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 community 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 valley 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 and 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 Packet Page. 915
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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 threeperson 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/ Packet Page. 916
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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 the 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 site to estimate at 3.21 persons per household15. 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 Packet Page. 918
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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 232 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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Waterman Ave
W Kendall Dr
E St
W Highland Ave
N Riverside Ave
Highland Ave
Kendall Dr
y210
y259
]^215
Fire Station 232
Fire Station 75
Fire Station 227
Fire Station 224
Project Boundary
Fire Station
0 5,000 2,500
Feet
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 RequirementsInfrastructure, 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 standards 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 Packet Page. 924
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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 Packet Page. 926
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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 117 (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%2C117.329611%2C11.53 Packet Page. 928
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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) during 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 were 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 the 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 performance requirements of State Fire Marshal Standard 12-7A-2.
4. The proposed Project structures would be constructed of ignition resistant18 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, valid 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 Packet Page. 931
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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. The 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 other 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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&&(66 $
OPEN
SPACE
LOT
OPEN
SPACE
LOT
PARK
PARK
DESIGNATED
REMAINDER
79 ft
66 ft
79 ft
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Feet
Parcel 1
Project Site - Parcel 1Property LineGrading Limits
Land Use
DevelopmentRoadway AccessAccess RoadEmergency Vehicle AccessWater 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 inward0-100-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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TANK
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Feet
FIGURE 6 - View 2
Parcel 1
Project Site - Parcel 1Property LineGrading Limits
Land Use
DevelopmentRoadway AccessAccess RoadEmergency Vehicle AccessWater 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 inward0-100-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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Feet
FIGURE 6 - View 3
Parcel 1
Project Site - Parcel 1Property LineGrading Limits
Land Use
DevelopmentRoadway AccessAccess RoadEmergency Vehicle AccessWater 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 inward0-100-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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Parcel 1
Project Site - Parcel 1Property LineGrading Limits
Land Use
DevelopmentRoadway AccessAccess RoadEmergency Vehicle AccessWater 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 inward0-100-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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NORTHPARK
BLVD
W CAMPUS PKWY
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Land Use
DevelopmentRoadway AccessAccess RoadEmergency Vehicle AccessWater 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 inward0-100-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. SBCFPD 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 dropped 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 resilience 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/ Packet Page. 947
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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 assessment (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 system 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 occurring 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 life, or loss of property. There are no warranties, 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 Packet Page. 949
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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 SBCFPD 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 evacuation, 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:
User’s Guide. Gen. Tech. Rep. RMRS-GTR-106 Ogden, Utah: Department of Agriculture, Forest Service, Rocky Mountain Research Station. 132p.
Arca, B., Laconi, M., Maccioni, A., Pellizzaro, G. and Salis, M., 2005. Validation of FARSITE model in Mediterranean area. University of Sassari.
Baltar, M., J.E. Keeley, and F. P. Schoenberg. 2014. County-level Analysis of the Impact of Temperature and Population Increases on California Wildfire Data. Environmetrics 25; 397-405.
Braun, K. 2002. Bushfire Threat to Homeowners. Community Perspectives about Fire, 2, 64-71.
Braziunas, K. H., Seidl, R., Rammer, W., & Turner, M. G. (2021). Can we manage a future with more fire? Effectiveness of defensible space treatment depends on housing amount and configuration. Landscape Ecology, 36(2), 309–330. https://doi.org/10.1007/s10980-020-01162-x Brown, J.K. 1982. Fuel and fire behavior prediction in big sagebrush. USDA Forest Service Res. Pap.
INT-290. 10p.
Brown, J.K., 1972. Field test of a rate-of-fire-spread model in slash fuels (Vol. 116). Intermountain Forest & Range Experiment Station, Forest Service, US Department of Agriculture.
Bushey, C.L. 1985. Comparison of observed and predicted fire behavior in the sagebrush and bunchgrass vegetation-type. In J.N. Long (ed.), Fire management: The challenge of protection and use: Proceedings of a symposium. Society of American Foresters. Logan, UT. April 17–19, 1985. Pp. 187–201.
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California Fire Alliance (CFA). 2004. California Fire Siege, 2003, The Story.
CAL FIRE. 2019. Scott McLean interview AP news. Wildfire Acreage Way Down in California. Web site:
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CAL FIRE. 2006. General Guidelines for Creating Defensible Space. May 8, 2006. https://bof.fire.ca.gov/ media/4mwdav3l/rpc-2-c-defensible-space-guidance-document_ada.pdf Cochrane, M. A., Moran, C. J., Wimberly, M. C., Baer, A. D., Finney B, M. A., Beckendorf, K. L., Eidenshink, J., & Zhu, Z. 2012. Estimation of wildfire size and risk changes due to fuels treatments. International Journal of Wildland Fire, 21, 357–367. https://doi.org/10.1071/WF11079 Cohen, J.D., and Butler, B.W., 1996, October. Modeling potential structure ignitions from flame radiation exposure with implications for wildland urban interface fire management. In Thirteenth Fire and Forest Meteorology Conference, Lorne, Australia (p. 82).
Cohen, Jack D. 1995. Structure ignition assessment model (SIAM). In: Weise, D.R.; Martin, R.E., technical coordinators.
Proceedings of the Biswell symposium: fire issues and solutions in urban interface and wildland ecosystems. 1994 February 15¬17; Walnut Creek, California. Gen. Tech. Rep. PSW-GTR-158. Albany, Elia, M., Giannico, V., Lafortezza, R., & Sanesi, G. 2019. Modeling fire ignition patterns in Mediterranean urban interfaces. Stochastic Environmental Research and Risk Assessment, 33(1), 169–181. https://doi.org/10.1007/s00477-018-1558-5
FireFamily Plus. 2008. U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 124 p http://www.firelab.org/project/firefamilyplus.
Fox, D. M., Carrega, P., Ren, Y., Caillouet, P., Bouillon, C., & Robert, S. 2018. How wildfire risk is related to urban planning and Fire Weather Index in SE France (1990–2013). Science of the Total Environment, 621, 120–129. https://doi.org/10.1016/j.scitotenv.2017.11.174 FRAP (Fire and Resource Assessment Program). 2007. Fire Hazard severity Zones in SRA. Adopted by California Department of Forestry and Fire Protection on November 7, 2007. Accessed July 2023. https://frap.fire.ca.gov
Gorte, R. W. 2011. Wildfire protection in the Wildland-Urban interface. In Wildfires and Wildfire Management.
Grabner, K. W.; Dwyer, J.P.; Cutter, B. E. 2001. Fuel model selection for BEH AVE in midwestern oak savannas.
Northern Journal of Applied Forestry. 18: 74-80.
Grabner, K., Dwyer, J. and Cutter, B., 1997. Validation of BEHAVE fire behavior predictions in oak savannas using five fuel models. UNITED STATES DEPARTMENT OF AGRICULTURE FOREST SERVICE GENERAL TECHNICAL REPORT NC, pp.202-215.
Hall, John R. 2013. US Experience with Sprinklers. National Fire Protection Association Report. 91 pp.
Holland, R. F. 1986. Preliminary Descriptions of the Terrestrial Natural Communities of California. NongameHeritage Program, California Department of Fish and Wildlife.
Huntzinger, R. (2010). Determining the Necessary Components of an Evacuation and Shelter in Place.
Emmitsburg: National Fire Academy.
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Keeley, J.E. and Syphard, A.D., 2018. Historical patterns of wildfire ignition sources in California ecosystems. International journal of wildland fire, 27(12), pp.781-799.
Keeley, J.E., and P.H. Zedler. 2009. “Large, High-Intensity Fire Events in Southern California Shrublands:
Debunking the Fine-Grain Age Patch Model.” Ecological Applications 19:69–94.
Keeley, J.E., 2004. Impact of antecedent climate on fire regimes in coastal California. International Journal of Wildland Fire, 13(2), pp.173-182.
Keeley, J.E. and Fotheringham, C.J., 2003. Impact of past, present, and future fire regimes on North American Mediterranean shrublands. In Fire and climatic change in temperate ecosystems of the Western Americas (pp. 218-262). New York, NY: Springer New York.
Keeley, J.E. and S.C. Keeley. 1984. Post fire recovery of California coastal sage scrub. The American Midland Naturalist 111:105-117.
Lawson, B.D. 1972. Fire spread in lodgepole pine stands. Graduate Student Theses, Dissertations, & Professional Papers. 2357. https://scholarworks.umt.edu/etd/2357
Linn, R. 2003. “Using Computer Simulations to Study Complex Fire Behavior.” Los Alamos National Laboratory, MS D401. Los Alamos, NM.
Marsden-Smedley, J.B. and Catchpole, W.R., 1995. Fire behaviour modelling in Tasmanian buttongrass moorlands. II. Fire behaviour. International Journal of Wildland Fire, 5(4), pp.215-228.
McAlpine, R.S. and Xanthopoulos, G., 1989. Predicted vs Observed fire spread rates in ponderosa pine fuel beds:
a test of American and Canadian systems. In Proceedings of the 10th Conference on Fire and Forest Whitewood= Compte rendu du 10ieme Congress sur les incendies et la meterologie forestiere and editeurs DC Maiver, H. Auld, R. Whitewood. Ottawa, Ont.? Forestry Canada 1989.
Mensing, S.A., Michaelsen, J. and Byrne, R., 1999. A 560-year record of Santa Ana fires reconstructed from charcoal deposited in the Santa Barbara Basin, California. Quaternary Research, 51(3), pp.295-305.
Mockrin, M.H., Fishler, H.K. and Stewart, S.I., 2020. After the fire: Perceptions of land use planning to reduce wildfire risk in eight communities across the United States. International journal of disaster risk reduction, 45, p.101444.
Nasiatka, P. 2003. Southern California Firestorm 2003 Report for the Wildland Fire Lessons Learned Center.
Mission Centered Solutions.
National Fire Protection Association. 2021. Myths vs Facts About Home Sprinklers. NFPA Web site at: NFPA’s Fire Sprinkler Initiative-Myths and facts about home fire sprinklers Newman, S.M., Carroll, M.S., Jakes, P.J. and Paveglio, T.B., 2013. Land development patterns and adaptive capacity for wildfire: Three examples from Florida. Journal of Forestry, 111(3), pp.167-174.
Nichols, K., F.P. Schoenberg, J. Keeley, and D. Diez. 2011. “The Application of Prototype Point Processes for the Summary and Description of California Wildfires.” Journal of Time Series Analysis 32(4): 420–429.
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Romero-Calcerrada R, Novillo CJ, Millington JDA, Gomez-Jimenez I (2008) GIS analysis of spatial patterns of human-caused wildfire ignition risk in the SW of Madrid (Central Spain). Landscape Ecology 23, 341-354. doi:10.1007/S10980-008-9190-2
Rothermel, R.C. 1983. How to predict the spread and intensity of forest and range fires. GTR INT-143. Ogden, Utah: USDA Forest Service Intermountain Research Station.161.
Rothermel, R.C., and G.C. Rinehart. 1983. Field Procedures for Verification and Adjustment of Fire Behavior Predictions. Res. Pap. INT-142. Ogden, Utah: U.S. Department of Agriculture, Forest Service, Intermountain Forest, and Range Experiment Station. 25 p.
Safford, H. D., Schmidt, D. A., & Carlson, C. H. (2009). Effects of fuel treatments on fire severity in an area of wildland-urban interface, Angora Fire, Lake Tahoe Basin, California. Forest Ecology and Management, 258, 773–787. https://doi.org/10.1016/j.foreco.2009.05.024 San Bernardino County Fire Protection District. 2024. Ready, Set, Go! program. https://www.sbcounty.gov/ uploads/SBCFire/documents/programs/20231130_sbcfire_ready_set_go_flyer.pdf San Bernardino County Fire Protection District. 2024. 2021-2022 Annual Report. Accessed March 2024. https://sbcfire.org/annualreports/fy-21-22/
San Bernardino County Fire Protection District. 2024. Safety. https://sbcfire.org/safety/ Sawyer, J.O, T. Keeler-Wolf, and J.M. Evens. 2009. A Manual of California Vegetation. Second Edition. California Native Plant Society Press. Sacramento, California. 1,300 pp.
Scott, Joe H., and Robert E. Burgan. 2005. Standard Fire Behavior Fuel Models: A Comprehensive Set for Use with Rothermel’s Surface Fire Spread Model. Gen. Tech. Rep. RMRS-GTR-153. Fort Collins, CO: U.S.
Department of Agriculture, Forest Service, Rocky Mountain Research Station. 72 p.
Scott, J.H. and Reinhardt, E.D., 2001. Assessing crown fire potential by linking models of surface and crown fire behavior (No. 29). US Department of Agriculture, Forest Service, Rocky Mountain Research Station.
Scott, J. H., Thompson, M. P., & Gilbertson-Day, J. W. 2016. Examining alternative fuel management strategies and the relative contribution of National Forest System land to wildfire risk to adjacent homes - A pilot assessment on the Sierra National Forest, California, USA. Forest Ecology and Management, 362, 29–37. https://doi.org/10.1016/j.foreco.2015.11.038
Sneeuwjagt, R.J. and Frandsen, W.H., 1977. Behavior of experimental grass fires vs. predictions based on Rothermel’s fire model. Canadian Journal of Forest Research, 7(2), pp.357-367.
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Stone, D.R., 1990. California’s endemic vernal pool plants: some factors influencing their rarity and endangerment. Vernal pool plants-their habitat and biology, pp.89-107.
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Syphard AD, Radeloff VC, Keuler NS, Taylor RS, Hawbaker TJ, Stewart SI, Clayton MK (2008) Predicting spatial patterns of fire on a southern California landscape. International Journal of Wildland Fire 17, 602–613. doi:10.1071/WF07087
Syphard, Alexander D, Volker C Radeloff, Jon E. Keeley, Todd J. Hawbaker, Murray K. Clayton, Susan I. Stewart, Roger B. Hammer. 2007. Human Influence on California Fire Regimes. Ecological Applications. https://doi.org/10.1890/06-1128.1
Syphard AD, Bar Massada A, Butsic V, Keeley JE (2013) Land use planning and wildfire development policies influence future probability of housing loss. PLoS ONE 8(8), e71708. doi:10.1371/JOURNAL.
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Syphard, Alexandra D. and Jon E. Keeley. 2015. Location, timing, and extent of wildfire vary by cause of ignition.
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Syphard, Alexandra & Brennan, Teresa & Keeley, Jon. (2014). The role of defensible space for residential structure protection during wildfires. International Journal of Wildland Fire. 23. 1165-1175.
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Syphard, Alexandra & Keeley, Jon & Massada, Avi & Brennan, Teresa & Radeloff, Volker. (2012). Housing Arrangement and Location Determine the Likelihood of Housing Loss Due to Wildfire. PloS one. 7. e33954. 10.1371/journal.pone.0033954.
Syphard, A.D. and Keeley, J.E., 2016. Historical reconstructions of California wildfires vary by data source. International Journal of Wildland Fire, 25(12), pp.1221-1227.
Wang, H.H., Finney, M.A., Song, Z.L., Wang, Z.S. and Li, X.C., 2021. Ecological techniques for wildfire mitigation:
Two distinct fuel break approaches and their fusion. Forest Ecology and Management, 495, p.119376.
Warziniack, T., Champ, P., Meldrum, J., Brenkert-Smith, H., Barth, C.M. and Falk, L.C., 2019. Responding to risky neighbors: testing for spatial spillover effects for defensible space in a fire-prone WUI community. Environmental and Resource Economics, 73, pp.1023-1047.
Weather Spark. 2023. Climate and Average Weather Year-Round in San Bernardino, San Bernardino Climate, Weather By Month, Average Temperature (California, United States) - Weather Spark Weise, D.R. and J. Regelbrugge. 1997. Recent chaparral fuel modeling efforts. Prescribed Fire and Effects Research Unit, Riverside Fire Laboratory, Pacific Southwest Research Station. 5p.
Zhou, A. 2013. Performance evaluation of ignition-resistant materials for structure fire protection in the WUI. Fire and Materials 2013 - 13th International Conference and Exhibition, Conference Proceedings, January 2013, 355–366.
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Appendix A
Representative Photo Log
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ATTACHMENT 1
PHOTO LOG
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PHOTO LOCATION KEY
1: IMG 0476-
0483
2: IMG 0485-
0492
3: IMG 0494-
0501
4: IMG 0503-
0510
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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. VegetaƟon is dense 4-5-foot-tall shrubs.
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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 vegetaƟon is present on the other side of the wash visible in the picture.
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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. VegetaƟon on-site is 4-5-foot-tall dense shrubs.
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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. VegetaƟon on and off-site is 4-5-foot-tall dense shrubs.
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Appendix B
Fire History Map
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SOURCE: BASE MAP- ESRI MAPPING SERVICE; FIRE DATA-CALFIRE 2023 02 1
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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
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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 intensities, this analysis incorporated 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, geographic 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 continuity, 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 nonnative grasses, sage scrub, and dispersed large shrubs. With that said, fuels 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 variables 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 distance (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 Packet Page. 976
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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 upslope 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 (97th percentile) and typical (50th 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 weather input variables used in the Fire BehavePlus modeling efforts.
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APPENDIX C / BEHAVEPLUS FIRE BEHAVIOR MODELING SUMMARY
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Table 3. Wind and Weather Input Variables
Model Variable
Summer Weather (50th Percentile) On
and Offshore Wind
Peak Weather (97th 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 spread 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 accounted 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 given 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
Length1 (feet)
Fireline Intensity1
(BTU/feet/
second)
Spread Rate1
(mph)
Spotting
Distance1
(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.
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Table 5. Modeling Results for Post-Project Conditions
Fire Scenarios
Flame
Length1 (feet)
Fireline Intensity1
(BTU/feet/
second)
Spread Rate1
(mph)
Spotting
Distance1
(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.
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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.
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Appendix D
Ignition-Resistant Construction Requirements
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APPENDIX D / IGNITION-RESISTANT CONSTRUCTION REQUIREMENTS 14428
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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.
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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 noncombustible 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.
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Appendix E
Prohibited Plant List
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APPENDIX E
FUEL MODIFICATION ZONE PROHIBITED PLANTS LIST
14428
E-1 July 2025
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 Packet Page. 989
APPENDIX E
FUEL MODIFICATION ZONE PROHIBITED PLANTS LIST
14428
E-2 July 2025
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 Council’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.
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ATTACHMENT J
University Hills-Power Point
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PLANNING COMMISSION
January 13, 2026 Item 2 Specific Plan Amendment 23-01
and Subdivision 23-05
Community Development & Housing Department
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Adoption of the Addendum to the Final Environmental Impact Report and Mitigation Monitoring and Reporting Program (SCH #2007071155) in compliance with the California Environmental Quality Act.Approval of Specific Plan Amendment No. 23-01 Approval of Subdivision 23-05Dissolve Development Agreement No. 08-02 404.3-acreAPNs: 0265-041-12, 0265-051-12 and -13; 0265-061-16; 0265-011-06, -07, and -08; 0265-051-09; and 0265-021-13University Hills Specific Plan (SP-UH) Community Development & Housing Department
Proposed Project
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LOCATION/ZONING MAP:
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AERIAL MAP:
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PLANNING AREAS: REFERENCE
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ANALYSIS:
ProjectBackgroundAmendment SubdivisionPedestrian and Bicycle ConnectivityRoadways, Traffic, and CirculationUtilities and Infrastructure Community Development & Housing Department
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ANALYSIS:
LandscapingRecreation AreasLighting Off-Site ImprovementsConstruction ScheduleDissolution of Development Agreement 08-02General Plan Compatibility Community Development & Housing Department
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ACCESS TO PROPOSED DEVELOPMENT
Project Site
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ACCESS 1: CONNECTION FROM CAMPUS CIRCLE TO BADGER CANYON RD
Project Site
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EXISTING SITE: CAMPUS CIRCLE AND BADGER CANYON
ACCESS 1
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EXISTING SITE: SOUTH TO CSUSB FROM ACCESS 1
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ACCESS 2: CONNECTION FROM W DEVILS CANYON TO BADGER
CANYON RD
Project Site
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EXISTING SITE: DEVILS CANYON AND BADGER CANYON ACCESS 2 Packet Page. 1004
TENTATIVE PARCEL MAP 20595 :
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TENTATIVE PARCEL MAP 20595 :
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TENTATIVE PARCEL MAP 20595 :
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SITE PLAN:
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FIRE DEPARTMENT FUEL MODIFICATION PLAN LAYOUT:
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RECOMMENDATION:
The Planning Commission adopt Resolution No. 2026-0XX forwarding a Recommendation that the Mayor and City Council :
1. CONSIDER the Addendum to the certified Subsequent Final Environmental Impact Report (SCH #2007071155) for Specific Plan Amendment 23-01 and Subdivision 23-05, in accordance with Section 15164(a) of the Public Resources Code, and direct the Planning Commission Secretary to prepare and file with the Clerk of the County of San Bernardino a Notice of Determination as provided under Public Resources Code, Section 21152(c) and California Code of Regulations, Title 14, Section 15094; and2. APPROVE Specific Plan Amendment 23-01 and Subdivision 23-05based on the Findings of Fact and subject to the recommended Conditions of Approval.
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1 2
3 RESOLUTION OF THE CITY OF SAN BERNARDINO ADOPTING THE
FACTS, FINDINGS AND STATEMENT OF OVERRIDING CONSIDERATIONS, 4 CERTIFYING THE FINAL SUBSEQUENT ENVIRONMENTAL IMPACT
5 REPORT, ADOPTING THE MITIGATION MONITORING AND REPORTING
PLAN, AMENDING THE GENERAL PLAN AND THE UNIVERSITY DISTRICT 6 SPECIFIC PLAN, ADOPTING THE UNIVERSITY HILLS SPECIFIC PLAN 7 AND APPROVING TENTATIVE PARCEL MAP NO. 18969, TENTATIVE TRACT MAP NO. 186% AND TENTATIVE TRACT MAP NO. 18140.
8 9
10 11
12 13
RESOLUTION NO. 2008- 422
SECTION I. RECITALS
a) WHEREAS, the Mayor and Common Council of the City of San Bernardino (" City") adopted the General Plan for the City, and the University District Specific Plan, by Resolution No. 2005-362 on November 1, 2005; and b) WHEREAS, Inland Communities Corp. made application for the 14 University Hills Specific Plan and associated Tentative Parcel Map No, 18969, Tentative 15 16
17 Tract Map No. 18696 and Tentative Tract Map No. 18140; and c) WHEREAS, a Subsequent Environmental Impact Report was completed 18 for the project by Michael Brandman Associates; and
19 20
21 d) WHEREAS, the University District Specific Plan includes the area proposed for development under the University Hills Specific Plan; and e) WHEREAS, on Apri117, 2008, the Environmental Review
22 Committee determined that the University Hills Specific Plan could have significant 23 24
25 26
27 28
effects on the environment, and thus warranted preparation of a Subsequent Environmental Impact Report (EIR) pursuant to the California Environmental Quality Act (CEQA); and
f) WHEREAS, the Notice ofPreparation, indicating the intent ofthe City to prepare a Draft Subsequent Environmental Impact Report was made known to the 1 Packet Page. 1077
2008- 422
comments from April 24, 2008 to May 23, 2008; and
g) WHEREAS, on May 7, 2008, the City held a public scoping meeting to solicit public comments on the preparation ofthe Draft Subsequent EIR; and h) WHEREAS, the City considered the concerns and comments received during the Notice of Preparation comment period in the preparation of the Draft Subsequent ErR, pursuant to CEQA; and
i) WHEREAS, a Draft Subsequent EIR was distributed for a 45-day public review period from August 1, 2008 to September 15, 2008; and 2 Packet Page. 1078
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3 Packet Page. 1079
2008- 422
Division staffreport, and the recommendation ofthe Planning Commission; and r) WHEREAS, the Mayor and Common Council made no substantial modifications to the University Hills Specific Plan, Tentative Parcel Map No. 18969, Tentative Tract Map No. 18696, and Tentative Tract Map No, 18140 which were not considered by the Planning Commission during its public hearing;
NOW, THEREFORE, THE MAYOR AND COMMON COUNCIL HEREBY
4 Packet Page. 1080
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1. 2.
