Other Model Inputs
In addition to the aforementioned inputs, the following inputs were included in the FlamMap runs:
Simulation Time: The model simulation time was set at 5 hours (300 minutes). This duration was sufficient to allow modeled fires to reach the project site. Resolution: The calculation resolution was set at 30 meters, the same resolution as the base data files (e.g., elevation, fuels).
Wind Vectors: Wind vectors were modeled within the FlamMap runs using WindNinja tool embedded in the FlamMap software. WindNinja models the effect of topography on wind speed and direction generates wind vector files for use in the modeling runs. The grid resolution for the WindNinja analysis was set at 90 meters.
The FARSITE software package also requires additional settings to initiate model runs. The following outlines the settings used for the three FARSITE runs completed in support of this project:
The ‘Time Step’ used for all runs was 60 minutes (1 hour). The ‘Perimeter Resolution’ for all runs was 60 meters. The duration for all runs was maximized at 8 hours.
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The ‘Enable Spot Fire Growth’ ignition frequency input variable was set at 5% and the ignition delay was set at 2 minutes for all model runs.
5.2.4.2 Modeling Results
The output files generated for each of the FlamMap runs are the result of the analyses for potential fire behavior in the project area and those using the Minimum Travel Time tool. Fire behavior model results represent flame length and spread rate and MTT results represent fire Arrival Time. For the MTT analysis, one grid and one contour file were generated for each run (Summer and Peak) representing the time necessary for a fire to reach a particular location (Arrival Time), considering modeling inputs and ignition location(s). Maps depicting the Arrival Time grid and potential fire behavior and for the Peak and Summer weather scenarios are included in Appendices C-1 through C-4. The FlamMap Arrival Time results vary depending on the scenario analyzed.
Two different output files were generated from the FARSITE models, representing one run for each Scenario (Peak and Summer). The output files are a GIS shapefile representing fire perimeter boundaries at 1 hour intervals for the duration of the FARSITE run (8 hours). Maps depicting the FARSITE fire perimeters for the Peak and Summer weather scenarios are included in Appendices C-5 and C-6, respectively. The FARSITE fire progression results vary depending on the scenario analyzed (Peak or Summer).
For the models analyzing a fire during Peak (Santa Ana) wind and weather conditions, arrival time to the project boundary is approximately 4 hours from the ignition locations based on the FlamMap MTT analysis. Arrival time to the project boundary is also approximately 4 hours from the ignition location based on the FARSITE analysis. For the model analyzing a fire during Summer (On-Shore) wind and weather conditions, arrival time to the project boundary is approximately 40 minutes from the nearest ignition location (end of Wild Oak Lane) based on the FlamMap MTT analysis. Arrival time to the project boundary is also less than 1 hour from this same location based on the FARSITE analysis. For the Summer model, fires originating along San Pasqual Road and Cloverdale Road may take in excess of 3 hours (FlamMap MTT analysis) and up to 5 hours (FARSITE analysis) to reach the project site as they are slowed by developments along Rockwood and Harwood Roads.
The FlamMap and FARSITE modeling results are based on the data inputs presented herein.
FlamMap calculates fire growth across the landscape assuming independence of fire behavior between neighboring cells in the landscape and holds the wind and fuel moisture inputs constant for the duration of the modeling run. Therefore, the FlamMap results presented in this FPP provide a conservative estimate of the amount of time necessary for a fire to reach the project site Fire Protection Plan
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as the model does not consider changes to wind speed, wind direction, or fuel moisture influenced by terrain, time of day, or changes in regional weather patterns. While the FARSITE model allows for a temporal analysis of fire spread, the inclusion of constant wind speed and direction data in the model were used to represent specific weather scenarios, and do not account for real-world changes in wind speed or direction that may be realized during an actual fire event.
Further, current research indicates that FARSITE analyses tend to over-predict fire spread rates (Finney 1998). The FARSITE modeling effort did calculate spotting from surface fires, thus spread rates resulting from FARSITE models are based on the progression of the flaming front of the fire plus spotting ahead of the fire front. Changes in wind, weather, or pockets of different fuel types are not accounted for in this analysis. 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 variable weather patterns over time, small-scale topographic variations, or changing vegetation patterns.
Based on the FlamMap analysis of during Peak fire conditions, and consistent with the FARSITE analysis, the rate of spread was approximately 3.4 miles per hour (covering a distance of 13.5 miles in 4 hours). This modeling result is supported by an analysis of previous fires burning in San Diego County during Santa Ana wind events. Specifically, the 2007 Witch Fire, which burned the project site, exhibited extreme fire behavior with spread rates reaching 2.5 miles per hour (Grijalva et al., 2008) and the 2003 Cedar Fire burned at a rate of approximately 3 miles per hour (USFS and CAL FIRE 2003).
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6 EMERGENCY RESPONSE AND SERVICE
6.1 Fire Facilities
The Project is currently located within the CAL FIRE Valley Center Fire Protection District and the County of San Diego. The project proponent proposes an annexation of the entire project site into the City of Escondido. Once finalized, the Escondido Fire Department (EFD) will provide initial response to the Proposed Project site from the on-site station. The EFD operates seven Fire Stations that could respond to a fire or medical emergency at the site. Table 6 provides a summary of the EFD’s fire and emergency medical delivery system.
Table 6
Escondido Fire Department Responding Stations Summary
Fire
Station Address Apparatus
Staffing
(Total/Station) Maximum Travel Distance Travel Time**
On-Site Safari Highlands
Ranch
Paramedic Engine TBD 3.05 miles*** 1 to 5.8 min
1 310 North Quince
Escondido, California
92029
Paramedic Engine
Truck Company
Brush Engine
2 Ambulances
27 7.3 miles* 16 min
2 421 North Midway
Escondido, California
92029
Paramedic Engine
Brush Engine
Ambulance
9 6.2 miles* 13 min
3 1808 Nutmeg Street
Escondido, California
92029
Paramedic Engine
Brush Engine
9 9.3 miles* 17 min
4 3301 Bear Valley
Parkway
Escondido, California
92029
Paramedic Engine
Brush Engine
9 6.1 miles* 10 min
5 2319 Felicita Road
Escondido, California
92029
Paramedic Engine
Brush Engine
Ambulance
15 6.9 miles* 15 min
6 1735 Del Dios Road
Escondido, California
92029
Paramedic Engine 9 7.8 miles* 14 min
7 1220 North Ash
Escondido, California
92029
Paramedic Engine
Ambulance
9 7 miles. 15 minutes
* Distance measured to Project entry gate located on Safari Highlands Ranch Road at the southern edge of property except for the On-Site station which measures distance to the most distant lot. ** Assumes travel to the primary project’s north end, and speeds calculated with the ISO travel time formula Time = 0.65+1.7(Distance) Fire Protection Plan
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The closest existing EFD Fire Station is FS 4, located at 3301 Bear Valley Parkway, which staffs a minimum of three firefighters 24 hours per day/seven days per week and houses one Paramedic Engine (Type I) and a Type III brush engine. Secondary response would be provided from this and other EFD Fire Stations as needed. Station 2 is the next closest EFD station and is located at 421 North Midway. The station staffs three on-duty, 24-hours per day and houses a Paramedic Engine and a Type III brush engine.
