project meets all fire and building code requirements and includes appropriate protections for the fire environment in which it is located. These measures are discussed in more detail throughout this FPP.
Implementation Measures:
1. The proposed buildings will be constructed of ignition resistant 1 construction materials and each single - family detached residential unit will include the installation of a National Fire Protection Association (NFPA) 13D automatic interior fire sprinkler system based on the latest adopted Building and Fire Codes for occupancy types.
2. Fuel Modification will be provided around the perimeter of Project site, as required by SBCFPD and will be a minimum of 100 feet wide in all directions through on-site Fuel Modification Zones (FMZ) and Defensible Space or a combination of on-site and off-site FMZ equivalent areas.
3. Paved roads are provided throughout the Project site.
4. Landscape plantings will not utilize prohibited plants that have been found to be highly flammable; landscape plant material must be drought tolerant and fire -resistant plantings recommended by the SBCFPD for use in Fuel Modification Zones (See Appendix E, Prohibited Plant List).
5. Fire apparatus access roads (i.e., public, and private streets) will be provided throughout the residential development and will vary in width and configuration but will all provide at least the minimum required unobstructed travel lanes, lengths, turnouts , turnarounds, width, and clearances required by applicable codes. Primary access and internal circulation will comply with the requirements of the SBCFPD.
6. Each of the single-family detached residential units will be equipped with automatic residential interior fire sprinkler systems respectively meeting NFPA 13D and SBCFPD requirements for the occupancy type.
7. Water capacity and delivery will be provided by a reliable water source for operations and during emergencies requiring extended fire flow.
1 A type of building material that resists ignition or sustained flaming combustion sufficiently to reduce losses from wildland-urban interface conflagrations under worst-case weather and fuel conditions with wildfire exposure of burning embers and small flames, as prescribed in CBC, Chapter 7A and State Fire Marshal Standard 12-7A-5, Ignition-Resistant Materials.
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8. FMZ Inspections. The University Hills Homeowners Association (HOA) will hire a 3rd party, SBCFPD - approved, FMZ inspector and landscape plan reviewer to provide annual certification (written report submitted to SBCFPD by May 1) that the HOA maintained property including all FMZs and met the requirements of this FPP.
9. Should future iterations of the Project’s site plan result in buildings that do not achieve a minimum of 100 feet of defensible space, then alternative materials and methods may be proposed to provide the functional equivalency of a full 100 feet of defensible space. Alternative materials and methods will be to the satisfaction of the SBC FPD and may include structural hardening enhancements or landscape features, like non-combustible walls.
The following measures shall be established in the Covenants, Conditions and Restrictions (CC&Rs) for the Project and implemented by the Project’s Bill of Assurance (BOA) or Property Manager. Annual maintenance should occur before May 1st of each year and be inspected by SBCFPD or an approved third party.
1. On-going maintenance of all fuel modification zones would occur at least annually or as needed by the Project’s Property Manager and/or BOA, or another approved entity.
2. The property owner and/or property management company will provide informational brochures at time of occupancy, which will include an outreach and educational role to ensure fire safety measures detailed in this FPP have been implemented and development-wide “Ready, Set, Go!”2 plans prepared.
Early evacuation for any type of wildfire emergency within the development is the preferred method of providing business safety, consistent with the SBCFPD’s current approach for evacuation. As such, the Project will formally adopt, practice, and implement a “Ready, Set, Go!” approach to Project site evacuation. The “Ready, Set, Go!” concept is widely known and encouraged by the state of California and most fire agencies, including; Pre -planning for emergencies, including wildfire emergencies, focuses on being prepared, having a well -defined plan, minimizing potential for errors, maintaining the Project site’s fire protection systems, and implementing a conservative (evacuate as early as possible) approach to evacuation and Project site uses during periods of fire weather extremes.
This FPP provides a detailed analysis of the Project, the potential risk from wildfire, and potential impacts on the SBCFPD, as well as analysis on meeting or exceeding the requirements of San Bernardino County. Further, this FPP provides requirements, recommendations, and measures to reduce the risk and potential impacts to acceptable levels, as determined by the SBCFPD.
2 https://sbcfire.org/readysetgofire/
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1 Introduction
This Preliminary Fire Protection Plan (FPP) has been prepared for the proposed University Hills single -family detached residential unit development (Project) in the County of San Bernardino (County), California . The purpose of this FPP is to evaluate the potential impacts resulting from wildland fire hazards associated with the Project ’s land uses and identify and verify the proposed implementation measures adequately mitigate those risks to a level consistent with the County thresholds. Additionally, this plan established and memorializes the fire safety requirements and standards of the Fire Authority Having Jurisdiction (FAHJ), which is the San Bernardino County Fire Protection District (SBCFPD). Requirements, standards, and recommendations are based on Project-specific design features and incorporate input from the Project applicant, planners, engineers, and architects, as well as the SBCFPD.
As part of the assessment, the FPP has considered the fire risks presented by the Project site including the property location, the site’s topography, geology, surrounding combustible vegetation (fuel types), climatic conditions, fire history, and proposed land uses for the Project site and the surrounding area. The plan addresses water supply, access, structural ignitability and fire resistive building features, fire protection systems and equipment, impacts to existing emergency services, defensible space , and vegetation management for the Project site and to address potential fire impacts to the surrounding area. Th is FPP also identifies and prioritizes areas for hazardous fuel reduction treatments and recommends the types and methods of treatment that will protect structures and essential infrastructures within the Project site. The FPP also recommends measures that developer and builders and the Property Manager will take to reduce the probability of structural and vegetation ignition.
The Project is located within the boundaries of the SBCFPD and thus the FPP addresses the SBCFPD’s response capabilities and response travel time within the Project area, along with projected funding for facility improvements and fire service maintenance.
The following tasks were performed toward the completion of this plan:
▪ Gather Project site specific climate, terrain, and fuel data; ▪ Collect Project site photographs;
▪ Process and analyze the data using the latest geographic information system (GIS) technology; ▪ Predict fire behavior using scientifically based fire behavior models, comparisons with actual wildfires in similar terrain and fuels, and experienced judgment;
▪ Analyze and guide design of proposed infrastructure;
▪ Analyze the existing emergency response capabilities; ▪ Assess the potential fire risk posed by the construction and operation of the Project to the Project site and surrounding area; and
▪ Prepare this FPP detailing how fire risk will be mitigated on the Project site and in the surrounding areas, ▪ Through a system of fuel modification, structural ignition resistance enhancements, and fire protection delivery system upgrades.
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Field observations were utilized to augment existing digital Project site data in generating the fire behavior models and formulating the recommendations presented in this FPP. Refer to Appendix A, Representative Photo Log for Project site photographs of existing conditions.
1.1 Intent
The intent of this FPP is to provide fire planning guidance and requirements for reducing fire risk and demand for fire protection services associated with the Project. To that end, the fire protection “system” detailed in this FPP includes redundant layering of measures, including pre-planning, fire prevention, fire protection, passive and active suppression, and related measures proven to reduce fire risk. The fire protection system planned for the Project has proven, through real-life wildfire encroachment examples throughout Southern California, to reduce the fire risk associated with this type of residential development.
1.2 Applicable Codes and Existing Regulations
The FPP demonstrates that the Project site would comply with the San Bernardino County Fire Protection District (SBCFPD) Fire Code (Ordinance No. FPD 23 -01), San Bernardino County Development Code, Chapter 82.13 Fire Safety Overlay and California Code of Regulations, Title 24, Part 2, 2022 California Building Code (CBC), including Chapter 7A, which is based on the 2021 International Building Code, Part 2.5, 2022 California Residential Code (CRC), which is based on the 2021 International Residential Code (IRC), and Part 9, 2022 California Fire Code (CFC), including Chapter 49, which is based on 2021 International Fire Code (IFC). Additionally, SBCFPD references Fire Standards for informational purposes in clarifying and interpreting provisions of CFC, National Fire Protection Association (NFPA) and California Public Resources Code (PRC).
Chapter 7A of the CBC addresses structural ignition resistance and reducing ember penetration into structures, a leading cause of structure loss from wildfires (California Building Standards Commission, 2023). Thus, code compliance is a critical component of the requirements of the FPP, given the Project’s wildland-urban interface (WUI) location and fire hazard severity zone designation. The entire Project site is located within an area considered to be a Local Responsibility Area (LRA) Very High Fire Hazard Severity Zone (VHFHSZ) as designated by CAL FIRE3.
Areas to west and south of the Project site are LRA High Fire Hazard Severity Zones (HFHSV) and Moderate Fire Hazard Severity Zones (MFHSVZ) (see Figure 1, Fire Hazard Severity Zone ). It should be noted that CAL FIRE released new LRA FHSZ maps for Southern California on March 24, 2025 . Local agencies have 120 days from receiving the maps from CAL FIRE to adopt the new maps or provide modifications that are additive. The review and possible acceptance of FHSZ designations in State Responsibility Area (SRA), LRA, and FRA will be in compliance with California Government Code Sections 51175 through 51189 . Fire hazard designations are based on topography, vegetation, and weather, among other factors with more hazardous sites, including steep terrain, unmaintained fuels, and vegetation, and WUI locations. Projects situated in high and very high FHSZ areas require fire hazard analysis and the application of fire protection measures to create ignition -resistant structures and defensible communities within these WUI locations. HFHSZ and VHFHSZ designations do not, in and of themselves, indicate that it is unsafe to build in these areas.
As described in this FPP, the University Hills Project site will meet all applicable fire and building code requirements for building in these higher fire hazard areas or meet the intent of the code through the application of Project site- specific fire protection measures. These codes have been developed through decades of post-fire structure saving
3 https://experience.arcgis.com/experience/6a9cb66bb1824cd98756812af41292a0
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and loss evaluations to determine what causes building loss during wildfires. The resulting fire codes now focus on mitigating former structural vulnerabilities through construction techniques and materials so that the buildings are resistant to ignitions from direct flames, heat, and embers, as indicated in the 2022 CBC (Chapter 7A, Section 701A Scope, Purpose, and Application) (California Building Standards Commission, 2023).
The Proposed Project will also be consistent with the following codes and regulations:
▪ Applicable sections of the 2022 California Building Code, including Ch. 7A – Materials and Construction Methods for Exterior Wildfire Exposure: minimum standards for a new building located in a WUI area to resist the intrusion of flame or burning embers projected by a vegetation fire. ▪ Applicable sections of the 2022 California Fire Code, including Chapter 49 (as adopted and amended , added to by SBCFPD 2022 Fire Code) – Requirements for Wildland-Urban Interface Fire Areas: minimum standards to increase the ability of a building to resist the intrusion of flame or burning embers being projected by a vegetation fire.
▪ California Public Resources Code, Div. 4, Part 2, Ch. 3, Sec. 4290: minimum fire safety standards related to defensible space in Hazardous Fire Areas; Sec. 4291: Defensible space maintenance on Mountainous, Forest-, Brush- and Grass-Covered Lands.
▪ California Government Code, Title 5, Div. 1, Part 1, Ch. 6.8, Sec. 51175 -51189: Very High Fire Hazard Severity Zones. It should be noted the Project site is located within an area considered to be a LRA VHFHSZ as designated by CAL FIRE.
▪ California Government Code, Title 7, Div. 2, Ch. 4 Sec. 66474.02: requirements for tentative map approval in a very high fire hazard severity zone.
1.3 Project Summary
1.3.1 Location
The Project proposes construction of three hundred and twenty-seven (327) single-family detached residential units located north of California State University San Bernardino campus on the opposite side of Badger Hill in the County of San Bernardino, California. Regional access to the Project site is provided by Interstate 215 (I -215) from the University Parkway Exit. Local access t o the site is provided along Badger Canyon Road . The existing site and surrounding areas are shown in Figure 2, Project Location.
The Project site covers a total gross area of 338.80 acres, including 36.46 acres designated for three-hundred twenty-seven (327) single-family detached residential units, 20.64 acres for streets, and 46.86 acres allocated to open space and parks. An additional 234.84 acres are identified as a designated remainder within Tentative Tract Map No. 20595. The site is identified by Assessor’s Parcel Numbers (APNs) 0265-041-12-0-000, 0265-051-09-0- 000, 0265-021-13-0-00, 0265-011-07-0-000, 0265-01-08-0-000, and 0265-011-06-0-000. The site is bounded on the north by a designated remainder APN: 0265-021-13, on the east APN: 0265-031-25, on the south by open space flood control basin and further APN: 0265-041-15, and on west by open space and further APN: 0265-041- 15 (Figure 2).
A site visit conducted on February 24, 2025, by a Dudek Fire Protection Planner indicated that the site is currently vacant and undeveloped with naturally occurring vegetation which consists of low growing highly combustible plant species. The site is characterized by a large flat valley that is slightly sloping south . The Project site’s existing conditions are shown in Appendix A, Representative Photo Log.
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1.3.2 Project Description
The University Hills Project (Project) proposes the development of three-hundred twenty seven (327) residential lots on a parcel of approximately 338.80 acres, located within thein the Hazardous Fire Area in the City of San Bernardino (Figure 3, Proposed Site Plan ). The Project represents an amendment to the previously approved University Hills Specific Plan, incorporating 36.46 acres for residential and related uses, alongside 46.86 acres dedicated to open space and parks. Additionally, 234.84 acres are deemed as a designated remainder.
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FHSZ in LRA - Reclassified from SRA
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FHSZ in LRA - Recommended 2007-2011
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FHSZ in SRA - Effective April 1, 2024
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Fire Hazard Severity Zone
Fire Protection Plan - University Hills Project
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Fire Protection Plan - University Hills Project
SOURCE: USA Topo Maps 7.5 Minute Series San Bernardino North Quadrangle T ownship 1N; Range 4W; Section 4-5 and 8-9Date: 3/18/2025 - Last saved by: lterry - Path: Z:\Projects\j1442800\MAPDOC\DOCUMENT\FPP\Figure 1 Project Location-Par1.mxd Project Site - Parcel 1
FIGURE 2
Adelanto
Apple Valley
Barstow
Big Bear
Lake
Blythe
Bradbury
Brea
California
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Canyon Lake
Coachella
Colton Desert
Hot Springs
Indian
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Palm Springs
Palmdale
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Fire Protection Plan - University Hills Project
Proposed Site Plan
FIGURE 3
SAN BERNARDINO COUNTY
FLOOD CONTROL DISTRICT
PROPERTY
N CAMPUS PARKWAY
STATE OF CALIFORNIA PROPERTYEX. UNIVERSITY
CAMPUS CIRCLE
SAN BERNARDINO COUNTY
FLOOD CONTROL DISTRICT
PROPERTY
STATE OF CALIFORNIA PROPERTY
TOTAL LOT COUNT = 327
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2 Project Site Risk Analysis
2.1 Field Assessment
After reviewing available digital study area information, including topography, vegetation types, fire history, and the Project’s development footprint, a Dudek Fire Protection Planner conducted a field assessment of the University Hills Project area in February 24, 2025, in order to confirm and acquire Project site information, document existing conditions, and to determine potential actions for addressing the protection of the Project’s structures. While on the Project site, Dudek’s Fire Protection Planner assessed the area’s topography, natural vegetation, fuel loading, surrounding land use and general susceptibility to wildfire. The completed field tasks include:
▪ Vegetation estimates and mapping refinements.
▪ Fuel load analysis.
▪ Topographic features documentation.
▪ Photograph documentation.
▪ Confirmation and verification of hazard assumptions.
▪ Off-site, adjacent property fuel and topography conditions. ▪ The surrounding land use confirmations.
▪ Necessary fire behavior modeling data collection.
▪ Ingress and egress documentation.
▪ Nearby Fire Station reconnaissance.
Study area photographs were collected (refer to Appendix A, Representative Photo Log), and fuel conditions were mapped using aerial images. Field observations were utilized to augment existing Project site data in generating the fire behavior models and formulating the recommendations detailed in this FPP report.
2.2 Project Site Characteristics and Fire Environment
Fire environments are dynamic systems and include many types of environmental factors and Project site characteristics. Fires can occur in any environment where conditions are conducive to ignition and fire movement.
Areas of naturally vegetated open space are typically comprised of conditions that may be favorable to wildfire spread. The three major components of fire environment are topography, climate, and vegetation (fuels). The state of each of these components and their interactions with each other de termines the potential characteristics and behavior of a fire at any given moment. It is important to note that wildland fire may transition to urban fire if structures are receptive to ignition. Structure ignition depends on a variety of factors and can be prevented through a layered system of protective features including fire resistive landscapes directly adjacent to the structure(s), application of known ignition resistive materials and methods, and suitable infrastructure for firefighting purposes.
Understanding the existing wildland vegetation and urban fuel conditions on and adjacent to the Project site is necessary to understand the potential for fire within and around the Project site.
The following sections discuss the Project site characteristics, local climate, and fire history within and surrounding the Project site. The University Hills Project is similar concerning topography, vegetative cover, and proximity to
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adjacent residential areas, available access, and planned use. The following sections discuss the characteristics of the Project site at a regional scale. The intent of evaluating conditions at this macro -scale is providing a better understanding of the regional fire environment, which is not constrained by property boundary delineations.
2.2.1 Topography
Topography influences fire risk by affecting fire spread rates. Typically, steep terrain results in faster fire spread up- slope and slower fire spread down-slope in the absence of wind. Terrain that forms a funneling effect, such as chimneys, chutes, or saddles on the landscape can result in especially intense fire behavior. Conversely, flat terrain similar to this Project site, tends to have an insignificant effect on fire spread, resulting in fires that are driven by vegetation and wind.
The overall Project site is relatively flat as it sits in large flat valley that is slightly sloping south, away from the San Bernardino Mountains towards the base of Badger Hill. Elevations at the Project site range from approximately 1,613 feet above mean sea level (AMSL) at the southern boundary to 1,865 feet AMSL at the northern limits of the site. Adjacent open space slightly slopes down along the western and southern borders of the project site.
2.2.2 Climate
Throughout Southern California and particularly at the Project site, climate plays a significant role in influencing fire risk. The region experiences a typical Mediterranean climate, characterized by warm, dry summers and cool, wet winters. Average high temperatures range from approximately 43°F in December to around 96°F in August.
Precipitation has been averaging between 0.04 inches to 2.3 inches and typically occurs between November to April. The average hourly wind speed ranges between 5.3 mph and 7 .1 mph. The prevailing wind direction is an onshore flow from the west.4
From a regional perspective, the fire risk in southern California can be divided into three distinct “seasons” (Nichols et al. 2011, Baltar et al 2014). The first season, the most active season and covering the summer months, extends from late May to late September. This is followed by an intense fall season characterized by fewer but larger fires.
This season begins in late September and continues until early November. The remaining months, November to late May cover the mostly dormant, winter season. Mensing et al. (1999) and Keeley and Zedler (2009) found that large fires in the region consistently occur at the end of wet periods and the beginning of droughts. Fires can be a significant issue during summer and fall, before the rainy period, especially during dry Santa Ana wind events.
Although Santa Ana events can occur anytime of the year, they generally occur during the autumn months, although the last few years have resulted in spring (April - May) and summer events. Santa Ana winds may gust up to 75 miles per hour (mph) or higher. This phenomenon markedly increases the wildfire danger and intensity in the Project area by drying out and preheating vegetation (fuel moisture of less than 5% for 1 -hour fuels is possible) as well as accelerating oxygen supply, and thereby, making possible the burning of fuels that otherwise might not burn under cooler, moist conditions.
The prevailing wind pattern is from the west (onshore), but the presence of the Pacific Ocean causes a diurnal wind pattern known as the land and sea breeze system. During the day, winds are from the west –southwest (sea), and at night winds are from the northeast (land). The highest wind velocities are associated with downslope, canyon, and Santa Ana winds.