3. 4.
5. 6.
Initial Study;
Notice ofPreparation;
Responses to the Notice ofPreparation;
Draft Subsequent EIR;
7. Notice ofCompletion;
List of persons, organizations and public agencies commenting on the Draft Subsequent EIR;
Comments received on the Draft Subsequent EIR during and after the public review period;
Responses to comments on the Draft Subsequent EIR.
5 Packet Page. 1081
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E. Although the Final SEIR identifies certain significant adverse environmental effects that would result if the University Hills Specific Plan, Tentative Parcel Map No. 18969, Tentative Tract Map No. 18696 and Tentative Tract Map No. 18140 are adopted and approved, all significant adverse environmental effects that can feasibly be avoided or mitigated will be avoided or mitigated by the implementation of the mitigation measures as set forth in the Mitigation Monitoring and Reporting Plan for the Final SEIR, The Mitigation Monitoring and Reporting Plan is attached to this Resolution as Exhibit C and incorporated herein by reference, F, The Final SEIR has described the alternatives to the University Hills Specific Plan, even though these alternatives may impede the attainment ofthe objectives 6 If
Packet Page. 1082
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1 Specific Plan, set forth ill the Facts, Findings and Statement of Overriding 2 Considerations.
3 I. The Final Subsequent Environmental Impact Report, the Mitigation 4 5
Monitoring and Reporting Plan, and the Facts, Findings and Statement of Overriding 6 Considerations reflect the independent review, analysis and judgment of the Mayor and 7 Common Council ofthe City ofSan Bernardino.
8 SECTION III. GENERAL PLAN AMENDMENT FINDINGS
9 10
11 12 A. The proposed General Plan Amendment No. 08-03 is consistent with the 13 following General Plan goals and policies:
14 2.2 Promote development that integrates with and minimizes impacts on 15 surrounding land uses.
16 2. 2.2 Require new uses to provide mitigation or buffers between existing uses 17 where potential adverse impacts could occur, including, as appropriate, 18 decorative walls, landscape setbacks, restricted vehicular access, 19 enclosure ofparking structures to prevent sound transmission, and control 20 oflighting and ambient illumination.
21 2, 2.4 Hillside development and development adjacent to natural areas shall be 22 designed and landscaped to reserve natural features and habitat and 23 protect structures from the threats from natural disasters, such as wildfires 24 and floods.
25 The proposed project will cluster residential development, provide more open space than 26 the currently approved Specific Plan, and has integrated a comprehensive fire protection 27 buffer into the document to assure protection ofthe residents in the future. The plan also 28 Based upon substantial evidence in the record, the Mayor and Common Council hereby find:
7 Packet Page. 1083
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1 2
3 4
5 6
7 8
9 10
11 the open space area will not be impacted by development, and can also be studied 12 further.
13 B. The proposed amendments will not be detrimental to the public interest, 14 health, safety, convenience, or welfare of the City. The proposed General Plan 15 Amendment is consistent with General Plan policies, and the projects associated with the 16 Specific Plan will be required to comply with all City requirements for infrastructure 17 development, including sanitary sewer and domestic water. Further, the Specific Plan 18 has been designed to protect the future residents from fire through integration of a fire 19 protection plan; and from geotechnical hazards through restrictions on development in 20 and near earthquake fault zones.
21 C. The proposed amendments will maintain the appropriate balance of land 22 uses within the City. The proposed Amendment is located in an area where open space 23 and residential land uses are proposed in the General Plan and University District 24 Specific Plan currently. General Plan Amendment No. 08- 03 proposes an increase in the 25 amount of open space land, and proposes residential densities greater than those 26 currently planned in the Paradise Hills Specific Plan, in order to allow a clustered 27 development plan. The proposed Specific Plan will impact less land and cluster the 28 residential land uses, rather than impacting natural resources in Badger Canyon. Land uses open space to minimize the hazards associated with flooding and earthquake faulting on the site,
2.6 Control development and the use of land to minimi7.e adverse impacts on significant natural, historic, cultural, habitat and hillside resources.
2.6. 1 Hillside development and development adjacent to natural areas shall be designed and sited to maintain the character ofthe City' s significant open spaces and historic and cultural landmarks.
The proposed Amendment will allow for the preservation of Badger Canyon for biological and geologic study. In addition, historic resources identified as occurring in 8 Packet Page. 1084
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1 use and circulation element amendments proposed by General Plan Amendment No. 08- 2 3
03 apply equally to corresponding elements of the University District Specific Plan, which was adopted concurrently with the General Plan by Resolution No. 2005- 362, D. Being a case of an amendment to the General Plan Land Use Map, the subject parcels are physically suitable (including but not limited to, access, provision of utilities, compatibility with adjoining land uses, and absence of physical constraints) for the requested land use designation and the anticipated land use development. The proposed project has integrated designs which will minimize slope impacts, provide a backbone circulation and utility system, and be visually buffered from the surrounding 4 5
6 7
8 9
10 11
areas.
12 SECTION IV, UNIVERSITY HILLS SPECIFIC PLAN FINDINGS
13 14
15 hereby find:
16 A, The proposed plan is consistent with the General Plan and the University 17 District Specific Plan. The University Hills Specific Plan is located within the University 18 District Specific Plan area, and is consistent with that Plan' s Vision, in that it will 19 provide physical connectivity between the Specific Plan area and the University; be a 20 part ofthe University Town concept by providing an area where faculty housing will be 21 provided within the Plan; participate in transit efforts to connect the Plan area to the 22 University and other parts of the City; and enhance the regional recreational link in the 23 area by extending planned regional trails through the University Hills Specific Plan area. 24 B. The proposed plan will not be detrimental to the public interest, health, 25 safety, convenience or welfare of the City. The Specific Plan includes standards which 26 will protect residents from the San Andreas Fault, and the potential for ground rupture 27 associated with the Fault, through prohibitions on development in those areas. The Plan 28 also incorporates bio-swales into open space and slopes to allow for the filtration of 9 Based upon substantial evidence in the record, the Mayor and Common Council Packet Page. 1085
2008- 422
1 2
3 4
5 6
7 8
9 10
11 are shallow enough to build upon. The site will be terraced to allow for flatter 12 development areas. The intensity of development proposed allows for 234,8 acres to be 13 preserved as permanent open space, which will provide a valuable resource for the 14 project' s residents, the University, and the City as a whole, 15 D. The proposed plan will ensure the development of a desirable character 16 which will be compatible with existing and proposed development in the surrounding 17 neighborhood. The site is visually isolated from surrounding neighborhoods, and 18 development of the project will have only minimal impacts on surrounding views, as 19 demonstrated in the Specific Plan and SEIR. The character ofthe development, although 20 more intense than lands to the south and west, is consistent with the University District 21 Specific Plan concepts of an urban village in association with the University, which is 22 adjacent to the property,
23 E. The proposed plan will contribute to a balance of land uses so that local 24 residents may work and shop in the community in which they live. The Specific Plan 25 will include connections to local transit, and will be within walking distance of the 26 California State University, San Bernardino ( CSUSB) campus. The Plan also includes a 27 planning area reserved for University faculty housing, which could generate up to 60 28 units within close proximity to CSUSB. In addition, the project is convenient to local surface water, which will prevent pollution. The Specific Plan also requires the clubhouse be constructed to meet LEED requirements, which will reduce potential impacts on greenhouse gases. The. mitigation measures included in the EIR will also protect the residents and visitors to the project area from environmental hazards, C. The subject property is physically suitable for the requested land use designation(s) and the anticipated land use development. The areas designated for restricted or prohibited development within the Specific Plan are those where hazards could occur, The balance of the site where development will be permitted is gently sloping, and outside the City' s Hillside Management Overlay, meaning that the slopes 10 Packet Page. 1086
2008- 422
1 commercial areas, and with the extension ofpathways, trails and sidewalks as planned in 2 the Specific Plan, will be easily accessible for shopping and employment. 3 Based upon substantial evidence in the record, the Mayor and Common Council 11 Packet Page. 1087
2008- 422
D, The site is physically suitable for the proposed density of development.
The tentative parcel map implements the Specific Plan planning areas, which are designed to accommodate higher densities of residential units in areas suitable for development, to allow greater open space preservation. The open space land is also included in the parcel map, and will be restricted as open space in perpetuity upon recordation ofthe parcel map,
E. The design of the subdivision is not likely to cause substantial environmental damage, or substantially and unavoidably injure fish or wildlife or their habitat. The design ofthe parcel map, and the mitigation measures included in the SEIR for the project, assure that areas of environmental hazards are restricted or prohibited 12 Packet Page. 1088
2008- 422
1 parcel map will also provide a connection to Campus Parkway through the University, 2 pursuant to a written agreement between the University and the applicant. 3 4
5 6 hereby find:
7 A. The proposed tentative tract map is consistent with the General Plan, the 8 University Hills Specific Plan and the Development Code, The proposed tract map will 9 create 26 single family residential lots which are consistent with the development 10 standards established in the Specific Plan.
11 B. The design of the proposed subdivision is consistent with the General 12 13
Plan. The tract map implements planning area 12 ofthe Specific Plan, which allows for 14 single family residential units on lots of the size proposed. The tentative tract map is 15 also consistent with the high quality design goals and policies of the General Plan, 16 insofar as it implements a master planned community which will have extensive 17 amenities for its residents,
18 19
20 21
22 23
24 25
26 27
28 SECTION VI. TENTATIVE TRACT MAP NO, 18696 FINDINGS
Based upon substantial evidence in the record, the Mayor and Common Council C. The site is physically suitable for the type ofproposed development. The tract map does not occur in areas designated for restricted or prohibited development within the Specific Plan. The site is gently sloping, and outside the City' s Hillside Management Overlay District, The lots within the tentative tract map will be terraced to allow for flatter development areas,
D. The site is physically suitable for the proposed density of development.
The Tract Map proposes 26 lots on 3, 11 acres, consistent with the density of 3. 2 to 9.0 units per acre allowed in the Standard Lot Detached (SLD) designation assigned to the 13 Packet Page. 1089
2008- 422
acre.
14 Packet Page. 1090
2008- 422
c. The site is physically suitable for the type of proposed development. The 15 Packet Page. 1091
2008- 422
1 development areas in the Specific Plan, nor does it occur adjacent to any open space area 2 proposed north ofthe tract map,
3 F, The design of the subdivision is not likely to cause serious public health 4 5
problems. The tentative tract map is not within a restricted development area, and is not 6 on the San Andreas Fault. The design of the tentative tract, as conditioned, will meet 7 City requirements for sight-lines and street widths for surrounding streets, to allow safe 8 transport through the site.
9 G, The design of the subdivision and the type of improvements do not 10 conflict with any easements, acquired by the public at large, for access through or use of 11 property within the proposed subdivision. The tentative tract map incorporates existing 12 13
easernents without interfering with them, Any easements created through the master 14 parcel map (TPM No. 18969) for the project, will be implemented in the tentative tract 15 map as necessary,
16 17
18 19
20 21
22 23
24 25
26 27
28 SECTION VIII. CERTIFICATION OF THE SUBSEOUENT ENVIRONMENTAL
IMPACT REPORT
NOW, THEREFORE BE IT RESOLVED, FOUND AND DETERMINED by the Mayor and Common Council of the City of San Bernardino that the Final Subsequent Environmental Impact Report ( SCH # 2007071155) is adequate and complete in that it addresses the environmental effects of General Plan Amendment No. 08-03, the University Hills Specific Plan, Tentative Parcel Map No, 18969, Tentative Tract Map No. 18696 and Tentative Tract Map No. 18140, and fully complies with the requirements of the California Environmental Quality Act, the CEQA Gnidelines and the City' s Environmental Review Procedures. The Final Subsequent Environmental Impact Report 16 Packet Page. 1092
2008- 422
1 . is hereby certified; the Facts, Findings and Statement of Overriding Considerations are 2 hereby adopted; and the Mitigation Monitoring and Reporting Plan is hereby adopted. 3 SECTION IX. ADOPTION OF THE GENERAL PLAN AMENDMENT AND 4 5
UNIVERSITY HILLS SPECIFIC PLAN
6 Based upon the above-referenced findings, General Plan Amendment No. 08-03 7 and the University Hills Specific Plan No. 07-01 ( attached and incorporated herein as 8 Exhibits D and E, respectively) are hereby adopted.
9 SECTION X. APPROVAL OF TENTATIVE PARCEL MAP NO. 18% 9. TENTATIVE 10 TRACT MAP NO. 18696 AND TENTATIVE TRACT MAP NO. 18140 11 Based upon the above-referenced findings, Tentative Parcel Map No. 18969, Tentative 12 13
Tract Map No. 18696 and Tentative Tract Map No, 18140 ( attached and incorporated 14 herein as Exhibits F, G, and H, respectively) are hereby approved. 15 SECTION XI. NOTICE OF DETERMINATION
16 17
hereby directed to file a Notice of Determination with the County of San Bernardino 18 19
20 Environmental Quality Act in preparing and certifying the Final Subsequent 21 Environmental Impact Report and adopting the Facts, Findings and Statement of 22 Overriding Considerations, the Mitigation Monitoring and Reporting Plan, General Plan 23 Amendment No. 08-03, the University Hills Specific Plan, Tentative Parcel Map No. 24 25
26 27
28 In accordance with the provisions of this Resolution, the Planning Division is Clerk of the Board of Supervisors certifying the City' s compliance with the California 18969, Tentative Tract Map No. 18696 and Tentative Tract Map No. 18140. A copy of the Notice ofDetennination will be forwarded to the State Clearinghouse. 17 Packet Page. 1093
2008- 422
18 Packet Page. 1094
2008- 422
1 RESOLUTION OF THE CITY OF SAN BERNARDINO ADOPTING THE 2 FACTS, FINDINGS AND STATEMENT OF OVERRIDING CONSIDERATIONS,
CERTIFYING THE FINAL SUBSEQUENT ENVIRONMENTAL IMPACT
3 REPORT, ADOPTING THE MITIGATION MONITORING AND REPORTING
PLAN, AMENDING THE GENERAL PLAN AND THE UNIVERSITY DISTRICT 4 SPECIFIC PLAN, ADOPTING THE UNIVERSITY HILLS SPECIFIC PLAN 5 AND APPROVING TENTATIVE PARCEL MAP NO. 18969, TENTATIVE TRACT MAP NO. 18696 AND TENTATIVE TRACT MAP NO. 18140.
6 I HEREBY CERTIFY that the foregoing Resolution was duly adopted by the Mayor and 7 joint .
Common Council ofthe City of San Bernardino at a regular meeting thereof, held 8 9
on the 17~ h day of November 2008, by the following vote to wit:
10 Council Members:
11 12
13 14
15 16
17 18
19 20
21 Aves Navs Abstain Absent
ESTRADA L
BAXTER x
BRINKER x
DERRY x
KELLEY
x
JOHNSON L
MC CAMMACK x
k~
22 23
24 25
26 27
28 Rachel G. Clark, City Clerk
The foregoing resolution is hereby approved this /~ day ofNoverilber, 2008, PATRICK J. MORRIS, Mayor
City of San Bernardino
By:
J esF. Penman
ity Attorney
19 Packet Page. 1095
I' ..
Exhibits to the Resolution of the city of San Bernardino adopting the Facts, Findings and Statement of Overriding Considerations, certifying the Final Subsequent Environmental Impact Report, adopting the Mitigation Monitoring and Reporting Plan, amending the General Plan and the Univenity District Specific Plan, adopting the Univenity BiOs Specific Plan and approving Tentative Parcel Map No. 18969, Tentative Tract Map No. 18696 and Tentative Tract Map No. 18140:
Exhibit A 1 - 4 (Bound Document)
1. Initial Study
Z. Notiee ofPreparation (NOP)
3. Responses to NOP
4. Draft Subsequent
Environmental Impaet Report
Exhibit A 5: Notiee ofCompletion
Exhibit A 6 - 8 (Bound Document)
6. List of persons, organizations and
pub1ie agencies commenting on the
Draft Subsequent Environmental
Impaet Report (DSEIR)
7. Comments received on the DSEIR
during and after the public comment
period
8. Responses to comments on the DSEIR
Exhibit B: Environmental Findings ofFaet and Statement ofOverriding Considerations Exhibit C: Mitigation Monitoring and Reporting Plan (Bound with Exhibit A 6 - 8) Exhibit D: General Plan Amendment No. 08-03
Exhibit E: University Hills Specific Plan (Bound Doeument) Exhibit F: Tentative Parcel Map No. 18969 (Large Format Map) Exhibit G: Tentative Traet Map No. 18696 (Large Format Map) Exhibit H: Tentative Traet Map No. 18140 (Large Format Map) Packet Page. 1096
EXHIBIT A 1- 4
Bound Document)
DRAFT
Environmental Impact Report
University Hills Specific Plan
City of San Bernardino, California
SCH #2007071155
EXHIBIT A
1. Initial Study
2. Notice of Preparation (NOP)
3. Responses to NOP
4. Draft Subsequent Environmental
Impact Report
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Prepared by:
Michael Brandman Associates
621 Carnegie Drive, Suite 100
San Bernardino, CA 92408
Contact: Kent Norton, Project Director
l;Jll
l;ch. ldl1r:mJm, 1,} h",.; u.!<' s
Draft EIR
August 1, 2008
Packet Page. 1097
I .
EXHIBIT A 5
I
City of San Bernardino Development Services Department
Notice of Completion and Availability of Draft Subsequent EIR To: Responsible and Interested Agencies, Special Interest Groups, Local Residents, and Other Interested Persons
From: City of San Bernardino Development Services Department 300 North D Street, San Bernardino, CA 92418
Contact: Terri Rahhal, City Planner
CLERK OF THE BOARD
AUG . 1 7.008
COUNlY OF
SAN BERNARDINO
The City of San Bernardino is the Lead Agency and has released for public review a Draft Subsequent Environmental Impact Report (EIR) for the proposed project. The Draft Subsequent EIR is supported by the previously certified EIR for the Paradise Hills Specific Plan, Subject: University Hills Specific Plan Draft Subsequent EIR Project Title: University Hills Specific Plan
Project Location: The Proposed Project is located in the northern portion ofthe City of San Bernardino in San Bernardino County, California, It is located just north ofthe California State University San Bernardino (CSUSB) campus on 404 acres of vacant land in the foothills ofthe San Bernardino Mountains, Access to the project area is proposed via Campus Parkway offNorthpark Boulevard to the west and from Little Mountain Road off Northpark Boulevard to the east.
Project Description: The UHSP consists of 404,3 total acres, with 169, 5 acres or 42 percent ofthe site proposed for residential and related uses, including 10,2 acres of parks and recreational uses, The project proposes a total of980 units with a gross density of2.4 dwelling units per acre (980 units divided by 404.3 acres) and a net density of 5, 8 units per acre, excluding natural open space ( 980 units divided by 169, 5 acres).
Residential densities range from 0,0 to 20 dwelling units per acre, The lowest densities (0-3, 1 units per acre) are located north ofthe San Andreas Fault and include single-family detached estate homes. Immediately south ofthe San Andreas Fault in the West Village area are standard detached lots ( 3, 2- 9 units per acre).
Mixed Detached and Attached units (9, 1- 15 units per acre and 17 units per acre, reSl>ectively) are located in the interior and perimeter ofthe site, The highest densities ( 15. 1- 20 units per acre) are generally located in the interior portions of the West Village area around the clubhouse and in the East Village area behind Badger Hill, Four (4) acres ofthe highest density area (Planning Area 16) will be dedicated to CSUSB for exclusive use as faculty housing (approx, 60 units), Three subdivisions are currently proposed: Tentative Parcel Map No, 18969, Tentative Tract Map 18696 and Tentative Tract Map 18140.