6.2 Emergency Response Travel Time Coverage
The City of Escondido’s Quality of Life Standard is to respond to all priority Level One or Emergency type calls within 7 minutes and 30 seconds, a total of 90% of the time. In 2012, EFD’s response time for all stations was 6 minutes and 32 seconds for all urgent calls. Response to the project site from the closest existing EFD fire stations would not achieve the response time standard for first arriving. Response from Station 4 is calculated at roughly 10 minutes to main entrance of the site. The full effective firefighting force is estimated to arrive within 16 minutes.
Therefore, the project does not comply with the City’s response time standards and will require provisions for an on-site fire station.
To mitigate the unachievable City of Escondido’s Quality of Life Standard threshold, a new fire station will be built in conjunction with the project. The station will be located at the southern tip of the project boundary, located near the main entrance of the project off of Safari Highlands Ranch Road. The new station will be a 6,000 to 10,000 square feet building with three bays for apparatus and five dorm rooms for staff (See Figure 5). The station will be staffed 24/7 with five to six career firefighters, who would provide initial response. The station will likely have one Paramedic Engine, one Brush Engine and one Ambulance. Travel time from the new station to the most remote (distant) lot within the Project is 5.8 minutes. This would enable just under 2 minutes for dispatch and turnout and is considered to meet the 7.5 minute Escondido Fire Department response goal.
NORTH
1 INCH = 30 FT.
( IN FEET )
GRAPHIC SCALE
GATE HOUSE
FIRE STATION
RV/STORAGE PARKING
TENNIS
POOL
SPA
WADING
SPLASH PAD
PLAYGROUND
POOL CABANA
POOL CABANA
CLUBHOUSE
FITNESS CENTER
Northern
Emergency
Evacuation
Access Road
Zoo Road
Emergency
Evacuation
Access
Safari Highlands Boundary
Open Space Lots
Development
Proposed
Fire
Station
Location
Proposed On-Site Fire Station Exhibit
FIGURE 5
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SOURCE: MCCULLOUGH LANDSCAPE ARCHITECTURE, INC. 2016
Fire Station Site Plan
Key Map
Fire
Station
Lot
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6.3 Estimated Calls and Demand for Service from the Project The EFD documented 14,536 total emergency calls for 2015 (Escondido Fire Department 2016) for a City population of approximately 147,0953(City of Escondido 2016). The call volume of 99 per 1,000 persons per year is higher than the national average of approximately 82 calls. For this analysis, we’ll use the higher (most conservative) per capita call volume of roughly 0.1 for City of Escondido. Based on the proposed development plans, the project's estimated 1,716 residents (assumes an average of 3.12 occupants per residence for this type of community (SANDAG 2014)) would generate roughly 172 calls per year (0.5 calls per day), most of which are expected to be medical-related calls (approximately 80.4% of total emergency incidents).
Service level requirements are not expected to be significantly impacted with the increase of 172 calls per year (0.5 call per day) for a station (EFD Station 4) that currently responds to roughly 3 calls per day (1,034 calls per year, 86 calls per month, 21 calls per week) . The next closest fire station is station
2. This EFD station responds to 2,676 calls per year or approximately 7.3 calls per day. For reference, a station that responds to 5 calls per day in an urban setting is considered average and 10 calls per day is considered busy. Therefore, the project is not expected to cause a decline in Station 4 level of service. The requirements described in this FPP are intended to aid firefighting personnel and minimize the demand placed on the existing emergency service system. Regardless of the potential impact on Station 4, the planned new fire station on site will be able to respond to the project’s generated calls, and have significant capacity to respond to other calls from outside the project in a timeframe that is a substantial improvement from existing service.
6.4 Response Capability Impact Assessment and Mitigation Cumulative impacts from multiple projects can cause fire response service decline and must be analyzed for each project. The Safari Highlands Ranch project and its proposed usage by up to 1,716 residents represents an increase in potential service demand of approximately 172 calls per year, well within the capacity of the existing EFD Fire Stations. However, this total adds to an existing busy service obligation for Station 4 and the station’s response time to the entrance of the project site exceeds the City’s response time standard. This cumulative impact is considered potentially significant, but mitigated through the construction of a new, on-site fire station that is staffed year round. A modern fire station will be built with fair-share contributions by the Project and through assessments, property taxes, and/or a separate agreement. The final funding amount will be determined by the applicant and City of Escondido and included in a Fire Service Agreement to be completed at later stages of planning prior to map recordation.
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3 City population total number is from San Diego Association of Governments 2014 estimates which reflect 2010 U.S. Census data.
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7 FIRE SAFETY REQUIREMENTS- INFRASTRUCTURE,
BUILDING IGNITION RESISTANCE, AND DEFENSIBLE SPACE
7.1 Roads
7.1.1 Access and Egress
Site access will comply with the requirements of the 2014 San Diego County Consolidated Fire Code, California Code of Regulations; Title 14, and Escondido 2016 Fire Code (Sections 503.1 and 503.2). The project’s circulation system will consist of both public and private roads with each being built to the respective standards and maintained by funded entities (HOAs and/or Facilities Maintenance Fee, or San Diego County).