4 https://weatherspark.com/y/1969/Average-Weather-in-San-Bernardino-California-United-States-Year-Round
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2.2.3 Vegetation
2.2.3.1 Fuels (Vegetation)
The proposed Project site and surrounding areas primarily support low- to- moderate-load sage scrub plant communities intermixed with non-native grasslands, and disturbed habitat. Vegetation types were derived from an on-site field assessment of the Project site. The majority of the areas adjacent to the Project site are vegetated with sage scrub interspersed with grasses, riparian, and sparse deciduous trees . The vegetation cover types were assigned corresponding fuel models for use during Project site fire behavior modeling. Sect ion 3.0 describes the fire modeling conducted for the Project Area.
2.2.3.2 Vegetation Dynamics
The vegetation characteristics described above are used to model fire behavior, discussed in Section 3.0 of this FPP. Variations in vegetative cover type and species composition have a direct effect on fire behavior. Some plant communities and their associ ated plant species have increased flammability based on plant physiology (resin content), biological function (flowering, retention of dead plant material), physical structure (bark thickness, leaf size, branching patterns), and overall fuel loading. For example, non-native grass dominated plant communities become seasonally prone to ignition and produce lower intensity, higher spread rate fires. In comparison, sage scrub can produce higher heat intensity and higher flame lengths under strong, dry wind patterns, but does not typically ignite or spread as quickly as light, flashy grass fuels.
As described, vegetation plays a significant role in fire behavior and is a critical component to the fire behavior models discussed in this report. A critical factor to consider is the dynamic nature of vegetation communities. Fire presence and absence at varying cycles or regimes disrupts plant succession, setting plant communities to an earlier state where less fuel is present for a period of time as the plant community begins its succession again.
Simply stated, high frequency fires tend to convert shru blands to grasslands or maintain grasslands, while fire exclusion tends to convert grasslands to shrublands, over time. In general, biomass and associated fuel loading will increase over time, assuming that disturbance (fire, or grading) or fuel reduction efforts are not diligently implemented. It is possible to alter successional pathways for varying plant communities through manual alteration.
This concept is a key component in the overall establishment and maintenance of the proposed fuel modification zones on-site. The fuel modification zones on the Project site will consist of irrigated and maintained landscapes as well as thinned native fuel zones that will be subject to regular “disturbance” in the form of maintenance and will not be allowed to accumulate excessive biomass (live or dead) over time, which results in reduced fire ignition, spread rates, and intensity. Conditions adjacent to the Project’s footprint (outside the fuel modification zones), where the wildfire threat will exist post -development, are classified as low to medium fuel loads due to the dominance of sage scrub-grass fuels.
2.2.4 Fire History
Fire history is a critical component of an FPP. Fire history data provides valuable information regarding fire spread, fire frequency, most vulnerable areas, and significant ignition sources, amongst others. In turn, this understanding of why fires occur in an area and how they typically spread can then be used for pre -planning and designing defensible communities.
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Fire history represented in this FPP uses the Fire and Resource Assessment Program (FRAP) database. FRAP summarizes fire perimeter data dating to the early 1900s but is incomplete due to the fact that it mostly includes fires over 10 acres in size and has incomplete perimeter data, especially before the mid-20th century (Syphard and Keeley 2016). However, the data does provide a summary of recorded fires and can be used to show whether large fires have occurred in the Project area, which indicates whether they may be possible in the future.
According to available data from the CAL FIRE in the FRAP database, there have been 135 fires that have burned within 5 miles of the site since the beginning of the historical fire data record, the majority of which have burned within the San Bernadino Mountains, northeast and northwest of the Project site. Recorded wildfires within 5 miles range from approximately .38 acres to approximately 91,428 acres (2003 Old Fire). The 2003 Old Fire merged with the 2003 Grand Prix Fire crossing into Los Angeles County (2003 Padua Fire), one of the fourteen fires creating the 2003 Fire Siege. The 2003 Fire Siege combined a total of fourteen wildfires scorching over 750,000 acres in seven southern California counties5. Prior to that, the 1980 Panorama Fire (approximately 23,626 acres) destroyed three- hundred and twenty-five (325) buildings and four (4) fatalities, had been the area’s most devasting fire. The 2020 El Dorado Fire (approximately 22,774 acres) is the most significant recent fire, resulting in ten (10) destroyed structures, six (6) damaged structures and one firefighter death. There have been only two (2) fires on record that have burned on the Project site, the 1967 County Roads #15 Fire (approximately 453 acres) and the 1979 Sierra Series (approximately 1,838 acres)6. SBCFPD may have data regarding smaller fires (other fires less than 10 acres) that have occurred on-site that have not been included herein. Fire history for the general vicinity of the Project site is illustrated in Appendix B, Fire History Map.
Based on an analysis of the fire history data set, specifically, the years in which the fires burned, the average interval between wildfires within 5 miles of the site was calculated to be approximately every one to two years with intervals ranging between 0 (multiple fires in the same year) to 11 years. It should be noted that the longer end of this interval is from the first half of the 20 th century, where the database is incomplete. Based on the analysis, it is expected that there will be wildland fires within 5 miles of the site at least every 11 years and on average, every one or two years, as observed in the fire history record. Based on fire history, wildfire risk for the site is associated primarily with a Santa Ana wind driven wildfire burning or spotting on-site from the north.
2.3 Analysis of Wildfire Risk from Adding
New Development
Humans (i.e., human related activities or human created features, services (i.e., powerlines and electrical equipment), or processes) are responsible for the majority of California wildfires (Syphard et al. 2007, 2008; Romero-Calcerrada et al. 2008). Certain human activities result in sparks, flames, or heat that may ignite vegetative fuels without proper prevention measures in place. These ignitions predominantly occur as accidents, but may also be purposeful, such as in the case of arson. Equipment and po werlines cause a substantial number of fires in San Bernardino County. After that, roadways are a particularly high source for wildfire ignitions due to high usage and vehicle-caused fires (catalytic converter failure, overheated brakes, dragging chains, tossed cigarette s, and others) (Romero-Calcerrada et al. 2008)). In Southern California, the population living at, working in, or traveling through the wildland urban interface is vast and provides a significant opportunity for ignitions every day. However, it is a relatively rare event when a wildfire occurs, and an even rarer event when a wildfire escapes initial containment efforts. Approximately 90 to 95% of wildfires are controlled below 10 acres (CAL FIRE 2019).
5 https://permanent.fdlp.gov/lps47731/2003FireStoryInternet.pdf 6 https://calfire-forestry.maps.arcgis.com/apps/mapviewer/index.html?layers=e3802d2abf8741a187e73a9db49d68fe
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Research indicates that contained development project s like the University Hills Project, are not associated with increased vegetation ignitions. Syphard and Keeley (2015) summarize all wildfire ignitions included in the CALFIRE Fire and Resource Assessment Program (FRAP) database dating back over 100 years. They found that equipment- caused fires were by far the most numerous – and these also accounted for most of the area burned – followed closely by the area burned by powerline fires. Ignitions classified as equipment caused frequently resulted from exhaust or sparks from power saws or other equipment with gas or electrical motors, such as lawn mowers, trimmers or tractors and associated with lower density housing. In San Diego County, and in areas like the open space areas near the Project site in San Bernardino County, ignitions were more likely to occur close to roads and structures, and at intermediate density land uses and structure densities.
As Exhibits 1 through 3 illustrate, new project density directly influences susceptibility to fire because in high density projects like the University Hills Project, there is one interface (the Project perimeter) with the wildlands whereas lower density development creates more structural exposure to wildlands, less or no ongoing landscape maintenance (an intermix rather than interface), and consequently more difficulty for limited fire resources to protect well-spaced buildings. The intermix includes deve lopment amongst the unmaintained fuels whereas the proposed Project converts all fuels within the footprint and provides a wide, managed fuel modification zone separating buildings from unmaintained fuel and creating a condition that makes defense easier. The majority of the Project site will be non-combustible paved surfaces, which will function as a fuel break because it will not allow ignition or fire spread. Syphard and Keeley go on to state that “The WUI, where housing density is low to intermediate is an apparent influence in most ignition maps,” further enforcing the conclusion that lower density development poses a higher ignition risk than higher density development. They also state that “Development of low -density, exurban housing may also lead to more homes being destroyed by fire” (Syphard et al. 2013). As discussed in detail throughout this FPP, the University Hills Project site is a planned ignition resistant residential development designed to include professionally managed and maintained fire protection components, and modern fire code compliant safety features that will greatly reduce the hazard of fi re spreading from the wildlands to the Project or from the Project to the adjacent wildlands . The conversion of the land within the current Project footprint to the proposed condition will reduce the amount of structures and their associated ignition potential from the dangerous state of low-density development described by Syphard and Keeley to ignition -resistant structures and Project perimeter.
Therefore, the development of the Project would not be expected to materially increase the risk of vegetation ignitions and would rather be expected to have reduced ignition potential.
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Exhibit 1. Example of “higher density” development. Homes are ignition resistant and excludes readily ignitable vegetative fuels throughout and provides a perimeter fuel modification zone. This type of new development requires fewer fire resources to defend and can minimize the likelihood of on-site fires spreading off-site.
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Exhibit 2. Example of “moderate density” development. Homes are located on larger properties and include varying levels of ignition resistance and landscape and fuel modification provision and maintenance. This type of development results in a higher wildland exposure level for all homes and does not provide the same buffers from wildfire encroaching onto the site or starting at a structure and moving into the wildlands as a higher density project.
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Exhibit 3. Example of “lower density” development. Homes are interspersed amongst wildland fuels, are of varying ages, and include varying levels of fuel modification zone setbacks. Homes are exposed to most or all sides by flammable vegetation and properties rely solely on owners for maintenance, are often far distances from the nearest fire station, and have minimal buffer from on-site fire spreading to wildlands.
Moreover, frequent fires and lower density housing growth may lead to the expansion of highly flammable exotic grasses that can further increase the probability of ignitions ( Syphard et al. 2012). This is not the case with the Proposed Project as the landscapes are managed and maintained to remove exotic fuels that may establish over time.
As discussed above, research indicates that it is less likely for higher density developments to be impacted by wildfires than lower density developments. The same protections that starve wildfire of fuels and minimize or prevent wildfire from transitioning into a contained, fuel-converted Project, such as the University Hills Project, also serve to minimize or prevent on-site fires from transitioning into the wildlands. Customized project FMZs are crucial as the strategic design and placement of fuels treatments can disrupt or slow fire spread, reduce fire intensity, and facilitate fire suppression within a landscape (Braziunas et al., 2021). This is true regardless of the direction a vegetation fire may be burning – whether toward a development or from within a development. The risk of a structure being destroyed is significantly lower when defensible space is implemented on both shallow and steep properties (Syphard et al., 2014). Even if just half the landscape is treated, the percentage of houses exposed to fire can decrease from 51% to 16% (Braziunas et al., 2021). Moreover, when FMZs are designed properly, they not only protect structures but also the surrounding environment. For example, when the Tahoe Basin experienced the Angora Fire in 2007, fuel treatments had the dual effect of saving homes and increasing forest survival (Safford et al., 2009) . In areas where fuel management had been conducted prior to the Angora Fire, home loss was significantly reduced in the adjacent community and 85% of the trees survived, as compared to the 22% that
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survived in untreated areas (Safford et al., 2009) .Fuel management treatments also facilitated the ecological benefit of reduced fire severity, including higher post -fire soil litter cover, higher herbaceous plant cover, higher diversity, and lower levels of invasive beetles (Safford et al., 2009). At a minimum, managing defensible space can reduce risk across multiple scales by damping fire risk, reducing the impact of fire, and in turn reducing annual fire risk (Braziunas et al., 2021). The University Hills Project can be compared to these high density developments as it shares similar characteristics. The majority of the Project site will be composed of non-combustible paved surfaces to reduce ignitions and fire spread. These measures will reduce the Project’s overall susceptibility to fire, compared to low density developments.
Further, the requirement that all structures will include the installation of an automatic interior fire sprinkler system significantly reduces the likelihood that a building fire spreads to the point of flashover, where a structure will burn beyond control and produce embers. Interior sprinklers are very efficient, keeping fires to the room of origin, or extinguishing the fire before the responding firefighters arrive. Similarly, the irrigated fuel modification zones are positioned throughout the Project. Irrigated zones include plants with high internal moisture and spacing between plants and plant groups that 1) make it di fficult to ignite and 2) make it difficult for fire to spread plant to plant.
Further, much of the Project area will be converted to non-combustible paved surfaces where no fires can ignite or spread. Lastly, the additional humans on the site result in fast detection of fires and fast firefighter response, a key in limiting the growth of fires beyond the incipient stage.
2.4 Off-site Wildfire Impacts
It is a relatively rare event when a wildfire occurs, and an even rarer event when a wildfire escapes initial containment efforts. Approximately 90 to 95% of wildfires are controlled below 10 acres (CAL FIRE 2019). Studies (Keeley & Syphard 2018; Syphard et al. 2007; Syphard & Keeley 2015) show the ignition resistance and fire safety awareness of the Project and its population influences the likelihood of fire ignitions and the potential for fire to spread off-site into adjacent wildland fuels and negative impact existing communities. As the research indicates, humans can drive wildfire ignition risk, but not discussed, they can also reduce it. When fire protection is implemented at the parcel level and leverages ignition resistant building materials, infrastructure improvements, and landscape design, the wildfire risk can be significantly reduced in the surrounding environment (Newman et al., 2013). When wildfire is planned for and incorporated into the building design, such as with the Project, it can not only withstand wildfire but prevent it. This prevention benefits the Project and the surrounding areas by reducing the landscape level fire risk. Further, given the Project ’s multi-scale approach to fire protection, it is unlikely that the Project would be a significant source of ignitions and result in increased off -site impacts related to wildfire, as discussed herein.
Common ignition sources in Southern California are related to powerlines and vehicles (Keeley & Syphard, 2018).
Powerlines-based ignitions are a concern with respect to off -site wildfire impacts. The highest likelihood of vegetation ignitions in the Project area would be related to existing roadways such as the new Badger Canyon Road and existing North Campus Parkway. However, the Project provides roadside fuel modification through a fire break along Badger Canyon Road and North Campus Parkway. Ongoing maintenance of these irrigated landscapes will continue in perpetuity as part of the Project. These efforts reduce or minimize the ability for a vehicle related spark, catalytic converter failure, or other ignition source to ignite and spread fire from the roadsides towards the Project.
The Project is not expected to significantly increase the already known fire risk associated with roads and in fact the Project- and road-adjacent fuel modification would aid in reducing the preexisting risk. Interior roadways in the parking lot are also not expected to result in significant vehicle ignitions. The on-site roadways would comply with all fire department access requirements and be encompassed by the ignition-resistant construction of the building,
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non-combustible paved surfaces, and irrigated landscaping. Therefore, even if ignition were to occur on the Project interior roadways it is highly unlikely, and less likely than current conditions that it would spread beyond the Project site due to the level of hardscape and the adjacent fuel modifications areas.
Reducing WUI exposure can address the protection of a wide range of highly valued resources and can offer protection to critical resources, habitat communities, and landscapes (Scott et al., 2016). Despite the potential for more frequent fire ignitions from developments, when developments are planned accordingly, such as the Project, the fuel availability and fuel continuity decrease, while the probability of fire suppression increases ( Fox et al., 2018). This is a result of planned alterations to fuel, increased ignition resistant construction, enhanced fire protection features, higher wildfire risk awareness, and maintenance of fire protection features. The dual benefit of building a fire -hardened project, like the University Hills Project, is that the same features that protect the development from wildfire also play a significant role in protecting wildlands and surrounding areas from Project - related fires.
2.4.1 Vegetation Management
A study in Southern Italy found that the ignition potential of an area was significantly influenced by landcover types and human drivers were low or inconsistent (Elia et al., 2019). Urban interfaces with shrubland -dominated vegetation were found to be more fire-prone than those with grasslands or other natural spaces (Elia et al., 2019).
The Project area is a mixture of non-native grasslands, sage scrub, and disturbed habitats. All the existing fuel on the site and within FMZ areas will be converted into hardscape or irrigated landscaping. The fuel conditions will be addressed through various vegetation management techniques, such as fuel modification zones (FMZs). The original intent of FMZs, also known as defensible space, was to protect natural resources from fires in developed areas and have since evolved to protect communities and structures. In an FMZ, combustible vegetation would be removed and/or modified and partially or totally replaced with more appropriately spaced drought -tolerant, fire- resistant plants. The goal is to provide a managed area where fire sprea d is not facilitated toward the Project or away from the Project into wildland areas. Fuel modification works by redistributing the risk of fire on a landscape and altering the interaction between fire, fuels, and weather (Cochrane et al., 2012). FMZs typically target surface fires but can also reduce the likelihood of canopy fires, lower ember cast, and have a shadow effect on the untreated landscape by lowering the probability of burning and the potential fire size (Cochrane et al., 2012). As a result, the risk of a structure being destroyed, whether from a fire from within the development or outside the development, is significantly lower when defensible space is implemented.
The Project FMZ will serve to create defensible space around the structures. Defensible space adjacent to structures also functions to limit the spread of fire from the built environment into off -site vegetation because the irrigated and maintained landscapes do not readily facilitate vegetation ignition or fire spread. Implementing defensible space can reduce the likelihood of structural ignition and support landscape -level risk reduction. The FMZ areas function as fuel breaks which are crucial in reducing fire risk and facilitating effective fire prevention (Wang et al., 2021). The irrigated zone acts as a green barrier that uses specific vegetation growth, such a high-internal moisture, fire-resistive species, to reduce fire spread (Wang et al., 2021). The high-internal moisture and spacing between plant groups make it more difficult for ignition to occur and fires to spread from plant to plant.
This affects fire behavior by reducing flame lengths, slowing spread rates, and lowering fire intensity. If a fire from a structure or vehicle spread s to the irrigated zone the fire -resistive species in this zone would be less likely to ignite, reducing the likelihood of the fire spreading off-site (Wang et al., 2021). The use of irrigated areas to reduce wildfire impacts can achieve wildfire mitigation and offer wildfire protection in fire -prone areas beyond the Project site (Wang et al., 2021). Further , fuel treatments also have an ecological benefit by reducing the potential fire
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severity which can result in high post-fire litter cover, higher herbaceous plant cover, higher biodiversity, and lower levels of invasive pests, benefiting adjacent open space areas (Safford et al., 2009). The benefits of defensible space and FMZs are not solely limited to the built environment. Positioning the low plant density, irrigated areas directly adjacent to the ember-resistant Zone 0, and implementing defensible space provides a significant buffer between structures and open space areas. These techniques aid in preventing ignitions in the built environment but also across the larger landscape.
However, long-term protection of the development and the surrounding area is dependent on the maintenance of fuel modification as even fire-safe designs can degrade over time. To alleviate this the Project will conduct regular assessments of the FMZs. During this maintenance, dead and dying material and undesirable plants will be removed. Thinning will also be conducted as necessary to maintain plant spacing and fuel densities. This will keep the FMZs and landscaped areas in a highly fire resistive condition free of accumulated flammable debris and plants.
Fuel treatments and defensible space do more than just protect structures. When they are a component of a place- based fire-hardened design, such as the Project, they can not only serve to protect structures from wildfire but function as a buffer for natural areas and surrounding communities. These features will further reduce the potential for wildfire in open space areas and potential impacts on surrounding communities.
2.4.2 Firefighter Response
As discussed in Section 4 below, the Project is anticipated to have an insignificant impact on the workload or response capacity from the closest fire station. Further, the on-site roads would be able to provide sufficient access for fire apparatus in a high-risk area. The Project also provides water supply and fire flow which are critical resources in firefighting. The Project defensible space areas will allow firefighters to safely position themselves at the development edge and begin tactical protection efforts (Warziniack et al., 2019). This allows firefighters to not only readily protect structures and reduce the likelihood of building ignitions but also gives them a safe position to respond to off-site wildfires. Using the Project’s fire protection features firefighters would be able to use the Project as a tactical resource for protecting open space areas, whether it be from on-site or off-site fires. The Project would create additional access for fire apparatuses that were not previously existing. Enh ancing firefighters’ ability to respond to an incident increases their ability to suppress a fire whether on -site or off-site. The presence of on-site fire resources increases response capacity and could be the difference between a small fire or a full conflagration.