Significant Environmental Effects: The Draft Subsequent EIR identifies significant unavoidable adverse impacts on air quality, populationlhousing growth inducementlSCAG consistency, and transportation,
Public Review Period: The Draft Subsequent EIR is available for public review beginning August 1, 2008 and ending September 15, 2008, during which time the public and interested parties are invited to comment on the Draft Subsequent E1R for the proposed project. Public comments may be sent during this time period to the following name and address:
City of San Bernardino Development Services Department
300 North D Street, San Bernardino, CA 92418
Contact: John Oquendo, Assistant Planner or
cn i v er<; i!.Y.biJ I s( i~5hiilW_rg
See Counter Planning Staff
to View Documents
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The Draft Subsequent ElR is Available for Public Review at the following locations:
City of San Bernardino Development Services Department, 300 N, "D" Street, 3'" Floor, San Bernardino, CA 92418,
Feldheym Central Library, 555 W, 6" Street, San Bernardino, CA 92410 City of San Bernardino web site, www.sbcitv. on.:
Public Meetings: The City of San Bernardino Planning Commission and the Mayor and Common Council will consider the University Hills Specific Plan and the Draft Subsequent Environmental Impact Report (EIR) at noticed public hearings, Agendas for the public meetings ofthe City of San Bernardino are routinely posted on the City' s web page,
Presence of the Site on Lists Enumerated under Sedion 65962.5 of the Government Code: The proposed project site is not included on any lists compiled pursuant to Section 65962, 5 of the Government Code, Packet Page. 1099
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EXHIBIT A 6 - 8 and EXHIBIT C
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5r~~:..':,~~~;:,~;'_:': W~' :;:?~~:,/;;~~~~~S~f:~?i:~':,;.:: :: f Final Environmemallmpact Repon
UniversilV Hills Specific Plan CilV of San Bernardino
SGB # 2001011155
October 22, 2008
EXHIBIT A
6. Ust of persons, organizations and
public agencies commenting on the
Draft Subsequent Environmental
Impact Report (DSEIR)
7. Comments received on the DSEIR during
and after the public comment period
8. Responses to comments on the DSEIR
EXHIBIT C: Mitigation Monitoring and Reporting Pian Iichacl Brandman Associates 621 E. Carnegie Drive, Suite 100
San Bernardino, CA 924118
Packet Page. 1100
I'
EXHIBIT B
Environmental Findings of Fact for the
Environmental Impact Report
University Hills Specific Plan
State Clearinghouse # 2007071155)
Prepared for:
City of San Bernardino
Planning Department
300 N, D Street
San Bemardino, CA 92418
909.384,5080
Contact: Terri Rahhal, City Planner
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Prepared by:
Michael Brandman Associates
621 E, Carnegie Drive, Suite 100
San Bernardino, CA 92408
909,884,2255
Contact: Kent Norton, AICP, REA,
Director of Environmental Services
Draft October 9, 2008
Packet Page. 1101
EnIl#lonnlMIaI FIndIngs ofhct
UrIlvwWIy"'" SpecIfIc""'" EIR InttDdut:fIon
TABLE OF CONTENTS
SectIon 1: Introduction ....................................................................................................... 2 1, 1 - Project Description ................,........................................................................... 2
1. 2 - Background and Project History ......................................................................., 3 1, 3 - Statutory and Regulatory Requirements.............,.....................,.....................,,, 4 1, 4 - Summary of Environmental Findings ................................................................. 5 Section 2: Finding Regarding Impacts that are Leu Than Significant and, Therefore, do not Require Mitigation ............................................................................ 7 2, 1 - Aesthetics, Light, and Glare......................,..,..........................,.......................... 7 2,2 - Agricultural and Mineral Resources,.......................,.........,.,.....,......................,. 7 2,3 - Recreation"...... '.',....,......,....., ,..,..,.."..,........,....,.. ,.........,..,................, ...." ....,.., 8 2,4 - Cumulative
Impacts..."."..,..,.............,..,..,............"..".....,......,...............,..,......, 8 2,5 -
Summary............"....,..,.."..,...,..,....."..,..,.......,...............,.....,..,..........,..........,, 16 Section 3: Finding Regarding Potentially Significant Effects that have been Mitigated to Below a Level of Significance with the Adoption of Mitigation lI_ u.... .................................................................................................... 17 3, 1 - Biological Resources................,................,...........................,........................, 17 3,2 - Cultural Resources"....,.."..,...,..,..,.."..,.....,..".."..,..,..".,..,...,....,..........,..,..,.... 18 3,3 - Geology and Soils ......,..............,........,................,........................,..,............... 20 3,4 - Hazards and Hazardous
Materials.........................,..,................................,...., 21 3,5 - Hydrology and
WaterQuality..,..................,...........................................,......... 22 3,6 - Land use ................"..,..,..,..,......,..,..,..........,.....,...,...........,........,..,..,..,.,..,....., 24 3,7 -
Noise..,.., ..., ,.,..,.."..... '.,........" ,.".. ,.. '...,..'.."",.., ,....,.., .......... ....,...,....,..,..,..,.... 25 3,8 - Public Services,..,..,..,........,.."..,......,...,.....,....."..,.,....,....,.."..,.,........,....,..,...., 27 3,9 - Utilities,.,...,..,..,..,..,..,.....,.., ......,..,..,... ,........,..",.. ......,..,..,..".., ............,.. ,....,.... 27 3, 10 - Cumulative
Impacts..............,.....,..,.."..,..,..,..."...."..,........,..,....,............,..,.., 28 Section 4: Finding Regarding Impacts not Mitigated to Below a Level of Slgnlflcance30 4, 1 - Air Quality,.....,.."....,..,......,.............,..,....,....."."..,......,....".......,............,.."..." 30 4,2 - Population and Housing and SCAG Consistency ..........................,................. 32
4.3 - Transportation ..,...,....,..,.....,..,.."....,......,.."..,.."..'...........,'.',........"....,..,..'..,." 33
4.4 - Cumulative, ....,..,.... ........ ,.......",..,.. ,."..,..,.., ,......... ,...."....,.., '.,..,... ....,....,.....,.. 36 Section 5: Finding Regarding Growth Inducing, Unavoidable Adverse, and Irreversible Impacts ....................................................................................................... 39 5, 1 - Growth Inducing Impacts................................................................................, 39
5.2 - Irreversible Impacts .................,...,..............,...,..".............,..,..,..,.."....,..,..,..,... 40 Section 6: Finding Regarding Alternatives to the Propo. ed ProJ8Ct............................. 42 6, 1 - No ProjectlNo Development Altemative,............,............................................. 43 6,2 - No Project - General Plan Development A
ltemative.......................,................
44 6,3 - Modified Specific Plan
Altemative......,..................................,.......................... 44
6.4 - EducationallnstitutionITechnology Park Altemative ........................................46 6,5 - Alternative Sites ,........,.............."..,.."..,..,..,..,..,..,..,..,..,..,....,....,..,..,..,....,....... 46 Section 7: Statement of Overriding Con.
lderatlons....................................................... 50 Packet Page. 1102
EnvInJnmene./ Fllldlt",. ofFfIct
SpecHfc""" EIR nfJoducIIon
SK'DOit't;>~.. '"""' '
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L! ., ^ + C....,_.! I.."._._~.,.~.__ ". C-.,-., .'._~.' '. . ,', ,,' ~.'_. _,' '_ ,.,' _,.._'..,." i .. ',:c, o.. .,,' _: .,". __.: '..'. -_.__ ,',' ''._"__-._,. _ _ ; f~Y;;J\: iL'T~;;:+, O:;:<,'k'Z--_~;;<(,--; i::{-~: ti:Jt' x~__:-'_;.',_-;-::.:',';(,'-,_; -_'",/>_, 1';'" i'_~fi';i -"~?- g~n~~;,;:;~~~.:- ~~~ This document contains the findings required under the California Environmental Quality Act CEQA) (Public Resources Code, ~ 21000, et seq.) and the State CEQA Guidelines (California Code ofRegulations, Title 14, fi 15000 et seq.), specifically CEQA Guidelines fi 15091, supporting the certification ofthe University Hills Specific Plan (UHSP) Environmental Impact Report (EIR) and approval ofthe project by the City ofSan Bernardino (City).
1. 1 - Project Description
The University Hills Specific Plan consists of404.3 total acres, with 169.5 acres or 42 percent ofthe site proposed for residential and related uses, including 10,2 acres ofpmts and recreational uses. The project proposes a total of980 units with a gross density of 2.4 dwelling units per acre (980 units divided by 404.3 tota1 acres) and a net density of 5, 8 units per acre, excluding natura1 open space (980 units divided by 169.5 acres). A tabular summary ofthe project components is provided in Table 3- 3.
A conceptual land plan for the Proposed Project is shown in Exhibit 3- 5 and photographs ofthe site are shown in Exhibit 3-6. Residential densities range from 0.0 to 20 dwelling units per acre.
The lowest densities (0-3.1 units per acre) are located north ofthe San Andreas Fault and include single-family detached estate homes. Immediately south ofthe San Andreas Fault in the West Village area are standard detached lots (3.2- 9 units per acre). Mixed Detached and Attached units
9. 1- 15 units per acre and 17 units per acre, respectively) are located in the interior and perimeter of the site. The highest densities ( 15. 1- 20 units per acre) are generally located in the interior portions of the West Village area around the clubhouse and in the East Village area behind Badger Hill. Four (4) acres ofthe highest density area (planning Area 16) will be dedicated to CSUSB for exclusive use as faculty housing (approx. 60 units).
It is estimated the UHSP project will eventually support a population of 3,283 persons based upon the maximum buildout of980 units times an average of3.35 persons per unit. This household size is based on 2000 US census data and the latest City demographic factors.
The UHSP contains 10.3 acres ofpmts including a .2.2-acre private clubhouse in the West Village area which can accommodate a pool and tennis courts and other active amenities, two O.5-acre recreational facilities in the East Village area, a 5- acre "California Walnut Grove Linear Park" along Badger Creek, and the 2. 1- acre Glider Park (planning Area 1) in the northwest comer ofthe site which will provide a safe approach zone for the hang gliders landing at the adjacent Andy Jackson Airpark. The project has an internal pedestrian/walking trails system that connects to a multi-purpose trail consistent with the planned regional trail for this area. The Project will preserve 234.8 acres (or 58 percent ofthe site) as natura1 open space that is proposed to be used by the nearby CSUSB as a land laboratory" called the "Akkad Preserve," The land laboratory will have minimal improvements but may include limited trails, signage, fencing, and various teaching stations, A detailed summary of the proposed land use plan for the UHSP is provided in Table 3-4, Planning Area Land Uses, Packet Page. 1103
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1. 2. Background and Project History
1. 2.1 - Background
Pursuant to CEQA Guidelines ~15051, the City of San Bernardino is the lead agency for the University Hills Specific Plan, with primary land use authority over the Proposed Project. The City determined that the project may have significant impacts on the environment; therefore, a Draft Subsequent Environmental Impact Report (EIR) was prepared. The City issued a Notice of Preparation ofaSubsequent Environmental Impact Report between August 28, 2007 through September 27, 2007, inviting comments from responsible agencies, other regu1atory agencies, organizations and individuals pursuant to CEQA Guidelines ~ 15082, In response to the Notice of Preparation (NOP), the City received written comments which assisted the City in identifying the issues and alternatives for analysis in the Draft EIR. The City also held a scoping meeting at City of San Bernardino City Hall on September 18, 2007 to inform the public and interested agencies about the project and to solicit public comments on the scope ofthe environmental issues to be addressed in the Draft EIR.
Pursuant to the CEQA Guidelines, the City prepared a Draft EIR (State Clearinghouse No. 2007091039) to analyze the project's potential adverse environmental impacts. Upon completion of the Draft EIR dated May 16, 2008, the City initiated a 45-day public comment period from May 16, to June 30, 2008, by filing a Notice ofCompletion (NOC) with the State Clearinghouse for the Governor' s Office ofPlanning and Research and publishing a Notice ofAvailability (NOA) for the Draft EIR in a newspaper ofgeneral circulation within the City' s jurisdiction (CEQA Guidelines ~ 15087).
Copies ofthe Draft EIR were distributed to state agencies through the State Clearinghouse. The NOA was sent to public agencies, organizations, and individuals and indicated where copies ofthe Draft EIR could be obtained, or available fur review. The City made copies ofthe Draft EIR available for local review at the City ofSan Bernardino Public Library 510 E, Florida Avenue, San Bernardino, CA 92543; San Bernardino Unified School District 2350 W. IAltl1am Ave, San Bernardino, CA 92545; City ofSan Bernardino Planning Dept 445 Florida Avenue San Bernardino, CA 92543.
During the public review period for the Draft EIR, the City consulted with and requested comments from all responsible and trustee agencies, other regu1atol)' agencies and other interested parties pursuant to CEQA Guidelines ~ 15086,
During the public review period, the City received 303 written comments on the Draft EIR. The City provided written response to comments received from the commenting agencies/individuals pursuant to Public Resources Code ~ 21092.5. The response to comments includes the comments received on the Draft EIR, a list ofthose commenting, and the City' s response to the significant environmental
points raised in the review and consultation process. The Final EIR for the project consists ofthe Draft EIR (incorporated by reference), the response to comments, mitigation monitoring report program (MMRP), and changes to the Draft EIR which clarifY, supplement, or update the information provided in the Draft EIR, None ofthe changes or supplemental information in the Final EIR Packet Page. 1104
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constitute significant new information as defined by CEQA Guidelines ~15508,5, Therefore, CEQA does not require recirculation ofthe Draft EIR
In summary, the Final EIR includes the Draft EIR, Response to Comments ( RTC), corrections and additions to the Draft EIR, and a Mitigation Monitoring Report Program (MMRP),
1. 2.2 - Project HIstory
The project, which was fonner1y known as The Paradise Hills Specific Plan, was submitted to the City ofSan Bernardino in 1991 and approved in 1993. The City of San Bernardino General Plan and Development Code govern land use and zoning on the project site. Both ofthese plans identify the project site as governed by the Paradise Hills Specific Plan. Currently, the proposed University Hills Specific Plan is not consistent with the City of San Bernardino General Plan Land Use. However, the project proposes to do a General Plan amendment, making the proposed project site consistent with the General Plan Land Use. Ifapproved, the University Hills Specific Plan (UHSP) would replace the Paradise Hills Specific Plan relative to land use on the Proposed Project site. The approved Paradise Hills Specific Plan proposed 504 residential units on approximately 229 acres ( 56.7 percent) with 175 acres ( 43.3 percent) to remain as natural open space. The residential units were divided into areas in the "foothill" development zone (383 units on 110.6 acres or 3.5 units per acre average density) and areas in the " hillside" development zone ( 121 units on 117,9 acres or 1 unit per acre average density).
The PHSP has a gross density of 1.25 units per acre (504 units on 404 acres) and a net density of2.2 units per acre (504 units on 229 acres - total size minus open space). Due to economic conditions, the project was never built.
1. 3 - Statutory and Regulatory Requlrementa
These fmdings are based upon the information in the record ofproceedings, including, but not limited to, the Final EIR, staffreports, project applicant' s materials, MMRP, and the testimony presented at public hearings.
Section 15091 ofthe CEQA Guidelines precludes the City from approving or carrying out a project for which a Draft EIR has been certified that identifies any significant environmental effects unless the City makes one or more ofthe following written finding(s) for each ofthose significant effects accompanied by a briefexplanation ofthe rationale for each finding:
1. Changes or alterations have been required in, or incorporated into, the project which will avoid or substantially lessen the significant environmental impact as identified in the Draft EIR; or
2, Such changes or alterations are within the responsibility and jurisdiction ofa public agency other than the City, and such changes have been adopted by such other agency, or can and should be adopted by such other agency; or
3, Specific economic, social, legal, or other considerations make infeasible the mitigation measures or project alternatives identified in the Draft EIR.
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Sections 15092 and 15093 ofthe CEQA Guidelines require that ifthe project will cause significant unavoidable adverse impacts, the City must adopt a Statement ofOverriding Considerations prior to approving the projecL A Statement ofOverriding Considerations states that any significant adverse project effects are acceptable ifexpected project benefits outweigh unavoidable adverse environmental impacts,
1. 4. Summary of Environmental Findings
As set forth in more detail below, the City of San Bernardino Planning Department bas endeavored in good faith to set forth the basis for its decision to approve the Proposed Project. All ofthe findings made by the City of San Bernardino are based upon its consideration ofthe Final ElRand the substantial evidence within the record as a whole. Each ofthese environmental issues is described in Section 2 (Introduction) and in Section 1 ( Executive Summary) ofthe Draft EIR.
Environmental impacts identified in the Final EIR which the City of San Bernardino finds are less than significant and do not require mitigation are as follows:
Aesthetics, Light, and Glare;
Agricultural and Mineral Resources;
Mineral Resources; and
Recreation.
Environmental impacts identified in the Final EIR as potentially significant, but which the City of San Bernardino finds can be mitigated to a less than significant level through the imposition ofmitigation measures and/or conditions set forth herein are as follows:
Biological Resources;
Cultural Resources;
Geology, Soils, and Seismicity;
Global Climate Change;
Hazards and Hazardous Materials;
Hydrology and Water Quality;
Land Use and Planning;
Noise;
Public Services;
Utilities.
Environmental impacts identified in the Final EIR as potentially significant but which the City ofSan Bernardino finds cannot be fully mitigated to a less than significant level despite the imposition ofall feasible mitigation measures are as follows:
Air Quality;
Population and housing and SCAG
Consistency; and
Transportation and Circulation.
Environmental impacts identified in the Final EIR as cumulative, unavoidable adverse, and irreversible are described in Section 5 ofthis document Packet Page. 1106
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Environmental impacts identified in the Final ElR as growth-inducing, unavoidable adverse, and irreversible are described in Section 6 ofthis document.
Alternatives to the Proposed Project that might eliminate or reduce significant environmental impacts are described in Section 7 ofthis document.
Public Resources Code ~ 21081.6 requires the City to prepare and adopt a mitigation monitoring and reporting program for any project for which mitigation measures have been imposed to assure compliance with the adopted mitigation measures, Prior to taking action to approve the project, the City of San Bernardino was presented with, heard, reviewed, and considered all ofthe infonnation and data in the administrative record, including, but not limited to, the Final ElR and all oral and written testimony presented to it during meetings and hearings. The Final ElR reflects the independent judgment ofthe City of San Bernardino and is deemed adequate for pwposes ofmaking decisions on the merits ofthe project and its related actions. No comments made in the public hearings conducted by the City of San Bernardino Planning Department or any additional information submitted to the City have produced any substantial new information requiring recirculation or additional environmental review ofthe Draft ElR WIder CEQA because no new significant environmental impacts were identified, no substantial increase in the severity ofany environmental impacts would occur and no feasible mitigation measures, as defined in CEQA Guidelines Section 15088.5, were rejected,
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The City of San Bernardino Planning Department finds that the following environmental impacts identified in the Draft EIR are less than significant, and as a result, mitigation is not required under CEQA.
2.1 . Aesthetics, Light, and Glare
From the visual simulations, it appears most views ofthe site would be obstructed by Badger Hill, especially from existing residences to the southeast, and by the Kendall Hills, which will block views from the southwest including the 1- 215 Freeway. Limited views ofthe site, especially the upper portions adjacent to the San Andreas Fault and Badger Canyon, will occur with distance from the site, including from residences across Northpark Boulevard to the southwest and from the Cal State University San Bernardino campus. The Specific Plan landscaping guidelines indicate that manufactured slopes will be replanted, but some ofthese slopes may be visible vom locations south and southwest ofthe site, The upper slopes ofthe San Bernardino Mountains and Badger Canyon will remain as permanent open space and views ofthese areas will not change from present conditions.
Several policies in the City ofSan Bernardino General Plan recognize that the project site (as the PHSP site) will be developed with residential uses. The proposed UHSP land plan increases development intensity on the alluvial fan areas bnt clusters or concentrates residences south ofthe San Andreas Fault and out ofBadger Canyon. On balance, the proposed UHSP land plan appears to be equivalent or superior to the previously approved PHSP in terms ofvisual impacts, The project site is not visible from 1- 215 or SR-18, and neither ofthese are designated scenic routes in the vicinity ofthe project site. Development ofthe Proposed Project would not affect views ofthe hills from 1- 215 because ofthe intervening Kendall Hills. For these reasons, the Proposed Project will have a less than significant impact on Aesthetics Light and Glare.
2.2 - Agricultural and Mineral Resources
According to the Farmland Mapping and Monitoring Program (FMMP) maps prepared by the California Resources Agency, there is no designated Prime Farmland, Unique Farmland, or Farmland ofStatewide Importance on the project site or adjacent areas, In addition, the site does not contain enough prime agricultural soils or other physical characteristics that would yield a significant LESA Model score, Furthermore, according to the City ofSan Bernardino General Plan, the project area is not designated for agricultural use, and there are no active Williamson Act contracts in place for any portion ofthe project area or adjacent areas,
According to the California Department ofConservation' s Mineral Land Classification report for the area, the project site occurs within an area that has been classified as MRZ- 3, These are areas where Packet Page. 1108
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the significance ofmineral deposits cannot be evaluated from available data. However, it should be noted that no mineral production currently occurs on or adjacent to the project area. Soil composition, depth-to-bedrock, and other factors make the site unattractive for sand and gravel operations, These types ofoperations are better suited to valley bottoms and arroyo channels, not the mountain foothills where the project is located, Other valuable mineral resource constituents are not known to occur in the project area. For these reasons, the Proposed Project will have a less than significant impact on Agriculture and Mineral Resources,
2.3 - Recreation
The Proposed Project would increase the City' s population and have a corresponding increase in park usage. However, the Proposed Project would provide 10.3 acres ofonsite park facilities and the equivalent of6. 1 acres ofin-lieu fee payments to acquire and develop additional parkland to offset its contribution to increase park usage.
The City' s General Plan shows the Foothills Regional Trail goes through the Proposed Project site.
The University Hills Specific Plan proposes a
regional trail along the extension ofCampus Parkway
through the site in a northwest-southeast direction to provide connections to the future planned extension ofthe Foothills Trail to the east and west ofthe project site.
In addition, the project would provide non-vehicular paths, sidewalks, etc. for project residents to travel within the project and to the CSUSB campus without using personal vehicles. For these reasons, the Proposed Project will have a less than significant impact on Recreation.
2.4 - Cumulative Impac1B
2.4.1 - Aesthetics, LIght, and Glare
The analysis area for evaluation ofcumulative impacts to aesthetics resources includes views ofthe southwestern portion ofthe San Bernardino Mountains to the north. Views ofthe site from surrounding areas are somewhat limited by the Kendall Hills to the southwest and Badger Hill immediately south ofthe site. The slopes with elevations above 2,000 feet are readily visible from downtown San Bernardino and other locations in this portion ofthe San Bernardino Valley where views are not blocked to the north. Views ofthe site from the 1- 215 Freeway are effectively blocked by the low Kendall Hills (along the north side ofKendall Drive west ofUniversity Parkway), Development ofthe project as proposed will not require grading above 1, 900 feet elevation other than the one reservoir pad, which means no manufactured slopes will be visible at a distance away from this project. Similarly, planned structures are residential in nature and generally one to three stories in height, Since views ofthe site are restricted on an area-wide basis, so too would be glare from reflections offwindows or direct views ofnight lighting such as streetlights. The project does not contain any lighted athletic fields so there will be no glare from this potential source. For these reasons, the project will not have cumulative impacts relative to views or glare, Packet Page. 1109
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This area is essentially vacant at present and bounded by national forest land on the north. Nighttime lighting levels are very low at present, although there is considerable spillover from night lighting at the CSUSB to the south. Ifthe Proposed Project is built, it will contribute to an overall increase in ambient nighttime light levels referred to as " sky glow" by the International Dark Sky Association, the most prominent group that monitors this urban and suburban development impact www,darkskies.onz), The development standards ofthe Specific Plan limit the insta1lation of lighting fixtures to the degree required for public safety by police and fire personnel. In addition, lighting levels will be relatively low, in tenns ofurban development, since the project is all residential and will have no commercial or institutional facilities that are lighted at night (e.g., shopping center).
Potential impacts would be reduced further by review ofproposed lighting plans during subsequent development review ofthe project as specific maps or buildings are proposed.
Cumulative impact analysis is guided by buildout assumptions identified in the Land Use Section of the San Bernardino General Plan, Within the City and surrounding vacant areas, approved and additional development would result in additional lighting and surfaces that will create glare. The General Plan estimates the City will grow by 23, 568 units from now until buildout, which will disturb thousands of acres of land (fable LU-3, City General Plan 2(05), but a relatively small amount ofthis
planned growth will occur in the foothills and areas surrounding the Proposed Project site, While the Proposed Project will incrementally contribute to an increase in sky glow, this area is planned for residential development and its contributions to ambient lighting levels is considered to be not cumulatively considerable.
2.4.2 - Agricultural and Minerai Resources
The analysis area for evaluation of cumulative impacts to the entire City and this portion ofthe San Bernardino Valley.
The project, when combined with other projects anticipated in the General Plan, would not result in cumulative impacts, Other projects that would occur under Genera1 Plan bui1dout may affect the availability ofexisting or historical agricultural land or areas with identified mineral resources.
Future development would also be required to comply with the City of San Bernardino General Plan, Fulfillment ofthese requirements would ensure that no significant impacts on these specialized land uses will occur from other projects that would occur under buildouL
2.4.3 - BIological Resources
The analysis area for evaluation ofcumulative impacts to biological resources includes this westem portion ofthe San Bernardino Mountains, its foothills along the southern slope ofthe mountains, as well as the canyons that drain these slopes, down to Cajon Creek and ultimately to the Santa Ana River southwest ofthe project area. The project will develop 160 acres ofalluvial fan terrace area covered by chaparral with vegetation ofdisturbed grassland and native scrub vegetation. Some of these lands overlap critical habitat for the Califomia gnatcatcher and San Bernardino kangaroo rat, However, neither ofthese species were found on the project site. Conversely, the project would preserve 235 acres of land comprising the foothills and canyons ofmiddle and upper Badger Canyon, J>.