The project site would have one main access road, Safari Highlands Ranch Road, which intersects with Rockwood Road between Old Ranch Road and Vistamonte Avenue. Safari Highlands Ranch Road will be a public roadway from its starting point at Rockwood Road up to the gated community entry and a private road beyond the entry gate. This road will provide:
At the entrance gate, a 64-foot-wide curb to curb with two 24-foot-wide travel lanes and a 16-foot-wide median
Inside the entrance gate, a 48-foot-wide curb to curb with two 20-foot-wide travel lanes and an 8 foot wide median
At first intersection, road width becomes 42 feet wide curb to curb with two 21-foot-wide travel lanes and demarcated bike lane
A relatively short section just north of the first intersection includes two 16-foot-wide travel lanes and an 8-foot-wide median
North of the 40-foot-wide section, the road becomes 36 feet wide curb to curb. This would allow two 12-foot-wide travel lanes and parking on both sides.
The Project includes gated secondary and tertiary emergency access roads at the northwest and southern portions of the development, providing the ability to move vehicles from the project in physically remote locations from the other Project roads. The northwestern road will be approximately 2.4 miles long and will connect to Stonebridge Road in the Hidden Hills Trails development. The southern road will be approximately one mile long and will connect to emergency access Zoo Road, which will be upgraded to accommodate emergency vehicles.
Both emergency access roads will be minimum 24 feet wide with two travel lanes.
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All internal residential streets will be 36 feet wide curb to curb. Residential driveways serving no more than two single-family dwellings will have a minimum of 16 feet of unobstructed improved width. Parking will not be allowed on streets including widths lower than 32 feet. Access roads to construction areas shall be completed and paved prior to issuance of building permits and prior to combustible construction occurring.
7.1.2 Road Widths
All on-site roads will be constructed to current County of San Diego Consolidated Fire Code and EFD Road standards, including minimum 12-foot travel lane widths unobstructed by parking (503.2.1), and shall be improved with asphalt paving materials. All streets within the project, public and private, include on-street parking when there is at least 36 feet of paved road width. Parking will be restricted along red curb painted fire lanes and by posting of signs stating “No Parking; Fire Lane” correctly marked per the California Vehicle code to preserve the unobstructed width for emergency response. The signs shall include language identifying the towing company and their phone number enabling legal enforcement of the no parking areas.
Turnouts along the secondary access road (northwestern road) will be provided to EFD’s requirements regarding spacing, taper and length.
7.1.3 Road Surface
All fire access and vehicle roadways will be of asphaltic concrete, except as noted for grades exceeding 15%, and designed and maintained to support the imposed loads of fire apparatus (not less than 75,000 pounds) that may respond, including Type I engines, Type III engines, and ladder trucks. Access roads shall be completed and paved prior to issuance of building permits and prior to combustible construction occurring. The project HOA will be a funded entity provided the responsibility to maintain roads so that they meet City of Escondido and EFD requirements.
7.1.4 Interior Circulation Roads
Interior circulation roads include all roadways that are considered common or primary roadways for traffic flow through the site and for fire department access and serving in excess of two structures. Any dead-end roads serving new buildings that are longer than 150 feet shall have approved provisions for fire apparatus turnaround in accordance with EFD standards at the time of approval. EFD’s Fire Marshal shall establish a policy identifying acceptable turnarounds for various Project product types.
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Fire apparatus turnarounds to include turning radius of a minimum 28 feet, measured to inside edge of improved width, per Consolidated Fire Code. Minimum paved radius width for a project cul-de-sac is 38 feet. Cul-de-sac bulbs will have signs posted “No Parking; Fire Lane.” Cul-de-sacs shall have a red painted curb with white letters “No Parking Fire Lane”.
Cul-de-sac bulbs are required on dead-end roads in residential areas where roadways serve more than two residences.
Roadways and/or driveways shall provide fire department access to within 150 feet of all portions of the exterior walls of the first floor of the structures (all structures are fire sprinklered). Traffic calming devices (including, but not limited to, speed bumps, speed humps, speed control dips, etc.) shall be prohibited unless approved by the fire code official (Sec. 503.4.1 Traffic calming devices).
Vertical clearance along roadways is required to be 13.5 feet. Proper maintenance is required to ensure that vegetation and trees on roadsides do not grow over or into the roadway and impede emergency apparatus access. No mature tree trunks or branches shall intrude into the road. The type of vegetation shall be fire resistant and comply with this plan. The gate house height will be posted on the roadway indicating a minimum 13.5 foot clearance. Interior circulation roads shall maintain a 20 to 50 feet buffer along either side where fuel modification/reduction is completed twice per year as is according to specifications provided in this FPP.
Angle of approach/departure shall not exceed 7 degrees (12%) (County Consolidated Fire Code, Section 503.2.7), unless mitigated to approval by the Fire Chief. The gradient for a fire apparatus access roadway shall not exceed 15.0%. The fire code official may allow roadway grades up to 20.0% provided that the roadway surface conforms to section 503.2.3. The fire code official may require additional mitigation measures where it is deemed appropriate.
7.1.5 Gates
All automatic gates shall be equipped with a Knox, emergency key-operated switch overriding all command functions and opening the gate(s). Automatic gates accessing through the main access and /emergency access roadways shall be equipped with approved emergency traffic control-activating strobe light sensor(s) which will activate the gate from both directions of travel on the approach of emergency apparatus. The automatic gate will have a battery back-up or manual mechanical disconnect in case of a Fire Protection Plan
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power failure. The gate(s) will include a magnetic or pressure activated switch for automatically opening the gate from the interior of the project for resident egress. Pole gates or other structures or devices which could obstruct fire access roadways or otherwise hinder emergency operations shall be equipped with an approved, Knox padlock.
7.1.6 Driveways
Any new structure that is 150 feet or more from a fire apparatus access road shall have a paved driveway meeting the following specifications:
Grades shall be less than 15%. If over 15%, they require Portland cement base with heavy broom finish and in no case can they exceed 20%.
Approved fire apparatus turnouts will be provided every 400 feet if driveway is over 800 feet long.
A residential driveway constructed of 3½" Portland cement concrete may be installed on any slope up to 20% provided that slopes over 15% have a deep broom finish perpendicular to the direction of travel or other approved surface to enhance traction.
Driveway gates shall comply with Section 7.1.3.
Driveway aprons will meet the code standard with a 28 degree inside turning radius.