2.4.3 Ignition Resistant and Noncombustible Construction The WUI fire problem is largely structures lacking ignition resistant features (i.e., ember resistant vents, interior sprinklers); therefore, the best mitigation is to reduce the likelihood of building ignition occurring (Zhou, 2013).
Structural characteristics play a significant role in whether a building burns, which is important in WUI environments as structures also serve as fuel (Gorte, 2011). The benefit of structure -based mitigation is that it not only lowers the on-site risk but also lowers the risk of wildfire across a landscape (Mockrin et al., 2020). In WUI areas, this is because structures are also fuels that can spread a fire into open space. With the incorporation of ignition-resistant construction, the likelihood of structural ignition occurring within the Project area is minimized. The Project will provide new code compliant, ignition resistive structures , which lowers the threat from on -site fires impacting off- site areas as the structures themselves are highly unlikely to function as fuel. The Project includes vent coverings to prevent ember penetration, and the Project buildings will also include NFPA 13D automatic interior fire sprinkler systems for occupancy type in every residential building. This is crucial in preventing off-site impacts as embers can also be generated by a structure fire and can be blown over the fuel modification into native fuels. Automatic
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sprinklers can isolate a fire to the point of origin, limit its ability to spread to the rest of the building, and even extinguish a fire before the responding firefighters arrive, thus damping the likelihood of ember production. The installation of an interior fire sprinkler system within each structure also reduces impacts on fire response capacity as the automatic sprinklers will allow firefighters to focus on reducing additional ignitions beyond the point of origin.
Structure design, such as Project’s, is crucial in protecting an area against wind -driven fires. The Project provides features that not only prevent fire intrusion but prevent structures fires from escaping into off-site areas. This allows the Project to not only protect the immediate area but the surrounding environment.
2.4.4 Shelter in Place Capability
Sheltering-in-place is the practice of going or remaining indoors during or following an emergency event. This procedure is recommended if there is little time for the public to react to an incident and it is safer for the public to stay indoors for a brief time rather than travel outdoors. According to common Emergency Operations Plan language, shelter -in-place is an approach that has been used and is actively contemplated for emergencies, including wildfires. Shelter-in-place advises people to stay secure at their current location.
Consistent with the Project’s approach, this tactic shall only be used if an evacuation causes a higher potential loss of life. Consideration should be given to assigning incident personnel to monitor the safety of citizens remaining in place. The concept of shelter -in-place is an available option in those instances where physical evacuation is impractical. Sheltering-in-place provides a safe haven within the impacted area.
This FPP provides significant evaluation and conclusions regarding the shelter -in-place capability of the Project ’s buildings. Among other things, the Project has been designed to include ignition -resistant structures with the use of ignition resistant construction materials, effective defensible space and fuel management zones, ember protection, and other redundant structure, infrastructure, building code, and water supply and flow requirements established as containing adequate protective features to function as temporary shelters during wildfires. All the on-site structures could be utilized for temporary refuge during wildfire. In addition, there may be protected open - air areas that would be enhanced to serve as temporary sheltering sites as a contingency plan if evacuation is considered undesirable. These sites would be designated with input from SBCFD and may include green spaces, leeside of buildings, or other protected areas.
Sheltering-in-place also has many advantages because it can be implemented immediately, allowing people to remain in their familiar surroundings, and providing individuals with everyday necessities such as telephone, radio, television, food, and clothing. However, the amount of time people can stay sheltered -in-place is dependent upon availability of food, water, medical care, utilities, and access to accurate and reliable information. It is not anticipated that any wildfire related shelter-in-place action would require longer than a few hours of on-site refuge.
The decision on whether to evacuate or shelter -in-place is carefully considered with the timing and nature of the incident. Sheltering-in-place is the preferred method of protection for people that are not directly impacted or in the direct path of a hazard. This will reduce congestion and transportation demand on the major transportation routes for those that have been directed to evacuate by police or fire personnel. Like with most new developments that incorporate ignition resistant construction, wide fu el modification zones, ember protection, and fire defensibility throughout, responding fire and law enforcement personnel will be able to direct people temporarily refuge on-site in designated buildings in the rare situation where shelter-in-place is determined to be safer than evacuating.
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Shelter-in-place at this location in the planned structures will also be an option available to emergency managers during a wildfire event. A shelter-in-place plan will be prepared and provided to all on -site personnel outlining the actions to take if shelter in place notification is provided by emergency management sources.
The Project buildings will be constructed of ignition resistant construction. Because of the ignition resistant construction, fuel modification zone setbacks and the type of lower fire intensity vegetative fuels in the vicinity of the site, sheltering in place is considered to be a safe option if a fast-moving wildfire precludes complete evacuation of the Project site. The heat flux produced by the nearest unmaintained vegetative fuels is not at a high enough temperature to ignite a concrete building even if it is directly next to the building. In this case, the heat would dissipate rapidly in the provided building setbacks and the concrete or stucco structures would be capable of absorbing any residual heated air that may intersect with the buildings. The primary concern is anticipated to be with smoke and air quality rather than exposure to flames and heated air. Measures to safely refuge persons within the buildings and minimize smoke and air quality issues would be enacted in this scenario. For example, w hen wildfire ignites, it is common for HVAC systems to be turned off and they can be fitted with sensors that turn them off automatically when smoke is detected. This minimizes the potential for drafting smoke through the ventilation system into the buildings.
Project Design Feature: Most of the primary components of the Project’s layered fire protection system are required by Fire and Building codes, because they have been evaluated in the lab and in real -time wildfires and found to result in saved structures. They are worth listing because they have been proven effective for minimizing structural vulnerability to wildfire. They also make shelter -in-place possible as an evacuation contingency option when evacuation is not possible.
Even though current Building and Fire Codes require these measures, at one time, many of them were used as mitigation measures for buildings in fire hazard areas, because they were known to reduce structure vulnerability to wildfire. These measures were adopted into the 2007 California Building Code and ha ve been retained and enhanced in code updates since then. The following Project features are required for new development in fire hazard areas and would form the basis of the system to provide adequate acc ess by emergency responders and provide the protection necessary to minimize structural ignitions:
▪ Application of the latest adopted ignition-resistant building codes; ▪ Exterior wall coverings are to be ignition resistant; ▪ For structures that achieve the minimum 100 feet of on -site fuel modification, all exterior windows, skylights, and exterior glazed door assemblies shall be constructed of multipaned glazing with a minimum of one tempered pane. All windows shall be UL listed, not of vin yl construction, and shall have a fire - resistant rating of not less than 20 minutes when evaluated according to NFPA 257/UL 263. ▪ Ember-resistant vents mesh screening should be between 1/16- and 1/8-inch noncombustible, corrosion resistant material (recommend BrandGuard, O’Hagin, or similar vents); ▪ NFPA 13D interior, automatic fire sprinkler systems within all residential buildings; ▪ Boxed or no eaves or soffits.
▪ There would be no use of paper-faced insulation or combustible installation in attics or other ventilated areas; ▪ There would be no use of plastic, vinyl (with the exception of vinyl windows with metal reinforcement and welded corners), or light wood on the exterior.
- Any vinyl frames to have welded corners and metal reinforcement in the interlock area to maintain integrity of the frame certified to ANSI/AAMA/NWWDA 101/I.S 2 97 requirements.
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▪ Skylights to be tempered glass (as applicable).
▪ Rain gutters and downspouts shall be non -combustible. They would be designed to prevent the accumulation of embers, leaf litter or debris, which can ignite roof edges , by requiring the installation of non-combustible debris covers and mesh over the top of rain gutters to minimize a common ignition point. ▪ Doors to be of approved noncombustible construction or would be solid core wood having stiles and rails not less than 1 3/8 inches thick or have a 20-minute fire rating. Doors to comply with City Building Code, ▪ There would be no combustible awnings, canopies, or similar combustible overhangs. ▪ No combustible fences to be allowed within 5 feet of structures. ▪ All chimneys and other vents on heating appliances using liquid fuel (no solid fuel burning appliances) , including outdoor fireplaces and permanent barbeques and grills, shall have spark arrestors that comply with the City Code. The code requires that openings would be between 1/16- and 1/8-inch and the screen would have comparable heat and corrosion resistance to 19-gauge galvanized or 24-gauge stainless steel.
Arrestors would be visible from the ground.
▪ Modern infrastructure, access roads, and water delivery system; ▪ Maintained FMZs.
Notably, automatic interior fire sprinklers, which would be provided in all structures (required by code since 2010), have an extremely high reliability track record (NFPA 2021) of controlling fire in 96% of reported fires, and statistics indicate that fires in structures with sprinklers resulted in 82% lower property damage and 68% lower loss of life (Hall 2013). NFPA 13D fire sprinklers are designed for structure protection and life safety. For wildland fire defense, should embers succeed in entering a structure, sprinklers provide an additional layer of life safety and structure protection.
Sheltering -In-Place as an Active Emergency Option
Sheltering-in-place or providing temporary refuge when evacuation is considered undesirable is not a new idea.
Sheltering-in-place has been a useful tool in the emergency management toolbox since the 1950’s. In some wildfire scenarios, temporarily sheltering in a protected structure is safer than evacuating. Huntzinger (2010) states that:
“If sheltering in place can provide the community with the same level of protection from an emergency incident as mass evacuation, this will be the recommended practice to use.” Many civilian deaths have occurred when the population evacuated late and was exposed to wildfire on unprotected roadways (Braun, 2002, CFA 2004). By contrast, fire hardened projects that have implemented similar fire protection, setbacks, and building standards have fared well in fire events, making them suitable for temporary shelter. Developments constructed in accordance with modern fire-safe development standards also survived the 2003 Simi Fire, the 2008 Freeway Complex Fire, and the 2020 Silverado Fire without a single building lost. Nasiatka (2003) points out that another advantage to sheltering in place in an appropriately protected location is that there would be a substantial reduction in the number of evacuees that would need to be managed, allowing those evacuees at greater risk (i.e., in older, less protected communities) to evacuate more quickly.
2.4.5 Wildfire Risk Awareness Education
The Project includes an education awareness program that is a key piece in wildfire prevention in the area (Steffey et al., 2020) . This program will provide wildfire information for the area and create greater risk awareness for employees and customers . The wildfire education program will be facilitated by the BOA, property manager, or similar entity and will disclose the potential wildfire risk and the requirements of the FPP. The educational program will also include information regarding the necessary la ndscape maintenance and structural-based fire protection
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features. Having ongoing education included in the Project creates a heightened level of wildfire risk awareness and fire protection measures. This benefits both the Project and the surrounding areas as people would be more aware of the wildfire risk and p otential impacts. Further, it decreases the likelihood the Project employees, customers, and other users would cause an uncontrolled ignition, and they would be aware of what steps to take if they observe an ignition. As such the impact on off-site areas would be further lowered by reducing the probability of ignition.
As described above it is not as simple to say development in areas with high fire hazards will equate to increased wildfire risk. It is possible to develop in these areas when fire is incorporated into Project design and create a site that is not only hardened against fire but designed to prevent fires. The dual benefit of creating a development that can prevent a fire is that it offers protection to the surrounding developed areas and the environment. The requirements and recommendations outlined in the FP P have been designed specifically for the proposed construction in the Project’s location and can significantly reduce the potential threat to off-site areas.
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3 Anticipated Fire Behavior
3.1 Fire Behavior Modeling
Following field data collection efforts and available data analysis, fire behavior modeling was conducted to document the type and intensity of fire that would be expected to be adjacent to the Project site given characteristic site features such as topography, vegetation, and weather (see Figure 1, Fire Hazard Severity Zone and Appendix B, Fire History). Dudek utilized BehavePlus software package (Andrews, Bevins, and Seli 2008) to analyze potential fire behavior on and adjacent to the Project site, with assumptions made for the pre - and post-Project slope and fuel conditions. Results are provided below and a more detailed presentation of the BehavePlus analysis, including fuel moisture and weather input variables, is provided in Appendix C, Fire Behavior Modeling Summary. BehavePlus modeling is described below followed by the fire spread modeling details.
3.2 Fire Behavior Modeling Analysis
An analysis was conducted to evaluate both pre - and post - Project vegetation fire behavior variables and to objectively predict flame lengths, intensities, and spread rates for two pre - proposed Project scenarios were evaluated, including one average summer weather conditions (southwest of the proposed Project site and northeast of the Project site). Additionally, two scenarios were run for post -Project conditions (one average and one extreme weather condition respectively). These fire scenarios incorporate d observed fuel types representing the dominant vegetation representative within and adjacent to the development site, in addition to slope gradients, wind, and fuel moisture values for both the 50th percentile weather (summer, on -shore and off-shore winds) and the 97th percentile weather (fall, off-shore winds). Modeling scenario locations were selected to better understand different fire behavior that may be experienced on or adjacent to the Project site.
To support the fire behavior modeling efforts conducted, a Dudek Fire Protection Planner analyzed the different vegetation types observed on and adjacent to the site and were classified into the aforementioned numeric fuel models. As is customary for this type of analysis, the terrain, and fuels directly adjacent to the site and proposed fuel modification zones (FMZ) are used for determining flame lengths and fire spread. Vegetation types, which were derived from the field assessment, were classified into f uel models. Fuel models are selected by their vegetation type, fuel stratum most likely to carry the fire, and depth and compactness of the fuels. Fire behavior modeling was conducted for vegetative types that are both on and adjacent to the proposed development. Fuel models were also assigned to illustrate post-Project fire behavior changes. Fuel models were selected from Standard Fire Behavior Fuel Models: a Comprehensive Set for Use with Rothermel’s Surface Fire Spread Model (Scott and Burgan 2005).
Fuel models were also assigned to the fuel FMZs to illustrate post -Project fire behavior changes. Based on the anticipated existing and post-Project vegetation conditions, six different fuel models were used in the fire behavior modeling effort presented herein. Fuel model attributes are summarized in Table 1.
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Table 1. Fuel Models Used for Fire Behavior Modeling
Fuel
Model
Type Title Description
Application
(Behave Run)
Existing conditions
SH5 High load dry
climate shrub
Heavy shrub load, depth 4 to 6 feet. Spread rate very
high; flame length very high.
Native chaparral
vegetation
SH2 Moderate load
dry climate shrub
The primary carrier of fire is woody shrubs and shrub
litter. Depth about one foot, no grass fuel is present.
Spread rate low; flame length low.
Native sage and forb
vegetation
SCAL18 Sage scrub,
buckwheat
The primary carrier of fire is sage, buckwheat, and
sparse grass. Average height about two to three feet.
Spread rate moderate; flame length moderate.
Native
sage/buckwheat
vegetation
Post -Project
GS1 Low load dry
climate grass-
shrub
The primary carrier of fire is grass and shrubs
combined. Shrubs are about one foot high; grass load
is low. Spread rate moderate; flame length low.
Thinned and
maintained native
vegetation
FB8 Irrigated
landscaping/
compact litter
The primary carrier of fire is landscaping litter, though lesser amounts of fine dead fuel may be present. The
landscaping material is generally hydrated with high
moisture content. Spread rate low; flame length low.
Irrigated landscaping
NB1 Urban or
suburban
development
Insufficient wildland fuel to carry wildland fire. Paved roadways, parking, hardscape
Tables 2A and 2B summarize the weather and wind input variables used in the BehavePlus modeling process.
Table 2A. Fuel Moisture and Wind Inputs
Variable Weather Condition (50th Percentile)
1h Moisture 3%
10h Moisture 5%
100h Moisture 7%
Live Herbaceous Moisture 60%
Live Woody Moisture 90%
20-foot Wind Speed (mph) 20
BehavePlus Wind Adjustment Factor 0.4
Table 2B. Fuel Moisture and Wind Inputs
Variable Weather Condition (97th Percentile)
1h Moisture 2%
10h Moisture 3%
100h Moisture 5%
Live Herbaceous Moisture 30%
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Table 2B. Fuel Moisture and Wind Inputs
Variable Weather Condition (97th Percentile)
Live Woody Moisture 60%
20-foot Wind Speed (mph) 40
BehavePlus Wind Adjustment Factor 0.4
3.3 Fire Behavior Modeling Results
The results presented in Tables 3 and 4 depict values based on inputs to the BehavePlus software and are not intended to capture changing fire behavior as it moves across a landscape. Changes in slope, weather, or pockets of different fuel types are not ac counted for in this analysis; rather, the models provide a worse-case wildfire behavior condition as part of a conservative approach. For planning purposes, the averaged worst-case fire behavior is the most useful information for conservative fuel modifica tion design. Model results should be used as a basis for planning only, as actual fire behavior for a given location would be affected by many factors, including unique weather patterns, small-scale topographic variations, or changing vegetation patterns.
The results of fire behavior modeling analysis for pre- and post-Project conditions are presented in Tables 3 and 4, respectively. Identification of modeling run (fire scenarios) locations is presented graphically in Figure 4, BehavePlus Analysis Map.
Fire Scenario locations and descriptions:
▪ Scenario 1. Fire flaming front approaching from the northeast towards the northern side of Parcel 1 Project boundary with 40 mph north/northeast winds; 18% downhill slope within 100 to 300 feet of edge of grading. - Existing conditions: undeveloped land off-site (to be preserved as open space) and on site with native vegetation (chaparral, sage scrub).
- Post-development conditions : include the same off-site conditions with irrigated manufactured slopes, fuel modification zones, and paved roadways on site. ▪ Scenario 2. Fire flaming front approaching from the southwest towards the western boundary of the Parcel 1 western boundary with 20 mph west/southwest winds; 6% uphill slope within 400 feet of edge of grading. - Existing conditions : undeveloped land off-site and on-site with native vegetation (sage scrub, forbs). - Post-development conditions : include the same off-site conditions with irrigated manufactured slopes, fuel modification zones, and paved roadways on site.
The results presented in Tables 3 and 4 depict values based on inputs to the BehavePlus software reflecting a “moment in time” and are not intended to capture changing fire behavior as it moves across a landscape. Changes in slope, weather, or pockets of d ifferent fuel types are not accounted for in this analysis, but the models provide the worst-case wildfire behavior condition as part of a conservative approach. For planning purposes, the averaged worst-case fire behavior is the most useful information fo r conservative fuel modification design. Model results should be used as a basis for planning only, as actual fire behavior for a given location would be affected by many factors, including unique weather patterns, small-scale topographic variations, or changing vegetation patterns.
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3.3.1 Existing Conditions
As presented in Figure 4, BehavePlus Analysis Map , wildfire behavior in the off-site chaparral, modeled as SH5, would exhibit the most intense fire behavior with the sage/buckwheat vegetation, modeled as SCAL18 exhibiting similar fire behavior (refer to Table 3, Fire Behavior Results for Existing Conditions). A worst-case fire under gusty Santa Ana winds and low fuel moistures is expected to be moving up to 4.7 mph. Flame length values were modeled at 35.5 to 36.3 feet. Spotting is projected to occur up to 1.8 miles from the flaming front.
The results of fire behavior modeling analysis for pre- and post-Project conditions are presented in Tables 3 and 4, respectively. Identification of modeling run (fire scenarios) locations is presented graphically in Figure 4, BehavePlus Analysis Map.
Table 3. Modeling Results for Existing Conditions
Fire Scenarios
Spread Rate
(mph)
Fireline Intensity
(BTU/feet/second)
Flame
Length
(feet)
Spotting
Distance 1
(miles)
Scenario 1: 18% downhill slope, 40 mph wind from NE
Fuel Model SH5 – Chaparral 4.7 13,958 36.3 1.8
Fuel Model SCAL18 – Sage, buckwheat 2.1 13,342 35.5 1.8 Fuel Model SH2 – Sage, forbs 0.7 1,515 13.1 0.9
Scenario 2: 6% uphill slope, 20 mph wind from W/SW
Fuel Model SH2 – Sage, forbs 0.3 603 8.6 0.4
Note:
1 Spotting distance from a wind driven surface fire.
3.3.2 Post-Development Conditions
As presented in Table 4, Fire Behavior Results for Post-Project Conditions, Dudek conducted modeling of the Project site for post-development fuel recommendations for the Project. The fuel modification area includes thinning and maintained vegetation, irrigated landscaping, and paved roadways on the periphery of the proposed Project . For modeling the post-development condition, fuel modification was modeled as thinned native vegetation (Fuel Model GS1) and irrigated landscaping (Fuel Model 8). Fuel model assignments for all other areas remained the same as those classified for the existing condition.