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which is a major drainage in this portion ofthe foothills. With mitigation, potential impacts to listed animal species were reduced to less than significant levels. With the preservation ofBadger Creek and its feeder canyons, potential regional impacts from this project on biological resources are not considered to be cumulatively considerable,
2.4.4 - Cultural Resources
The analysis area for evaluation ofcumulative impacts to cultural resources includes the entire City as outlined in the San Bernardino General Plan. The project vicinity represents an area with prehistoric settlement by several Native American groups prior to Spanish and Mexican settlement, and then American settlement during the mid-nineteenth century, The project site and surrounding areas are largely vacant at present. The site appears to contain remnants of a small residential " camp" and homestead but this area will remain in pennanent open space so there are no impacts in this regard.
Development ofthe project site will contribute to the incremental loss ofvacant lands that may contain cultural artifacts or resources, Potentially significant impacts were found for historic, archaeological, and paleontological resources, and for human remains, due to the possibility of encountering an unanticipated find during excavation. Mitigation measures are proposed to reduce the potentially significant impact to less than significant levels. With implementation ofthese mitigation measures, impacts to cultural resources would not be cumulatively considerable.
2.4.5 - Geology, Solis, and Seismicity
The analysis area for evaluation ofcumulative impacts to geology, soils, and seismicity includes this portion of San Bernardino County, due to the presence of several branches ofthe San Andreas Fault that cross the site. The various geotechnical investigations evaluated subsurface soil and groundwater conditions at the project site. The existing documents contained the results ofextensive field explorations, laboratory testing, engineering analyses, and design recommendations for previous development projects at or near the project site. From these documents, geotechnical conclusions and preliminary recommendations for planning ofthe proposed development were developed.
Cumulative impact analysis is guided by buildout assumptions identified in the Land Use Section of the San Bernardino General Plan, Within the City and surrounding vacant areas, approved and additional development would result in additional excavation activities and further intensification of land use that could potentially impact geology, soils, and seismicity in the area. The General Plan estimates the City will grow by 23, 568 units from now until buildout, which will disturb thousands of acres ofland (Table LU-3, City General Plan 2005).
Potentially significant project-level impacts were found concerning exposure ofpersons or structures to seismic hazards due to the presence of several faults onsite. Potentially significant impacts were also found concerning substantial erosion or loss oftopsoil during site construction, The Proposed Project would develop 980 residential units in this portion ofthe City. The General Plan identifies areas in the City where additional growth will occur that contain various geotechnical constraints, including faults and soil erosion. However, only a small amount ofthis growth will occur proximate to the San Andreas Fault Zone. The City' s General Plan, Development Code, development review Packet Page. 1111
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process, and uniform building code all require detailed geotechnical studies for proposed development which identilY impacts and appropriate mitigation for suspected geotechnical hazards, similar to the process applied to the USHP project.
Implementation ofthe UHSP project and future development under the General Plan, consistent with development guidelines from required geotechnical studies, will help reduce potential earth-related cumulative impacts to less than significant levels, Therefore, the Proposed Project will not make a substantial contribution to cumulatively considerable impacts relative to geology, soils, and seismicity,
2.4.6. Huards and Huardous Materials
The analysis area for evaluation ofcumulative impacts to hazards and hazardous materials includes the University District subarea identified in the San Bernardino General Plan as well as the City as a whole. Cumulative impact analysis is guided by buildout assumptions identified in the Land Use Section ofthe San Bernardino General Plan. Citywide, approved and additional development will result in additional excavation activities and further intensification ofland use that could potentially impact hazards and hazardous materials in the area. Development ofthe City is expected to increase housing by 23, 568 units from now until buildout, with some ofthat land being vacant while other lands have been developed.
Development ofthe Proposed Project would result in an increased demand for fire protection services, resulting in the need for additional fire protection facilities and personnel to cover the Proposed Project, Potentially significant impacts were not found concerning: ( 1) location on a site that would create a potential hazard to the public and the environment; (2) exposure of sensitive receptors to hazardous emissions, materials, substances, or waste; or (3) impeding the implementation of or physically interfering with an adopted emergency response or evacuation plan. The Proposed Project would develop 980 residential units in an outlying vacant area, but residential development in general does not generate significant amounts ofhazardous materials. Growth ofindustrial and to a lesser degree commercial uses in the City would generate more risk and potential impacts relative to hazardous materials on a cumulative basis, With implementation ofbest management practices and by following regulations, the Proposed Project would not make a substantial contribution to a cumulatively considerable impact relative to hazardous materials.
2.4.7. Hydrology and Water Quality
The analysis area for evaluation ofcumulative impacts to hydrology and water quality includes the University District sub-area, identified in the San Bernardino General Plan as well as the City as a whole. The project site is currently vacant and does not consume potable water. The Preliminary Hydrology Report was prepared to present an initial analysis ofthe Proposed Project' s effects on the local and regional drainage basin and to serve as a background for subsequent reports, such as a Stormwater Control Plan and a SWPPP, that are required during the development process. These and other subsequent documents will detail the design recommendations for the control of stormwater for the project site and be used to meet local and regional regulatory requirements.
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Cumulative impact analysis is guided by buildout assumptions identified in the Land Use Section of the San Bernardino General Plan. Citywide, approved and additional development will result in additional excavation activities and further intensification ofland use, which could potentially impact hydrology and water quality in the area. The tota1 residential units are expected to increase from 59, 146 at present to 82,714 at buildout, representing an increase of23,568 units, Potentially significant impacts were not found concerning the creation ofadditional impervious surface coverage and alteration ofexisting drainage patterns, potentially leading to downs1ream flooding or substantial erosion or siltation on- or offsite. Potentially significant impacts were found relating to adverse impacts to water quality during construction, adverse impacts to water quality from land use activities associated with the Proposed Project, substantial depletion ofgroundwater supplies or substantial interference with groundwater recharge, and creation ofrunoff water that could exceed the capacity ofexisting or planned stonnwater drainage systems. The Proposed Project would develop 980 residential units in this University District subarea. When taken into account with all residential and commercial buildout anticipated in the General Plan, the Proposed Project would result in a significant cumulative effect. However, the design ofthe project will incorporate water retention basins and bio-swales to increase infiltration ofwater as the new project is built.
The Proposed Project would cause a net increase in potable water demand by almost a million gallons per day in relation to existing demand on the project site. The City' s WSA bas indicated that this demand is accounted for in their long-tenn water supply planning and would not require the development ofadditional supplies. Unfortunately, City staffindicate that reclaimed water is not and will not be available to the project area at a cost effective rate due to its elevation (i.e., too high), and there is no infrastructure in place or planned to provide reclaimed water to the project site. Even with the ongoing uncertainty of imported water for Southern Califomia and the City' s General Plan goal of using recycled water whenever practical, this impact is considered less than significant due to the design and location ofthe project relative to water and reclaimed water. Furthermore, with the design ofthe project and recommended mitigation measures, the EIR concluded that water-related impacts ofthe Proposed Project would be reduced to less than significant levels. Therefore, the project will not have a cumulatively considerable impact regarding hydrology and water quality,
2.4.8 - Land Use
The analysis area for evaluation ofcumulative impacts to land use includes the University District subarea and the City as a whole, as identified in the San Bernardino General Plan. The project site and its surroundings are vacant. The General Plan designation for the project site is Residential Low RL) in the steeper areas and Residential Suburban (RS) in the flatter portions ofthe site - these designations would allow from 750 to 966 residential units to be built on the site, depending on how units were placed or clustered in hillside areas (see Section 4.8, Land Use, and 4.10, Population and Housing, for more infonnation on potential bui1dout estimates). In addition, the City approved the Paradise Hills Specific Plan which would allow 504 units to be built on the site.
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Cumulative impact analysis is guided by buildout assumptions identified in the Land Use Section of the San Bernardino General Plan, Within the City, approved and additional residential and commercial development will result in additional excavation activities and further intensification of land use. Total residential units will increase from 59,146 units at present to 82,714 units at buildout.
The University Hills project would increase the intensity ofdevelopment on the project site by 95 percent compared to the PHSP (980 vs, 504 units). However, it is estimated that approximately 750 to 966 units could be built on the UHSP project site under the RL and RS designations ofthe General Plan, depending on how units were actually clustered in hillside areas. Development under the UHSP would represent an increase of 1.5 to 31 percent over that allowed under the Genera Plan.
Section 4. 10, Population and Housing, ofthe EIR concluded that the Project would have siguificant population and housing impacts because it was not consistent with SCAG growth projections, however, it does not appear the Project would make significant contributions to cumulative land use impacts related to growth.
The project will intensify the land use designated by the General Plan by up to 31 percent. When combined with other projects anticipated in the General Plan, it is not anticipated that this potential amount of change would result in cumulatively considerable land use impacts, Other projects that would occur under General Plan buildout would not physically divide an established community, and they would be required to demonstrate compatibility with surrounding land uses and comply with the City of San Bernardino General Plan and Development Code, Fulfillment ofthese requirements would ensure that no significant impacts on land use occur from other projects that would occur under buildout,
2.4.9 - Noi..
The analysis area for evaluation of cumulative noise impacts encompasses the ambient noise environment around the project site as well as roadways that would experience increases in traffic volumes from project-generated trips. The cumulative noise impact analysis is gnided by evaluating increases in ambient noise levels in the project vicinity relative to existing conditions. Construction noise would result in temporary increases in ambient noise levels, and mitigation is proposed that would require implementation ofnoise control measures during construction activities. Because construction would be tempormy, ambient noise levels would not experience a pennanent increase and, therefore, no cumulatively considerable increase would occur. The Proposed Project would result in construction and operational vibration. Construction and operational vibration would not exceed significance thresholds at the nearest land uses (the residences south ofPlanning Areas 18 and 20 offofNorth I Street) and, therefore, would not be cumulative considerable. Project residential units would not be exposed to substantial vibration from vehicular activities due to the nature ofthe project (i.e., suburban residential), Therefore, project residents would not be exposed to significant sources ofvibration or noise, and impacts would not be cumulatively considerable. Vehicular trips generated by the Proposed Project would not cause ambient noise levels along any affected roadway segments to exceed acceptable noise standards under opening year or buildout conditions, Therefore, the Proposed Project would not have a cumulative considerable impact related to increased ambient Packet Page. 1114
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noise levels on nearby roadways. Onsite noise associated with the Proposed Project would not result in ambient noise levels increasing to unacceptable levels at any surrounding land uses, Therefore, the Proposed Project would not have a cumulative considerable impact related to increased ambient noise levels at surrounding land uses. Onsite noise associated with the Proposed Project may expose project residents to unacceptable levels. Mitigation is proposed that would require the installation of various structural noise attenuation measures to ensure that interior residential noise levels are within acceptable standards to reduce impacts to a less than significant level. Therefore, the Proposed Project would not have a cumulative considerable impact related to exposure ofproject residents to unacceptable noise levels. In summary, the Proposed Project would not resuh in increases in ambient noise that would be cumulatively considerable.
According to the City of San Bernardino General Plan Environmental Impact Report (2005 EIR), noise impacts would be significant after buildout until the San Bernardino Airport Master Plan has been adopted by the San Bernardino International Airport Authority (SBIAA) and corresponding noise contours have been established the extent ofimpact to parkland near the airport cannot be detennined, Parkland is designated as a sensitive use in the General Plan and should the noise contour exceed the limitations established by the General Plan no foreseeable mitigation could be accomplished ifthe park were to remain in use. Under those circumstances, the impact would be considered a significant adverse and unavoidable impact. The proposed UHSP is approximately
7.5 miles from the San Bemardino International Airport and is therefore outside the five (5) mile noise contour and will not impacted be impacted,
2.4.10 - Population and Housing
The analysis area for evaluation ofcumulative impacts to population and housing encompasses the SANBAG area and the entire Southern California region as monitored by SCAG.
Cumulative impact analysis is guided by the population growth assumptions included in the City of San Bernardino General Plan and SANBAG' s projections, The City of San Bernardino General Plan anticipates significant growth in San Bernardino between 2005 and 2030, The California Department ofFinance estimated San Bernardino' s population to be 200,280 in 2005, The General Plan projected a five-year increment for the City' s population; the projected 2007 population for the City is 205,010.
According to SCAG the City' s population for the year 2010 will be 207,021. The average annual increase in the City' s population is 1.5 percent. The average annual increasein the City' s 2007 population in combination with a 1.5 percent annual increase would make the total population 214,466 by the year 2010, The Proposed Project is anticipated to open in 2010, SCAG anticipates that the City' s population would be 207,021 persons that year, indicating that actual growth has occurred at a much lower rate than anticipated. The Proposed Project' s residential uses would directly add an estimated 3, 283 residents to the City' s population over approximately a 5- year period or through 2015, The Proposed Project would not create substantial new employment opportunities because this is a residential project.
Packet Page. 1115
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For the purposes ofproviding a worst-case scenario analysis, it is assumed that all ofthe 3,283 new residents ofthe project would also be new residents to the City, SANBAG' s forecast for population growth in San Bernardino is the same as that contained in the General Plan. Based on the existing population (205,010) and accounting for expected population growth between 2010 and 2015 ( 1.5 percent annually) , the City' s estimated population in 2010 without the Proposed Project would be 207,021 residents. The addition ofthe 3, 283 new residents associated with the Proposed Project would bring the population to 210,304, exceeding the City and SCAG' s 2010 population projection of 207,021 persons by two (2) percent. With the addition ofpopulation growth induced by the Proposed Project, the City' s 2015 population is estimated to be 212, 143 persons, which would slightly exceed the SANBAG' s 2015 projection (208,860) by two (2) percent. Although the slight addition of population from the proposed project is projected to exceed SANBAG' s 2010 projections by two (2) percent, the Proposed Project would not represent a cumulatively considerable growth-inducing impact relative to population and housing.
2.4.11 . Public Services and Recreation
The analysis area for evaluation ofcumulative impacts to public services and recreation includes the entire City of San Bernardino. The City of San Bernardino Parks and Community Services Department owns and maintains 52 park sites totaling 540 acres. Ofthese sites, 10 are dedicated community parks, 19 are neighborhood parks, 3 are special use parks, and 17 are pocket or miniparks.
Cumulative impact analysis is guided by buildout assumptions identified in the Land Use Section of the San Bernardino General Plan. Within the subareas that constitute the City, approved and additional residential and commercial development will resuh in a further intensification ofland use and continue to place demands on public services and recreation resources compared with existing conditions. Within the City, residential development will increase the housing stock from 59, 146 units to 82,714 units (+72 percent), and substantial development will also occur in the Sphere ofInfluence area (a total of95,664 units at bui1dout [Table LU-3, CSB General Plan 2005]).
Among public services and recreation resources, potentially significant impacts were found only for fue protection and emergency medical services, and trails. Potentially significant impacts were found regarding fire protection and emergency medical services that were due to the location ofthe project relative to existing police and fue facilities. Other projects that would occur under buildout could include mixed use projects with multistory buildings and both residential and commercial uses combined. Therefore, when considered with other projects associated with bui1dout, the Proposed Project would resuh in cumulative impacts for fue protection and emergency medical services. Since impacts for these resources are potentially significant for the Proposed Project separately, there would be a cumulatively considerable impact regarding fue protection and emergency medical services.
However, the same types ofmitigations that would reduce these project specific impacts to less than significant would be developed for other projects associated with buildout (i,e" dedication of sites for new police and fue facilities). After mitigation, therefore, no cumulatively considerable impacts to fire protection and emergency medical services would occur. An incremental increase in impacts to Packet Page. 1116
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local and regional trails was also found associated with increased numbers ofresidents and trail users in outlying areas. Other projects that would occur during buildout would also increase numbers of residents and new employees and create additional use ofthe Foothill Trail and other trails beyond that anticipated for the Proposed Project. The project is installing the section oftrail within its boundaries, so the Proposed Project is not expected to result in cumulative impacts to trails.
2.4.12. Utilities
The project, when combined with other projects anticipated in the General Plan, would not result in cumulative impacts. However, other projects that would occur under General Plan bui1dout may increase the amount ofenergy consumed by the City. Other projects in the planning area would be required to provide adequate assessment of local and regional energy facilities to conclude the future project would not significantly increase demands on energy consumption. Furthennore, future development would be required to comply with the City of San Bernardino General Plan. Therefore, because increased consumption ofenergy by the Proposed Project and other developments in the City have to comply with the City' s General Plan, or are already anticipated by local or regional energy facilities, the cumulative energy impacts ofthe Proposed Project would be less than significant. A detailed discussion of impacts and mitigation measure can be found in Section 4. 14, Utility Systems,
2.5 - Summary
Regional growth may eventually result in a number ofcumulatively considerable impacts, including traffic and air quality. However, the Proposed Project will not make significant contribution to any of these cumulatively considerable impacts either during construction or from use ofthe planned improvements.
Packet Page. 1117
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The City of San Bernardino Planning Department finds that the following environmental impacts identified in the Final EIR are potentially significant but can be mitigated to 8 less than significant level through the imposition ofmitigation measures and/or conditions identified in the Final EIR and summarized below,
3.1 - Biological Resources
3.1. 1 - Potentially Slgnlflcantlmpact
Implementation ofthe project has the potential to adversely impact Plummer' s mariposa lily, burrowing owl, nesting birds, andjurisdictional land.
3.1. 2 - Finding
With consideration ofthe above infonnation and the implementation ofmitigation measures BIO-18 through BIO-lc, and BIO-38, the project' s impacts to biological resources are found to be less than significant.
3.1. 3 - Facts In Support of Finding
The project-specific environmental effects will be eliminated or substantially lessened to less than significant levels by implementation ofthe following mitigation measures, as identified in the Final EIR:
MM Blo-1.
MM BlO-1b
Plummer' s Marisposa Lily. During the spring prior to grading, the developer shall retain 8 qualified biologist to conduct a focused survey ofthe proposed development areas to detennine ifthis species is present onsite. The survey shall be conducted according to the standard protocol established by CDFG. Ifthe species is present, the developer shall fund relocation ofthe plants to 8 suitable location within the permanent open space area.
Burrowing OwL Within 30 days ofgrading or any ground disturbance activities on the project site, 8 qualified biologist shall conduct 8 focused survey to detennine if burrowing owls are present onsite, The survey shall be conducted according to the standard protocol established by CDFG. Ifburrowing owls are detennined to be present on the site, mitigation shall follow the CDFG guidelines including passive relocation. Ifvegetation removal or ground disturbance begins within 30 days ofthe focused survey, no pre-construction survey would be required. Ifvegetation removal or ground disturbance activities begin after 30 days ofthe focused survey, 8 subsequent pre-construction survey would be required.
Packet Page. 1118
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MM BIO-1c NestiDg Birds. Iftrees or large shrubs (over 4 feet in height) will be removed during the nesting season (February 1 through August 31), a qualified biologist shall conduct a nesting bird survey no more than 30 days prior to any disturbance to identifY any potential nesting activity. Ifpasserine birds are found to be nesting, or there is evidence ofnesting behavior within 250 feet ofthe impact area, the biologist shall determine an appropriate buffer that shall be required around the nests, No vegetation removal or ground disturbance would occur within this buffer, For raptor species--- birds ofprey (e.g., hawks and ow1s}-this buffer would generally be 500 feet. A qualified biologist shall monitor the nests closely until it is detennined that the nests are no longer active, at which time construction activities may commence within the buffer area, Construction activity may encroach into the buffer area at the discretion ofthe biological monitor,
MM- BIO-3a Jurisdictional Laud. Prior to grading, the developer shall obtain a Clean Water Act Section 404 Pennit from USACE, a Clean Water Act Section 401 Certification from the RWQCB (Santa Ana Region), and a Streambed Alteration Agreement from CDFG ifjurisdictiona11and will be impacted. Offsite mitigation, ifnecessary, shall be provided at a minimum 1: I ratio depending on location and importance ofthe jurisdictional land removed, Ifthe project provides onsite mitigation equal or in excess ofits identified impact (i,e., removal ofjurisdictiona11and), no permits may be necessary. This determination shall be made by qualified biologists in consultation with City Planning, USACE, and CDFG staffbased on the final land plan and value assigned to the proposed bio-swales and other drainage improvements onsite,
3.2 - Cultural Resources
3.2.1 - Potentially Significant Impact
Implementation ofthe project has the potential to adversely impact unidentified cultural, archaeological, paleontological resources,
3.2.2 - Finding
With consideration ofthe above information and the implementation ofmitigation measures CUL-1 through CUL-4, the project' s
impacts to cultural resources are found to be less than significant
3.2.3. Facts In Support of Finding
The project-specific environmental effects will be eliminated or substantially lessened to less than significant levels by implementation ofthe following mitigation measures, as identified in the Final EIR:
MM CUL-1 The developer shall retain a qualified historian to survey the building remnants between Planning Areas 18 and 20 to detennine ifthey have any historical significance prior to excavation ofthe site. Due to their condition, they could not be Packet Page. 1119
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preserved or protected in place even ifit is determined they bad bistorical significance, Ifthey are determined to be significant, the developer sball retain a qualified bistorian to document the resource cbaracteristics for arcbival purposes prior to demolition. The historian will prepare areport and submit it to the appropriate infonnation center for their records,
The developer sbal1 retain a qualified arcbaeo1ogist to monitor grading to the satisfaction ofthe staffs ofthe County Museum and City Development Services Department. Ifpotentially significant archaeological or bistoric resources are encountered during subsurface activities, all construction within a 100-foot radius of the find sball cease until the monitor determines wbether the resource requires fw1her study. The developer shall include a standard inadvertent discoveIY clause in every construction contract to inform contractors ofthis requirement. Any previously undiscovered resources found during construction sball be recorded on appropriate DPR forms and evaluated for significance in terms ofCEQA criteria by a qualified archaeologist. Potentially significant culturaI resources consist of, but are not limited to, glass, ceramics, stone, bone, wood, rock and shell artifacts or features, including hearths, stroctura1 remains, or pre-bistoric dumpsites, Ifthe resource is determined to be significant under CEQA, a qualified archaeologist shall prepare and implement a researcb design and archaeological data recoveIY plan, ifnecessary. The archaeologist shall also perform appropriate technical analyses, prepare a full written report and file it with the appropriate information center, and provide for pennanent curation ofthe recovered resources.