7.1.7 Premises Identification
Identification of roads and structures will comply with the Consolidated Fire Code, Sections 503.3 and 505, as follows:
Approved numbers and/or addresses shall be placed on all new and existing buildings and at appropriate additional locations, plainly visible and legible from the street or roadway fronting the property when approaching from either direction. Address numbers on new construction shall be automatically illuminated by low voltage lighting. The numbers shall contrast with their background and shall meet the following minimum size standards: 4" high with a ½" stroke for residential buildings, 6" high with a ½" stroke for commercial and multi-residential buildings and 12" high with a 1" stroke for industrial buildings. Additional numbers shall be required where deemed necessary by the fire code official, such as rear access doors, building corners and entrances to commercial centers.
The fire code official may establish different minimum sizes for numbers for various categories of projects (Sec. 505.1 Address numbers).
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Multiple structures located off common driveways will include posting structure identification on structures, on the entrance to individual driveways, and at the entrance to the common driveway.
If the structure is 100 feet from the roadway, structure identification should also be located at the entrance to the driveway.
7.1.8 Response Map Updates
Any new development, which necessitates updating of emergency response maps by virtue of new structures, hydrants, roadways or similar features, are required to provide map updates to the City of Escondido. The applicant will provide a copy of building plans in Geo-Referenced format to be used by fire department for pre-fire planning purposes and for update of applicable incident response maps. Information shall specifically include a site plan and building plan showing locations of utility shut-offs, fire sprinkler risers and shut-off valves, the fire department connection for fire protection sprinkler system, fire alarm panels, fire hydrants, fire department connection standpipe, and Knox box . The map update information shall be provided in Cityapproved coordinate system.
7.2 Structures
7.2.1 Ignition-Resistant Structural Requirements
This section outlines ignition-resistant construction (for all structures) that will meet the requirements of the EFD Fire Code. The following construction practices respond to the requirements of the 2016 California Fire Code, the 2016 California Building Code (CBC), the California Code of regulations, Title 14, and the 2014 San Diego County Consolidated Fire Code (SDCCFC) as amended. These requirements include the ignition -resistant requirements found in Chapter 7A of the CBC and County Building Code. While these standards will provide a high level of protection to structures in this development, there is no guarantee of assurance that compliance with these standards will prevent damage or destruction of structures by fire in all cases.
7.2.2 Structure Setbacks
Structure setbacks are required in some jurisdictions, including Rincon Del Diablo (SDCCFC Section 4907.1.3 Structure Setback from Slope). Single-story structures shall be setback a minimum of 15 feet horizontally from top of slope to the farthest projection from a roof. A singlestory structure shall be less than 12 feet above grade. A two-story structure shall be setback a minimum of 30 feet horizontally from top of slope to the farthest projection for a roof. Structures greater than two stories may require a greater setback when the slope is greater than 2 to 1. A total Fire Protection Plan
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of up to 14 lots (worst case) may not be able to provide a full 30 feet of structure setback. For these lots, a single story structure can be provided if 15 feet of setback is available. For a two story structure to be constructed on these lots, mitigation through alternative materials and methods, as described further in Section 6.0 will be required. The intent of the code is to set back structures from vegetative fuel covered slopes. Some of the identified lots where the setbacks cannot be fully provided are adjacent internal slopes that will be landscaped and managed. These lots are not proposed to receive heat deflecting walls. The heat deflecting view wall potential locations (subject to further study and EFD approval) are depicted in (Appendix D).
7.2.3 Additional Requirements and Recommendations Based on Occupancy Type
All retail, commercial, and office buildings will comply with appropriate building codes.
7.3 Fire Protection Systems
7.3.1 Water
Water service for the Safari Highlands Ranch project will be provided by the City of Escondido Water Division (EWD) and will be consistent with EFD requirements (Section 507.2/507.3) for a residential development within a VHFHSZ area. Water utilities will include a connection to the City of Escondido water system, pumps to boost water, water storage tank, backup power, and an internal water distribution system that will use both pumps, reducing stations, and gravity feed. The City’s water service area requires new development to meet a 2,500 gpm fire flow which can be supplied from two or more fire hydrants. The pressures in the Proposed Project site will remain above 20 psi for a minimum duration of two hours when meeting the fire requirements for the City’s water service area and EFD fire flows. Fire hydrants will be operable prior to combustible lumber being dropped on site.
7.3.2 Hydrants
Hydrants shall be located along fire access roadways as determined by the EFD Fire Marshal to meet operational needs, at intersections, at the beginning radius of cul-de-sacs, and at a code exceeding 500 feet (on-center) spacing of fire access roadways, pursuant to the City of Escondido Fire Code (Ordinance No. 2016-116, 1-4; Section 507.5.1.1). Hydrants will be consistent with EFD Design Standards as follows:
Required installations. The location, type and number of fire hydrants connected to a water supply capable of delivering the required fire flow shall be provided on the public or private street, or on the site of the premises to be protected or both. Fire hydrants shall Fire Protection Plan
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be accessible to the fire department apparatus by roads meeting the requirements of section 503 of the CFC. Fire service laterals, valves, backflow preventers, and meters will be installed on site as required by the EWD. All fire department connections shall be installed in accordance with mounting requirements as specified by the EFD Fire Marshal. The northwestern emergency secondary access road will be provided two water tanks (10,000 gallons each) at locations approved by the EFD and fitted with connections compatible with EFD requirements. The water tanks will be independent, truck filled, secured to prevent water theft, and monitored at least annually. The tanks will be maintained by an independent contractor through the HOA. Location of fire hydrants. Hydrants will be in place and serviceable prior to delivery of combustible materials to the site. Fire hydrants shall be located according to engineering standards and as required by the fire code official using the following criteria and taking into consideration departmental operational needs. Fire hydrants will be every 1,000 feet apart along Safari Highlands Ranch Road. Hydrants within Project neighborhoods shall be 500 feet apart. Prior to the issuance of building permits, the applicant shall submit to EFD plans demonstrating a water system capable of handling the fire flow requirements. Fire hydrant construction and configuration. All fire hydrants shall be of bronze construction, including all internal parts except seats. Alternative materials may be used if approved by EFD’s Fire Marshal and EWD. The stems shall be designed and installed in a manner that will ensure that they will not be projected outward from the main body by internal water pressure due to disassembly. The number and size of fire hydrant outlets shall be at a minimum one 4-inch port and two, 2 1/2-inch ports. Signing of water sources and fire department connections. Fire hydrants shall be identified by a reflectorized blue marker and fire department connections shall be identified by a reflectorized green marker, with a minimum dimension of 3 inches, in the center of the travel lane adjacent the water source (SDCCFC Sec. 507.5.7.1). Crash posts will be provided where needed in on-site areas where vehicles could strike fire hydrants and will be consistent with Section 312 of the CFC.