The fuel modification areas experienced a significant reduction in flame length and intensity. The flames predicted during pre-development modeling during extreme weather conditions are reduced to less than 3.0 feet in length at the outer edges of the development due to the lack of combustible material present and the higher live and dead fuel moisture content for the irrigated landscaping.
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Table 4. Modeling Results for Post-Project Conditions
Scenario
Flame
Length (feet)
Fireline Intensity
(BTU/feet/second)
Spread Rate
(mph)
Spotting
Distance 1
(miles)
Scenario s 1: 25% downhill slope, 40 mph wind from NE
Fuel Model GS1 – maintained
shrubs for fuel modification
11.1 1067 2.0 0.8
Fuel Model 8 – Irrigated
landscaping/FMZ
2.6 46 0.1 0.3
Fuel Model NB1 – paved roadway NA NA NA NA
Scenario s 2: 20% uphill slope, 20 mph wind from SW
Fuel Model GS1 – maintained
shrubs for fuel modification
7.2 411 0.8 0.4
Fuel Model 8 – Irrigated
landscaping/FMZ
2.0 26 0.1 0.2
Note:
1 Spotting distance from a wind driven surface fire.
The results presented in Tables 3 and 4 depict values based on inputs to the BehavePlus software an d are not intended to capture changing fire behavior as it moves across a landscape. Changes in slope, weather, or pockets of different fuel types are not accounted for in this analysis, but the models provide the worst-case wildfire behavior condition as part of a conservative approach. For planning purposes, the averaged worst -case fire behavior is the most useful information for conservative fuel modification design. Model results should be used as a basis for planning only, as actual fire behavior for a given location would be affected by many factors, including unique weather patterns, small-scale topographic variations, or changing vegetation patterns.
The following describes the fire behavior variables (Heisch and Andrews 2010) as presented in Tables 4 and 5:
Surface Fire:
▪ Flame Length (feet): The flame length of a spreading surface fire within the flaming front is measured from midway in the active flaming combustion zone to the average tip of the flames. ▪ Fireline Intensity (Btu/ft/s): Fireline intensity is the heat energy release per unit time from a one-foot-wide section of the fuel bed extending from the front to the rear of the flaming zone. Fireline intensity is a function of rate of spread and heat per unit area and is related to flame length. Fireline intensity and the flame length are related to the heat felt by a person standing next to the flames. ▪ Surface Rate of Spread (mph): Surface rate of spread is the "speed" the fire travels through the surface fuels. Surface fuels include litter, grass, brush, and other dead and live vegetation within about 6 feet of the ground.
The information in Table 5 presents an interpretation of the outputs for five fire behavior variables as related to fire suppression efforts. The results of fire behavior modeling efforts are presented in Tables 3 and 4. Identification of modeling run locations is presented graphically in Figure 4 of this FPP.
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Table 5. Fire Suppression Interpretation
Flame Length (ft)
Fireline Intensity
(Btu/ft/s) Interpretations
Under 4 feet Under 100 BTU/ft/s Fires can generally be attacked at the head or flanks by people using hand tools. Hand line should hold the fire. 4 to 8 feet 100-500 BTU/ft/s Fires are too intense for direct attack on the head by people using hand tools. Hand line cannot be relied on to hold the fire. Equipment such as dozers, pumpers, and
retardant aircraft can be effective.
8 to 11 feet 500-1000 BTU/ft/s Fires may present serious control problems -- torching out, crowning, and spotting. Control efforts at the fire head will probably be ineffective.
Over 11 feet Over 1000 BTU/ft/s Crowning, spotting, and major fire runs are probable.
Control efforts at head of fire are ineffective.
3.4 Project Area Fire Risk Assessment
Wildland fires are a common natural hazard in most of southern California with a long and extensive history.
Southern California landscapes include a diverse range of plant communities, including vast tracts of grasslands and shrublands, like those found adjacent to the Project site. Wildfire in this Mediterranean -type ecosystem ultimately affects the structure and functions of vegetation communities (Keeley 1984) and will continue to have a substantial and recurring role (Keeley and Fotheringham 2003). Sup porting this are the facts that 1) native landscapes, from forest to grasslands, become highly flammable each fall and 2) the climate of southern California has been characterized by fire climatologists as the worst fire climate in the United States (Keeley 2004) with high winds (Santa Ana) occurring during autumn after a six-month drought period each year. Based on this research, the anticipated growing population of western San Bernardino County WUI areas, and the regions fire history, it can be anticipated that periodic wildfires may start on, burn onto, or spot into the Project site. The most common type of fire anticipated in the vicinity of the Project area is a wind-driven fire from the north moving through the chaparral and sage scrub vegetation on the adjacent lands.
With the conversion of the landscape to ignition-resistant development, wildfires may still encroach upon and drop embers on the site but would not be expected to burn through the site or produce sustainable spot fires due to the lack of available fuels. Studies indicate that even with older developments that lacked the fire protection provided in the Project, wildfires declined steadily over time (Syphard, et. al., 2007 and 2013) and further, the acreage burned remained relatively constant, even though the number of ignitions temporarily increased. This is due to the conversion of landscapes to ignition resistant, maintained areas, more humans monitoring areas resulting in early fire detection and discouragement of arson, and fast response from the fire suppression resources that are located within these developing areas.
Therefore, it will be critical that the latest fire protection technologies, developed through intensive research and real-world wildfire observations and findings by fire professionals, for both ignition resistant construction and for creating defensible space in the ever -expanding WUI areas, are implemented, and enforced. The Project, once developed, would not facilitate wildfire spread and would reduce projected flame lengths to levels that would be manageable by firefighting resources for protecting the Project site’s structures, especially given the ignition resistance of the structures and the planned ongoing maintenance of the entire Project site landscape.
Parcel 1
206
Path: Z:\Projects\j1442800\MAPD OC\DOCUM ENT\FPP\Figure 5 Beh avePlusAnalysisMap-Par1.mxd Project Site - Parcel 1
0 1,500 750
Feet
SOURCE: AERIAL-ESRI IMAGERY (accessed 2025)
FIGURE 4
BehavePlus Analysis Map
Fire Protection Plan - University Hills Project
SCENARIO
RUN #1
BBehavePlus Modeling Results for Existing Conditions
Fire Scenarios
Spread
Rate
(mph)
Fireline Intensity
(BTU/feet/second)
Flame
Length
(feet)
Spotting
Distance11
(miles)
Scenario 1: 118% ddownhill slope, 40 mph wind from NE
Fuel Model SH5 – Chaparral 4.7 36.313958 1.8
Fuel Model SCAL18 – Sage, buckwheat 2.1 35.513342 1.8
Fuel Model SH2 – Sage, forbs 0.7 13.11515 0.9
BBehavePlus Modeling Results for Post-PProject Conditions Scenario
Flame
Length
(feet)
Fireline Intensity
(BTU/feet/second)
Spread
Rate
(mph)
Spotting
Distance11
(miles)
Scenario 1:: 25%% downhill sslope, 40 mph wind from NE Fuel Model GS1 – maintained shrubs for fuel
modification
11.1 2.01067 0.8
Fuel Model 8 – Irrigated landscaping/FMZ 2.6 0.146 0.3
Fuel Model NB1 – paved roadway NA NANA NA
SCENARIO
RUN #2
Scenario 2:: 6% uphill slope, 20 mph wind from W/SW
Fuel Model SH2 – Sage, forbs 0.3 8.6603 0.4
Scenario 2 : 220% uphill slope, 20 mph wind from SW Fuel Model GS1 – maintained shrubs for fuel
modification
0.84117.2 0.4
Fuel Model 8 – Irrigated landscaping/FMZ 0.1262.0 0.2
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4 Emergency Response and Service
4.1 Emergency Response Fire Facilities
The Project site is located within the San Bernardino County Fire Protection District (SBCFPD) jurisdictional response area. Regionally, SBCFPD fire, emergency medical, and rescue services from 57 fire stations (full time and paid/volunteer)7. Inland Counties Emergency Medical Agency (ICEMA) provide s emergency medical services and transportation (ambulance service) for residents of San Bernardino, Inyo, and Mono Counties.8 The Valley Region Operating Area is American Medical Response (AMR)9. The SBCFPD serves over 2 million residents throughout 24 incorporated cities and all unincorporated portions of San Bernardino County’s Southern California Inland Empire.
At 20,160 square miles, San Bernardino County is the largest county in the continental United States. Figure 5 illustrates the fire station locations and Table 6 provides a summary of the location, equipment, and staffing levels for the closest responding fire stations.
The Project site lies within Battalion 4, East Valley Zone (Division 2) response area.10 SBCFPD has mutual aid agreements through CONFIRE, a Joint Powers Authority located in San Bernardino County California established to provide communications, dispatch, computer information systems support, and geographic information systems to CONFIRE members and contract agencies. 11 CONFIRE member agencies are: Apple Valley Fire Protection District, Chino Valley Independent Fire District, Colton Fire Department, Loma Linda Fire Department, Rancho Cucamonga Fire District, Redlands Fire Department, Rialto Fire Department, San Bernardino County Fire District, Victorville Fire Department. The SBCFPD is the sponsoring agency of the California Office of Emergency Services Regional Task Force 6 (CA-RTF-6). CA-RTF-6 consists of 30 personnel specially trained and equipped for large or complex Urban Search and Rescue operations.
Primary response will be provided by Fire Station No. 232 (FS 232), located at 6065 N. Palm Avenue in the Verdemont neighborhood of northern San Bernardino. FS 232 is approximately five minutes from the Project site and serves the foothill suburban communi ty known as Verdemont Heights. The station operates 24 hours a day, seven days a week, and is staffed by a three -person Engine Company consisting of a Captain, an Engineer, and a firefighter-paramedic. It is equipped with a Type 1 Medic Engine and a Type 3 Brush Engine (cross-staffed).
Secondary response will be provided by Fire Station No. 75 (FS 75), located at 2852 Macy Avenue in Muscoy, a nearby unincorporated community in San Bernardino County. FS 75 is approximately seven minutes from the Project site and provides service to the va lley region at the base of the foothills . The station operates 24 hours a day, seven days a week, and is staffed by a three-person Engine Company consisting of a Captain, an Engineer, and a firefighter-paramedic. It is equipped with a Type 1 Medic Engine and a Type 3 Brush Engine (cross-staffed).
Additional emergency response will be available from Fire Station No. 227 (FS 227), located at 282 W. 40th Street in the Wildwood Park neighborhood of San Bernardino. FS 227, which is slightly over seven minutes from the Project site, provides paramedic an d fire services to northern portions of the city. The station operates 24 hours a day,
7 https://sbcfire.org/fp5/
8 https://icema.sbcounty.gov/
9 https://www.sbcounty.gov/uploads/LAFCO//Downloads/Service_Review_Fire/Report/Fire_Service_Review.pdf 10 https://sbcfire.org/fp5/
11 https://www.confire.org/about
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seven days a week, and is staffed by a three -person Engine Company consisting of a Captain, an Engineer, and a firefighter-paramedic. It is equipped with a Type 1 Medic Engine and a Type 3 Brush Engine (cross-staffed).
Further support may be provided by Fire Station No. 224 (FS 224), located at 2641 N. E Street, just north of downtown San Bernardino. FS 224 is approximately 10 minutes and 30 seconds from the Project site and serves central urban areas of the city. The station operates 24 hours a day, seven days a week, and is staffed by a three- person Engine Company consisting of a Captain, an Engineer, and a firefighter-paramedic, a three -person Truck Company consisting of a Captain, an Engineer, and a firefighter, a two-person Squad Company consisting of two firefighter-paramedics, and a Battalion Chief. Available apparatus at FS 224 includes a Type 1 Medic Engine, a Medic Aerial Truck, a Medic Squad, and a Battalion Chief vehicle, enhancing its capacity to support major incidents.
In 2022, Medic Engine 224 was the fourth (4th) busiest fire engine in the nation.12 Table 6. Closest Responding SBCFPD Fire Station Summary Station Location Equipment Staffing
Fire Station 232 6065 N. Palm Avenue
San Bernardino, California
(1) Type 1 Medic Engine
(1) Type 3 Brush Engine
3 on-duty
Fire Station 75 2852 Macy Avenue
Muscoy, California
(1) Type 1 Medic Engine
(1) Type 3 Brush Engine
3 on-duty
Fire Station 227 282 W. 40th Street
San Bernardino, California
(1) Type 1 Medic Engine
(1) Type 3 Brush Engine
3 on-duty
Fire Station 224 2641 N. E Street
San Bernardino, California
(1) Type 1 Medic Engine
(1) Medic Aerial Truck
(1) Medic Squad
(1) Battalion Chief
8 on-duty
Source: SBCFPD - https://www.iafflocal935.org/division-2 Within the area’s emergency services system, fire and emergency medical services can be provided by other agencies.
Generally, each agency is responsible for structural fire protection and wildland fire protection within their area of responsibility. However, mutual aid agreements enable non-lead fire agencies to respond to fire emergencies outside their district boundaries. In the Project area, fire agencies cooperate under a statewide master mutual aid agreement for wildland fires. There are also mutual aid agreements in place with neighboring fire agencies and typically include interdependencies that exist among the region’s fire protection agencies for structural and medical responses but are primarily associated with the peripheral “edges” of each agency’s boundary.
4.1.1 Emergency Response Travel Time Coverage
In an effort to understand fire department response capabilities, Dudek conducted an analysis of the travel -time response coverage from the closest responding fire stations. The response time analysis was conducted using travel distances that were derived from Google Road data. Travel times were calculated by applying the distance at speed limit formula (T=(D/S) * 60, where T=time, D=distance in miles, and S=speed in MPH) as well as the nationally recognized Insurance Services Office (ISO) Public Protection Classification Program’s Response Time Standard formula (T=0.65 + 1.7 D, where T= time and D = distance) for comparison. Tables 7 and 8 present tabular results of the emergency response time analysis using the distance at speed formula and the ISO formula, respectively.
12 https://www.instagram.com/sanbernardinocountyfire/p/CdgzlEOM6T4/
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Table 7. Project Emergency Response Analysis using Speed Limit Formula Station
Travel Distance to Project
Site
Travel Time to
Project Entrance *
Total Response
Time**
Fire Station 232 2.9 miles 4 minutes
58 seconds
6 minutes
58 seconds
Fire Station 75 4.1 miles 7 minutes
2 seconds
9 minutes
2 seconds
Fire Station 227 4.4 miles 7 minutes
33 seconds
9 minutes
33 seconds
Fire Station 224 6.1 miles 10 minutes
27 seconds
12 minutes
27 seconds
Notes:
* Assumes travel distance and time to the Project site into the development for the respective fire station. Also assumes application of the distance at speed limit formula (T=(D/S) * 60, where T=time, D=distance in miles, and S=speed in MPH), a 35-mph travel speed, and does not include turnout time.
** Assumes travel distance and time to the Project site into development from the respective fire station, and application of the distance at speed limit formula (T=(D/S) * 60, where T=time, D=distance in miles, and S=speed in MPH), a 35 mph travel speed along with dispatch and turnout time, which can add an additional two minutes to travel time.
Table 8. Project Emergency Response Analysis using ISO Formula Station
Travel Distance to Project
Entrance
Travel Time to
Project Entrance* Total Response Time**
Fire Station 232 2.9 miles 5 minutes
35 seconds
7 minutes
35 seconds
Fire Station 75 4.1 miles 7 minutes
37 seconds
9 minutes
37 seconds
Fire Station 227 4.4 miles 8 minutes
8 seconds
10 minutes
8 seconds
Fire Station 224 6.1 miles 11 minutes
1 second
13 minutes
1 second
Notes:
* Assumes travel distance and time to the Project site into the development for the respective fire station. Also assumes application of the ISO formula, T=0.65+1.7(Distance), a 35-mph travel speed, and does not include turnout time. ** Assumes travel distance and time to the Project site into the development for the respective fire station. Also assumes application of the ISO formula, T=0.65+1.7(Distance), a 35 -mph travel speed, and dispatch and turnout time, which can add an additional two minutes to travel time.
The ISO response travel time formula discounts speed for intersections, vehicle deceleration, and acceleration, and does not include turnout time. As such, per the ISO response travel time formula:
▪ FS 232 is located approximately 2.9 miles from the Project site and is the closet fires station to the Project site. FS 232 can respond to an incident at the Project site within approximately 7 minutes and 35 seconds. ▪ The second closet fire station is FS 75, located approximately 4.1 miles from the Project site . FS 75 can respond to an incident at the Project site within approximately 9 minutes and 37 seconds. ▪ FS 227 located approximately 4.4 miles from the Project site can respond to an incident within 10 minutes and 8 seconds.
▪ FS 224 is located approximately 6.1 miles from the Project site . FS 224 can respond to an incident at Project site within approximately 13 minutes and 1 second.
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Emergency response time target thresholds include travel time along with dispatch and turnout time, which can add two minutes to travel time. FS 232 would provide an initial response as the closest fire station. As indicated in Table 7 and Table 8, the total response time from FS 232 to the Project site does meet the response time standard of 6 minutes according to the nationally recognized National Fire Protection Association (NFPA) 1710.
According to LAFCO for San Bernardino County 3231 , the objective is to have a less than 5 -minute response time 90% of the time in the district. FS 232 to the Project site is outside the response time standard of less than 5 minutes for the objective in th e district. FS 232 is estimated to arrive at the Project site approximately 4 minutes 58 seconds (Speed Limit Formula) or 5 minutes and 35 seconds (ISO Formula) after departing the station. All response calculations are based on an average response speed of 35 mph and are consistent with NFPA 1710.
4.2 Estimated Calls and Demand for Service from
the Project
Determining the potential impact associated with the Project ’s estimated population increase is required to compare how many additional calls may be realized and determine what effects they may have on the available response resources. The estimated incident call volume of the Project is based on a conservatively calculated estimate from the maximum potential number of additional people that would be expected on site. Emergency call volumes related to typical projects can be reliably estimated based on the historical per -capita call volume from a particular fire jurisdiction.
The following estimated annual emergency call volume generated by the Project is based upon per capita data for SBCFPD Division 2 (East Valley) July 1, 2024 – April 30, 2025. 13 ▪ Total population served: 519,58214.
▪ Total annual calls: 43,990, per capita call generation: .0847 ▪ Total annual fire calls (Structure, Vegetation, Vehicle, Other): 4,560, per capita call generation: .0087 ▪ Total annual medical aid calls: 33,395, per capita call generation: .0642 ▪ Total other calls (Investigation, Hazardous Materials, Public Service, Rescue, Traffic Collisions): 5,223, per capita call generation: .0100
▪ Total miscellaneous calls: 811, per capita call generation: .0015 Using the data above, the estimated annual emergency call volume for the Project site as calculated. In order to provide this conceptual estimate, Dudek made assumptions regarding the single-family detached residential units population within the Project s ite to estimate at 3.2 1 persons per household 15. The Project site estimated population for three hundred twenty-seven (327) single-family detached residential units is approximately 1,050 residents. Based on this estimate, the calculated call volume by type of call is provided in Table 9.