Prior to the start ofexcavation, a qualified paleontological monitor will be retained to conduct an oosite monitoring program to ensure protection ofpreviously unknown paleontological specimens, In the event a fossil is discovered during construction of the Proposed Project when the paleontological monitor is not present, excavation within 100 feet ofthe find shall be temporarily baited until the discoveIY is examined by a qualified paleontologist, in accordance with Society ofVertebrate Paleontology standards. The developer shall include a standard inadvertent discoveIY clause in every construction contract to inform contractors ofthis requirement, Tbe paleontologist sbal1 notifY the City ofthe procedures that must be followed before construction is allowed to resume at the location ofthe fmd. Ifthe find is determined to be significant and the Paleontologist determines that avoidance is not feasible, the paleontologist shall design and carry out a data recoveIY plan consistent with the Society ofVertebrate Paleontology standards. The plan shall be submitted to the City for review and approval, Upon approval, the plan shall be incorporated into the project. The Paleontologist sball also perform appropriate technical analyses, prepare a full written report and file it with the appropriate information center, and provide for permanent curation ofany recovered resources,
Packet Page. 1120
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MM CUL-4 Ifhuman remains are encountered during earth-disturbing activities for the Proposed Project, all work within 100 feet ofthe find shan stop immediately and the San Bernardino County Coroner' s office shall be notified, Ifthe Coroner detennines the remains are Native American in origin, the NAHC will be notified and, in turn, will notifY the person determined to be the Most Likely Descendent (MLD). The MLD will provide recommendations for treatment ofthe remains (CEQA Guidelines 15064.5; Health and Safety Code ~ 7050.5; Public Resources Code ~~ 5097,94 and 5097,98).
3.3 - Geology and Soils
3.3.1 - Potentially Significant Impact
Because the project is located in a seismically active region, the impacts in regard to geology and soil are considered potentially significant. California has stringent permitting and building design standards designed to minimize the adverse impacts in the event ofan earthquake. However, the Project may be damaged by seiche flows, soil erosion or topsoil loss, unstable geologic units, and expansive soils.
3.3.2 - FInding
With consideration ofthe above infonnation and the implementation ofmitigation measure GE0-1a, GEO- 1b, GEO-3a, and GE0-3b, the project' s
impacts to Geology and Soils are found to be less than
significant.
3.3.3 - Facta in Support of FindIng
The project-specific environmental effects will be eliminated or substantially lessened to less than significant levels by implementation ofthe following mitigation measures, as identified in the Final EIR:
MM GEO-1a Prior to the recordation ofany map in the area north ofthe South Branch ofthe San Andreas Fault (planning Area 15), detailed geologic investigations shall be prepared to detennine slope stability, landslide limits, and specific structura1 and grading requirements to identifY the most appropriate design and construction requirements for specific building foundations. This study must demonstrate that any residences to be built in this area will not be subject to landslides, or that risks associated with any landslide features or conditions can be alleviated or reduced to a level equivalent to that ofother residential planning areas in the project. This measure shall be implemented to the satisfaction ofthe City Planner in consultation with the City Geologist or qualified geotechnical personnel retained by the City, MM GEO-1 b Prior to the recordation ofany tract map in the area north ofthe South Branch ofthe San Andreas Fault (Planning Area 15), the developer must demonstrate that the reservoir in Planning Area 22 will have no impact on any homes in Planning Area 15 Packet Page. 1121
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from a seiche event that could occur from strong seismic ground shaking. The reservoir must be designed to withstand anticipated seismic shaking, and must be dyked or otherwise protected so as to protect downstream homes from seiche flow damage.
Prior to the commencement ofgrading activities, the applicant shall retain a qualified geotechnical consultant to test any areas planned for development that are underlain by existing imported fill soils to determine their in situ compaction and suitability for excavation and reuse as engineered fill. Soil testing can be avoided ifthe applicant elects to remove the fill and place it either in areas where it will not support buildings, be located in paved or landscaped areas, or be disposed ofoffsite, This measure shall be implemented to the satisfaction ofthe City Geologist.
The developer shall implement the grading recommendations identified in the GeoMat 2007 and the CHJ 2006 reports, Prior to the commencement ofbuilding construction, the applicant shall retain a qualified engineer to design foundations adequate to support the Proposed Project' s structures where necessary, based on the recommendations ofthe GeoMat 2007 study. Settlement analysis shall be performed once the structural design loads and foundation system geometJy have been defined for each building,
3.4 - Hazards and Hazardous Materials
3.4.1 - Potentially SIgnificant Impact
The drainage protection and planned improvements ofthe project do not rely on any USFS facilities or improvements to protect the site. In addition, a post-disaster recovery plan will be incorporated into the Specific Plan and the following mitigation measure is being added to address this concern raised by the City Planning Commission,
3.4.2 - Finding
With consideration ofthe above information and the implementation ofmitigation measure HAZ-1, the project' s impacts to hazards and hazardous material are found to be less than significant.
3.4.3 - Facts In Support of Finding
The project-specific environmental effects will be eliminated or substantially lessened to less than significant levels by implementation ofthe following mitigation measures, as identified in the Final EIR:
MM HAZ-1 Prior to issuance ofoccupancy permits, the developer shall prepare a Post-FirelFlood Recovery Plan for review and approval by the City. As appropriate, this plan shall incorporate planning guidelines from the Alluvial Fan Task Force (AFTF) established by the California Department ofWater Resources (DWR). The plan will Packet Page. 1122
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identifY the potential risks to project residents from various natural hazards from being located in the fire-prone foothills and adjacent to a large natural waterway Badger Creek). The plan will outline measures to be implemented after major fires or floods that will help protect future project residents to the degree practical. When approved, this plan shall be incorporated into the Specific Plan.
3.5 - Hydrology and Water Quality
3.5.1 - Po18ntlally Significant Impact
Implementation ofthe project has the potential to adversely impact water quality and groundwater.
Mitigation is required to offset any impacts to waters quality and groundwater.
3.5.2 - Finding
With consideration ofthe above infonnation and the implementation ofmitigation measures HYD-1a, HYD-1 b, HYD-2a, HYD-2b, and HYD-S, the project' s impacts to water quality and groundwater are found to be less than significant after mitigation,
3.5.3 - Facta In Support of Finding
The project-specific environmental effects will be eliminated or substantially lessened to a less than significant level by implementation ofthe following mitigation measures, as identified in the Final EIR:
MM HYD-1a Prior to the issuance ofgrading permits for any portion or phase ofthe project, the project applicant shall receive City approval SWPPP and Grading Plan to the City of San Bernardino that identifY specific actions and BMPs to prevent stonnwater pollution from construction sources. These BMPs shall be consistent with the Conceptual Water Quality Management Plan prepared for the project by PBS&] Engineers (see OElR Appendix G). The plans shall identifY a practical sequence for site restoration, BMP implementation, contingency measures, responsible parties, and agency contacts. The applicant shall include conditions in construction contracts requiring the plans to be implemented and shall have the ability to enforce the requirement through fmes and other penalties. The plans shall incorporate control measures in the following categories:
Soil stabilization practices;
Dewatering practices (ifnecessary);
Sediment and runoffcontrol practices;
Monitoring protocols; and
Waste management and disposal control practices,
Once approved by the City, the applicant' s contractor shall be responsible throughout the duration ofthe project for installing, constructing, inspecting, and maintaining the control measures included in the SWPPP and Grading Plan, Packet Page. 1123
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Each SWPPP shall identify pollutant sources that could affect the quality of stonnwater discharges from the construction site. Control practices shall include those that effectively treat target pollutants in stonnwater discharges anticipated from project construction sites. To protect receiving water quality, the SWPPP shall include, but is not limited to, the following elements:
Temporary erosion control measures (such as fiber rolls, staked straw bales, detention basins, temporary inlet protection, check dams, geofabric, sandbag dikes, and temporary revegetation or other ground cover) shall be employed for disturbed areas,
No disturbed surfaces will be left without erosion control measures in place during the winter and spring months (September 30 - March 30), Sediment shall be retained onsite by a system of sediment basins, traps, or other appropriate measures. Ofcritical importance is the protection ofexisting catch basins that eventually drain to Cajon Creek.
The construction contractor shall prepare Standard Operating Procedures for the handling ofhazardous materials on the construction site to eliminate or reduce discharge ofmaterials to stonn drains,
BMPs performance and effectiveness sha1l be determined either by visual means where applicable (i,e., observation ofabove-nonnal sediment release), or by actual water sampling in cases where verification ofcontaminant reduction or elimination, (inadvertent petroleum release) is required to determine adequacy ofthe measure.
Native grasses or other appropriate vegetative cover shall be established on the construction site as soon as possible after disturbance.
Landscaping Maullgement Plan. The developer shall develop and implement a Landscaping Management Plan (LMP) for landscaped areas with the goal ofreducing potential discharge ofherbicides, pesticides, fertilizers, and other contaminants to local waterways, All contractors involved in project-related landscaping conducted during the individual pbases ofdevelopment, as well as maintenance oflandscaping following project completion, shall complete their work in strict compliance with the LMP. The applicant shall be responsible for ensuring that requirements ofthe LMP are provided to and instituted by future project land owners and managers following project completion. The LMP shall be prepared by a licensed landscape architecture fmu with experience in methods to reduce or eliminate the use oflandscape chemicals that could cause adverse effects to the environment. At a minimum, this LMP shall:
Packet Page. 1124
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Require that pesticides and fertilizers not be applied in excessive quantities, and only applied at times when rain is not expected for at least 2 weeks, in an effort to minimize leaching and runoff into the stonn drainage system,
2. Encourage the use oforganic fertilizers and mulching of landscaped areas to inhibit weed growth and reduce water demands,
3, Utilize native, perennial, drought-tolerant vegetation to minimize irrigation needs.
4. Specify the maintenance measures to be used (e.g" mowing) and will specify an application schedule for all fertilizer amendments and pesticide applications,
5. Identify a list ofpreferred herbicides and pesticides and instances in which their use would be appropriate and the associated application rate.
MM HYD-2b Water QuaUty MalntenaDc:e Reports. The UHSP project shall fonn a Landscaping and Lighting Maintenance District (LLMD) to monitor water quality and provide regular reports to the City regarding water quality on the project site. A qualified professional shall be retained through the LLMD to prepare and provide annual documentation to the City Engineer that the onsite BMPs (i.e., water quality devices, improvements, and procedures) are functioning as planned to effectively protect water quality both onsite and on downstream uses/drainages. This includes the function and condition ofbioswales, street sweeping, etc. These reports shall be made to the satisfaction ofthe City Engineer in consultation with the RWQCB if necessary, If a report indicates water quality objectives are not being met and/or the RWQCB has expressed concerns in this regard, the LLMD will take appropriate steps and/or make appropriate improvements to achieve these objectives, to the satisfaction ofthe City Engineer,
MM HYD-6 Prior to approval ofany final maps, the developer shall submit drainage plans to the City Public Works Department for review and approval. The City shall review and approve all storm drain improvement plans prior to issuance ofany encroachment or building pennits that involve flood control facilities,
3.8 - Land use
3.8.1 - Potentially Significant Impact
Planning Area 24, which is the only planning area adjacent to USFS land, is proposed as pennanent open space that will be a " land laboratory" for the California State University San Bernardino CSUSB) campus, The Project developer is requested to work with the City and United States Forestry Service staffto install signage at appropriate locations clearly identifying the USFS Packet Page. 1125
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boundmy adjacent to the Proposed Project site, especially where any fU'e road or trails enter USFS property from the University Hills site,
3.6.2 - Finding
With consideration ofthe above infonnation and the implementation ofmitigation measure LU-1, the project' s impacts to hazards and hazardous material are found to be less than significant.
3.6.3 - Facts In Support of FindIng
The project-specific environmental effects will be eliminated or substantially lessened to less than significant levels by implementation ofthe following mitigation measures, as identified in the Final EIR:
MM LU-1 Prior to issuance ofany occupancy permits, the developer shall coordinate with City, CSUSB, and USFS staffs to identifY necessary access points and appropriate locations for such signage to clearly identify the USFS boundmy along the perimeter ofthe University Hills property (i.e., Planning Area 24). Such signage will be placed at strategic locations, including any road or trai1 access points, to the satisfaction of the City in consultation with CSUSB and USFS staffs.
3.7 - Nol. e
3.7.1 - Potentially Significant Impact
Implementation ofthe project has the potential to adversely impact sensitive receptors from shortterm construction activities and temporary or periodic increase in ambient noise levels. Mitigation is required to offset any impacts to noise and sensitive receptors.
3.7.2 - Finding
With consideration ofthe above infonnation and the implementation ofmitigation measures NOI- 1 through NOI-I i, the project' s
impacts to noise are found to be less than significant.
3.7.3 - Facts in Support of Finding
The project-specific environmental effects will be eliminated or substantially lessened to a less than significant level by implementation ofthe following mitigation measures, as identified in the Final EIR:
MM NOM. At the time the grading pennit application is submitted, the project applicant shall submit a Construction Noise Mitigation Plan to the City for review and approval.
The plan shall depict the location of staging areas for construction equipment and describe how noise would be mitigated for any nearby sensitive receptors..
MM NOI-1b Stationary noise-generating equipment (such as pumps and generators) will be located as far as possible from nearby noise-sensitive receptors (i.e., homes south of j
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PA 16-20) and no closer than 200 feet from any existing home within the Proposed Project site once occupancy has begun.
Noise-generating equipment will be shielded from nearby noise-sensitive receptors by noise-attenuating buffers such as structures or haul truck trailers, Onsite noise sources located less than 600 feet from noise-sensitive receptors will be equipped with noise-reducing engine bousings.
Portable acoustic barriers able to attenuate at least 6 dB will be placed around noisegenerating equipment in the " East Village" portion ofthe project site, Water tanks and equipment storage, staging, and warm-up areas will be located as far from noise-sensitive receptors as possible, and at least 200 feet from any existing borne within the Proposed Project site once occupancy has begun.
All construction equipment shall utilize noise reduction features (e,g., muftlers and engine shrouds) that are no less effective than those originally installed by the manufacturer.
No construction equipment shall be allowed to idle for more than 5 minutes ifit is within 100 feet of an existing house,
Prior to approval ofany subsequent tentative tract maps, the developer shall submit noise studies as appropriate for any residences within the project to assure that exterior and interior noise levels meet City noise standards based on actual final floor elevations, actual roadway cross sections and elevations, onsite topography after grading, etc. Walls or other attenuating improvements shall be installed as needed based on the results ofthese studies to assure onsite residences meet the City' s noise regulations,
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3.8 - Public Services
3.8.1 - Potentially Significant Impact
Implementation ofthe project has the potential to adversely impact library services, Mitigation is required to offset any impacts to library services.
3.8.2 - Finding
With consideration ofthe above information and the implementation ofmitigation PSR-4a and PSR4b, the project' s impacts to libnuy services are found to be less than significant.
3.8.3 - Facts In Support of Finding
The project-specific environmental effects will be eliminated or substantially lessened to a less than significant level by implementation ofthe following mitigation measures, as identified in the Final EIR:
MM PSR.... Prior to issuance ofthe first building permit for the project, the developer shall contact the City Library Director in writing and offer to provide up 2,000 square feet ofbuilding space in the clubhouse (plus parking), for a future satellite library facility, The developer shall provide the City Planning Department with written confirmation whether or not the Library Director chooses to locate a library facility on the Specific Plan property, based on the needs ofthe Department at that time relative to staffing and facilities.
MM PSR-4b Prior to issuance of the first building permft for the project, the developer shall demonstrate that the project can be connected via the internet to City library and other information technology systems, This may involve wireless or hard-wired connections, dapending on the City'srequirements at the time of hookup,
3.9 - Utilities
3.9.1 - Potentially Significant Impact
Implementation ofthe project has the potential to adversely impact solid waste capacity. Mitigation is required to offset any impacts to solid waste capacity.
3.9.2 - Finding
With consideration ofthe above information and the implementation ofmitigation measures US-4a and US-4b, the project' s
impacts to solid wast are found to be less than significant
3.9.3 - Facts in Support of Finding
The project-specific environmental effects will be eliminated or substantially lessened to a less than significant level by implementation ofthe following mitigation measures, as identified in the Final EIR:
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MM US4 Prior to the issuance of building pennits, the applicant shall submit a Construction Debris Recycling Plan to the City of San Bernardino identifying the procedures by which construction and demolition would be salvaged and recycled to the maximum extent feasible. The plan shall include proofthat a construction and demolition debris recycler is under contract to the applicant to perfonn this work, This Plan shall achieve at least a 50 percent reduction in construction waste, to the satisfaction ofthe City Planner,
MM US-4b Prior to the issuance of occupancy pennits, the developer shall provide the City with written assurance that all project residents will be provided with infonnation on City and County waste reduction and disposal activities, This infonnation may be provided by the developer or home owners association (HOA) as appropriate. This measure shall be implemented to the satisfaction ofthe City Planner.
3.10 - Cumulative Impacts
Potentially Significant Impact
The Proposed Project may have the potential to have cumulative impacts within three (3) miles ofthe project site.
Finding
With consideration ofthe above information, implementation ofproject specific mitiglltion measures was found to reduce impacts fiom the cumulative projects to less than significant levels, Therefore, no additional mitiglltion is needed other than project level mitigation measures, Facts In Support ofFinding
The project-specific environmental effects will be eliminated or substantially lessened to a less than significant level by implementation ofthe following mitiglltion measures, as identified in the Final EIR:
3.10.1 - Global Climate Change
Potentially Significant Impact
The Project may have potential impact to contribute to global green house gasses and global climate change,
Finding
With consideration ofthe above information and the implementation ofmitigation measure A1R-9a and A1R-9b, the project' s direct or indirect contribution to greenhouse gas emissions will be reduced to less than significant levels.
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The project-specific environmental effects will be eliminated or substantially lessened to less than significant levels by implementation ofthe following mitigation measures, as identified in the Final EIR:
MM AIR'" Areas and/or facilities to encourage recycling shall be provided and installed in all MDA and A (attached) residential areas (planning Areas 5, 6, 8-11, 13, 14, 16, ' 8, and 20) and in the clubhouse (planning Area 7) consistent with City requirements.
MM AlR-8b To increase energy efficiency, the following measures shall be implemented to the satisfaction ofthe City of San Bernardino: a) there shall be a minimum 10 percent reduction in all buildings, combined space heating, cooling, and water heating energy compared to the current Title 24 Standards; b) the project shall incorporate light roof colors and cool pavements in the residential driveway areas; c) each appliance (i,e" washer/dryers, refrigerators, stoves, etc.) provided by the builder must be Energy Star qualified ifan Energy Star designation is applicable for that appliance; d) low-flow appliances (i.e., toilets, dishwashers, shower heads, washing machines) shall be installed and; e) solar powered water heaters and photovo1taic cells (solar panels) shall be offered to homebuyers as an option.
Packet Page. 1130
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S~,,-(,-:_:-::~, :~'_-;;' ~"-:::':"'~ .,'(:-: :;;.'-? c.~~; ;--;:;:,? t:--Jt'~'_:'- X(: 3,;:~S( Y:<:5-;-:-~>'T<':: :::-'.,:. ..::< CEQA Guidelines Section 15126,2( a)(b) requires an Final EIR to identify and focus on the significant environmental effects ofthe Proposed Project, including effects that cannot be avoided ifthe Proposed Project were implemented,
This section describes significant impacts, including those that can be mitigated but not reduced to a less than significant level. Where there are impacts that cannot be alleviated without imposing a project a1temative, the EIR implications, and the reason why the project is being proposed, notwithstanding the Final EIR effect, are described. With implementation ofthe proposed mitigation measures, the Project will not create any significant environmental impacts.
4.1 - Air Quality
4.1. 1 . Potentially Significant Impact
Implementation ofthe project has the potential to adversely impact air quality and existing emissions ofgreenhouse gases. In addition the Proposed Project has the potential to adversely impact PM!o and PM2.s
levels, and may exceed SCAQMD localized daily thresholds. Other potentially significant impact can occur over the short-term duration ofthe Proposed Project (i.e., during construction),
4.1. 2. Finding
With consideration ofthe above information and even with the implementation ofmitigation measures AIR-I a
through AIR-1g, and AIR-3a through AIR-3d, the project' s impacts to air quality
criteria pollutants are found to be significant and unavoidable,
4.1. 3. Facts In Support of Finding
After the implementation ofthe identified mitigation measures, emissions of volatile organic compounds (VOC), nitrogen oxides ( ND,J, carbon monoxide (CO), su1fiu oxides ( SO,.), and particulate matter 2.5 ( PM2.5) will continue to exceed the South Coast Air Quality Management Plan' s ( SCAQMD) regional emission significance thresholds during construction and VOC, NOx" and CO during operations and, thus, are considered significant and unavoidable impacts.
MM A1R-1a Prior to construction ofthe proposed improvements, the project proponent will provide a Fugitive Dust Control Plan (FDCP) that will describe the application of standard best management practices to control dust during construction. Best management practices will include:
Application ofwater on disturbed soils a minimum oftwo times per day; Using track-out prevention devices at construction site access points; Stabilizing construction area exit points;
Limiting onsite construction traffic to 15 miles per hour on unpaved roads; Limiting onsite construction traffic to 25 miles per hour on paved roads; Packet Page. 1131
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Paving or providing a hard surface for onsite roads to reduce fugitive dust; Covering dirt haul vehicles; and
Replanting disturbed areas as soon as practical and other measures, as deemed appropriate to the site, to control fugitive dust,
The Fugitive Dust Control Plan shall be submitted to the City for review and approval prior to grading.
Prior to construction ofthe proposed improvements, a Construction Traffic Control Plan (CTCP) will be reviewed and approved by the City. The CTCP will describe in detail safe detours around the project construction site and provide temponuy traffic control (Le" flag person) during construction related truck hauling activities.
During construction ofthe proposed improvements, construction equipment shall be properly maintained at an offsite location, including proper tuning and timing of engines, Equipment maintenance records and equipment design specification data sheets shall be kept on-site during construction.
During construction ofthe proposed improvements, all contractors wiu be advised not to idle construction equipment on the site for more than five minutes.
During construction ofthe proposed improvements, onsite electrical hook ups shall be provided for electric construction tools including saws, drills and compressors, to eliminate the need for diesel powered electric generators.
Onsite grading equipment will comply with one or more ofthe following:
Use ofonsite grading and construction equipment equipped with oxidized diesel catalyst and fueled with aqueous diesel fuel during grading and construction operations with a reduced equipment fleet or hours ofoperation totaling a maximum of 17,000 horsepower hours per day;
Use ofonsite grading and construction equipment equipped with oxidized diesel catalyst with a reduced equipment fleet or hours ofoperation totaling a maximum of 14,000 horsepower hours per day;
Use ofonsite grading and construction equipment fueled with aqueous diesel fuel during grading and construction operations with a reduced equipment fleet or hours ofoperation totaling a maximum of 13, 000 horsepower hours per day; and Reduce the grading and construction equipment fleet or hours ofoperation to a maximum total of 10,000 horsepower hours per day,
Implementation ofthe Short- Tenn Air Quality Mitigation Measures shall be documented in an Air Quality Mitigation Implementation Plan, This plan will detail each mitigation measure and include daily logs documenting implementation of each Packet Page. 1132
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mitigation measure. Daily logs for each piece ofconstruction equipment will include the hours per day the equipment ran. A master daily log will document the hours of operation all equipment ran each day, The master daily log will also document timing and tuning ofequipment, the type offuel used on construction equipment, and any add-on emissions reduction equipment used such as oxidized diesel catalysts, MM A1R-3lI The project proponent shall install bicycle racks at the clubhouse, MDA and A attached) housing areas (Planning Areas 6, 8- 11, 13, 14, 16, 18, and 20), and all park sites to encourage non-vehicular trips within the project, MM A1R-3b The project design shall include signs posted in visible places in any truck parking areas that state, ''No Idling,"
MM A1R-3c The project proponent will coordinate with CSUSB to install improvements that will support future shuttle transit service for project residents, including bus turnouts, bus shelterslbenches, street lighting, and safe ingress/egress between the designated bus stop and adjacent uses. The developer will install identified improvements when the applicable road is constructed. ,
MM A1R-3d Provide onsite infonnation for clubhouse employees regarding local car pools, bus schedules and shuttle services in the area that service the project site, including maps showing the routes oftransit services and employee carpool destinations.