Vegetation Clearance. A three-foot clear space (free of ornamental landscaping and retaining walls) shall be maintained around the circumference of all fire hydrants.
7.3.3 Fire Sprinklers
All structures will be provided interior fire sprinklers. Automatic internal fire sprinklers shall be in accordance with National Fire Protection Association (NFPA) 13 or 13-D and City of Escondido installation requirements as appropriate. Actual system design is subject to final building design and the occupancy types in the structure.
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7.3.4 Smoke Alarm Systems
All residential units shall have electric-powered, hard-wired smoke detectors in compliance with County of San Diego Consolidated Fire Code. Hard-wired smoke alarms are to be equipped with battery backup.
7.4 Defensible Space/Fuel Modification Zones
An important component of a fire protection system is the fuel modification area. Fuel modification zones (FMZ) are designed to gradually reduce fire intensity and flame lengths from advancing fire by placing thinning zones, restricted vegetation zones, and irrigated zones adjacent to each other on the perimeter of all structures and adjacent open space areas. Therefore, the fuel modification area is an important part of the fire protection system designed for this site.
Predicted flame lengths vary on the site-adjacent slopes which will be directly adjacent the provided fuel modification zones. The zones are customized for the site based on slope and vegetation characteristics as well as resulting fire behavior modeling exercises. These variations were analyzed as were the site’s specific features and conditions which complement and augment the proposed fuel modification areas. Fire behavior modeling, as previously described, was used to predict flame lengths and was not intended to determine sufficient fuel modification zone widths. However, the results of the modeling do provide important information which is a key element for determining distances for minimizing structure ignition and providing “defensible space” for firefighters.
The significance of the Project’s FMZ’s cannot be understated. Based on scientifically modeled fire behavior calculations customized for the site, flame lengths under the most extreme fire weather conditions within the WUI areas could approach 65 feet in height. Under summer weather conditions, flame lengths could approach 33 feet in height along the southern and western edges of the Proposed Project site. Therefore, an appropriate FMZ would likely be roughly 100 feet under summer conditions and 150 feet wide under extreme weather conditions. Thus, providing enough set-back from flammable fuels and providing “defensible” space for firefighters in which they can work. For this project, as indicated in Appendix D, the FMZs are at least three times wide as the modeled flame lengths in each of the fuel types represented on site, resulting in fuel modification areas that exceed the standard 100 foot wide requirement. For the entire eastern and northern portions of the project, they are 200 feet, a 100% increase over the standard.
7.4.1 Project Fuel Modification Zone Standards
Fuel modification zones will be implemented according to the following requirements. These zones are presented graphically in Appendices D-1 through D-4. In addition, a Prohibited Plant Fire Protection Plan
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List is provided in Appendix E. Each zone would include permanent field markers to delineate the zones, aiding ongoing maintenance activities that will occur on site. The project would also hire a qualified EFD-approved 3rd party fuel modification zone inspector to provide inspections twice annually, as detailed in the following sections.
7.4.1.1 Zone 1 – Irrigated Structure Setback Zone (75 to 100 feet wide) Zone 1 is applicable site wide for every structure. All fuel modification will be provided within the project boundaries so there will be no off-site FMZ areas. The fuel modification zones start at the structures (rear wall) and extend outward. All developed landscape areas internal to the project will be to Zone 1 conditions. The standard Zone 1 will be a minimum 75 feet wide starting at the structure and moving outward (100 feet for the north and east sides of the project). All flammable native vegetation shall be removed. Single trees, ornamental shrubbery or cultivated ground covers may be permitted provided they are maintained in a manner that they do not readily transmit fire to the structure and meet the requirements herein. This zone will be planted with drought-tolerant, less flammable plants from the proposed Project Plant Palette (Appendix F) and an automatic irrigation system will be installed in this area to maintain hydrated plants without over-watering, allowing for run-off, or attracting nuisance pests. There will be no inclusion of non-fire resistive trees in the project’s interior landscapes or perimeter fuel modification zones.
Zone 1 includes the following key components:
1. Minimum of 75 feet wide;
2. Automatic irrigation system to maintain hydrated plants without over-watering or attracting nuisance pests;
3. High-leaf-moisture plants as ground cover, less than 4 inches high;
4. Shrubs are prohibited beneath tree crowns.
5. No trees within 10 feet of structures (drip line of mature trees shall be maintained 10 feet from structures);
6. Tree spacing of a minimum 10 feet between canopies or as specified in Table 7;
7. No tree limb encroachment within 10 feet of a structure or chimney, including outside barbecues or fireplaces;
8. Tree maintenance includes limbing-up (canopy raising) 6 feet or one-third the height of mature tree;
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9. Maintenance including ongoing removal and/or thinning of undesirable combustible vegetation, replacement of dead/dying plantings, maintenance of the programming and functionality of the irrigation system, regular trimming to prevent ladder fuels;
10. A minimum of 60 inches of horizontal clearance and unlimited vertical clearance around the exterior of the structure (360°) provided for firefighter access. Within this clearance area, landscape such as low ground covers and shrubs are permitted so long as their placement and mature height do not impede firefighter access, consistent with purpose of this guideline;
11. No combustible construction (structures) allowed in Zone 1 – HOA responsible for confirming that these conditions are met;
12. No permanent or portable fire pits, fire places, or flame generating devices that burn wood allowed within Zone 1 or within 10 feet of vegetation – HOA responsible for confirming that these conditions are met;
13. Trees and tree form shrub species that naturally grow to heights that exceed 2 feet shall be vertically pruned to prevent ladder fuels;
14. Grasses shall be cut to 4 inches in height. Native grasses can be cut after going to seed;
15. Ground covers within first 5 feet from structure restricted to non-flammable materials such as stone, rock, concrete, bare soil, or other; and
16. Vegetation/Landscape Plan prepared and submitted to EFD in compliance with this plan.
7.4.1.2 Zone 2 – Thinning Zone (75 to 100 feet wide)
A thinning zone reduces the fuel load of a wildland area adjacent to Zone 1, and thereby, reduces heat and ember production from wildland fires, slows fire spread, and reduces fire intensity. Zone 2 adjoins Zone 1 and measures 75 or 100 feet in most areas with some slight variation in width, depending on available distance to property line. Along the northern and eastern sides of the project, where effects of a Santa Ana wind driven wildfire would be greatest, a full 100 feet of Zone 2 will be provided.