13 https://sbcfire.org/statistics/
14 Dudek estimated the census population for Division 2 (East Valley) from census tract populations within the SBCFPD Division 2 boundaries https://data.census.gov/all?q=san+bernardino 15 https://data.census.gov/all?q=san+bernardino
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Table 9. Calculated Call Volume (Conceptual Based on 1,050 residents) for Project Site
Type of Call
Per Capita Call
Generation Factor
Number of Estimated
Annual Calls
Total Calls .0847 89
Total Fires .0087 9
Total Medical Aid .0642 67
Total Other .0100 11
Total MISC .0015 2
As mentioned, the single-family detached residential units will increase the call volume at a rate of conservatively calculated (the actual number of calls may be lower than this estimate) up to eighty-nine (89) calls per year (. 24 calls per day or 7.4 calls per month). Fire Station 232 emergency response time in 2021 totaled 1, 579 calls per year16 (approximately 4.3 calls per day or 131 calls per month). The level of service demand for the Project raises the overall call volume but it is not expected to impact FS 232 to a point where they cannot meet the demand. For perspective, 5 calls per day are typical in an urban or suburban area. A busy fire station company would be one with 10 to 15 or more calls per day. When University Hills Project site is built out, FS 2 32 could potentially respond to additional .24 calls per day or 7.48 calls per month, although the number may be likely lower that based on the conservative nature of the population and calls per capita data used in this estimate.
16 https://www.iafflocal935.org/2018-call-stats/
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Date: 6/12/2025 User: rstrobridge Path: Z:\Projects\j1442800\MAPDOC\FPP\Encore Hills Fire Protection Plan.aprx Map: SBCFPD Fire Stations Map Layout: Figure 5 SBCFPD Fire Stations Map SOURCE: Bing Maps 2024, CALFIRE 2023
Fire Protection Plan - University Hills Project
SBCFPD Fire Stations Map
FIGURE 5
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5 Fire Safety Requirements-
Infrastructure, Building Ignition
Resistance, and Defensible Space
The FPP demonstrates that the development site would comply with applicable portions of the San Bernardino County Fire Protection District Fire Code, Ordinance No. FPD 23 -01, SBCFPD Fire Code Fire Prevention Standards A-1, A-2, A-3, A-4, SRA-1, as well as applicable portions of the San Bernardino County Development Code, Chapter
82.13 Fire Safety Overlay . SBCFPD Fire Code adopts with amendments the 2022 CFC , including Chapter 49 , California Code of Regulations, Title 24, Part 9 , based on the 2021 edition of the International Fire Code .
Furthermore, the Project will be consistent with applicable portions of Article III, Section 5-61 – Building Code, which adopts with amendments the 2022 edition of the CBC, including Chapter 7A, California Code of Regulations Title 24, Part 2 governs the building, infrastructure, and defensible space requirements detailed in this FPP. The Project will meet or exceed applicable codes or will provide alternative materials and/or methods (as warranted). While these standards will provide a high level of protection to structures within the development, there are no guarantees that compliance with these standards will prevent damage or destruction of structures by fire in all cases. The following summaries highlight important fire protection features. Prior to bringing combustible materials onto the site, utilities should be in place, fire hydrants operational, an approved all -weather roadway, or an approved road surface alternative in place, and interim defensible space zones established and approved. A response map update, including roads and fire hydrant locations, in a format compatible with current SBCFPD mapping shall be provided to the SBCFPD. The following summaries highlight important fire protection features.
5.1 Fire Apparatus Access
The proposed Project site will be accessible via two (2) access points, one on the existing North Campus Parkway and the other on the new Badger Canyon Road.
Project site access, including road widths and connectivity, will comply with the requirements of the SBCFPD Fire Code Fire Prevention Standards A -1, A-2, A-3, A-4, SRA-1, the 2022 California Fire Code, and all other applicable codes including:
▪ Roadways and/or driveways will provide fire department access to within 150 feet of all portions of the exterior walls of the first floor of each structure (CFC 503.1.1). ▪ Further, there must be a walkway approved by the SBCFPD leading from fire apparatus access roads to exterior openings (CFC 504.1).
▪ Roadway design features (e.g., speed bumps, humps, speed control dips, planters, and fountains) that could interfere with emergency apparatus response speeds and required unobstructed access road widths will not be installed or allowed to remain on roadways without approval of an SBCFPD official (CFC 503.4). ▪ Given the Project is required by CFC D104.1 to have at least two access points, those access points shall be placed a distance apart equal to not less than one half of the length of the maximum overall diagonal dimension of the lot or area to be served, measured in a straight line between accesses (D104.3).
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5.1.1 Roads
All fire access roads associated with the Project will be in compliance with SBCFPD Fire Code Fire Prevention Standards A-1, A-2, A-3, SRA-1, the 2022 California Fire Code, and all other applicable codes. Fire apparatus access roads shall be provided to within 150 feet of all exterior portions of the first story of every building, facility or structure as measured by an approved route around the exterior building or structure.
5.1.1.1 Maximum Dead-End Road Length
There are no dead-end fire apparatus access roads planned in the Project area. The fire access lanes around are continuous and loop around the entirety of the development. Dead-end roads between 150 feet and 750 feet in length require a 96-foot diameter cul-de-sac or other approved method of fire apparatus turnaround (CFC Section D103.4). All dead-end fire access roads included at any phase of the development shall comply with the following:
▪ The maximum length of dead-end fire access roadways shall be six hundred (six hundred) feet in length in all residential developments (SBCFPD Standard A-1).
5.1.1.2 Surface and Grade
Fire access roads must be able to support fully loaded fire engines and be of a subtle enough grade to facilitate their travel. The surface and grade of all fire apparatus access roads associated with the Project comply with SBCFPD Fire Prevention Standard Fire Apparatus Access Road Design, Construction and Maintenance (SBCFPD Standard A-1):
▪ All roads comply with access road standard s of the capability of supporting an imposed load of at least 75,000 pounds, fire apparatus weight is distributed as 55,000 lbs. on the rear dual axles and 20,000 lbs. on the front axle.
▪ Fire access roadways shall be paved with a concrete or asphalt material in order to provide “all weather” safe driving.
▪ Unless otherwise approved, the grade of a fire apparatus access road shall not exceed 12% and the cross slope shall not exceed 5%.
▪ The angles of approach and departure for fire apparatus access roads shall be a maximum of 5% grade change for ten feet of approach and departure.
▪ All turns within fire access roadways that accommodate two-way traffic of fire apparatus shall be a minimum of 19 feet inside radius and 45 feet outside radius.
▪ Fire access roadways require at least a 50-foot straight section of roadway between radius turns.
5.1.1.3 Width and Clearance
Fire apparatus access roads must be of an appropriate width and clearance to facilitate the ingress and egress of engines. The width and clearance of fire access roads associated with the Project comply with SBCFPD Fire Prevention Standard Fire Apparatus Access Road Designation and Marking (SBCFPD Standard A-2):
▪ Fire apparatus access roadways serving all buildings, structures, or facilities, shall be a minimum of 26 feet in unobstructed width. Roadways that have raised medians shall have an unobstructed one -way width of
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20 feet with signage posted ‘per SBCFPD Standard A -2. Such medians shall be a maximum of 50 feet in width except where approved by the Fire Code Official. Roadways with raised medians shall have intersections or median breaks located at a maximum of 600 feet apart or as approved by the Fire Code Official.
▪ All fire access roadways shall be no less than 14 feet 6 inches in unobstructed vertical clearance, as measured from the roadway surface at the highest elevation to the lowest point of any obstruction. ▪ Parking is not permitted on roadways that are less than 32 feet in width. In addition, parking that is perpendicular or diagonal to the edge of the roadway shall not obstruct the required minimum width of 26 feet for fire access.
5.1.1.3.1 Aerial Fire Apparatus Access Roads
Approved aerial fire apparatus access roads shall be provided for buildings that are three (3) stories or more or thirty feet or more in height associated with the Project comply with SBCFPD Fire Prevention Standard Fire Apparatus Access Road Design, Construction and Maintenance (SBCFPD Standard A-1):
▪ Aerial fire apparatus access roads shall have a minimum unobstructed width of thirty (30) feet. ▪ All fire access roadways shall be no less than 14 feet 6 inches in unobstructed vertical clearance, as measured from the roadway surface at the highest elevation to the lowest point of any obstruction ▪ Overhead utilities, powerlines, and any other items that could be considered obstructions shall not be located within the aerial fire apparatus access area.
▪ Aerial fire apparatus access shall be provided in locations to enable rapid and safe access to the roof of the building. The location of all roof access points shall be approved by SBCFPD.
5.1.1.4 Fire Lane Marking
All roadways equal to or less than SBCFPD Standards for width, including private roads, where the roadway width would preclude any parking along the sides of the road or where parking along only one side of the road is allowed shall be designated and marked as a fire lane associated with the Project comply with SBCFPD Fire Prevention Standard Fire Apparatus Access Road Designation and Marking (SBCFPD Standard A-2):
▪ All roadways encircling and/or providing direct access to commercial developments shall be designated as a fire lane.
▪ Areas within fifteen feet (15’) of any fire appliance shall be designated as a fire lane. ▪ All fire apparatus access roads shall be identified by approved signs, approved red curbs and/or approved pavement striping.
Signage :
▪ Signs shall be no less than eighteen inches (18”) high by twelve inches (12”) wide and made of durable material.
▪ Signs shall be labeled, “NO PARKING,” “FIRE LANE,” and “CVC 22500.1” in all upper-case letters. ▪ Letting shall be no less than three inches (3”) high with red letting on white background . “CVC 22500.1” shall have one inch (1”) letters.
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▪ The perimeter of the sign shall have a one inch (1’’) red boarder. ▪ Signs shall be installed with no less than a seven -foot (7 ’) clearance from the bottom of the sign to finish grade.
▪ Signs shall be installed with twenty-four inches (24”) of the curb face. ▪ Signs shall be located no more the fifty feet (50 ’) apart when installed on one side of the street and one hundred feet (100’) apart when installed on both sides of the street. ▪ There shall be a sign within five feet (5’) of the beginning and end of any fire lane.
Red Curbing :
▪ Curbing used to designate fire lanes shall be painted in a weather-resistant red paint. Reflective paint may be used for higher visibility.
▪ Curbing shall be labeled, “NO PARKING – FIRE LANE – CVC 22500.1” in all upper-case letters. ▪ Lettering shall be no less than three inches (3”) high with white lettering on a red background and placed on the face and top of the curb.
▪ Lettering shall be located no more than fifty feet (50 ’) apart and within five feet (5 ’) of the beginning and end of any fire lane.
5.1.2 Gates
Multiple gates may be proposed as part of the Project, one along the existing North Campus Parkway and another on the newly constructed Badger Canyon Road. All gates associated with the Project shall comply with the SBCFPD Fire Prevention Standard Gates and Other Obstructions to Fire Apparatus Access (SBCFPD Standard A-3):
Manually Operated Security Gates :
▪ Manual gates shall have a means of emergency operation that allows manual operation by one person .
Manually operated gates shall be equipped with an approved “Knox” padlock or equivalent locking system acceptable to SBCFPD.
▪ Manual gates shall either slide open horizontally or swing inward in the direction of emergency vehicle ingress.
▪ Gates provide emergency access to fuel modification zones or wildland areas shall have a clear open width of the access road.
▪ Parking of vehicles shall not obstruct any entrance, or the operation of any gate installed per the requirements of SBCFPD. “NO PARKING” signs designed and installed in accordance with SBCFPB Standard A-2 may by required as directed by SBCFPD.
▪ When required by SBCFPD, entry gates shall be installed to provide a minimum of forty feet (40’) of fire apparatus stacking from the intersecting road.
Electrically Operated Security Gates
▪ Electrically operated security gates at multifamily residential properties (apartments, gated housing tracts, etc.) shall be equipped with an emergency preemption device, or an automatic means of opening the gate for emergency access by SBCFPD. The location and type of emergency opening devices shall be approved
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by the SBCFPD and may include Opticom, or equivalent sensors and/or Knox key switches as deemed necessary by SBCFPD.
▪ Any preemption devices on electric gates shall override all normal gates operations and completely open the gate(s). After preemption devices are activated, gates shall be maintained in an open position for a minimum of twenty (20) minutes, after which the gate controller shall automatically reset and close the gates.
▪ All electric motors operation security gates that obstruct fire apparatus access roadways or systems shall be listed in accordance with ASTM F2200 and UL 325 and shall reach the fully open position within a total time not to exceed one second for each one foot of obstructed required width. ▪ A safety loop or device that prevents the gate from closing on vehicles going through the gate shall be installed on all electric gates.
▪ An automatic exit loop that activates the gate in the direction of egress shall be installed on all electric gates, or an additional preemption device/Knox switch may be installed in the direction of emergency vehicle egress with approved by SBCFPD.
Electric gates without battery backup power shall be provided with a manual release to allow the gate to be operated manually when electrical service is interrupted.
5.1.3 Premises Identification
Identification of roads and structures will comply with SBCFPD Fire Prevention Standard Building and Premises Identification (SBCFPD Standard B-1) as follows:
▪ The address identification shall be legible and affixed to the building and placed in a position that is visible from the street or fire department access road fronting the property. ▪ All address identification characters shall contrast with their background. ▪ Address identification shall be Arabic numerals or alphabetical letters. Numbers shall be spelled out. ▪ Each character shall not be less than eight inches (8”) high with a minimum stroke width of one inch (1”). ▪ During the hours of darkness, they shall be electrically illuminated with an internal low voltage light source. ▪ Where building setbacks exceed 200 feet from the street, or where address identification would not be visible or would otherwise be obstructed, additional non -illuminated address identification shall be displayed on a monument, sign or other approved means used to identify structures. Additional address identification characters shall not be less than six inches (6”) in height, with a minimum stroke width of three-quarter inches (3/4”).
▪ Where required, address identification shall be provided in additional approved locations to facilitate emergency response.
▪ Address identification shall be maintained.
▪ Buildings which have vehicular access to the rear side by means of a drive aisle, alley, or parking lot shall also display address identification meeting the minimum requirements of this Standard on the rear of the building
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5.1.4 Ongoing Infrastructure Maintenance
The Project BOA and/or Property Manager(s) shall be responsible for long term funding and maintenance of internal private roads , communal fuel modification zones, and fire protection systems ( including fire sprinklers ). The maintenance responsibilities of fuel modification zones and defensible space are discussed in more detail in section 5.4.
5.1.5 Pre-Construction Requirements
Prior to bringing lumber or combustible materials onto the site, site improvements within the active development area shall be in place, including utilities, operable fire hydrants, an approved, temporary roadway surface, and fuel modification zones established. These features shall be approved by the fire department designee prior to combustibles being brought on -site. Any combustible scrap materials will be noticed on a daily basis or more frequently, as required by the SBCFPD.
5.2 Infrastructure and Fire Protection Systems
5.2.1 Water Supply
Water service for Project site will be provided by San Bernardino County Municipal Water District, Division 1 17 (SBCMWD). All water storage and hydrant locations, mains, and water pressures would be designed to fully comply with SBCFPD Fire Flow Requirements. As detailed in the SBCFPD Fire Code Section 507 and California Fire Code Section 903.2, all residential structures are required to have NFPA 13D property protection internal fire sprinklers.
Therefore, water supply must meet a two-hour fire flow requirement.
The water supply will be capable of supplying the required fire flow for fire protection and sized according to the applicable codes and design standards. An SBCFPD official will be notified prior to a water supply test or provided with approved documentation before approval of the water supply system (CFC Section 507.4).
5.2.2 Hydrants
Fire Hydrant systems shall comply with SBCFPD Fire Code 507.5.1 through 507.5.6 and SBCFPD Fire Prevention Standards.
5.2.3 Automatic Fire Sprinkler Systems
Fire sprinklers systems shall be in accordance with SBCFPD Fire Prevention Standard Fire Sprinkler Systems in Non-Residential Buildings (SBCFPD Standard F -1), and National Fire Protection Association (NFPA) Standard 13.
Fire sprinkler plans for each structure will be submitted and reviewed by SBCFPD for compliance with the applicable fire and life safety regulations, codes, and ordinances as well as the SBCFPD Standard F-1.
17 https://open.sbcounty.gov/datasets/c84c98f3562e497db74ab82af4c1c6a7/explore?location=34.091056%2C- 117.329611%2C11.53
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5.3 Ignition Resistant Construction and Fire
Protection Systems
All new structures within the Project site will be constructed to Fire Code standards. Each of the proposed buildings will comply with the enhanced ignition -resistant construction standards of the 2022 CBC (Chapter 7A). These requirements address roofs, eaves, exterior walls, vents, appendages, windows, and doors and result in hardened structures that have been proven to perform at high levels (resist ignition) durin g the typically short duration of exposure to burning vegetation from wildfires. Appendix D, Ignition-Resistant Construction Requirements provides a summary of the requirements for ignition resistant construction.
While these standards will provide a high level of protection to structures in this development, there is no guarantee that compliance with these standards will prevent damage or destruction of structures by fire in all cases.
There are three primary concerns for structure ignition: 1) radiant and/or convective heat, 2) burning embers, and 3) direct flame impingement (NFPA 1144 2008, IBHS 2008, and others). Burning embers have been a focus of building code updates for at least the last decade, and new structures in the Wildland Urban Interface (WUI) built to these codes have proven to be very ignition resistant. Likewise, radiant, and convective heat impacts on structures have been minimized through Chapter 7A exterior fire ratings for walls, windows, and doors. Additionally, provisions for modified fuel areas separating wildland fuels from structures have reduced the number of fuel-related structure losses. As such, most of the primary components of the layered fire protection system provided the Project are required by the SBCFPD but are worth listing because they have been proven effective for minimizing structural vulnerability to wildfire and, with the inclusion of required NFPA 13D automatic interior fire sprinklers within all residential buildings for extinguishing interior fires, should embers succeed in entering a structure. Even though these measures are now required by the latest Building and Fire Codes, at one time, they were used as mitigation measures for buildings in WUI areas, because they wer e known to reduce structure vulnerability to wildfire. These measures performed so well; they were adopted into the code. The following Project features are required for new development in WUI areas and form the basis of the system of protection necessary to minimize structural ignitions as well as providing adequate access by emergency responders:
1. The 7A Materials and Construction Methods for Exterior Wildfire Exposure CBC chapter details the ignition resistant requirements for the following key components of building safely in wildland urban interface and fire hazard severity zones:
a. Roofing Assemblies (covering, valleys and gutters)
b. Vents and Openings
c. Exterior wall covering
d. Open Roof Eaves
e. Closed Roof Eaves and Soffits
f. Exterior Porch Ceilings
g. Floor projections and underfloor protection
h. Underfloor appendices
i. Windows, Skylights and Doors
j. Decking
k. Accessory structures
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2. New class-A fire rated roof and associated assembly. With the proposed class-A fire rated roof, areas where there will be attic or void spaces requiring ventilation to the outside environment, the attic spaces will require either ember-resistant roof vents or a minimum 1/16-inch mesh (smaller sizes restrict air flow) and shall not exceed 1/8 -inch mesh for side ventilation (recommend Vulcan, BrandGuard, O’Hagin or similar vents. Structures along the perimeter of the development shall not have any vents on th e side of the structures that face the fuel modification zones and/or off -site vegetation areas. All vents used for this Project will be approved by SBCFPD.
3. Per Chapter 7A of the CBC, for structures that achieve the minimum 100 feet of on-site fuel modification, all exterior windows, skylights, and exterior glazed door assemblies shall be constructed of multipaned glazing with a minimum of one tempered pane. All windows shall be UL listed, not of vinyl construction, and shall have a fire-resistant rating of not less than 20 minutes when tested according to NFPA 257/UL 263 (such as SaftiFirst, SuperLite 20 -minute rated glass product), or be tested to meet the pe rformance requirements of State Fire Marshal Standard 12-7A-2.
4. The proposed Project structures would be constructed of ignition resistant 18 construction materials and include the installation of National Fire Protection Association (NFPA) 13D automatic interior fire sprinkler systems within all residential buildings, based on the latest adopted Building and Fire Code requirements for each occupancy type.