4.2 - Population and Housing and SCAG Conslst8ncy
4.2.1 . Potentially Significant Impact
Implementation ofthe project has the potential to induce population growth beyond the SCAG local and regional forecasts,
4.2.2 - Finding
With consideration ofthe above infonnation, implementation ofthe Proposed Project will cause the SCAG Consistency and regional growth to be significant and unavoidable.
4.2.3. Facts In Support of Finding
Although forecasted population growth in San Bernardino for 2010 is projected to exceed the SCAG projections, the proposed UHSP project would significantly exacerbate this condition by adding an additional 476 units (980 - 504) or 12 percent ofgrowth. SCAG population numbers are the basis for other regional plans (e.g., regional housing allocation strategies), and population growth in excess of the forecast represents a significant growth inducement impact. No mitigation is available to reduce this impact to a less than significant level; therefore, growth inducement beyond the SCAG local and regional forecasts is a significant unavoidable impact ofthe Proposed Project, Furthennore, the Proposed Project is generally consistent with the policies ofthe City' s general Plan, except for the provision ofemployment in a housing rich sub-region. The Draft EIR concluded that Packet Page. 1133
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these inconsistencies mean the project will have a significant impact relative to growth inducement and minor inconsistencies with regional growth policies and there is no feasible mitigation available to eliminate this impact,
4.3 - Transportation
4.3.1 - Potentially Significant Impact
Implementation ofthe project has the potential to create operations at intersections to degrade to unacceptable levels without planned improvements in the opening year, In addition, five intersections are expected to operate at unacceptable levels of service by 2030. With mitigation measures TRANS1, TRANS-2, and TRANS-8, impacts to intersections will be less than significant, However, impacts to freeway operations are significant and unavoidable,
4.3.2 - Finding
With consideration ofthe above infonnatiOD, implementation ofthe Proposed Project will cause freeway operations to be significant and unavoidable.
4.3.3 - Facts in Support of Finding
MM TRANS-1 Prior to the issuance ofthe flTSt building permit, the developer shall install or provide fair share payments to the City to install improvements referred to in Table 5 in the TIA (KA 2008).). Iffair share payments are not paid prior to issuance ofthe first building permits, the UHSP will be required to install improvements, and be reimbursed by the City upon completion. . Improvements include:
Traffic signal at Northpark Boulevard and Campus Parkway; Cross Street Stop at Little Mountain Drive and Project Access; Add two (2) 1eft- turn lanes on northbound leg ofUniversity Parkway at Northpark Boulevard;
Add two (2) 1eft- turn lane on northbound 1- 215 Freeway ramp; Add a left-turn lane on the northbound leg ofLittle Mountain Drive at Project Access;
Add a
right-turn lane on the northbound leg ofLittle Mountain Drive at Project Access;
Add a left-turn lane on the southbound leg ofNorthpark Boulevard at Campus Parkway;
Add a through lane to the eastbound leg ofLittle Mountain Drive at Project Access;
Add a
right- turn-over1ap to the eastbound leg ofUniversity Parkway at Northpark Boulevard;
Add a
right-turn lane to the eastbound leg ofLittle Mountain Drive at Project Access;
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Add a left-turn lane to the westbound leg ofNorthpark boulevard at Campuss Parkway;
Ad~ three (3) left-turn lanes to the westbound leg ofUniversity Parkway at Notthpark Boulevard;
Add a left turn lane to the westbound leg ofLittle Mounntain Drive at Project Access;
Add a
through lane to the westbound leg ofNorthpark Boulevard and Campus Parkway; and
Add a
through lane to the westbound leg ofLittle Mountain Drive atProject Access;
Add a
right-turn lane to the westbound leg ofUniversity Parkway at Northpark Boulevard.
To implement this measure, a
right- turn lane can be striped or unstriped, but to
function as a
right- turn lane, there must be sufficient width for right- turn vehicles to travel outside the through lanes.
The TIA for this project estimated that the fair share cost for these improvements would be just over
4.1 miIlion as ofwhen the TIA was prepared (July 2, 2008). Exhibit 4.12- 3 iIlustrates the proposed improvements that the project will need to implement. With construction ofthese improvements, LOS at local intersections will meet the City' s General Plan thresholds.
MM TRAMS-2 Prior to the issuance ofthe 600111 building pennit, the developer sha11 install or provide fair share payments to the City for installation of improvements refeJTed to in Table 8 in the TIA (KA 2008).). Iffair share payments are not paid prior to the issuance ofthe 600111 building permit, the UHSP wiIl be required to install improvements, and be reimbursed by the City upon completion. Improvements include:
Cross street stop at Campus Parkway at 1- 215 Freeway northbound ramp; Cross street stop at Campus Parkway at 1- 215 Freeway southbound ramp; Add a
thorough lane on northbound leg ofcampus Parkway and Kendall Drive;
Add a
thorough lane on the northbound leg of campus Parkway and at 1-215 Freeway northbound ramp;
Add a
thorough lane onnorthbound leg of campus Parkway and at 1- 215 Freeway southbound ramp;
Add a
right-turn lane onnorthbound leg ofUniversity Parkway at Kendall Drive;
Add a right-turn lane on the northbound leg ofUniversity Parkway at 1- 215 Freeway southbound ramp;
Add a left-turn lane on the southbound leg ofCampus Parkway at 1- 215 Freeway southbound ramp;
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Add a thorough lane on the southbound leg ofCampus Parkway at Kendall Drive;
Add a
thorough lane on the southbound leg of Campus Parkway at 1- 215 Freeway northbound ramp;
Add a
thorough lane on the southbound leg ofCampus Parkway at 1- 215 Freeway southbound ramp;
Add a right-turn lane on the southbound leg ofUniversity Parkway at 1-215 Freeway northbound ramp;
Add a
right-turn lane on the eastbound leg ofUniversity Parkway at 1- 215 Freeway northbound ramp;
Add a left-turn lane on the eastbound leg ofCampus Parkway at Kendall Drive;
Add a left-turn lane on the eastbound leg ofCampus Parkway at 1- 215 Freeway northbound ramp;
Add a
right-turn lane on the westbound leg ofCampus Parkway at 1- 215 Freeway northbound ramp.
To implement this measure, a right- turn lane can be striped or unstriped, but to function as a rightturn lane, there must be sufficient width for right-turn vehicles to travel outside the through lanes.
As shown in Table 4.12- 6, all intersections would meet the City' s General Plan thresholds with improvements by 2030 after the implementation ofthe improvements outlined in Measure MM-- TRAN8-2.
MM T~ Prior to the commencement ofconstruction, the developer shall provide a Construction Traffic, Staging, and Parking Management Plan to the City ofSan Bernardino for review and approval. All construction contracts sha1l include a clause requiring compliance with the Construction Traffic, Staging, and Parking Management Plan and the developer shall be able to enforce the provisions ofthe plan through penalties, up to and including, termination ofthe contract. The plan shall include the following provisions:
Construction truck traffic shall be limited to the following designated routes:
Campus Parkway from the site and west ofNorthpmk Boulevard to Kendall Drive, and Kendall Drive from Campus Parkway to Palm Avenue, Construction truck traffic shall be prohibited on all other roadways, unless compelling circumstances warrant such movements (e.g., a major traffic accident).
Signage shall be installed at construction truck ingress and egress points alerting motorists to such movements.
Soil, debris, or other loose materials shall be covered with tarps or other restraining material during haul movements on roadways
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On-site and off-site construction staging and parking locations shall be identified, as weU as any necessary. shuttle service needed to transport workers from off-site locations, For safety reasons, off-site staging or parking shall not be allowed west ofNorthpark Boulevard or on the CSUSBCal State San Bernardino campus.
A pre-construction conference shall be held advising all construction contractors ofthe requirements ofthe Construction Traffic, Staging, and Parking Management Plan.
4.4 - Cumulative
4.4.1 - PotentiaUy Significant Impact
The Proposed Project may have the potential to create cumulative impacts within three (3) miles of the project site. Areas that have a cumulative impact by the Proposed Project that are significant and unavoidable are listed and defined below,
Air Quality
The analysis area for evaluation of cumu1ative impacts to air quality includes the South Coast Air Basin ( SCAB), which is identical to the boundaries ofthe SCAQMD. The SCAB includes the counties ofOrange, Los Angeles, Imperial, and Ventura, Riverside, and San Bernardino (including the City of San Bernardino),
Cumulative impact analysis is guided by buildout assumptions identified in the Land Use Section of the San Bernardino General Plan, Within the project region, and the SCAB, approved and additional development will result in additional excavation activities and further intensification of land use, which could potentially lead to impacts to air quality in the area. Within the City ofSan Bernardino, the total residential units will increase from 59, 146 units at present to 82,714 units at buildout 23, 568 units or I.S percent average annual growth). Construction and operation ofthese additional land uses would emit substantial quantities ofcriteria pollutants that would likely exceed SCAQMD' s daily significance thresholds.
Potentially significant impacts were not found for exposure ofconstruction workers or the public to substantial amounts oftoxic air pollutants, creation ofcarbon monoxide bot spots that would exceed federal or State concentration standards, exposure of sensitive receptors to substantial pollutant concentrations, or generation ofobjectionable odors that would affect a substantial number ofpeople, Significant, unavoidable impacts were found concerning construction and operational emissions that exceed SCQMD thresholds, inconsistency with the projections contained in the Air Quality Management Plan, and emissions representing only an incremental contribution ofglobal greenhouse gases, The Proposed Project would develop 980 residential units in this vacant outlying area ofthe City. This represents 4,2 percent ofthe growth expected in the City from now until buildout.
When taken into account with all residential and commercial buildout anticipated in the General Plan, the Proposed Project would result in a significant cumulative effect. Therefore, this effect would be Packet Page. 1137
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cumulatively considerable without mitigation applied, since the effect ofthis project by itself is a potentially significant impact. However, according to the City of San Bernardino General Plan Environmental Impact Report (2005 ElR), air quality would be significant after buildout during long tenn and short term construction, and contributing to cumulatively considerable net increase of criteria pollutants for which the project region is in a state of non-attainment. Therefore, project-level emissions would be cumulatively significant and unavoidable due to the City' s significant and unavoidable buildout projections for regional air quality.
Mitigation in the fonn of extensive air pollution control measures is proposed, but it would not reduce project construction and operation emissions below SCQMD thresholds; however, it would prevent project greenhouse gas emissions from being cumulatively considerable.
Transportation
The analysis area for evaluation ofcumulative impacts to transportation includes the University District subarea identified in the San Bernardino General Plan, as well as the City as a whole. The Traffic Impact Analysis analyzed the traffic impacts ofthe Proposed Project and looked at traffic impacts at opening year and at buildout ofthe project. Project-level traffic impacts are found in several intersections that would exceed the General Plan threshold ofLOS C at peak hour, and, will therefore have a significant impact. N addition, significant impacts are related to cumulative traffic and congestion on the 1- 215 Freeway in the vicinity ofthe Proposed Project.
Cumulative impact analysis is guided by buildout assumptions identified in the Land Use Section of the San Bernardino General Plan. Within the University District subarea, approved and additional development will result in additional excavation activities and further intensification of land use that could potentially impact transportation in San Bernardino. Furthermore, the Proposed Project will contribute to cumulatively considerable traffic impacts even with implementation ofall feasible project specific mitigation.
A number ofroadway improvements would be implemented in conjunction with the Proposed Project that would help reduce cumulative traffic impacts. Potentia11y significant impacts were not found concerning the creation of inadequate access for emergency services or conflicts with the General Plan. Potentially significant impacts were found for congestion during peak hours along this portion ofthe 1- 215 Freeway,
When taken into account with all residential and commercial buildout anticipated in the General Plan, the Proposed Project would result in a significant cumulative effect on area traffic. Therefore, this effect would be cumulatively considerable without mitigation applied, since the effect ofthis project by itselfis a potentially significant impact. Wilh implementation ofproject mitigation measures MM TRANS- 1 through MM TRANS-8, project impacts will not make substantial contributions to cumulatively considerable degradation ofintersection performance but will contribute to ongoing freeway congestion.
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RndltI/I ~"'' 11 /mpecfsfa Below. L.etfeI ofSJspdllcMce However, according to the City of San Bernardino Environmental Impact Report (2005 EIR), the City does not cooperate with the regional transportation agencies toward mitigating impacts to regional transportation facilities, However, potential traffic impacts to the freeway mainline segments and ramps were evaluated and mitigation measures were suggested to reduce impacts. However, the City stated that improvements to the freeway system are the responsibility ofthe existing regional transportation agencies and not the City ofSan Bernardino, Without the authority to implement the mitigation measures, the impact to freeway segments would remain significant and unavoidable requiring a statement ofoverriding considerations. Therefore, project-level traffic would be cumulatively significant and unavoidable due to the City' s significant and unavoidable buildout projections.
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5.1 - Growth InducIng Impacts
5.1. 1 - Description
There are two types ofgrowth-inducing impacts that a project may have: direct and indirect. To assess the potential for growth-inducing impacts, the project' s characteristics that may encourage and facilitate activities that individually or cumulatively may affect the environment must be evaluated CEQA Guidelines Section 15126.2[ d]).
5.1. 2 - Finding
Direct growth-inducing impacts occur when the development ofa project imposes new burdens on a community by directly inducing population growth, or by leading to the consln1ction ofadditional developments in the same area. Also included in this category are projects that remove physical obstacles to population growth (such as a new road into an undeveloped area or a wastewater treatment plant with excess capacity that could allow additional development in the service area).
Construction ofthese types ofinftastructure projects cannot be considered iso1ated from the development they facilitate and serve. Projects that physically remove obstacles to growth or projects that indirectly induce growth may provide a catalyst for future unre1ated development in an area, such as a new residential community, that requires additional commercial uses to support residents, The Proposed Project would result in the development of980 units on 404 acres in an outlying but somewhat suburbanizing area (e.g" development to the west along Campus Parkway). The residential units included in the Proposed Project would be expected to result in direct population growth of3, 283 new residents. The Proposed Project is expected to create only a few newjobs at the clubhouse.
Section 4,10 ofthe Draft EIR examined the project' s contributions to local as well as regional housing and population growth and found it to be in excess ofthat outlined in the City' s General Plan that was used for estimating growth impacts by SCAG, Although by itselfthe project would only incrementally increase growth, it would contribute to an overall cumulative increase that may not have been anticipated in regional planning efforts. Therefore, the project is considered somewhat growth inducing. This increase will be offiet somewhat by the fact that the project is in an area that is not planned for additional suburban development, so its actual influence on area-wide growth will likely be limited.
The project site is not currently served by infrastructure although roads and utilities are generally adjacent or nearby to the site. However, the Proposed Project would require the extension of roadways and utility systems into areas not presently served; therefore, the Proposed Project could be considered to be removing a barrier to potential growth through the extension ofurban infrastructure.
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The Riverside-Corona Feeder supplies several southern California Counties, including San Bernardino. The supplier connects to the Santa Ana River watershed and supplies over 400,000 acrefeet of ground water per year, New wet year water will corne from local runoff, including regulated releases from Seven Oaks Reservoir and the State Water Project. The R-C Feeder is a multiple benefit regional water supply project. The water will be stored in San Bernardino Valley and Chino groundwater basins. Stored water will be delivered to consumers through a new groundwater pumping capacity. The new pumping and delivery capacity will enable water to be stored safely by providing the means to control local water tables,
The water supply assessment proposes the UHSP will connect to reservoirs, similar to the RiversideCorona Feeder. The reservoirs will include a common inlet/outlet pipe with flexible connections, isolation valves and an altitude valve to prevent overflow. To improve mixing in the tank, each inlet/outlet pipeline would have two check valves, forcing water to travel a greater distance from inlet to outlet in a circular motion. The reservoirs would have separate overflow pipes and drain pipes that would discharge to a concrete gutter. The gutter would convey stonn flows, reservoir overflows and drainage along the access road to the downstream development stonn drain.
5.1. 3 - Facts in Support of Finding
Because ofits size and intensity, as well as its destination potential, the Proposed Project may be a catalyst for future unrelated projects. This may include new development projects or redevelopment ofexisting properties. Note that no such projects have been identified at the time ofthis writing, and it would be speculative to identify any potential locations or types ofprojects,
5.2 - IrreV81'81bl8 Impacts
5.2.1 - Description
Section 15126,2{ c) ofthe CEQA Guidelines requires a discussion ofthe extent to which a Proposed Project will commit nonrenewable resources to uses those future generations will probably be unable to reverse so that such current consumption may be justified,
5.2.2. Finding
The CEQA Guidelines describe three distinct categories of significant irreversible changes; they are defined as " changes in land use that would commit future generations", " irreversible changes from environmental actions", " and consumption of non-renewable resources", The Draft EIR has evaluated the project' s commitment to these irreversible changes in the implementation ofthe project and has found that the use of such resources is justified by the long-term benefits ofthe project. However, the Proposed Project would not be consistent with Air Quality, PopulationIHousinglSCAG Consistency, and Freeway Transfonnationa1 uses,
5.2.3 - Facts In Support of Finding
The project site will be in long-term used as a residential development. In addition, the new uses will be utilized as a resource for the City over the long-term, In addition, 10ng-tenn development ofthe Packet Page. 1141
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project wilI be similar to other residential development projects in the City of San Bernardino.
Analyses ofall three distinct categories ofsignificant irreversible changes are defined as:
Ch8ngw In Land Use That Would Commit Future Generet/ons The project proposes to construct 980 residential units. The Proposed Project will consists of404.3 total acres, with 169.5 acres or 42 percent ofthe site proposed for residential and related uses, including 10.2 acres ofparks and recreational uses. The project proposes a gross density of2.4 dwelling units per acre (980 units divided by 404.3 tota1 acres) and a net density of 5, 8 units per acre, excluding natural open space (980 units divided by 169.5 acres). Residential densities range from 0.0 to 20 dwelIing units per acre, This change in land use is more compatible with the sUlTOunding area, therefore, the change in land use would not commit future generations to a significant change in land use,
Irreversible CIItmges from Environmental Actions
Irreversible changes to the environment could occur ifhazardous substances are released associated with development ofthe Project. Compliance with the requirements and mitigation measures would reduce impact to less than significant. No other sources of irreversible changes from environmental actions are forecast to occur.
Consumption ofNon-Reneweb1e Resources
Consumption ofnon-renewable resources would be the conversion ofagricu1turalland to urban uses, consumption ofenergy resources such as electricity and natura1 gas, and the loss ofpotential mining resources,
The Draft EIR detennined that development ofthe project site would not result in a significant impact on land that is considered suitable for agricu1tura1 use. IN addition, the site is not identified as a mineral resource site and more suitable locations in the sUlTOunding regions are currently being used as mineral resource sites. Given the proximity to CSUSB, the site would not be a suitable for mining ofmineral resources in the future.
The project wilI consume non-renewable energy resources during construction and operation such as petroleum products, construction materials, electricity and natura1 gas. Construction impacts to nonrenewable would be short-term. Operation ofthe Project is required to comply with mandatoI)' requirements ofTitle 24 in regard to energy efficient building design and is required to utilize energy conservation measures during operations ofthe facilities within the project.
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CEQA requires that a Final EIR evaluate a reasonable range ofalternatives to a project, or to the location ofthe project, which: 1) are capable ofavoiding or substantially lessening any significant adverse environmental impact associated with the project; and 2) may be feasibly accomplished in a successful manner within a reasonable period oftime considering the economic, environmental, social and technological factors involved (CEQA Guidelines ~ 15126,6).
A Final EIR must only evaluate reasonable alternatives to a project which could feasibly attain most ofthe project objectives and evaluate the comparative merits ofthe alternatives (CEQA Guidelines A 15126.6; Sierra Club 1/. COU1ItyofNapa, 121 Cal. App. 4th 1490 [ 2004]). In all cases, the consideration ofalternatives is to bejudged against a rule ofreason (CEQA Guidelines A 15126.6,).
The lead agency is not required to select the environmentally superior alternative identified in the Final EIR ifthe alternative does not provide substantial advantages over the Proposed Project and: 1) through the imposition ofmitigation measures the environmental effects ofa project can be reduced to a less than significant level; or 2) there are social, economic, technological or other considerations which make the alternative infeasible.
The discussion ofalternatives is required to include the "No project" alternative. CEQA further requires that the City identify an environmentally superior alternative. Ifthe "No project" alternative is the environmentally superior alternative, an environmentally superior alternative must be identified from among the other a1tematives (CEQA Guidelines, A 15126.6.).
CEQA Guidelines A 15126.6 requires a Final EIR to evaluate an alternative site when an alternative location would avoid or substantially lessen significant effects. The Final EIR considered five (5) alternatives that may reduce anticipated impacts to less than significant levels, or will improve the acceptability or successful implementation ofthe residential improvements. A swnmary ofProject Alternative Impacts are contained in Table 1.
The objectives for the project as identified in the Final EIR and considered by the City are the following:
Include high-quality, high-density housing in a mixed-use setting to increase the diversity of housing opportunities in San Bernardino and provide housing options that are not currently available to local residents;
Use high-quality architecture and landscaping that will maintain and enhance the aesthetic character ofthe City of San Bernardino;
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Provide a "sustainable" community that encompasses construction as well as daily living in tenns ofenergy and water conservation, wise choice and use ofbuilding materials, reduction of air pollutants, safety, wa1kability and connectivity to surrounding uses, etc,; Provide ample amenities including a community clubhouse and extensive trail system to encourage healthy and enjoyment ofopen space,
Maximize roadway safety through the provision ofmultiple vehicular ingress and egress opportunities to the Proposed Project internal roadways and parking facilities and improvements to the surrounding circulation system;
Create increased new property and sales taxes annually, in perpetuity, forthe City of San Bernardino, and increased annual property taxes for San Bernardino County and various other local government agencies; and
Increase property values in the City ofSan Bernardino and surrounding unincorporated County areas.
6.1 - No ProjectlNo Development Alternative
6.1. 1 - Description
CEQA requires that a "No Project" a1ternative be evaluated compared to the Proposed Project, The No Project alternative evaluates existing conditions on the site in the absence ofthe Proposed Project, Under this a1ternative, the project site would remain vacant would not be developed into a residential community, Assuming the project site remains vacant, all significant impacts will be avoided.
However, any benefits ofthe project related to providing housing opportunities for families as well as providing infrastructure in an area that is undergoing surrounding residential development would not be realized.
6.1. 2 - Finding
This alternative would eliminate any adverse environmental impacts associated with developing the project site into a residential community, It would also eliminate the significant impacts associated with the project (i.e. air quality, population, housing, and SCAG consistency, transportation),
6.1. 3 - Facta In Support of Finding
The No Project - No Development Alternative would eliminate the seven significant impacts ofthe Proposed Project relative to construction and occupancy ofthe proposed UHSP. However, it would result in an indirect impact to future growth ofthe City. Furthennore, this alternative does not achieve any ofthe objectives ofthe Proposed Project.