Zone 2 includes the following key components:
1. Zone 2 requires a minimum of 50% thinning or removal of plants (50% no fuel);
2. Grasses shall be cut to 4 inches in height. Native grasses can be cut after going to seed;
3. Ground cover less than 6 inches high;
4. No trees, except coast live oak (Quercus agrifolia), or Engelmann oak (Quercus engelmannii); Fire Protection Plan
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5. Trees and tree-form shrub species that naturally grow to heights that exceed 4 feet shall be vertically pruned to prevent ladder fuels;
6. No shrubs, except single-specimen native shrubs, exclusive of sage scrub, 20 feet on center;
7. Maintenance including ongoing removal and thinning of dead/dying planting, and regular trimming to prevent ladder fuels;
8. Plant species introduced into Zone 2 shall not include prohibited or highly flammable species;
9. No vegetation found on the Prohibited Plant List (Appendix E) shall be planted or remain in any Fuel Modification Zone.
7.4.2 Other Vegetation Management
7.4.2.1 Roadside Fuel Modification Zones
As required under SDCCFC, an area of 20 feet from each side of fire apparatus access roads within most neighborhoods shall be improved to Zone 1 standards described above and maintained clear of all but fire-resistive vegetation. Safari Highlands Ranch Road, the primary access backbone road will have an area of 50 feet of fuel modification on each side. The roadside fuel modification zones will consist of 20 feet of Zone 1 and 30 feet of Zone 2 or a 50-foot wide Zone 1. Both emergency access roadways will have 10 feet of thinned vegetation (Zone 2) adjacent to both sides of the road. These areas shall be maintained by the HOA. Vertical clearance of 13 feet 6 inches shall also be maintained along fire apparatus access roads.
7.4.2.2 Tree Planting and Maintenance Standards
Trees may be planted within the Proposed Project site as long as they conform to the SDCCFC, Section 4907.3.1.Trees (EFD has adopted the County standard). On the Project site, tree planting in the park and maintenance areas as well as along roadways is acceptable, as long as they meet the following restrictions as described below:
For streetscape plantings, fire resistive trees can be planted 10 feet from edge of curb to center of tree trunk. Care should be given to the type of tree selected, that it will not encroach into the roadway, or produce a closed canopy effect. Crowns of trees located within a FMZ shall maintain a minimum horizontal clearance of 10 feet for fire resistant trees. Mature trees shall be pruned to remove limbs one-third the height or 6 feet, whichever is less, above the ground surface adjacent to the trees. Dead wood and litter shall be regularly removed from trees. Ornamental trees shall be limited to groupings of 2–3 trees with canopies for each grouping separated horizontally as described in Table 7.
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Table 7
Distance Between Tree Canopies by Percent Slope
Percent of Slope Required Distances Between Edge of Mature Tree Canopies (1) 0–20 10 feet
21–40 20 feet
41+ 30 feet
1 Determined from canopy dimensions as described in Sunset Western Garden Book (Current Edition) 2 2014 CFC Section 4907.3.1. Trees, County of San Diego.
7.4.2.3 Trail Vegetation Management
Trails include the community pathways that are all accessible from public roads and the network of open space trails, interconnecting the community. Trail maintenance shall occur on the trails to remove flashy fuels and maintain the trail in a useable, low fuel condition. The community pathways will be accessible by emergency all-terrain vehicles, such as “UTVs” accessed at numerous locations within the community. The open space trail network will be accessible from the Proposed Project via trail access points and trails that will be wide enough for emergency UTV/ATV access.
7.4.2.4 Environmentally Sensitive/Riparian Areas
Once the FMZs are in place, there will not be a need to expand them as they have been planned to meet the fire code. However, if unforeseen circumstances were to arise that required hazard reduction within an area considered environmentally sensitive or part of the Multispecies Conservation Plan, it may require approval from the City or County and the appropriate resource agencies (California Department of Fish and Game, U.S. Fish and Wildlife Service, U.S. Army Corps of Engineers) prior to any vegetation management activities occurring within those areas.
7.4.2.5 Pre-Construction Structure Locations
1. Vegetation management on structure location will not be required until construction begins, unless it is located within the fuel modification zone of a structure under construction or completed.
2. Prior to issuance of a permit for any construction, grading, trenching, or installation of fences, the outermost 50 feet of each structure location (building pad) is to be maintained as a Vegetation Management Zone. This entails removal of vegetation as needed.
3. The remainder of the Vegetation Management Zones required for the particular lot shall be installed and maintained prior to combustible materials being brought onto any lot under construction.
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4. Existing flammable vegetation shall be reduced by 100% on vacant lots upon commencement of construction.
5. Dead fuel, ladder fuel (fuel which can spread fire from ground to trees), and downed fuel shall be removed and trees/shrubs shall be properly limbed, pruned, and spaced per this plan.
7.4.3 Undesirable Plants
Certain plants are considered to be undesirable in the landscape due to characteristics that make them highly flammable. These characteristics can be physical or chemical. The plants included in the Prohibited Plant List (Appendix E) are unacceptable from a fire safety standpoint, and will not be planted on the site or allowed to establish opportunistically within the fuel modification zones or landscaped park and maintenance areas.
7.4.4 Fuel Modification Area Vegetation Maintenance
All fuel modification area vegetation management shall occur as-needed for fire safety, compliance with the FMZ requirements detailed in this FPP, and as determined by the EFD.
The Project HOA or other established funding and management entity for each development area or neighborhood if separate, shall be responsible for all vegetation management throughout the respective project sites, in compliance with the requirements detailed herein and FAHJ requirements. The HOA(s) shall be responsible for ensuring long-term funding and ongoing compliance with all provisions of this FPP, including vegetation planting, fuel modification, vegetation management, and maintenance requirements throughout the Safari Highlands Ranch project.