5. Modern infrastructure, access roads, and water delivery system.
5.4 Defensible Space and Vegetation Management
WUI fire protection requires a systematic approach, which includes the components of infrastructure and water, structural safeguards (addressed in the FPP), and adequate defensible space setbacks. A critical component of a fire protection system for this Project is the provision for ignition -resistant landscapes. A fuel modification zone (FMZ) is a strip of land where combustible vegetation has been removed and/or modified and partially or totally replaced with more adequately spaced, drought-tolerant, fire resistant plants in order to provide a reasonable level of protection to structures from wildland fire. FMZs are designed to provide vegetation buffers that gradually reduce fire intensity and flame lengths from advancing fire by strategically placing thinning zones, restricted vegetation zones, and irrigated zones adjacent to each other on the perimeter of the WUI exposed structures.
Cohen (1995) performed structure ignition fire research studies that suggest, as a rule -of-thumb, larger flame lengths and widths require wider fuel modification zones to reduce structure ignition. For example, val id Structure Ignition Assessment Modeling results indicate that a 20 -foot-high flame has minimal radiant heat to ignite a structure (bare wood) beyond thirty-three feet (horizontal distance). Whereas a 70-foot-high flame requires about 130 feet of clearance to prevent structure ignitions from radiant heat (Cohen and Butler 1996). For this fire study example, bare wood was used, which is more combustible unlike the ignition-resistant construction of the Project.
For the Project, assuming 42-foot flame lengths (modeled under a Santa Ana wind gust) , the 100 feet of fuel modification is more than sufficient.
Based on the modeled extreme weather flame lengths for the Project site once developed and FMZs are in place, wildfire flame lengths are projected to be approximately between 1 and 3 feet in height within the areas of the Project Footprint that are not paved (the well-maintained irrigated areas of the development) . The adjacent sage
18 A type of building material that resists ignition or sustained flaming combustion sufficiently to reduce losses from wildland-urban interface conflagrations under worst-case weather and fuel conditions with wildfire exposure of burning embers and small flames, as prescribed in CBC, Chapter 7A and State Fire Marshal Standard 12-7A-5, Ignition-Resistant Materials.
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scrub intermixed with non-native grasslands would remain unaltered and retain the fire behavior of existing conditions. This can be altered when neighboring property owners perform weed abatement. The fire behavior modeling system used to predict these flame lengths was not intended to determine sufficient FMZ widths, but it does provide the average predicted length of the flames, which is a key element for determining “defensible space” distances for providing firefighters with room to work and minimizing structure ignition. Due to site constraints, it is not possible to achieve a minimum 100 feet of on-site fuel modification width for every building on the Project site.
Areas of the development that do not achieve the required minimum 100 feet of defensible space on site will provide off site equivalent defensible space and FMZs or provide a non-combustible, six-foot heat-deflecting wall.
5.4.1 San Bernardino County Fuel Modification Zone Standards and Defensible Space
Defensible space, coupled with property hardening, is essential to improve a building’s chance of surviving wildfire.
Defensible space is the buffer created between a building and the grass, trees, shrubs, or any wildland area that surrounds it. This space is needed to slow or stop the spread of wildfire, and it helps protect buildings from catching fire—either from embers, direct flame contact or radiant heat. Proper defensible space also provides firefighters with a safe area to work in, to defend the building. The purpose of this section is to document SBCFPD’s standards and make them available for reference . SBCFPD’s Fire Code are consistent with the 2022 California Fire Code (Section 4907 — Defensible Space), Government Code 51175 – 51189, and Public Resources Code 4291, which require that fuel modification zones be provided around every building that is designed primarily for human habitation or use within an SRA or a LRA VHFHSZ.
FMZ and Defensible Space, when properly maintained, along with other fire hazard reducing features, will effectively minimize the potential for structure ignition from direct flame impingement or radiant heat within the Project area.
Assembly Bill 3074, passed into law in 2020, requires a third zone for defensible space. This law required the Board of Forestry and Fire Protection to develop the regulation for a new ember-resistant zone (Zone 0) within 0 to 5 feet of the home by January 1, 2023. The intensity of wildfire fuel management for a traditional FMZ varies within the 100-foot perimeter of the structure, with more intense fuels ’ reduction occurring closer to the structure. A Fuel Modification Plan shall be reviewed and approved by a SBCFPD Fire Safety Specialist for consistency with defensible space and fire safety guidelines. The Project’s Fuel Modification Plan — Parcel 1 (Figure 6) conceptually displays a non-combustible and fully irrigated FMZ area for the Project site.
To ensure long-term identification and maintenance, a fuel modification area shall be identified by a permanent zone marker meeting the approval of SBCFPD. All markers will be located along the perimeter of the fuel modification area at a minimum of 500 feet apart or at any direction change of the fuel modification zone boundary.
This applies only to the on-site FMZ areas and would not be provided off -site on roadways and similar landscapes that are providing FMZ equivalent. FMZs will be maintained on at least an annual basis or more often as needed to maintain the fuel modification buffer function.
5.4.2 San Bernardino County Fuel Modification Zones
The Fuel Modification Zones affect new structures and developments built in the high fire hazard areas. A plan shall be approved by the SBCFPD that helps protect developments by requiring vegetation planted in zones around structures to be selected from an approved list and identifies areas that require brush clearance or thinning . The entire property from the exterior of the building to the property lines will be either irrigated landscaping or
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non-combustible paved surfaces in the form of roads, walkways, parking areas, and loading and unloading areas.
The landscaping requirements for each zone is described below.
ZONE “O” – Ember Resistant Zone
Zone 0 applies around all project structures. T he first five (5) feet from the home is the most important for preventing ember ignition. Keeping the area closet to buildings, structures, and decks clear will prevent embers from igniting materials that can spread the fire to the structure.
The majority of homes lost to wildfire are ignited by flying embers. Embers can travel miles ahead of the active front of wildfires.
What to do:
1. Use hard scape like gravel, pavers, or concrete. No combustible bark or mulch.
2. Remove all dead and dying plants, weeds, debris (leaves, needles, etc.) from your roof, gutter, deck, porch, stairways, and under any areas of your home.
3. Remove all branches within ten feet (10’) of any chimney or stovepipe outlet.
4. Limit combustible items (like outdoor furniture and planters) on top of decks.
5. Relocate firewood and lumber to Zone 2.
6. Replace combustible fencing, gates, and arbors attached to the homes with noncombustible alternatives.
7. Consider relocating garbage and recycling containers outside this zone.
8. Consider relocating boats, RV’s vehicles, and other combustible items outside this zone.
ZONE “1” – “Wet Zone” Keep it Lean, Clean and Green within 30 feet of structures.
Zone 1 applies to all project structures and facilities including parks and retention basins. Regularly clear dead or dry vegetation and create space between trees. Vegetation to be irrigated. During drought times when watering is limited, pay special attention to clearing dead or dying material. Removing dead plants and creating space between trees and shrubs creates a buffer on the property and reduces potential fuel for fire.
What to do:
1. Remove all the dead plants, grass, and weeds.
2. Remove dead or dry leaves and pine needles.
3. Trim trees regularly to keep branches at a minimum of ten feet (10’) from structures.
4. Plantings should be limited to well irrigated, well -spaced low fuel volume, high fuel moisture, drought tolerant, low profile fire resistive groundcover, shrubs or lawn
5. Spacing between shrubs should be two times the height of the shrub. Trees shall be limbed and pruned 1/3 of the height or six feet (6') from ground, spacing shall be thirty feet (30') for mature trees.
6. Create a separation between trees, shrubs, and items that could catch fire, such as patio furniture, wood piles, swing sets, etc.
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ZONE “2” 31-100 feet from structures .
Zone 2 applies around all project structures beginning at the edge of Zone 1 (30 feet) and continuing outwards up to 100 feet. Zone 2 treatments continue to reduce potential fuel within 100 feet of structures. 100 feet of defensible space is required by Public Resource Code (PRC) 4291.
What to do:
1. Manufactured slopes and landscape plantings to be well-irrigated.
2. Natural vegetation should be maintained to have horizontal space between shrubs and trees and vertical space between grass, shrubs, and trees. Spacing between shrubs should be two times the height of the shrub. Trees shall be limbed and pruned 1/3 of the height or six feet (6') from ground, spacing shall be thirty feet (30') for mature trees.
3. Maintain all vegetation free of deadwood.
4. Cut or mow annual grass down to maximum height of four inches (4”), no dry grass is allowed.
5. Remove fallen leaves, needles, twigs, bark, cones, and small branches. However, they may be permitted as mulch to a depth of three inches (3”).
6. Keep ten feet (10’) of clearance around exposed wood piles, down to bare mineral soil, in all directions.
7. Clear areas around outbuildings and propane tanks. Keep ten feet (10’) of clearance to bare mineral soil and no flammable vegetation for an additional ten feet (10’) around the exterior.
ZONE “ 3” 100 feet from Property Line measured inwards towards project .
Zone 2 applies between the Project and unmaintained open space measured from the Property Line 100 feet inward. Remove and reduce fuel from a potential fire pathway from unmaintained open space towards the structures.
What to do:
1. Manufactured slopes and landscape plantings to be well-irrigated.
2. Interrupt continuous fuel beds by providing horizontal space between shrubs and trees and vertical space between grass, shrubs, and trees. Spacing between shrubs should be two times the height of the shrub, with twenty feet (20’) between large groupings of shrubs or trees. Trees shall be limbed and pruned 1/3 of the height or six feet (6’) from ground, spacing shall be thirty feet (30') for mature trees.
3. Maintain all vegetation free of deadwood.
4. Cut or mow annual grass down to maximum height of four inches (4”), no dry grass is allowed.
5. Remove fallen leaves, needles, twigs, bark, cones, and small branches. However, they may be permitted as mulch to a depth of three inches (3”).
6. Keep ten feet (10’) of clearance around exposed wood piles, down to bare mineral soil, in all directions.
7. Clear areas around outbuildings and propane tanks. Keep ten feet (10’) of clearance to bare mineral soil and no flammable vegetation for an additional ten feet (10’) around the exterior.
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5.4.3 Ongoing Infrastructure and FMZ Maintenance
Vegetation management, i.e., assessment of fuel modification zone conditions and removal of dead and dying and undesirable species; as well as thinning as necessary to maintain specified plant spacing and fuel densities, shall be completed annually by May 1 of each year and more often as needed for fire safety. The Project’s BOA and/or Property Manager shall be responsible for all fuel modification vegetation management in compliance with the plan and the SBCFPD requirements for all areas of the Project site, including fuel modification zones. The Project’s BOA and/or Property Manager will assure lots comply with the plan initially and on an ongoing basis. Chapter 7A requirements for ongoing maintenance of fire -resistive building materials and fire sprinkler systems will be maintained to a code -complying level, as -approved in this or similar documents, in perpetuity . Additionally, the Project’s BOA and/or Property Manager shall be responsible for ensuring long-term funding and ongoing compliance with all provisions of the FPP, including vegetation planting, fuel modification on the perimeter, and maintenance requirements on all communal areas and roadsides.
Maintenance of FMZ ’s and Defensible Space is a critical component for the long -term fire safety of the Project. maintenance obligations will be as follows:
▪ All future plantings shall be in accordance with SBCFPD fuel modification requirements. ▪ The SBCFPD will review landscape plans and provide corrections where necessary so that they are in compliance with SBCFPD standards.
▪ Changing landscaping in communal areas will be reviewed by the SBCFPD and approved prior to installation.
Project ’s BOA and/or Property Manager :
▪ The Project’s BOA and/or Property Manager will maintain the access roads within the Development Footprint adjacent to open space areas.
▪ The Project’s BOA and/or Property Manager will be required to annually maintain the FMZs (or as needed). ▪ The Project’s BOA and/or Property Manager will maintain all communal areas, including trees planted along internal roadways and in other areas throughout the Project.
5.4.4 Construction Phase Vegetation Management
Vegetation management requirements shall be implemented at commencement and throughout the construction phase. Vegetation management for the Project area shall be performed pursuant to the FPP and FAHJ on all building locations prior to the start of work and prior to any import of combustible construction materials. Adequate, code complying, fuel breaks shall be created around all grading, site work, and o ther construction activities in areas where there is flammable vegetation. Fuel Modification Zones will be maintained, as approved, throughout construction and in perpetuity thereafter. Caution must be used not to cause erosion or ground (including slope) instability or water runoff due to vegetation removal, vegetation management, maintenance , landscaping, or irrigation. Combustible materials will not be brought on-site without prior fire department approval.
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5.5 Pre-Construction Defensible Space Requirements
Per SBCFPD, a fuel modification plan (refer to Figure 6) shall be submitted and have preliminary approval prior to any subdivision of land; or, have final approval prior to the issuance of a permit for any permanent structure used for habitation; where, such structure or subdivision is located within areas designated as a Fire Hazard Severity Zone within SRA or within the LRA. An on-site inspection must be conducted by the SBCFPD, and final approval of the fuel modification plan issued prior to a certificate of occupancy being granted by the building code official.
As an additional consultant recommendation, prior to bringing lumber or combustible materials onto the Project site, improvements within the active development area shall be in place, including utilities, operable fire hydrants, an approved, temporary roadway surface, and fuel modification zones established. As demonstrated in Figure 6, Fuel Modification Plan — Parcel 1, there are some areas where 100 feet of Fuel Modification cannot be achieved on site. This section allows for a conservative fire analysis of the Project area.
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MERGENCYE
EHICLEV
CCESSA
OPEN
SPACE
LOT
OPEN
SPACE
LOT
PARK
PARK
DESIGNATED
REMAINDER
79 ft
66 ft
79 ft
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Feetn
Parcel 1
1 2
34 5
Project Site - Parcel 1
Property Line
Grading Limits
Land Use
Development
Roadway Access
Access Road
Emergency Vehicle Access
Water Quality Basin
Fuel Modification Zone
Zone 0 (0-5 ft)
Zone 1 (5-30 ft)
Zone 2 (30-100 ft)
Zone 3 Property line (PL) to 100 ft inward
0-100-ft (Water Tank)
20-ft Roadside Zone
FIGURE 6 - View 1
Fuel Modification Plan - Parcel 1
Fire Protection Plan - University Hills Project
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SPACE
LOT
WATER
TANK
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Feetn
FIGURE 6 - View 2
Parcel 1
1 2
34 5
Project Site - Parcel 1
Property Line
Grading Limits
Land Use
Development
Roadway Access
Access Road
Emergency Vehicle Access
Water Quality Basin
Fuel Modification Zone
Zone 0 (0-5 ft)
Zone 1 (5-30 ft)
Zone 2 (30-100 ft)
Zone 3 Property line (PL) to 100 ft inward
0-100-ft (Water Tank)
20-ft Roadside Zone
Fuel Modification Plan - Parcel 1
Fire Protection Plan - University Hills Project
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SPACE
LOT
OPEN SPACE LOT
PARK
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Feetn
FIGURE 6 - View 3
Parcel 1
1 2
34 5
Project Site - Parcel 1
Property Line
Grading Limits
Land Use
Development
Roadway Access
Access Road
Emergency Vehicle Access
Water Quality Basin
Fuel Modification Zone
Zone 0 (0-5 ft)
Zone 1 (5-30 ft)
Zone 2 (30-100 ft)
Zone 3 Property line (PL) to 100 ft inward
0-100-ft (Water Tank)
20-ft Roadside Zone
Fuel Modification Plan - Parcel 1
Fire Protection Plan - University Hills Project
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CAMPUS PARKWAY
BADGER CANYON RD
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Feetn
Parcel 1
1 2
34 5
Project Site - Parcel 1
Property Line
Grading Limits
Land Use
Development
Roadway Access
Access Road
Emergency Vehicle Access
Water Quality Basin
Fuel Modification Zone
Zone 0 (0-5 ft)
Zone 1 (5-30 ft)
Zone 2 (30-100 ft)
Zone 3 Property line (PL) to 100 ft inward
0-100-ft (Water Tank)
20-ft Roadside Zone
FIGURE 6 - View 4
Fuel Modification Plan - Parcel 1
Fire Protection Plan - University Hills Project
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CAMPUS PARKWAY
BADGER CANYON RD
NORTHPARKBLVD
W CAMPUS PKWY
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Parcel 1
1 2
34 5
Project Site - Parcel 1
Property Line
Grading Limits
Land Use
Development
Roadway Access
Access Road
Emergency Vehicle Access
Water Quality Basin
Fuel Modification Zone
Zone 0 (0-5 ft)
Zone 1 (5-30 ft)
Zone 2 (30-100 ft)
Zone 3 Property line (PL) to 100 ft inward
0-100-ft (Water Tank)
20-ft Roadside Zone
FIGURE 6 - View 5
Fuel Modification Plan - Parcel 1
Fire Protection Plan - University Hills Project
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6 Wildfire Education Program
Early evacuation for any type of wildfire emergency at the Project site is the preferred method of providing for employees and customer safety, consistent with the SBCFPD’s current approach. As such, the Project’s BOA and/or Project’s Property Manager would formally adopt, practice, and implement a “Ready, Set, Go!” approach to evacuation19. The “Ready, Set, Go!” concept is widely known and encouraged by the State of California and most fire agencies. Pre-planning for emergencies, including wildfire emergencies, focuses on being prepared, having a well-defined plan, minimizing the potential for errors, maintaining the Project site ’s fire protection systems, and implementing a conservative (evacuation as early as possible) approach to evacuation and Project area activities during periods of fire weather extremes.
Project occupants would be provided ongoing education by the BOA/Property Management regarding wildfires and the FPP ’s requirements. The educational information must include maintaining the landscape and structural components according to the appropriate standards designed for the development. Informational handouts, website pages, mailers, fire-safe council participation, inspections, and seasonal reminders are some methods that would be used to disseminate wildfire and relocation awareness information. SB CFPD would review and approve all wildfire educational material and programs before printing and distribution.
Additionally, management of on -site entities occupying the site ’s structures will be required to register for Countywide alerts via the Telephone Emergency Notification Systems (TENS) and San Bernardino Ready App (SB Ready)20. Personnel and employees will be strongly encouraged to also register to receive emergency alerts.
6.1 Recognition for Fire Safety and Maintaining
Fire Insurance
Insurance companies have begun to assess communities against guidelines above and beyond the fire code and local standards documented within this FPP. Due to the heightened standard assessed by the insurance industry, homeowners and communities have been d ropped from insurance or have experienced rate increases despite complying with the minimum codes and standards.
The Firewise USA program administered by NFPA is a certification program for communities to gain recognition for the fire-wise design and maintenance of their community. Firewise USA began in 2019 with seven sites that were challenged to improve the fire r esilience of their communities through a focused approach to active wildfire risk reduction. This is done through a collaborative framework created to empower neighbors to get organized and take action to reduce wildfire risk at a local level. The program has grown to include over 1.5 million residents living in Firewise USA communities (Firewise USA, n.d.a). The insurance industry, due to Department of Insurance Regulation #REG-2020-00015, is required to recognize the Firewise certification and consider it when it comes to determining if a community is insurable; cuts to insurance premiums have been made based on this certification. Given the established framework of Firewise USA, its direct mention in regulatory language, and its existing adoption by multiple insurance companies, it can be reasonably anticipated that more companies will require the same certification from customers that attempt to pursue discounted policies.
19 https://www.sbcounty.gov/uploads/SBCFire/documents/programs/20231130_sbcfire_ready_set_go_flyer.pdf 20 https://sbcfire.org/alertwarning/
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There are several requirements to become a Firewise USA community and multiple living documents must be prepared. Firewise USA communities must have a minimum of 8 dwelling units and a maximum of 2,500, meaning the proposed Project, in its entirety, would be able to participate in the program (Firewise USA, n.d.b). To become certified, a board or committee of volunteers made up of residents and partners such as a representative of the local FD would first need to be formed. A community wildfire risk assessm ent (CWRA) would then need to be completed, either independently or with assistance from a third-party consultant such as Dudek. The CWRA would need to be updated at least every five years. From the CWRA, a three -year action plan would be created that prioritizes risk reduction actions to be taken within the community and would need to be updated at least every three years. Every year, a worksheet would need to be filled out compiling the volunteer hours performed towards the goals outlined in the three -year action plan. One volunteer hour is required to be performed per dwelling unit within the community, or an investment of monetary equivalent in mitigation efforts can be made in lieu of volunteer hours (Firewise USA, n.d.b).