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6.2 - No Project - General Plan Development Alternative
6.2.1 - Description
Under this alternative, the site would be developed under the approved PHSP as outlined under the previous ElR certified in 1993, which allowed 504 residential units.
6.2.2 - Finding
Under this alternative, there would be similar impacts associated with the Proposed Project, as the land use designation is the similar for the existing General Plan/Specific Plan as the Proposed Project, Developing the Project area for residential uses could have potential adverse impacts on the adjacent residential development. It would potentially increase impacts related to Aesthetics, Light, and Glare, Biological Resources, Cultural Resources Geology, Soils, and Seismicity, Hazards and Hazardous Materials, and Hydrology and Water Quality,
6.2.3 - Facts In Support of Finding
The No Project - General Plan Development Alternative would have incrementally fewer impacts related to 10ng-tenn occupancy ofthe project site since it would allow the development of approximately halfthe numberofunits compared to the Proposed Project (504 vs. 980 or 48.5%)1 However, the UHSP proposes aggressive water and energy conservation measures that would substantially reduce the differences in these impacts. This alternative would have similar or increased short-term air quality impacts from grading but reduced construction-related impacts (i.e., fewer units). Long-tenn air quality impacts under this alternative would be reduced to less than significant levels, This alternative may have increased impacts on biological and cultural resources, and the City' s water distribution system ifdevelopment were to occur as outlined in the previously approved Paradise Hills Specific Plan, This alternative would also create increased risks to project residents and residences related to wildand fues and geotechnical constraints. Growth inducement and impacts related to consistency with SCAG growth policies would be reduced to less than significant levels under this alternative. This alternative does not meet the objectives ofthe project to the same degree as the Proposed Project in that the PHSP does not contain CUJTent water or energy conservation strategies,
6.3 - Modified Specific Plan Alternative
6.3.1 - Description
To reduce air quality and growth inducement impacts, this alternative would be phased and have more "mixed" uses (i,e., 100,000 square feet ofcommercial and other non-residential) on the site. It would also have fewer residential lots (approximately 700 units) but with higher densities than those allowed under the UHSP to be able to cluster units more effectively. This alternative would likely require many buildings with 3-4 stories rather than 2-3 story buildings under the current UHSP. The CUJTent " clubhouse" area would become more of a community center under this alternative, with taller buildings and approximately 100,000 square feet of a mixture of commercial and professional office uses, Each residential planning area would be larger overall than under the UHSP, and each would be Packet Page. 1145
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built on pads that could be more isolated in tenns ofgrading. At present, the land plan requires that the entire development area (approximately 170 acres) be graded at one time to balance earthwork onsite (i.e" no substantial import of soil onto or export of soil offofthe site), Balancing earthwork within a development area is an important consideration ofproject design, not only for cost, but to minimize the import or export of soil from the site, which could significantly increase short-tenn traffic, noise, and air quality impacts. The only feasible way to accomplish this balancing with smaller planning areas would be to "pair" two planning areas, one upslope and one downslope, and use the cut material from the upper area to create a pad for the lower area. This would necessarily create a more terraced look to the development,
The road system would be similar to that ofthe proposed UHSP but there would be more open space between the Planning Areas and the project would be built over a longer period oftime to reduce
short-tenn construction impacts,
6.3.2. Finding
Under this alternative, impacts from residential development woud be either equivalent or reduced; however, the alternative would not reduce environmental impacts in regard to Air Quality and Transportation,
6.3.3. Facta in Support of Finding
The Modified Specific Plan Alternative would have incrementally fewer impacts related to long-tenn occupancy ofthe project site since it would allow the development offewer residential units compared to the Proposed Project (700 vs. 980 or 40 percent less), However, the addition of commercial and office uses under this "mixed use" plan would generate a greater amount oftraffic than the Proposed Project, especially during peak periods. The mixed uses would help reduce the number and length of vehicular trips offofthe project site, This alternative could reduce short-term (daily) air quality impacts from grading and construction to less than significant levels, however, it would extend those impacts over a longer period oftime if development phasing were increased (i.e., from 5 to 10 years), Long-term air quality impacts under this alternative would increased by adding non-residential uses, and would still exceed significance thresholds.
This alternative would have equivalent impacts on biological and cultural resources, and would likely create similar risks to project residents and residences (and businesses and employees) related to wildand fires and geotechnical constraints, Growth inducement and impacts related to consistency with SCAG growth policies would be reduced to less than significant levels under this alternative.
This alternative would meet some ofthe objectives ofthe project, Packet Page. 1146
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6.4 - EducationallnatitutlonfTechnology Park Alternative
6.4.1 - Description
The University District Specific Plan identifies the general area for technology park uses, which would be supported and will benefit from research at the University , To reduce air quality and growth inducement impacts, this alternative would eliminate residential uses and place an educational institution and related technology uses in this area to support CSUSB. These uses could be in conjunction with or in support ofthe Cal State San Bernardino campus. The proposed alternative would house approximately 2,75 million square feet ofoffice space, industrial use, and educational research for information technologies. Based on discussions with the San Bernardino City Unified School District, this plan does not envision K-12 facilities at this time, The road system would be similar to that ofthe proposed UHSP but there might be more open space between various buildings or uses, and they may be built over a longer period oftime to reduce short-term construction impacts.
6.4.2 - Finding
Long-term air quality impacts would not be reduced as the educational institutionltechnology park uses would generate more vehicular peak hour traffic. However, additional impacts would be similar or reduced compared to the Proposed Project.
6.4.3. Facts In Support of Finding
The Educational Institutionffechno10gy Park Altemative would produce very different impacts compared to those from the residential uses ofthe Proposed Project. It would likely generate more peak hour traffic, but non-peak hour traffic may be substantially less that that ofthe Proposed Project.
The addition ofeducational and institutional uses under this plan would likely not reduce short-term daily) air quality impacts from grading and construction to less than significant levels due to the need to grade the entire area for efficient site planning, Long-term air quality impacts under this alternative would probably be higher than those produced by residential uses, and would still exceed significance thresholds.
This alternative would have equivalent impacts on biological and cultural resources, and would likely create similar risks to project employees and students rather than to project residents and residences in terms ofwildand fires and geotechnical constraints. Growth inducement and impacts related to consistency with SCAG growth policies would be reduced to less than significant levels under this alternative. Although the alternative project may meet certain objectives to the same degree as the Proposed Project, it does not meet all the specific project objectives already outlined in the approved PHSP.
6.5 - Alternative Sites
6.5.1 - Description
CEQA requires the evaluation ofalternative sites ifmoving the Proposed Project to another site would eliminate or avoid one or more significant impacts ofthe Proposed Project. The impacts to both short-term and long-term air quality would occur regardless of location, The significant impact Packet Page. 1147
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to freeway traffic might be reduced by a different location, but the 1- 215 Freeway experiences similar levels ofcongestion from its intersection with the 1- 15 four miles to the north down to its intersection with the 1- 10 Freeway six miles to the south
6.5.2. Finding
It is not likely that an aItemative location would eliminate the significant traffic impact ofthe Proposed Project. Unless the UHSP project can be buih with mixed uses or adjacent to a transit center (no sites ofthis size available near the San Bernardino center), the Proposed Project cannot be made consistent with the growth projections or policies ofSCAG.
6.5.3. Facts In Support of Finding
The ahernative location would not eliminate the significant impacts ofthe Proposed Project. Based on discussions with City staff and a survey ofthe surrounding area, there are no other vacant sites of this size in the northern portion ofSan Bernardino. This analysis demonstrates that impacts of development as proposed under the UHSP on an alternative site would be equivalent to those ofthe UHSP developed on this location. Therefore, an ahernative site is not a feasible or viable option for this project
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Table 1: Summary of Project Altematlva 'mpacta
Em.1ror~, nrnt ProtIa.... No, Prvjeot-Ho::.:: r::.; IfodIIIM ~ U'.IJIIllI ] at.....;' ProI' i!t ~'" ' · .,.. , SIl.......... ' fTr ...,,.... 1III, m..a~.,'..... .~
Aesthetics, Less than No impact Somewhat i Equivalent but Increased but I... I Ligb~ and significant i increased i more non- than significant Glare' I
I --- J residential uses ! __ J, Air Quality ---! SlllDifkut i No impact j'Less Slgnithanll..
nt i Less than
I " SillDlflcant
Iii
I
I =: significant
on
I S11lD11I.. nt : No impact i Slgnifkut i Sl1lD11Icut i I Biological ILess than 1:0
impact i ~:=~ t- I t:i:.., mixed ~+
LeSSiIi8D---- 1
E~ r:~:::'~ '
NoO: ~:- In'~
banudtl...--+-~
thth:anM: J~Less:-than~-----
j
i Geology, Soils, I Less than _...-'
I
and Seismic' Significant than si - cant si&f!1>! cant significant __ Hazards and Less than No impact I
Reduced but I... I
Less than , Significant
i HaDrdous Significant ~ than significant significant ' Inusecreased bam181 i~~ -
Hydrology and Less than No impact Increased but less
L
I Less than - - Less tbaD----
I t:-; u~: ~::
t
No impact ~ ;~
fi~
f~=~ut leSS
I ~~~:~ f- Noise-- I ~:: t ----i- No impBCt ~:;;:::" d I... - ~ =~-: I= L Si . tIDCfeased bUll... cant ~ l
than significant _ f
ilia.. significant . than significant _
I,
Population. Slgnlllcant No impact I
Less than ! Less than I Less than
Housing, and Growth Inducing '
I
significant
I
significant i significant SCAG 1_& SCAG policies
I
l_<;:
Public
onsistency +
Services Less than f-==: .. No impact Reduced but lesS-~ educed but....i- Mixed but I... 1'_
and Recreation Si' cant than si ' cant than significant __ I than significant'l
Tnmsportation S.... III..nt , No impact Slgnlllcut Slgnlllcut i Slplflcut I
and_~ ilwlati:", ~ con~: _ I Fwy congestion Local traffic ,& I Local traffic _& I Agriculture and Less than
L
No impact -- - -!- Less ttWi------ t-~ :,,~!'!!...
on
Mineral Significant I I, significant I
significant . significant Resources
ftility sYstems I
Less thantNoimpact i Reduced------ j Reduce<t---- + Reduced-- - i I--MeetSProjecl I ~~
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6.5.4. Finding
The Final EIR detennined that the Proposed Project would produce significant impacts to Air Quality, Population, Housing and SCAG Consistency, and Transportation, The Final EIR also determined the project could potentially contribute to cumulatively considerable impacts to Air Quality and Transportstion; however, the recommended measures do not reduce impacts under the less than significant threshold. All five alternatives reduce at least one ofthe three significant and unavoidable impacts; however, they create potential land use compatibility conflicts between the alternate uses and the General Plan. In addition the alternatives would not fully implement the project' s objectives ofproviding an active residential community with connectivity to the existing residential uses. Since none ofthe alternatives are considered environmentsIly superior to the Proposed Project, they are rejected in favor ofthe Proposed Project.
6.5.5. Facts In Support of Finding
None ofthe aItematives achieve the objectives ofthe project to the same degree as the Proposed Project. The environmentsI effects ofeach alternative in relation to the Proposed Project are summarized in Table 1.
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HIlls SpecIIIc""" ElR SIlIIlt._ t ofOvwrIdIng Cona/deI-' S~' 1':fta~_^:,_'-:--" tlii~ fi """" V'lf~"'",," ~_"'" TION8c CEQA Guidelines Section 15093 ( a) states that:
CEQA requires the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits of a Proposed Project against its unavoidable environmental risks when determining whether to approve the project. Ifthe specific economic, legal, social, technological, or other benefits of a Proposed Project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered " acceptable."
Where the decision ofthe public agency allows the occurrence ofsignificant effects which are identified in the Final EIR but are not avoided or substantially lessened the agency shall state in writing the specific reasons to support its action based on the Final EIR and/or other information in the record. This ststement may be necessary ifthe agency also makes a fmding under Section I 509 I ( a)(2) or 15091 ( a)(3).
As identified above, the City ofSan Bernardino fmds that the project does produce significant and un-mitigable impacts to Air Quality, Population, Housing and SCAG Consistency, and Transportation, and, therefore, requires a Statement ofOverriding Considerations. The findings have also analyzed a number ofalternatives to determine whether they are reasonable and feasible alternatives to the proposed action and whether they might reduce or eliminate the significant impacts ofthe proposed action. The City of San Bernardino finds that the project will provide specific economic, social, and other benefits that outweigh the unavoidable adverse environmental impacts of the project, such that those impacts are considered acceptable. Each ofthe benefits ofthe Proposed Project cited is hereby determined to be, in itselfand independently ofthe other project benefits, a basis for overriding all significant adverse environmental impacts identified in the EIR and in these fmdings. These benefits are as follows:
I, The Paradise Hills project land plan proposed extensive grading and development within the middle and upper reaches ofBadger Canyon, however, that project was never built. In addition to the General Plan designating the project site as a Specific Plan, the Land Use Plan in the City' s Land Use Element designates the lower (southern) portion ofthe site for Residential Suburban RS) uses with a density of 4.5 units per acre (7,200 square foot lots), and the northern portion i.e" north ofthe San Andreas Fault and in the middle and upper reaches ofBadger Canyon) for Residential Low (RL) development at 3.1 units per acre. The University Hills Specific plan addresses the steep slopes surrounding Badger Creek and designated it as Open Space ( OS). 2, The northern portions ofthe site are mitigated with a Hillside Management Overlay as well as a Foothill Fire Zone Overlay to help to minimize the spread ofwildfires, property damage, and reduce the risk to the public health and safety.
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3. The University Hills Specific Plan replaces the Paradise Hills Specific Plan and includes a new land use map, zoning districts, development standards, design guidelines, and infrastructure requirements for the development ofthe site. The following elements ofthe Specific Plan promote the land use goals ofthe General Plan:
Placing housing in close proximity to CSUSB.
Accommodating up to 60 faculty units, which will create a direct and long-1asting relationship with CSUSB.
Orienting the development and clubhouse toward CSUSB.
Allowing CSUSB to share conference facilities in the clubhouse.
Dedicating approximately 235 acres ofpermanent open space to CSUSB as a "land laboratory."
Carefully weaving University Hills into its physical surroundings by clustering development on the lower slopes and away from physical hazards, preserving significant drainage ways.
4. The Project allows residents the opportunity to live, work, and play in the immediate area. This reduces the need to use the automobile, which in turn reduces congestion, improves air quality, fosters walking, and improves overall health and wellness.
5. University Hills is a significant opportunity for the City to achieve many goals described in its General Plan, such as providing housing types suitable for a variety of lifestyles and incomes.
University Hills accommodates a
range ofliving opportunities including estate, single-family detached, small-lot detached, cluster court homes, townhomes, and stacked flats, In addition, University Hills provides fOur acres that will be dedicated to CSUSB and can accommodate up to 60 units for exclusive use as faculty housing.
6. University Hills accommodates 980 residences situated in several neighborllOods, which are separated by open space corridors, drainage ways, and sloped areas and interconnected by a series oftrails and roadways,
7. Development is focused onto approximately 170 acres, or 42 percent ofthe totsI site and is mainly concentrated south ofthe South Branch ofthe San Andreas Fault on the lower portions of the site where the average slopes are generally below 15 percent. North ofthe South Branch of the San Andreas Fault, approximately 235 acres, or 58 percent ofthe site, remains undeveloped and is designated as permanent open space. It will be dedicated to CSUSB for use as a laboratory
to study the local biology, habitat, and geology. The compact design limits the development footprint so that open lands are maximized; natural drainage ways are maintained and w
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incorporated into the design ofthe project as open space amenities; landscaping and hazards are avoided or mitigated.
8, The land laboratory contains a variety ofnative plant species; natural drainages, including Badger Creek; and the San Andreas Fault system. The proximity ofthese features to the CSUSB campus provides unique educational opportunities. It is envisioned that the biology, geology, geography and environmental studies, and science education departments would be the primary users ofthe land laboratory, but it could be used by other disciplines.
9. Uuiversity Hills is designed and programmed to create a long-term and synergistic relationship
with CSUSB. In particular, University Hills directly responds to input from the University through the provision ofland for faculty housing, the 235-acre land laboratory, pathways, bike lanes, and the California Walnut Grove Linear Park.
10. University Hills is designed to minimhe the impacts ofIight inlrusion and spillover. CSUSB is contemp1ating building an observatory on Badger Hill immediately adjacent to University Hills.
To help preserve a dark nighttime sky, this Specific Plan includes strict controls on the type and design oflighting.
II. Uuiversity Hills is also located within the University District Specific Plan, which was approved November 1, 2005, The University District Specific Plan acts as the umbrella document for a 6,375-acre area, ofwhich University Hills is a part. The intent ofthe University District Specific Plan is to "lay a foundation for the integration ofthe University into the surrounding community." The University District Specific Plan focuses on creating:
Pedestrian-oriented developments
A seamless connection between the community and University Integrated cwriculum with CSUSB
A ''university town"
Enhanced link to regional recreation
An efficient vehicular and pedestrian system
A range ofhousing types to accommodate a wide range ofpopulation, including University faculty and staff.
Quality housing
The University District Specific Plan assumed the Paradise Hills Specific Plan in its land use plan and was amended to reflect the land plan for University Hills in conjunction with this project.
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EXHffiIT D
General Plan Amendment 08-03 consists ofthe following changes:
1. Amendment ofthe Land Use Map to change the land use designations within the project area to:
Large Lot Detached (LLD)
Standard Lot Detached (SLD)
Mixed Detached/Attached Residential (MDA)
Attached Residential (A)
Parks (P)
Clubhouse
Internal Slopes
Open Space
Consistent with Figure 2-9 ofthe University Hills Specific Plan.
2. Amendment ofthe University District Specific Plan to change the following:
University District SP Fi2Ure Chanlle Consistent
With University Hills
Snecific Plan Filrure
Figure 2-9
Figure 3- 1
Figure 3- 11
Figure 2-6 (Open Space)
Figure 7 Land Use Plan
Figure 8 Vehicular Circulation Plan
Figure 9 Trails Plan
Figure 10 Open Space Plan
I......
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EXHIBIT F
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DEVB.OPER / APPLICANT
INLAND COMMUNITIES CORP,
1801 AVENUE OF THE STARS, SUITE 1205
LOS ANGELES, CA 90067
PH: ( 310) 277- 7551
CONTACT: MOHAMAD YOUNES
ARED UNDER THE SUPrRIASION OF:
Engineering
Planning
Surveying
Construction Services
7 !Jl'J$
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10370 Hemet sl Suite 200
Riverside. CA 92503
Phone: ( 951) 358- 1433
Fox: ( 951) 358- 1434
MASTER PARCEL MAP NO. 18969
stBJIVISION NO.
PAGE t OF 5
OWItER
FONTANA CORNERS III
A LIMITED CALIFORNIA PARTNERSHIP
1801 AVENUE at THE STARS, SUITE 1205
LOS ANGELES, CA 90067
PH: ( 310) 277- 7551
CONTACT: JIM AHMAD
RflfSION
NO. DAlE' ~ 7ION BY
Packet Page. 1156
III
EXHIBIT G
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DEVELOPER / APPLICANT
INLAND COMMUNITIES CORP.
1801 AVENUE OF THE STARS, SUITE 1205
LOS ANGELES, CA 90067
PH: ( 310) 277- 7551
CONTACT: MOHAMAD YOUNES
PREPARED IJNDCR THE: SlJl'ERVISION OF':
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0310 Hemet st Suite 200
Riverside, CA 92503
Phone: ( 95/) 358- 1433
Fax: ( 951) 358- 1434
J
Engineering
Planning
Surveying
Construction Services
TENTAnVE TRACT MAP NO. 1B696
SI.E1DMSION NO.
PAGE 1 OF 1
OWlloER
FONTANA CORNERS 11/
A LIMITED CALIFORNIA PARTNERSHIP
1801 A VENUE OF THE STARS, SUITE 1205
LOS ANGELES, CA 90067
PH: ( 310) 277- 7551
CONTACT: JIM AHMAD
RE1AS1ON
NO. 1M IE' 0ESafIPT/ON BY
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EXHIBIT H
III
Large-Format Map)
DEVELOPER / APPLICANT
INLAND COMMUNITIES CORP,
1801 AVENUE OF THE STARS, SUITE 1205
LOS ANGELES, CA 90067
PH: ( 310) 277- 7551
CONTACT: MOHAMAD YOUNES
PREPARED UNDER THC StJPER'tfSION OF:
AMUFA
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PREPARED B)!
Engineering
Planning
Surveying
Construction Services
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Rm CXP. t1lf,/. JO/llII
10370 Hemel sl Suile 200
RiverSide, CA 92503
Phone: ( 951) 358- 1433
Fax: ( 951) 358- 1434
TENTATM TRACT MAP NO. 18UO
SU1DfVISION NO.
PAGE 1 OF 1
NO.
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FONTANA CORNERS 1/1
A LIMITED CALIFORNIA PARTNERSHIP
1801 A VENUE OF THE STARS, SUITE 1205
LOS ANGELES, CA 90067
PH: ( 310) 277- 7551
CONTACT: JIM AHMAD
RE1IISION
DAlE' DESCRIPTION BY
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Addendum to the Subsequent EIR Link:
https://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:47e97317-553a-4951-b780- 35d4f7fc18bd
Appendixes for SFIER:
https://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:5a989e44-6d36-4740-8cdd68c1fe5fde28 Packet Page. 1159
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
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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 Packet Page. 1162
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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 Packet Page. 1163
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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 twentyseven (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 could 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 on 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 Packet Page. 1168
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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 resistant1 construction materials and each singlefamily 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, SBCFPDapproved, 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 SBCFPD 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. This 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 sitespecific fire protection measures. These codes have been developed through decades of post-fire structure saving 3 https://experience.arcgis.com/experience/6a9cb66bb1824cd98756812af41292a0 Packet Page. 1173
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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 to 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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Fire Hazard Severity Zone
Fire Protection Plan - University Hills Project
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Project Location
Fire Protection Plan - University Hills Project
SOURCE: USA Topo Maps 7.5 Minute Series San Bernardino North Quadrangle Township 1N; Range 4W; Section 4-5 and 8-9
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FIGURE 2
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Apple Valley
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Bradbury
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California
City
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Hot Springs
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Palm Springs
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SOURCE: Kimley Horn 2025
Fire Protection Plan - University Hills Project
Proposed Site Plan
FIGURE 3
SAN BERNARDINO COUNTY
FLOOD CONTROL DISTRICT
PROPERTY
N CAMPUS PARKWAY
STATE OF CALIFORNIA PROPERTY
EX. 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 determines 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 Packet Page. 1182
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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 upslope 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 Packet Page. 1183
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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. Section 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 associated 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 shrublands 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 counties
5. Prior to that, the 1980 Panorama Fire (approximately 23,626 acres) destroyed threehundred 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 20th 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 powerlines 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 cigarettes, 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 Packet Page. 1185
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Research indicates that contained development projects 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 equipmentcaused 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 development 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 fire 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 Packet Page. 1189
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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 difficult 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, Packet Page. 1190
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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 Projectrelated 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, fireresistant plants. The goal is to provide a managed area where fire spread 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 spreads 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 Packet Page. 1191
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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 placebased 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. Enhancing 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 offsite 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 Packet Page. 1192
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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 openair 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 fuel 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, when 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 have 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 access 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 vinyl construction, and shall have a fireresistant 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 landscape maintenance and structural-based fire protection Packet Page. 1195
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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 potential 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 FPP 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 incorporated 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 fuel 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 grassshrub
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 accounted 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 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 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 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.