7.4.5 Annual FMZ Compliance Inspection
The Project HOA shall obtain an FMZ inspection and report from a qualified EFD-approved 3rd party inspector in May and September of each year certifying that vegetation management activities throughout the project site have been performed pursuant to this FPP. This inspection report and certification of compliance with the FPP shall be provided to EFD annually by June 1st and October 1st.
7.4.6 Construction Phase Vegetation Management
Vegetation management requirements shall be implemented at commencement and throughout the construction phase. Vegetation management shall be performed pursuant to this FPP and EFD requirements on all building locations prior to the start of work and prior to any import of Fire Protection Plan
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combustible construction materials. Adequate fuel breaks shall be created around all grading, site work, and other construction activities in areas where there is flammable vegetation.
In addition to the requirements outlined above, the project will comply with the following important risk-reducing vegetation management guidelines:
All new power lines shall be underground for fire safety during high wind conditions or during fires on a right-of-way that can expose aboveground power lines. Temporary construction power lines may be allowed in areas that have been cleared of combustible vegetation. A construction fire prevention plan shall be prepared to minimize the likelihood of ignitions and pre-plan the site’s fire prevention, protection and response plan. 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.
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8 ALTERNATIVE MATERIALS AND METHODS FOR
NON-CONFORMING TOP OF SLOPE SETBACKS
There are up to 14 lots that cannot provide a full 30 feet of setback from top of slope for two story homes (Appendix D). Single story homes may be constructed on these lots provided that 15 feet of setback is available with no additional measures provided. Some of these lots are adjacent to internal slopes and as those slopes may be landscaped and maintained absent of native fuels, they will not be provided heat deflecting walls. Further analysis of which homes will be adjacent slopes with native, more flammable fuels will be provided to determine which will be subject to the heat deflecting walls. As such, this FPP incorporates additional analysis and measures that will be implemented to compensate for potential fire related threats to these lots. These measures are customized for this site based on the analysis results and focus on providing functional equivalency as a full fuel modification zone.
The maximum number of 14 lots that cannot provide a full 30 feet setback from the top of slope are being protected through a combination of extended fuel modification zone (up to 200 feet) and will also be provided heat deflecting walls/view walls if two story structures are planned. No additional mitigation measures are required if single story residences are built.
Research has indicated that the closer a fire is to a structure, the higher the level of heat exposure (Cohen 2000). However, studies indicate that given certain assumptions (e.g., 10 meters of low fuel landscape, no open windows), wildfire does not spread to homes unless the fuel and heat requirements (of the home) are sufficient for ignition and continued combustion (Cohen 1995, Alexander et al. 1998). Construction materials and methods can prevent or minimize ignitions.
Similar case studies indicate that with nonflammable roofs and vegetation modification from 10–18 meters (roughly 32–60 feet) in southern California fires, 85–95% of the homes survived (Howard et al. 1973, Foote and Gilless 1996). Similarly, San Diego County after fire assessments indicate strongly that the building codes are working in preventing home loss: of 15,000 structures within the 2003 fire perimeter, 17% (1,050) were damaged or destroyed. However, of the 400 structures built to the 2001 codes (the most recent at the time), only 4% (16) were damaged or destroyed.
Further, of the 8,300 homes that were within the 2007 fire perimeter, 17% were damaged or destroyed. A much smaller percentage (3%) of the 789 homes that were built to 2001 codes were impacted and an even smaller percentage (2%) of the 1,218 structures built to the 2004 Codes were impacted (IBHS 2008). Damage to the structures built to the latest codes is likely from flammable landscape plantings or objects next to structures or open windows or doors (Hunter 2008).
These results support Cohen’s (2000) findings that if a community’s homes have a sufficiently low home ignitability (i.e., 2014 San Diego County Consolidated Code and 2016 California Building Code), the community can survive exposure to wildfire without major fire destruction.
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This provides the option of mitigating the wildland fire threat to homes/structures at the residential location without extensive wildland fuel reduction. Cohen’s (1995) studies suggest, as a rule-of-thumb, larger flame lengths and widths require wider fuel modification zones to reduce structure ignition. For example, valid SIAM results indicate that a 20-foot high flame has minimal radiant heat to ignite a structure (bare wood) beyond 33 feet (horizontal distance).
Whereas, a 70-foot high flame may require about 130 feet of clearance to prevent structure ignitions from radiant heat (Cohen and Butler 1996). This study utilized bare wood, which is more combustible than the ignition resistant exterior walls for structures built today.
Obstacles, including steep terrain and non-combustible walls can block or deflect all or part of the radiation and heat, thus making narrower fuel modification distances possible. Fire behavior modeling conducted for this project indicates that fires in the off-site areas would result in roughly 33-foot flame lengths under summer conditions. Extreme conditions may result in longer flame lengths, approaching 65 feet.
As indicated in this report, the FMZs and additional fire protection measures proposed for this project provide equivalent wildfire buffer. They are based on a variety of analysis criteria including predicted flame length, fire intensity (Btu), site topography and vegetation, extreme and typical weather, position of structures on pads, position of roadways, adjacent fuels, fire history, current vs. proposed land use, neighboring communities relative to the proposed project, and type of construction. The fire intensity research conducted by Cohen (1995), Cohen and Butler (1996), and Cohen and Saveland (1997) and Tran et al. (1992) supports the structure setback alternatives proposed for this project.
8.1 Heat Deflecting Walls
The project’s slopes in the areas of concern along with the elevated lots/pads adjacent, provide an opportunity to place a non-combustible, six foot tall, heat-deflecting wall (lower 1 to 2 feet block wall and upper 4 to 5 feet dual pane, one pane tempered glazing) to provide additional deflection for these lots to compensate for top of slope setbacks.
When buildings are set back from slopes, and a wall is placed at the top of slope, flames spreading up those slopes are deflected vertically and over the structure where cooling occurs, reducing the effects of convective heat on the structure. If a structure cannot be setback adequately, or where the slope is less than 30%, a noncombustible wall can help deflect the flames from the structure (NFPA 2005). The duration of radiant heat impact on the downhill facing side of the house is also reduced. An imaginary line extended along the slope depicts the path of the heat (hot air rises) and flame. The structure set back is important to avoid heat and/or flame intersection with the structure.