In addition to the Firewise certification, the community can hire a qualified individual such as Dudek to assess the community regularly to document compliance with not only the fire code but the insurance industry minimums.
Wildfire Risk Assessments have proven valuable in helping communities maintain fire insurance or even apply for reduced premiums, given that the insurance industry evaluates fire resistant features above and beyond what the fire code requires.
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7 Conclusion
This FPP for the University Hills Project provides guidance for vegetation maintenance for the landscaped areas on the Project site. As described, vegetation maintenance measures will be provided on all landscaped areas of the proposed Project. The requirements and recommendations provided in this FPP have been designed specifically for the Project. This analysis and its fire protection justifications are supported by fire science research, results from previous wildfire incidents, and fire agencies that have approved these concepts. The fire protection sy stem provided for the Project site includes a redundant layering of code -compliant, fire-resistant construction materials and methods that have been shown through post -fire damage assessments to perform extremely well against wildfire and ember storm conditions . To address areas where the Project is unable to meet the Fire Code due to site constraints, code -exceeding measures have been suggested to meet the intent of the provisions of the Fire Code. The use of these methods and materials along with ongoing maintenance will result in a development that will be highly defensible with minimal firefighting resource demands . It is Dudek ’s professional opinion that this project, like any project built to the most recent fire safety code requirements, will not be vulnerable to fire losses experienced by older, less ignition resistant projects and the Project is considered to represent a low wildfire risk to its occupants based on its ability to provide for evacuations . It is necessary to understand that Projects occ urring within fire hazard severity zones and wildland urban interface areas with higher potential fire hazards represent lower overall fire safety risk when the buildings and community are built to ignition resistant levels as required by code. Conversely, older communities that do not include the ignition resistant strategies may occur in a location that represents lower potential fire hazards outside of a fire hazard severity zone or wildland urban interface but may actually be at higher overall fire risk due to the vulnerabilities inherent in their construction.
Ultimately, it is the intent of this FPP to guide the fire protection efforts for the Project in a comprehensive manner.
Implementation of the measures detailed in this FPP will reduce the risk of wildfire spreading from the Project site into surrounding areas and will improve the ability of firefighters to fight fires on the Project property and neighboring properties and resources, irrespective of the cause or location of ignition.
Note that this is a conceptual plan, which provides enough detail for SBCFPD ’s approval. Detailed plans, such as improvement plans and building permits, demonstrating compliance with the concepts in the FPP and with City and County Fire Code requirements, would be submitted to SBCFPD at the time they are developed. Fire is a dynamic and somewhat unpredictable occurrence and as such, this FPP does not guarantee that a fire will not occur or will not result in injury, loss of li fe, or loss of property. There are no war ranties, expressed or implied, regarding the suitability or effectiveness of the recommendations and requirements in this FPP, under all circumstances.
The Project’s developers, contractors, engineers, and architects are responsible for the proper implementation of the concepts and requirements set forth in the FPP. The Project’s BOA and/or property managers are also responsible for maintaining their structures and lots, including fuel modification and landscape, as required by this FPP, the SBCFPD, and as required by the City and County Fire Codes. Alternative methods of compliance with this FPP can be submitted to the fire authority for consideration.
It will be extremely important for all employees, the Project ’s BOA and/or property managers, and occupants to comply with the recommendations and requirements described and required by the FPP on their property. The responsibility to maintain the fuel modification and fire protection features required for the Project site lies with the Project’s BOA, and/or Property Manager or similar entity. Said the responsible party would oversee ongoing education and maintenance of the communal areas, and the SBCFPD would enforce the vegetation management
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requirements detailed in this FPP. Such requirements would be made as part of deed encumbrances and CC&Rs for each lot, as appropriate.
It is recommended that the University Hills Project maintain a conservative approach to fire safety. This approach must include maintaining the landscape and structural components according to the appropriate standards and embracing a “Ready, Set, Go!” stance on evacuation . The Project is not to be considered a shelter -in-place development. However, the fire agencies and/or law enforcement officials may, during an emergency, as they would for any new development providing the layers of fire protection as the Project, determine that it is safer to temporarily refuge employees or visitors on the Project site. When an evacuation is ordered, it will occur according to pre -established evacuation decision points or as soon as notice to evacuate is received, which may vary depending on many environmental and other factors. Fire is a dynamic and somewhat unpredictable occurrence, and it is important for anyone living at the WUI to educate themselves in practices that will improve safety.
The goal of the fire protection features, both required and those offered beyond the Codes, provided for the Project is to provide the structures with the ability to survive a wildland fire with little intervention of firefighting forces.
Preventing ignition to structures results in a reduction of the exposure of firefighters and occupants to hazards that threaten personal safety. It will also reduce property damage and losses. Mitigating ignition hazards and fire spread potential reduces the threat to structures and can help the fire department optimize the deployment of personnel and apparatus during wildfire. The analysis in this FPP provides support and justifications for acceptance of the proposed fuel modification zones for the proposed Project Development Footprint based on the site -specific fire environment.
This plan is intended to outline the generally accepted protocols which it is anticipated will be designed and, as appropriate, refined by S BCFPD at the appropriate time(s) into the final site -specific plan for the University Hills Project. Inasmuch as fire is a dynamic and often unpredictable occurrence, it cannot be guaranteed that, despite precautionary measures, a fire will not occur or that it will not result in injury, loss of life, or damage to or loss of property. No warranties expressed or implied are made herein, notwithstanding that the goal remains to identify a suite of appropriate measures calculated, to the extent feasible under the circumstances, which would mitigate the potential for such injury or damage. Although the SBCFPD may determine to recommend, or mandate, particular ameliorative measures in advance, the responsibility to react to and implement suitable fire protection features required for the project site lies with the Project’s BOA and/or Property Manager. In the event the Project ’s HOA and/or Property Management Company undertakes ongoing education and maintenance of the communal areas, this would be additive and support the common mission.
Likewise, the SBCFPD may elect to develop and/or implement enforcement of vegetation management requirements. It is common to plan for these contingencies by adopting a “Ready, Set, Go” stance on emergency response (whether fire, earthquakes, flooding, chemical spills, etc.) and on dislocation or evacuat ion, along with other components discussed below, where appropriate. Experience garnered from other situations tends to support that “shelter-in-place” may be, but is not always, the preferred option. Fire and/or law enforcement officials may, during an emergency, determine that it is safer to temporarily refuge residents on -site. Again, where evacuation is ordered, ideally it will align with pre -established evacuation decision -tree points. Meetings and even drills are considered beneficial to augment the preparedness of owners, occupants, workers, and other potentially affected persons within the development for an incident that could occur with little or no warning.
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Limitation On Reliance Or Dependence Upon Report
Any person or entity furnished with this report and/or who reviews it agrees that the advance written consent of Dudek be sought and furnished to such person or entity prior to the review, reliance or authorization as to any matters that are the subject of the reports by any person or entity (whether through act or omission as set forth in the report), other than Dudek’s direct client. In such case, obtaining Dudek ’s consent shall not be subject to any fee or charge (other than reasonable copy costs, where applicable).
Dudek expressly disavows, does not assume any responsibility for, nor will be liable for any claims, losses, or damages associated with any matters that are the subject of this or other reports it prepares or contributes to respecting this project, however characterized (including without limitation as sounding in tort, breach of contract, misrepresentation by act or omission, failure to adhere to applicable standards of professionalism, statutory liability, etc.), whether in law or equity, whether known or unknown, and whether actual or contingent, excepting only Dudek’s direct client, as to which the limitation of liability provisions in the contract between Dudek and its client shall govern.
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8 List of Preparers
Project Manager and Site Visit
Austin Ott
Fire Protection Planner V
Dudek
Fire Behavior Modeling
Doug Nickles
Fire Protection Planner V
Dudek
Fire Plan Preparer
Dave Stimson
Fire Protection Planner II
Dudek
GIS Analyst and Mapping
Rachel Strobridge
Geospatial Analyst
Dudek
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9 References
Alexander, M. E. 1998. Crown fire thresholds in exotic pine plantations of Australia. Canberra, Australia: Australian National University. 228 p. Ph.D. Thesis
Anderson, Hal E. 1982. Aids to Determining Fuel Models for Estimating Fire Behavior. USDA Forest Service Gen.
Tech. Report INT-122. Intermountain Forest and Range Experiment Station, Ogden, UT. https://www.fs.usda.gov/rm/pubs_int/int_gtr122.pdf
Andrews, P.L. 1980. Testing the fire behavior model. In Proceedings 6th conference on fire and forest meteorology. April 22–24, 1980. Seattle, WA: Society of American Foresters. Pp. 70–77.
Andrews, Patricia L.; Collin D. Bevins; and Robert C. Seli. 2008. BehavePlus fire modeling system, version 3.0:
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Appendix A
Representative Photo Log
UNIVERSITY HILLS (2/24/2025)
ATTACHMENT 1
PHOTO LOG
PHOTO LOCATION KEY
1: IMG 0476-
0483
2: IMG 0485-
0492
3: IMG 0494-
0501
4: IMG 0503-
0510
Picture 1: IMG 0477 Taken at the southwest corner of the Project along Badger Canyon Road looking northeast over the Project area. Topography slopes upwards to north. Vegetation is dense 4-5-foot-tall shrubs.
Picture 2: IMG 0481 Taken at the southwest corner of the Project along Badger Canyon Road looking southwest away from the Project area. Some shrub vegetation is present on the other side of the wash visible in the picture.
Picture 3: IMG 0509 Taken at the eastern boundary of the Project area looking west over the Project area. Topography slopes upwards towards the north. Vegetation on-site is 4-5-foot-tall dense shrubs.
Picture 4: IMG 0506 Taken at the eastern boundary of the project site looking east away from the project area.
Topography slopes downwards towards the south and east. Vegetation on and off-site is 4-5-foot-tall dense shrubs.
Appendix B
Fire History Map
Project Site - Parcel 1
5-Mile Buffer
Historic Fire Perimeters (Year)
2020 - 2023
2010 - 2019
2000 - 2009
1990 - 1999
1980 - 1989
1970 - 1979
1960 - 1969
1911 - 1959
SOURCE: BASE MAP- ESRI MAPPING SERVICE; FIRE DATA-CALFIRE 2023 0 21
Milesn
Date: 6/10/2025 - Last saved by: cgardner - Path: Z:\Projects\j1442800\MAPDOC\UniversityHills_Fire.aprx
APPENDIX B
Fire History Map
Fire Protection Plan - University Hills Project
Appendix C
BehavePlus Fire Behavior Modeling Summary
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1 BehavePlus Fire Behavior
Modeling History
Fire behavior modeling has been used by researchers for approximately 50+ years to predict how a fire will move through a given landscape (Linn 2003). The models have had varied complexities and applications throughout the years. One model has become the most widely used as the industry standard for predicting fire behavior on a given landscape. That model, known as “BEHAVE,” was developed by the U. S. Government (USDA Forest Service, Rocky Mountain Research Station) and has been in use since 1984. Since that time, it has undergone continued research, improvements, and refinement. The current version, BehavePlus 6.0, includes the latest updates incorporating years of research and testing. Numerous studies have been completed evaluating the validity of the fire behavior models’ ability to predict fire behavior given site specific inputs. One of the most successful ways the model has been improved has been through post -wildfire modeling (Brown 1972, Lawson 1972, Sneeuwjagt and Frandsen 1977, Andrews 1980, Brown 1982, Rothermel and Rinehart 1983, Bushey 1985, McAlpine and Xanthopoulos 1989, Marsden-Smedley, and Catchpole 1995, Grabner et. al. 1997, Alexander 1998, Grabner et al. 2001, Arca et al. 2007). In this type of study, Behave is used to model fire behavior based on pre -fire conditions in an area that recently burned. Real-world fire behavior, documented during the wildfire, can then be compared to the predicted results of Behave and refinement to the fuel models incorporated, retested, and so on.
Fire behavior modeling conducted on this site includes a relatively high-level of detail and analysis which results in reasonably accurate representations of how wildfire may move through available fuels on and adjacent to the property. Fire behavior calculations are based on site-specific fuel characteristics supported by fire science research that analyzes heat transfer related to specific fire behavior. To objectively predict flame lengths, spread rates, and fireline inte nsities, this analysis incorporat ed predominant fuel characteristics, slope percentages, and representative fuel models observed on site. The BehavePlus fire behavior modeling system was used to analyze anticipated fire behavior in key areas within and adjacent to the proposed Project site. Predicting wildland fire behavior is not an exact science. As such, the movement of a fire will likely never be fully predictable, especially considering the variations in weather and the limits of weather forecasting. Nevertheless, practiced, and experienced judgment, coupled with a validated fire behavior modeling system, results in useful and accurate fire prevention planning information. To be used effectively, the basic assumptions and limitations of BehavePlus must be understood.
▪ First, it must be realized that the fire model describes fire behavior only in the flaming front. The primary driving force in the predictive calculations is dead fuels less than one-quarter inch in diameter. These are fine fuels that carry fire. Fuels greater than one inch have an insignificant effect while fuels greater than three inches have no effect on fire behavior.
▪ Second, the model bases calculations and descriptions on a wildfire spreading through surface fuels that are within six feet of the ground and contiguous to the ground. Surface fuels are often classified as grass, brushes, litter, or slash.
▪ Third, the software assumes that weather and topography are uniform. However, because wildfire almost always burns under non-uniform conditions, the length of the projection period and choice of fuel model must be carefully considered to obtain useful predictions.
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▪ Fourth, the BehavePlus fire behavior computer modeling system was not intended for determining sufficient fuel modification zone/defensible space widths. However, it does provide the average length of the flames, which is a key element for determining “defensible space” distances for minimizing structure ignition.
Although BehavePlus has some limitations, it can still provide valuable fire behavior predictions which can be used as a tool in the decision-making process. In order to make reliable estimates of fire behavior, one must understand the relationship of fuels to the fire environment and be able to recognize the variations in these fuels. Natural fuels are made up of the various components of vegetation, both live and dead, that occur on a site. The type and quantity will depend upon the soil, climate, geograp hic features, and the fire or other disturbance history of the site. The major fuel groups of grass, shrub, trees, and slash are defined by their constituent types and quantities of litter and duff layers, dead woody material, grass and forbs, shrubs, regeneration, and trees. Fire behavior can be predicted largely by analyzing the characteristics of these fuels. Fire behavior is affected by seven principal fuel characteristics: fuel loading, size and shape, compactness, horizontal co ntinuity, vertical arrangement, moisture content, and chemical properties.
2 Modeling Inputs
Dudek utilized the BehavePlus software package to analyze fire behavior potential for the proposed development site in San Bernardino County, California. For this analysis, two pre- proposed Project scenarios were evaluated, including one average summer weather conditions northeast of the proposed Project site and southwest of the Project site. Additionally, two scenarios were run for post-project conditions (One average and one extreme weather condition respectively). The proposed Project site currently is undeveloped with largely unmaintained vegetation throughout the site. It is generally flat with minor change in elevation throughout the site and is covered with non- native grasses, sage scrub, and dispersed large shrubs . With that said, f uels and terrain adjacent to the development area could produce flying embers that may affect the proposed Project, but defenses will be built into the structures to prevent ember penetration and to extinguish fires that may result from ember penetration. It is the fuels directly adjacent to and within fuel modification zones that could have the potential to affect the proposed Project’s structures from a radiant and convective heat perspective as well as from direct flame impingement , however, the ignition resistant structures would be surrounded by irrigated landscape and hardscape areas.
BehavePlus software requires site -specific variabl es for surface fire spread analysis, including fuel type, fuel moisture, wind speed, and slope data. The output variables used in this analysis include flame length (feet), rate of spread (feet/minute), fireline intensity (BTU/feet/second), and spotting di stance (miles), crown fire flame length (feet), crown fire intensity (BTU/feet/second), crown fire spotting distance (miles) . The following provides a description of the input variables used in processing the BehavePlus models for the proposed Project site. In addition, data sources are cited and any assumptions made during the modeling process are described.
2.1 Vegetation (Fuels)
The seven fuel characteristics help define the 13 standard fire behavior fuel models and the five custom fuel models developed for Southern California (Anderson 1982; Weise & Regelbrugge 1997) . According to the model classifications, fuel models used in BehavePlus have been classified into four groups, based upon fuel loading (tons/acre), fuel height, and surface to volume ratio. Observation of the fuels in the field (on site) determines which
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fuel models should be applied in BehavePlus. The following describes the distribution of fuel models among general vegetation types for the standard 13 fuel models and the custom Southern California fuel models:
▪ Grasses Fuel Models 1 through 3
▪ Brush Fuel Models 4 through 7, SCAL 14 through 18
▪ Timber Fuel Models 8 through 10
▪ Logging Slash Fuel Models 11 through 13
In addition, the aforementioned fuel characteristics were utilized in the development of 40 more fire behavior fuel models developed for use in BehavePlus modeling efforts (Scott & Burgan 2005). These new models attempt to improve the accuracy of the standard 13 fuel models outside of severe fire season conditions, and to allow for the simulation of fuel treatment prescriptions. The following describes the distribution of fuel models among general vegetation types for the new 40 fuel models:
▪ Grass Models GR1 through GR9
▪ Grass-shrub Models GS1 through GS4
▪ Shrub Models SH1 through SH9
▪ Timber-understory Models TU1 through TU5
▪ Timber litter Models TL1 through TL9
▪ Slash blowdown Models SB1 through SB4
To support the fire behavior modeling efforts conducted for the proposed, a Dudek Fire Protection Planner analyzed the different vegetation types observed on and adjacent to the site and they were subsequently classified into the aforementioned numeric fuel models. As is customary for this type of analysis, the terrain, and fuels directly adjacent to the site and proposed fuel modification zones (FMZ) are used for determining flame lengths and fire spread.
Table 1. Existing Fuel Model Characteristics
Fuel Model
Assignment Vegetation Description Location
Fuel Bed Depth
(Feet) 1
SH5 High load, dry climate
shrub
Represents the chaparral vegetation and
the shrubs within the proposed Project site
4-5 feet.
SH2 Moderate load, dry
climate shrub
Dense shrubs vegetation throughout the
proposed Project site
4-5 feet
SCAL18 Sage scrub, buckwheat Brush vegetation throughout the proposed Project site
4-5 feet
Note:
1 Listed fuel bed depths are a reflection of the fuel models that best depict the vegetation in and around the Proposed Project site and not an exact measure of local vegetation (Anderson 1982; Scott & Burgan 2005).
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Table 2. Post-development Fuel Model Characteristics
Fuel Model
Assignment Vegetation Description Location
Fuel Bed Depth
(Feet) 1
GS1 Low load, dry climate
grass shrub
Onsite Zone 1 and 2 fuel modification 0.2 ft.
FB8 Irrigated
landscaping/compact
litter
Thinned landscape throughout the
perimeter of the Project site
<2.0 ft.
NB1 Urban or suburban
development
Paved roadway. 0 ft.
Note:
1 Listed fuel bed depths are a reflection of the fuel models that best depict the vegetation in and around the Proposed Project site and not an exact measure of local vegetation (Anderson 1982; Scott & Burgan 2005).
2.2 Topography
Topography influences fire risk by affecting fire spread rates. Typically, steep terrain results in faster fire spread up- slope and slower fire spread down -slope in the absence of wind. Flat terrain tends to have insignificant effect on fire spread, resulting in fires that are driven by wind . The proposed Project site is relatively flat and gently slopes from approximately 1,613 feet above mean sea level ( AMSL) in the southeastern corner to approximately 1,865 feet AMSL in the northwest corner. The open space surrounding the Project maintains the same relatively flat slope.