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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
Distance1
(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
Distance1
(miles)
Scenarios 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
Scenarios 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 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 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). Supporting 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.
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Parcel 1
206
Path: Z:\Projects\j1442800\MAPDOC\DOCUMENT F\ PP\Figure 5 BehavePlusAnalysisMap-Par1.mxd Project Site - Parcel 1
0 1,500750 Feet
SOURCE: AERIAL-ESRI IMAGERY (accessed 2025)
FIGURE 4
BehavePlus Analysis Map
Fire Protection Plan - University Hills Project
SCENARIO
RUN #1
BehavePlus 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 13958 36.3 1.8
Fuel Model SCAL18 – Sage, buckwheat 2.1 13342 35.5 1.8
Fuel Model SH2 – Sage, forbs 0.7 1515 13.1 0.9
BehavePlus Modeling Results for PostProject Conditions Scenario
Flame
Length
(feet)
Fireline Intensity
(BTU/feet/second)
Spread
Rate
(mph)
Spotting
Distance
1 (miles)
Scenario 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
RUN #2
Scenario 2: 6% uphill slope, 20 mph wind from W/SW
Fuel Model SH2 – Sage, forbs 0.3 603 8.6 0.4
Scenario2 : 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 Packet Page. 1204
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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) provides 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 community 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 valley 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 and 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 threeperson 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/ Packet Page. 1207
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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 the 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 site to estimate at 3.21 persons per household15. 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 232 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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Waterman Ave
W Kendall Dr
E St
W Highland Ave
N Riverside
Av
e
Highland Ave
Kendall Dr
Ä210
Ä259
§¨215
Fire Station 232
Fire Station 75
Fire Station 227
Fire Station 224
Project Boundary
Fire Station
0 2,500 5,000
n Feet 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 RequirementsInfrastructure, 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 standards 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 Packet Page. 1215
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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 Packet Page. 1217
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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 117 (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%2C117.329611%2C11.53 Packet Page. 1219
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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) during 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 were 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 the 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 performance requirements of State Fire Marshal Standard 12-7A-2.
4. The proposed Project structures would be constructed of ignition resistant18 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, valid 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 Packet Page. 1222
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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. The 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 other 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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EMERGENCY
VEHICLE
ACCESS
OPEN
SPACE
LOT
OPEN
SPACE
LOT
PARK
PARK
DESIGNATED
REMAINDER
79 ft
66 ft
79 ft
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Parcel 1
1 2
4 3
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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FIGURE 6 - View 2
Parcel 1
1 2
4 3
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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FIGURE 6 - View 3
Parcel 1
1 2
4 3
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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Parcel 1
1 2
4 3
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
NORTHPARK
BLVD
W CAMPUS PKWY
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Parcel 1
1 2
4 3
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. SBCFPD 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 dropped 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 resilience 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 assessment (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 system 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 occurring 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 life, or loss of property. There are no warranties, 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 Packet Page. 1240
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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 SBCFPD 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 evacuation, 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
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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:
User’s Guide. Gen. Tech. Rep. RMRS-GTR-106 Ogden, Utah: Department of Agriculture, Forest Service, Rocky Mountain Research Station. 132p.
Arca, B., Laconi, M., Maccioni, A., Pellizzaro, G. and Salis, M., 2005. Validation of FARSITE model in Mediterranean area. University of Sassari.
Baltar, M., J.E. Keeley, and F. P. Schoenberg. 2014. County-level Analysis of the Impact of Temperature and Population Increases on California Wildfire Data. Environmetrics 25; 397-405.
Braun, K. 2002. Bushfire Threat to Homeowners. Community Perspectives about Fire, 2, 64-71.
Braziunas, K. H., Seidl, R., Rammer, W., & Turner, M. G. (2021). Can we manage a future with more fire? Effectiveness of defensible space treatment depends on housing amount and configuration. Landscape Ecology, 36(2), 309–330. https://doi.org/10.1007/s10980-020-01162-x Brown, J.K. 1982. Fuel and fire behavior prediction in big sagebrush. USDA Forest Service Res. Pap.
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Brown, J.K., 1972. Field test of a rate-of-fire-spread model in slash fuels (Vol. 116). Intermountain Forest & Range Experiment Station, Forest Service, US Department of Agriculture.
Bushey, C.L. 1985. Comparison of observed and predicted fire behavior in the sagebrush and bunchgrass vegetation-type. In J.N. Long (ed.), Fire management: The challenge of protection and use: Proceedings of a symposium. Society of American Foresters. Logan, UT. April 17–19, 1985. Pp. 187–201.
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CAL FIRE. 2019. Scott McLean interview AP news. Wildfire Acreage Way Down in California. Web site:
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CAL FIRE. 2006. General Guidelines for Creating Defensible Space. May 8, 2006. https://bof.fire.ca.gov/ media/4mwdav3l/rpc-2-c-defensible-space-guidance-document_ada.pdf Cochrane, M. A., Moran, C. J., Wimberly, M. C., Baer, A. D., Finney B, M. A., Beckendorf, K. L., Eidenshink, J., & Zhu, Z. 2012. Estimation of wildfire size and risk changes due to fuels treatments. International Journal of Wildland Fire, 21, 357–367. https://doi.org/10.1071/WF11079 Cohen, J.D., and Butler, B.W., 1996, October. Modeling potential structure ignitions from flame radiation exposure with implications for wildland urban interface fire management. In Thirteenth Fire and Forest Meteorology Conference, Lorne, Australia (p. 82).
Cohen, Jack D. 1995. Structure ignition assessment model (SIAM). In: Weise, D.R.; Martin, R.E., technical coordinators.
Proceedings of the Biswell symposium: fire issues and solutions in urban interface and wildland ecosystems. 1994 February 15¬17; Walnut Creek, California. Gen. Tech. Rep. PSW-GTR-158. Albany, Elia, M., Giannico, V., Lafortezza, R., & Sanesi, G. 2019. Modeling fire ignition patterns in Mediterranean urban interfaces. Stochastic Environmental Research and Risk Assessment, 33(1), 169–181. https://doi.org/10.1007/s00477-018-1558-5
FireFamily Plus. 2008. U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 124 p http://www.firelab.org/project/firefamilyplus.
Fox, D. M., Carrega, P., Ren, Y., Caillouet, P., Bouillon, C., & Robert, S. 2018. How wildfire risk is related to urban planning and Fire Weather Index in SE France (1990–2013). Science of the Total Environment, 621, 120–129. https://doi.org/10.1016/j.scitotenv.2017.11.174 FRAP (Fire and Resource Assessment Program). 2007. Fire Hazard severity Zones in SRA. Adopted by California Department of Forestry and Fire Protection on November 7, 2007. Accessed July 2023. https://frap.fire.ca.gov
Gorte, R. W. 2011. Wildfire protection in the Wildland-Urban interface. In Wildfires and Wildfire Management.
Grabner, K. W.; Dwyer, J.P.; Cutter, B. E. 2001. Fuel model selection for BEH AVE in midwestern oak savannas.
Northern Journal of Applied Forestry. 18: 74-80.
Grabner, K., Dwyer, J. and Cutter, B., 1997. Validation of BEHAVE fire behavior predictions in oak savannas using five fuel models. UNITED STATES DEPARTMENT OF AGRICULTURE FOREST SERVICE GENERAL TECHNICAL REPORT NC, pp.202-215.
Hall, John R. 2013. US Experience with Sprinklers. National Fire Protection Association Report. 91 pp.
Holland, R. F. 1986. Preliminary Descriptions of the Terrestrial Natural Communities of California. NongameHeritage Program, California Department of Fish and Wildlife.
Huntzinger, R. (2010). Determining the Necessary Components of an Evacuation and Shelter in Place.
Emmitsburg: National Fire Academy.
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Keeley, J.E. and Syphard, A.D., 2018. Historical patterns of wildfire ignition sources in California ecosystems. International journal of wildland fire, 27(12), pp.781-799.
Keeley, J.E., and P.H. Zedler. 2009. “Large, High-Intensity Fire Events in Southern California Shrublands:
Debunking the Fine-Grain Age Patch Model.” Ecological Applications 19:69–94.
Keeley, J.E., 2004. Impact of antecedent climate on fire regimes in coastal California. International Journal of Wildland Fire, 13(2), pp.173-182.
Keeley, J.E. and Fotheringham, C.J., 2003. Impact of past, present, and future fire regimes on North American Mediterranean shrublands. In Fire and climatic change in temperate ecosystems of the Western Americas (pp. 218-262). New York, NY: Springer New York.
Keeley, J.E. and S.C. Keeley. 1984. Post fire recovery of California coastal sage scrub. The American Midland Naturalist 111:105-117.
Lawson, B.D. 1972. Fire spread in lodgepole pine stands. Graduate Student Theses, Dissertations, & Professional Papers. 2357. https://scholarworks.umt.edu/etd/2357
Linn, R. 2003. “Using Computer Simulations to Study Complex Fire Behavior.” Los Alamos National Laboratory, MS D401. Los Alamos, NM.
Marsden-Smedley, J.B. and Catchpole, W.R., 1995. Fire behaviour modelling in Tasmanian buttongrass moorlands. II. Fire behaviour. International Journal of Wildland Fire, 5(4), pp.215-228.
McAlpine, R.S. and Xanthopoulos, G., 1989. Predicted vs Observed fire spread rates in ponderosa pine fuel beds:
a test of American and Canadian systems. In Proceedings of the 10th Conference on Fire and Forest Whitewood= Compte rendu du 10ieme Congress sur les incendies et la meterologie forestiere and editeurs DC Maiver, H. Auld, R. Whitewood. Ottawa, Ont.? Forestry Canada 1989.
Mensing, S.A., Michaelsen, J. and Byrne, R., 1999. A 560-year record of Santa Ana fires reconstructed from charcoal deposited in the Santa Barbara Basin, California. Quaternary Research, 51(3), pp.295-305.
Mockrin, M.H., Fishler, H.K. and Stewart, S.I., 2020. After the fire: Perceptions of land use planning to reduce wildfire risk in eight communities across the United States. International journal of disaster risk reduction, 45, p.101444.
Nasiatka, P. 2003. Southern California Firestorm 2003 Report for the Wildland Fire Lessons Learned Center.
Mission Centered Solutions.
National Fire Protection Association. 2021. Myths vs Facts About Home Sprinklers. NFPA Web site at: NFPA’s Fire Sprinkler Initiative-Myths and facts about home fire sprinklers Newman, S.M., Carroll, M.S., Jakes, P.J. and Paveglio, T.B., 2013. Land development patterns and adaptive capacity for wildfire: Three examples from Florida. Journal of Forestry, 111(3), pp.167-174.
Nichols, K., F.P. Schoenberg, J. Keeley, and D. Diez. 2011. “The Application of Prototype Point Processes for the Summary and Description of California Wildfires.” Journal of Time Series Analysis 32(4): 420–429.
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Romero-Calcerrada R, Novillo CJ, Millington JDA, Gomez-Jimenez I (2008) GIS analysis of spatial patterns of human-caused wildfire ignition risk in the SW of Madrid (Central Spain). Landscape Ecology 23, 341-354. doi:10.1007/S10980-008-9190-2
Rothermel, R.C. 1983. How to predict the spread and intensity of forest and range fires. GTR INT-143. Ogden, Utah: USDA Forest Service Intermountain Research Station.161.
Rothermel, R.C., and G.C. Rinehart. 1983. Field Procedures for Verification and Adjustment of Fire Behavior Predictions. Res. Pap. INT-142. Ogden, Utah: U.S. Department of Agriculture, Forest Service, Intermountain Forest, and Range Experiment Station. 25 p.
Safford, H. D., Schmidt, D. A., & Carlson, C. H. (2009). Effects of fuel treatments on fire severity in an area of wildland-urban interface, Angora Fire, Lake Tahoe Basin, California. Forest Ecology and Management, 258, 773–787. https://doi.org/10.1016/j.foreco.2009.05.024 San Bernardino County Fire Protection District. 2024. Ready, Set, Go! program. https://www.sbcounty.gov/ uploads/SBCFire/documents/programs/20231130_sbcfire_ready_set_go_flyer.pdf San Bernardino County Fire Protection District. 2024. 2021-2022 Annual Report. Accessed March 2024. https://sbcfire.org/annualreports/fy-21-22/
San Bernardino County Fire Protection District. 2024. Safety. https://sbcfire.org/safety/ Sawyer, J.O, T. Keeler-Wolf, and J.M. Evens. 2009. A Manual of California Vegetation. Second Edition. California Native Plant Society Press. Sacramento, California. 1,300 pp.
Scott, Joe H., and Robert E. Burgan. 2005. Standard Fire Behavior Fuel Models: A Comprehensive Set for Use with Rothermel’s Surface Fire Spread Model. Gen. Tech. Rep. RMRS-GTR-153. Fort Collins, CO: U.S.
Department of Agriculture, Forest Service, Rocky Mountain Research Station. 72 p.
Scott, J.H. and Reinhardt, E.D., 2001. Assessing crown fire potential by linking models of surface and crown fire behavior (No. 29). US Department of Agriculture, Forest Service, Rocky Mountain Research Station.
Scott, J. H., Thompson, M. P., & Gilbertson-Day, J. W. 2016. Examining alternative fuel management strategies and the relative contribution of National Forest System land to wildfire risk to adjacent homes - A pilot assessment on the Sierra National Forest, California, USA. Forest Ecology and Management, 362, 29–37. https://doi.org/10.1016/j.foreco.2015.11.038
Sneeuwjagt, R.J. and Frandsen, W.H., 1977. Behavior of experimental grass fires vs. predictions based on Rothermel’s fire model. Canadian Journal of Forest Research, 7(2), pp.357-367.
Steffey, E., Budruk, M. and Vogt, C., 2020. The mitigated neighborhood: Exploring homeowner associations’ role in resident wildfire-mitigation actions. Journal of Forestry, 118(6), pp.613-624.
Stone, D.R., 1990. California’s endemic vernal pool plants: some factors influencing their rarity and endangerment. Vernal pool plants-their habitat and biology, pp.89-107.
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Syphard AD, Radeloff VC, Keuler NS, Taylor RS, Hawbaker TJ, Stewart SI, Clayton MK (2008) Predicting spatial patterns of fire on a southern California landscape. International Journal of Wildland Fire 17, 602–613. doi:10.1071/WF07087
Syphard, Alexander D, Volker C Radeloff, Jon E. Keeley, Todd J. Hawbaker, Murray K. Clayton, Susan I. Stewart, Roger B. Hammer. 2007. Human Influence on California Fire Regimes. Ecological Applications. https://doi.org/10.1890/06-1128.1
Syphard AD, Bar Massada A, Butsic V, Keeley JE (2013) Land use planning and wildfire development policies influence future probability of housing loss. PLoS ONE 8(8), e71708. doi:10.1371/JOURNAL.
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Syphard, Alexandra D. and Jon E. Keeley. 2015. Location, timing, and extent of wildfire vary by cause of ignition.
International Journal of Wildland Fire. 11 pp.
Syphard, Alexandra & Brennan, Teresa & Keeley, Jon. (2014). The role of defensible space for residential structure protection during wildfires. International Journal of Wildland Fire. 23. 1165-1175.
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Syphard, Alexandra & Keeley, Jon & Massada, Avi & Brennan, Teresa & Radeloff, Volker. (2012). Housing Arrangement and Location Determine the Likelihood of Housing Loss Due to Wildfire. PloS one. 7. e33954. 10.1371/journal.pone.0033954.
Syphard, A.D. and Keeley, J.E., 2016. Historical reconstructions of California wildfires vary by data source. International Journal of Wildland Fire, 25(12), pp.1221-1227.
Wang, H.H., Finney, M.A., Song, Z.L., Wang, Z.S. and Li, X.C., 2021. Ecological techniques for wildfire mitigation:
Two distinct fuel break approaches and their fusion. Forest Ecology and Management, 495, p.119376.
Warziniack, T., Champ, P., Meldrum, J., Brenkert-Smith, H., Barth, C.M. and Falk, L.C., 2019. Responding to risky neighbors: testing for spatial spillover effects for defensible space in a fire-prone WUI community. Environmental and Resource Economics, 73, pp.1023-1047.
Weather Spark. 2023. Climate and Average Weather Year-Round in San Bernardino, San Bernardino Climate, Weather By Month, Average Temperature (California, United States) - Weather Spark Weise, D.R. and J. Regelbrugge. 1997. Recent chaparral fuel modeling efforts. Prescribed Fire and Effects Research Unit, Riverside Fire Laboratory, Pacific Southwest Research Station. 5p.
Zhou, A. 2013. Performance evaluation of ignition-resistant materials for structure fire protection in the WUI. Fire and Materials 2013 - 13th International Conference and Exhibition, Conference Proceedings, January 2013, 355–366.
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Appendix A
Representative Photo Log
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UNIVERSITY HILLS (2/24/2025)
ATTACHMENT 1
PHOTO LOG
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PHOTO LOCATION KEY
1: IMG 0476-
0483
2: IMG 0485-
0492
3: IMG 0494-
0501
4: IMG 0503-
0510
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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.
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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.
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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.
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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.
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Appendix B
Fire History Map
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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 1 2
n Miles
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
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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 intensities, this analysis incorporated 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, geographic 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 continuity, 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 nonnative grasses, sage scrub, and dispersed large shrubs. With that said, fuels 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 variables 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 distance (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 Packet Page. 1267
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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 upslope 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 (97th percentile) and typical (50th 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 weather input variables used in the Fire BehavePlus modeling efforts.
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Table 3. Wind and Weather Input Variables
Model Variable
Summer Weather (50th Percentile) On
and Offshore Wind
Peak Weather (97th 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 spread 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 accounted 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 given 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
Length1 (feet)
Fireline Intensity1
(BTU/feet/
second)
Spread Rate1
(mph)
Spotting
Distance1
(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.
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Table 5. Modeling Results for Post-Project Conditions
Fire Scenarios
Flame
Length1 (feet)
Fireline Intensity1
(BTU/feet/
second)
Spread Rate1
(mph)
Spotting
Distance1
(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.
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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.
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Appendix D
Ignition-Resistant Construction Requirements
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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.
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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 noncombustible 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.
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Appendix E
Prohibited Plant List
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APPENDIX E
FUEL MODIFICATION ZONE PROHIBITED PLANTS LIST
14428
E-1 July 2025
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 Packet Page. 1280
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FUEL MODIFICATION ZONE PROHIBITED PLANTS LIST
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E-2 July 2025
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 Council’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.
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STATE OF CALIFORNIA – CALIFORNIA NATURAL RESOURCES AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF WATER RESOURCES
P.O. BOX 942836
SACRAMENTO, CA 94236-0001
(916) 653-5791
City of San Bernardino
Planning Division
290 North D Street
San Bernardino, CA 92401
Dear City of San Bernardino:
The California Department of Water Resources (DWR) previously sent a letter dated January 12, 2026 (enclosed) regarding existing Lease No. EBE-80 (Lease), on San Bernardino County APN 0265-031-24-0000 (also known as DWR Parcel No. EBE-80), under which DWR leases the property to the Crestline Soaring Society (Crestline) for use as the Andy Jackson Airpark (Airpark). The Lease allows Crestline to operate and maintain a hang-gliding landing site, parking area, and access to the site.
The prior letter summarized DWR’s obligation under Article 410 of its Federal Energy Regulatory Commission (FERC) license that it relocate the Airpark in connection with construction of the Devil Canyon Power Plant Second Afterbay many years ago. The prior letter also asked the City to consider potential impacts to the Airpark—and any resulting implications for DWR’s FERC license— when reviewing nearby projects.
This letter provides an update based on DWR’s additional analysis of whether approval of the University Hills Development would have any impact on DWR’s ongoing FERC license obligations.
Under the license, Article 410 required DWR to file a plan to relocate the Airpark; DWR submitted that plan, and FERC approved it in 1993. Article 410 does not designate the Airpark as a FERC project recreation facility or impose any ongoing recreation or relocation obligations on DWR.
Accordingly, Article 410 imposed a one-time mitigation obligation upon DWR; there are no continuing or additional FERC license obligations related to the Airpark, and DWR considers its responsibilities under the license on this issue to be complete.
Based on the results of DWR’s analysis, DWR has no further comment regarding the approval of the University Hills Development as it relates to DWR’s FERC license.
Please contact me if you have any further questions at [email protected].
Sincerely,
Kristen Greenacre
Senior Right of Way Agent
cc: Jaime Shelden, Crestline Soaring Society
David Hardy, Encore Capital Management
Docusign Envelope ID: E1717134-A34C-43EE-A295-61DA435219B2 4/15/2026
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January 12, 2026
VIA EMAIL
Lisa Sherrick, Chair
Larry Quiel, Vice Chair
Casey Dailey, Commissioner
Amelia Lopez, Commissioner
Ivan Garcia, Commissioner
Ronnika Ngalande, Commissioner
Benjamin Pratt, Commissioner
Dan Carlone, Commissioner
Orlando Garcia, Commissioner
Planning Commission
City of San Bernardino
201 North E Street, 3rd Floor
San Bernardino, CA 92401
[email protected]
Michael Rosales, Senior Planner
Community Development & Housing Dept.
City of San Bernardino
201 North E Street, 3rd Floor
San Bernardino, CA 92401
[email protected]
Re: Comment on Addendum to University Hills Specific Plan (SCH No. 2007071155) for Specific Plan Amendment 23-01 and Subdivision 23-05 (Tentative Tract Map 20595) January 13, 2026 Planning Commission Agenda Item 2
Dear Chair Sherrick, Vice Chair Quiel, Honorable Planning Commissioners, and Mr.
Rosales:
This comment is submitted on behalf of Supporters Alliance for Environmental Responsibility (“SAFER”) regarding Specific Plan Amendment 23-01 and Subdivision 23-05 (Tentative Tract Map 20595), which proposes the development of 327 single-family residential lots, located on an approximately 404.03-acre site at Badger Canyon Road and W.
Frontline Road in the City of San Bernardino (“Project”), to be heard as Agenda Item 2 at the Planning Commission’s January 13, 2026 meeting.
SAFER objects to the City’s reliance on an Addendum to the University Hills Specific Plan Final Subsequent Environmental Impact Report (SCH No. 2007071155) certified in 2008 (“UHSP FSEIR”), for the Project. Under the California Environmental Quality Act (“CEQA”), an addendum is not appropriate because the Project is not within the scope of the prior program EIR and there is new information available since certification of the 2008 UHSP FSEIR indicating new significant impacts and/or the availability of new Packet Page. 1283
January 12, 2026
Comment on Addendum to University Hills Specific Plan (SCH No. 2007071155) for Specific Plan Amendment 23-01 and Subdivision 23-05 (Tentative Tract Map 20595) January 13, 2026 Planning Commission Agenda Item 2