2.3 Weather Analysis
Historical weather data for the San Bernardino County region was utilized in determining appropriate fire behavior modeling inputs for the proposed Project area. Average, on-shore (50th weather percentile and extreme off-shore (97th percentile) weather conditions were derived from Remote Automated Weather Stations (RAWS) and utilized in the fire behavior modeling efforts conducted in support of this report. The Devore RAWS Station (RAWS ID 045113) was utilized to find average and extreme weather values for the proposed Project area. The station was closest as it is the closest at approximately 3 miles northeast of the proposed Project site and would adequately approximate proposed Project site weather conditions. Data from fire seasons dating back to 2017 and up through 2025 were included in the analysis.
RAWS fuel moisture and wind speed data were processed utilizing the Fire Family Plus software package to determine atypical (97 th percentile) and typical (50 th percentile) weather conditions. Data from the RAWS was evaluated from August 1 through December 31 for each year between 2017 and 2025 for 97th percentile weather conditions and from May 1 through September 30 for each year between 2017 and 2025 for 50th percentile weather conditions.
Following analysis in Fire Family Plus, fuel moisture information was incorporated into the Initial Fuel Moisture file used as an input in BehavePlus. Wind speed data resulting from the Fire Family Plus analysis was also determined.
Initial wind direction and wind speed values for the five BehavePlus runs were manually entered during the data input phase. The input wind speed and direction are an average surface wind at 20 feet above the vegetation over the analysis area. Table 3 summarizes the wind and wea ther input variables used in the Fire BehavePlus modeling efforts.
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Table 3. Wind and Weather Input Variables
Model Variable
Summer Weather (50 th Percentile) On
and Offshore Wind
Peak Weather (97 th Percentile)
Offshore Wind
Fuel Models SH5 SH5
1h Moisture 3% 2%
10h Moisture 5% 3%
100h Moisture 7% 5%
Live Herbaceous Moisture 60% 30%
Live Woody Moisture 90% 60%
20-foot Wind Speed (mph) 20 40
BehavePlus Wind
Adjustment Factor
0.4 0.4
3 Fire Behavior Modeling Efforts
As mentioned, the BehavePlus fire behavior modeling software package was utilized in evaluating anticipated fire behavior adjacent to the proposed Project site. Two focused scenarios were completed for pre-Project existing fuels conditions, and two were completed for the post proposed Project conditions. The results of the modeling effort included anticipated values for surface fires flame length (feet), rate of spread (mph), fireline intensity (Btu/ft/s) , and spotting distance (miles). The aforementioned fire behavior variables are a vital component in understanding fire risk and fire agency response capabilities. Flame length, the length of the flame of a spreading surface fire within the flaming front, is measured from midway in the active flaming combustion zone to the average tip of the flames (Andrews, Bevins, and Seli 2008). Fireline intensity is a measure of heat output from the flaming front and also affects the potential for a surface fire to transition to a crown fire. Fire spre ad rate represents the speed at which the fire progresses through surface fuels and is another important variable in initial attack and fire suppression efforts (Rothermel and Rinehart 1983). Spotting distance is the distance a firebrand or ember can travel down wind and ignite receptive fuel beds. Two pre-Project and two post -Project fire modeling scenario locations were selected to better understand the different fire behavior that may be experienced on or adjacent to the site based on slope and fuel conditions; these fire scenarios are explained in more detail below:
Fire Scenario Locations and Descriptions:
▪ Scenario 1. Fire flaming front approaching from the northeast towards the northern side of Parcel 1 Project boundary with 40 mph north/northeast winds; 18% downhill slope within 100 to 300 feet of edge of grading. - Existing conditions: undeveloped land off-site (to be preserved as open space) and on site with native vegetation (chaparral, sage scrub).
- Post-development conditions: include the same off -site conditions with irrigated manufactured slopes, fuel modification zones, and paved roadways on site. ▪ Scenario 2. Fire flaming front approaching from the southwest towards the western boundary of the Parcel 1 western boundary with 20 mph west/southwest winds; 6% uphill slope within 400 feet of edge of grading. - Existing conditions: undeveloped land off-site and on-site with native vegetation (sage scrub, forbs).
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- Post-development conditions: include the same off-site conditions with irrigated manufactured slopes, fuel modification zones, and paved roadways on site.
4 Fire Behavior Modeling Results
The results presented in Tables 4 and 5 depict values based on inputs to the BehavePlus software and are not intended to capture changing fire behavior as it moves across a landscape. Changes in slope, weather, or pockets of different fuel types are not ac counted for in this analysis. For planning purposes, the averaged worst -case fire behavior is the most useful information for conservative fuel modification design. Model results should be used as a basis for planning only, as actual fire behavior for a gi ven location will be affected by many factors, including unique weather patterns, small-scale topographic variations, or changing vegetation patterns.
The proposed Project site maintains similar slope and vegetation types on and offsite. The fire behavior models have been run considering pre-Project and post-Project conditions. Under the summer weather conditions modeled in Scenario 1, a fire burning in the off-site chaparral, modeled as SH5, would exhibit the most intense fire behavior with the sage/buckwheat vegetation, modeled as SCAL18 exhibiting similar fire behavior (refer to Table 3, Fire Behavior Results for Existing Conditions). A worst-case fire under gusty Santa Ana winds and low fuel moistures is expected to be moving up to 4.7 mph. Flame length values were modeled at 35.5 to 36.3 feet. Spotting is projected to occur up to 1.8 miles from the flaming front.
The results of fire behavior modeling analysis for pre- and post-Project conditions are presented in Tables 4 and 5, respectively. Identification of modeling run (fire scenarios) locations is presented graphically in Figure 4, BehavePlus Analysis Map.
Table 4. Modeling Results for Existing Conditions
Fire Scenarios
Flame
Length 1 (feet)
Fireline Intensity 1
(BTU/feet/
second)
Spread Rate 1
(mph)
Spotting
Distance 1
(miles)
Scenario 1 ( Pre-Project): 18% downhill slope , 40 mph wind from NE Fuel Model SH5 – Chaparral 36.3 13,958 4.7 1.8
Fuel Model SCAL18 – Sage,
buckwheat
35.5 13,342 2.1 1.8
Fuel Model SH2 – Sage, forbs 13.1 1,515 0.7 0.9
Scenario 2 (Pre -Project): 6% uphill slope, 20 mph wind from W/SW Model SH2 – Sage, forbs 8.6 603 0.3 0.4
Note:
1 Wind-driven surface fire.
APPENDIX C / BEHAVEPLUS FIRE BEHAVIOR MODELING SUMMARY
14428 C-7
JULY 2025
Table 5. Modeling Results for Post-Project Conditions
Fire Scenarios
Flame
Length 1 (feet)
Fireline Intensity 1
(BTU/feet/
second)
Spread Rate 1
(mph)
Spotting
Distance 1
(miles)
Scenario 1 ( Post-Project onsite ): 25% downhill slope, 40 mph wind from NE Fuel Model GS1 – maintained shrubs
for fuel modification
11.1 1,067 2.0 0.8
Fuel Model 8 – Irrigated
landscaping/FMZ
2.6 46 0.1 0.3
Fuel Model NB1 – paved roadway N/A N/A N/A N/A
Scenario 2 ( Post -Project onsite ): 20% uphill slope, 20 mph wind from SW Fuel Model GS1 – maintained shrubs
for fuel modification
7.2 411 0.8 0.4
Non-burnable N/A N/A N/A N/A
Note:
1 Wind-driven surface fire.
The following describes the fire behavior variables (Heisch and Andrews 2010) as presented in Tables 4 and 5:
Surface Fire:
▪ Flame Length (feet): The flame length of a spreading surface fire within the flaming front is measured from midway in the active flaming combustion zone to the average tip of the flames. ▪ Fireline Intensity (Btu/ft/s): Fireline intensity is the heat energy release per unit time from a one-foot wide section of the fuel bed extending from the front to the rear of the flaming zone. Fireline intensity is a function of rate of spread and heat per unit area and is related to flame length. Fireline intensity and the flame length are related to the heat felt by a person standing next to the flames. ▪ Surface Rate of Spread (mph): Surface rate of spread is the "speed" the fire travels through the surface fuels. Surface fuels include litter, grass, brush, and other dead and live vegetation within about 6 feet of the ground.
The information in Table 6 presents an interpretation of the outputs for five fire behavior variables as related to fire suppression efforts. The results of fire behavior modeling efforts are presented in Tables 4 and 5. Identification of modeling run locations is presented graphically in Figure 4 of the FPP.
Table 6. Fire Suppression Interpretation
Flame Length
(ft)
Fireline Intensity
(Btu/ft/s) Interpretations
Under 4 feet Under 100 BTU/ft/s Fires can generally be attacked at the head or flanks by people using hand tools. Hand line should hold the fire.
4 to 8 feet 100-500 BTU/ft/s Fires are too intense for direct attack on the head by people using hand tools. Hand line cannot be relied on to hold the fire.
Equipment such as dozers, pumpers, and retardant aircraft can be effective.
APPENDIX C / BEHAVEPLUS FIRE BEHAVIOR MODELING SUMMARY
14428 C-8
JULY 2025
Table 6. Fire Suppression Interpretation
Flame Length
(ft)
Fireline Intensity
(Btu/ft/s) Interpretations
8 to 11 feet 500-1000 BTU/ft/s Fires may present serious control problems -- torching out, crowning, and spotting. Control efforts at the fire head will probably be ineffective.
Over 11 feet Over 1000 BTU/ft/s Crowning, spotting, and major fire runs are probable. Control efforts at head of fire are ineffective.
Appendix D
Ignition-Resistant Construction Requirements
APPENDIX D / IGNITION-RESISTANT CONSTRUCTION REQUIREMENTS 14428
JULY 2025
D-1
As of the date of this fire protection plan, the following are the requirements for ignition resistant construction for The Proposed Project, including requirements under Chapter 7A of the California Building Code (CBC). In addition, exterior building construction including roofs, eaves, exterior walls, doors, windows, decks, and other attachments must meet the most current CBC Chapter 7A ignition resistance requirements at the time of building permit application.
1. All structures will be built with a Class A roof assembly, including a Class A roof covering. Roofs shall have a roofing assembly installed in accordance with its listing and the manufacturer’s installation instructions.
2. Where the roof profile allows a space between the roof covering and roof decking, the spaces shall be constructed to prevent the intrusion of flames and embers, be fire stopped with approved materials or have one layer of minimum 72-pound mineral-surfaced non-perforated cap sheet complying with ASTM D 3909 installed over the combustible decking. However, openings on barrel tiles or similar roof coverings, must be fire stopped (bird stopped) with approved materials to prevent the accumulation of debris, bird nests, etc. between the tiles and decking material.
3. When provided, exposed valley flashings shall be not less than 0.019-inch (No. 26 galvanized sheet gage) corrosion-resistant metal installed over a minimum 36-inch-wide underlayment consisting of one layer of minimum 72-pound mineral-surfaced non-perforated cap sheet complying with ASTM D 3909 running the full length of the valley.
4. All rain gutters, down spouts and gutter hardware shall be constructed from metal or other non-combustible material to prevent wildfire ignition along eave assemblies.
5. All chimney, flue or stovepipe openings attached to a fireplace, stove, or other solid or liquid fuel burning equipment or device shall be equipped with an approved spark arrester. An approved spark arrester is defined as a device intended to prevent sparks from escaping into the atmosphere and constructed of nonflammable materials, having a 12-gauge minimum thicknesses with openings no greater than ½ inch, or other alternative material the SBCFPD determines to provide equal or better protection. It shall be installed to be visible for the purposes of inspection and maintenance.
6. The exterior surface materials shall be non-combustible, including hard or ignition resistant, such as stucco.
In all construction, exterior walls shall extend 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.
7. All eaves, fascias, 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 4”x 6” rafter tails.
8. Paper-faced insulation shall be prohibited in attics or ventilated spaces.
9. Automatic interior fire sprinklers for residential buildings shall be installed according to the National Fire Protection Association (NFPA) 13D requirements.
10. Roof vents, dormer vents, gable vents, foundation ventilation openings, ventilation openings in vertical walls, or other similar ventilation openings shall be louvered and covered with 1/16-inch, noncombustible, corrosion-resistant metal mesh or other approved material that offers equivalent protection.
11. Attic or foundation ventilation louvers or ventilation openings in vertical walls shall not exceed 144 square inches per opening and shall be covered with 1/16” inch mesh corrosion -resistant metal screen or other approved material that offers equivalent protection. Ventilation louvers and openings may be incorporated as part of access assemblies.
APPENDIX D / IGNITION-RESISTANT CONSTRUCTION REQUIREMENTS 14428
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D-2
12. No attic ventilation openings or ventilation louvers shall be permitted in soffits, in eave overhangs, between rafters at eaves, or in other overhanging areas.
13. All fences and gate assemblies (fences, gates, and fence posts) attached or within five feet of a structure shall be of non-combustible material or pressure-treated exterior fire-retardant wood.
14. 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, pressure-treated exterior fire - retardant wood or ignition resistant construction. 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.
15. Accessory structures attached to buildings with habitable spaces and projections shall be in accordance with Chapter 7A of the CBC.
16. Detached accessory structures located less than 50 feet from a building containing habitable space shall be constructed in accordance with Chapter 7A of the CBC. a. Exception: Accessory structures less than 120 square feet in floor area located at least 30 feet from a building containing a habitable space.
17. Exterior doors shall be approved non-combustible construction, solid core wood and shall conform to the performance requirements of standard SFM 12-7A-1 or shall be of approved noncombustible construction, or solid core wood having stiles and rails not less than 1⅜ inches thick with interior field panel thickness no less than 1¼ inches thick, or shall have a fire-resistance rating of not less than 20 minutes when tested according to National Fire Protection Association (NFPA) 252.
18. All glass or other transparent, translucent or opaque glazing materials, that is used in exterior windows, including skylights, or exterior glazed door assemblies shall be constructed of multipane glazing with one tempered pane meeting the requirements of Section 2406 (2016 CBC) Safety Glazing.
19. Vinyl window assemblies are deemed acceptable if the windows have the following characteristics:
a. Frame and sash are comprised of vinyl material with welded corners. b. Metal reinforcements in the interlock area.
c. Glazed with insulating glass, annealed or tempered (one layer of which must be tempered glass). d. Frame and sash profiles are certified in AAMA Lineal Certification Program. e. Certified and labeled to ANSI/AAMA/NWWDA 101/LS2-97 for Structural Requirements.
Appendix E
Prohibited Plant List
APPENDIX E
FUEL MODIFICATION ZONE PROHIBITED PLANTS LIST
14428
July 2025 E-1
Botanical Name Common Name Comment*
Trees
Abies species Fir F
Agonis juniperina Juniper Myrtle F
Casuarina cunninghamiana River She-Oak F
Chamaecyparis species (numerous) False Cypress F
Cryptomeria japonica Japanese Cryptomeria F
Cupressocyparis leylandii Leyland Cypress F
Cupressus species (C. fobesii, C. glabra, C.
sempervirens,)
Cypress (Tecate, Arizona, Italian, others) F
Eucalyptus species (numerous) Eucalyptus F, I
Juniperus species (numerous) Juniper F
Lithocarpus densiflorus Tan Oak F
Melaleuca species (M. linariifolia, M. nesophila, M.
quinquenervia)
Melaleuca (Flaxleaf, Pink, Cajeput Tree) F, I
Picea (numerous) Spruce F
Palm species (numerous) Palm F, I
Pinus species (P. brutia, P. canariensis, P. b. eldarica, P. halepensis, P. pinea, P. radiata, numerous others)
Pine (Calabrian, Canary Island, Mondell, Aleppo,
Italian Stone, Monterey)
F
Platycladus orientalis Oriental arborvitae F
Pseudotsuga menziesii Douglas Fir F
Tamarix species (T. africana, T. aphylla, T. chinensis, T. parviflora)
Tamarix (Tamarisk, Athel Tree, Salt Cedar,
Tamarisk)
F, I
Taxodium species (T. ascendens, T. distichum, T.
mucronatum)
Cypress (Pond, Bald, Monarch, Montezuma) F
Taxus species (T. baccata, T. brevifolia, T. cuspidata) Yew (English, Western, Japanese) F Thuja species (T. occidentalis, T. plicata) Arborvitae/Red Cedar F Groundcovers, Shrubs & Vines
Acacia species Acacia F, I
Adenostoma fasciculatum Chamise F
Adenostoma sparsifolium Red Shanks F
Agropyron repens Quackgrass F, I
Anthemis cotula Mayweed F, I
Arctostaphylos species Manzanita F
Arundo donax Giant Reed F, I
Artemisia species (A. abrotanium, A. absinthium, A.
californica, A. caucasica, A. dracunculus, A.
tridentata, A. pynocephala)
Sagebrush (Southernwood, Wormwood,
California, Silver, True tarragon, Big, Sandhill)
F
Atriplex species (numerous) Saltbush F, I
Avena fatua Wild Oat F
Baccharis pilularis Coyote Bush F
Bambusa species Bamboo F, I
Bougainvillea species Bougainvillea F, I
Brassica species (B. campestris, B. nigra, B. rapa) Mustard (Field, Black, Yellow) F, I
APPENDIX E
FUEL MODIFICATION ZONE PROHIBITED PLANTS LIST
14428
July 2025 E-2
Botanical Name Common Name Comment*
Bromus rubens Foxtail, Red brome F, I
Castanopsis chrysophylla Giant Chinquapin F
Cardaria draba Hoary Cress I
Cirsium vulgare Wild Artichoke F,I
Conyza bonariensis Horseweed F
Coprosma pumila Prostrate Coprosma F
Cortaderia selloana Pampas Grass F, I
Cytisus scoparius Scotch Broom F, I
Eriogonum species (E. fasciculatum) Buckwheat (California) F Fremontodendron species Flannel Bush F
Heterotheca grandiflora Telegraph Plant F
Hordeum leporinum Wild barley F, I
Juniperus species Juniper F
Lactuca serriola Prickly Lettuce I
Larrea tridentata Creosote bush F
Lolium multiflorum Ryegrass F, I
Lonicera japonica Japanese Honeysuckle F
Mimulus aurantiacus Sticky Monkeyflower F
Miscanthus species Eulalie Grass F
Muhlenbergia species Deer Grass F
Nicotiana species (N. bigelovii, N. glauca) Tobacco (Indian, Tree) F, I Pennisetum setaceum Fountain Grass F, I
Perovskia atroplicifolia Russian Sage F
Phoradendron species Mistletoe F
Pickeringia montana Chaparral Pea F
Rhus (R. diversiloba, R. laurina, R. lentii) Sumac (Poison oak, Laurel, Pink Flowering) F Ricinus communis Castor Bean F, I
Rhus Lentii Pink Flowering Sumac F
Salvia species (numerous) Sage F, I
Salsola australis Russian Thistle F, I
Solanum Xantii Purple Nightshade (toxic) I
Silybum marianum Milk Thistle F, I
Thuja species Arborvitae F
Urtica urens Burning Nettle F
*F = flammable, I = Invasive
Notes:
1. Plants on this list that are considered invasive are a partial list of commonly found plants. There are many other plants considered invasive that should not be planted in a fuel modification zone and they can be found on The California Invasive Plant Counci l’s Website www.cal-ipc.org/ip/inventory/index.php. Other plants not considered invasive at this time may be determined to be invasive after further study.
2. For the purpose of using this list as a guide in selecting plant material, it is stipulated that all plant material will burn under various conditions.
3. The absence of a particular plant, shrub, groundcover, or tree, from this list does not necessarily mean it is fire resistive.
4. All vegetation used in Fuel Modification Zones and elsewhere in this development shall be subject to approval of the Fire Code Official.
5. Landscape architects may submit proposals for use of certain vegetation on a project specific basis. They shall also submit justifications as to the fire resistivity of the proposed vegetation.