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Heat-deflecting landscape view walls of masonry
construction with fire-rated glazing that are six feet in height (roughly lower two feet masonry construction and upper tfour feet dual pane, one pane tempered glazing or equivalent and meeting Chapter 7A and/or EFD approval) will be
incorporated at top of slope/edge of lot for lots where a full 30 feet of structure setback for the second story is not possible (Typical example illustrated in Figure 6). The landscape walls provide a vertical, non-combustible surface in the line of heat, fumes, and flame travel up the slope. Once these fire byproducts intersect the wall, they are deflected upward or, in the case where lighter fuels are encountered, they are quickly consumed, heat and flame are absorbed or deflected by the wall, and the fuels burn peaks out within a short (30 second– 2 minute) time frame (Quarles and Beall 2002). Walls like these have proven to deflect heat and airborne embers on numerous wildfires in San Diego, Orange, Los Angeles, Ventura, and Santa Barbara County. Rancho Santa Fe Fire Protection District, Laguna Beach Fire Protection District, Orange County Fire Authority, and others utilize these walls as Alternative methods based on observed performance during wildfires. This has led to these agencies approving use of noncombustible landscape walls as mitigations for reduced setbacks at top of slope. These walls are consistent with NFPA 1144 Standard for Reducing Structure Ignition Hazards from Wildland Fire – 2008 Edition, Section 5.1.3.3 and A.5.1.3.3 and International Urban Wildland Interface Code (ICC 2012). NFPA 1144, A.5.1.3.3 states: “Noncombustible walls and barriers are effective for deflecting radiant heat and windblown embers from structures.”
8.2 Additional Structure Protection Measures
The following additional measures will be implemented to “mitigate” potential structure fire exposure related to the provided FMZs and top of slope structure setbacks on this project. These measures are customized for this site, its unique topographical and vegetative conditions, and focus on providing functional equivalency for structure setbacks. In order to provide compensating structural protection in the absence of a full FMZ, and in addition to all residences being built to the latest ignition resistant codes, the structures exposed to the preserved biological riparian woodlands will receive varying degrees of additional measures.
8.2.1 Additional Project Fire Protection Measures
Any additional structure or landscape item (in addition to the residence) in the designated Fuel Modification Zone areas must be constructed from non-combustible materials such as stone, steel, or heavy timber/pre-treated, fire retardant wood. HOA must enforce as part of the CC&Rs, a landscape plan review process for a formal landscape improvement Figure 6. Example of Heat
Deflecting Wall
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plan submittal and approval by a licensed landscape architect to ensure that plant palette and non-combustible materials are employed within the designated Fuel Modification Zones and private lot landscaping.
Fuel modification for common area lots will be pre-designed and installed by the project developer. For private lots, landscape plans for front, side, and rear yards for the entire project will need to be approved by the HOA landscape committee and EFD through a formal process prior to any landscape improvement work by a homeowner. Designated Fuel Modification Zones that include rear and side-yard areas (outside house setback envelopes) will be inspected annually by the landscape committee and/or Escondido Fire Department or a third party inspector for conformance with the requirements provided in the project's Fire Protection Plan. Inspections will include common lots and the contractor will work with the HOA to provide compliance and a report to the EFD. CC&R's shall include this language so that homeowners acknowledge this provision. The 3rd party fuel modification zone inspector will be tasked with at least annually providing evaluation of the northern emergency access road water tank levels. All structures will be built to the Chapter 7A ignition resistant standards and will be provided interior sprinklers, to code.
Structure eaves will be closed when facing wildland fuels, per code. External dryer vents will be baffled or fitted with ember resistant mesh. Exposed wood, including fascia and architectural trim boards, will not be allowed on the side of structures facing the wildland fuels unless considered “heavy timber” or beams with a minimum nominal dimension of 4 inches.
No combustible fences or gates will be allowed attached to dwellings, the first five feet from the structure will be non-combustible. Fences using fire retardant treated wood products or other materials to meet this requirement will be subject to approval of the EFD. The project proponent will provide an emergency equipped UTV vehicle equipped with a patient gurney and other EFD requested equipment (specifications to be determined in a fire service agreement) for use on the trails and community pathways.
It is understood that the EFD may require additional measures based on a structure’s proximity to fuels and the fuel loads represented by those areas. This FPP is provided to assist the EFD with determinations of any additional measures. The information provided herein supports the ability of the proposed structures and FMZs to withstand the predicted short duration, low to moderate intensity wildfire and ember shower that would be expected from wildfire burning in the vicinity of the site or within the site’s landscape.
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9 EMERGENCY PRE-PLANNING - EVACUATION
9.1 Quick Reference - Wildland Fire Evacuation Plan
Evacuation is a process by which people are moved from a place where there is immediate or anticipated danger, to a safer place, and offered temporary shelter facilities. When the threat passes, evacuees are able to return to their normal activities, or to make suitable alternative arrangements.
Figure 7 indicates the Emergency Evacuation Routes available to the Safari Highlands Ranch Community. The exhibit highlights the community’s backbone interior roads along with primary access points and off-site roads and major traffic corridors leading to designated evacuation areas.
The available evacuation routes for the residents and guests of Safari Highlands Ranch are (Figure 7):
1. Egress to the west and south via Rockwood Road – This is the primary Safari Highlands Ranch access road and interconnects with Cloverdale Road to the West.
Cloverdale Road north is a dead end. Cloverdale Road south offers travel options to SR78 east or west, or continuing south to San Pasqual Road which intersects Bear Valley Parkway to the south and west and into Escondido.
2. Egress to the south and west on Zoo Road - this gated secondary access road provides a route to Old Battlefield Road (gated road into existing Eagle Crest Golf Course community), which connects into Rockwood Road and then to the south and west as described above. Zoo Road continues south past Old Battlefield Road to SR-78, from which point, travel to the east or west is possible.
3. Egress to the west via north emergency secondary egress route – this gated emergency only secondary access road interconnects with Meadow Creek Lane to the west which then intersects Hidden Trails Road, which offers travel to the S6 (Valley Parkway/Valley Center Road) or continued travel to the west into urban areas of Escondido. Travel to the west along this emergency secondary egress may be directed by law enforcement. However, residents are not advised to utilize this route without law enforcement direction because it is a gated road and should not be assumed passable.
This evacuation plan has been prepared specifically for the Safari Highlands Ranch and focuses on wildland fire evacuations, although many of the concepts and protocols will be applicable to other emergency situations. Ultimately, this plan will be used by the Safari Highlands Ranch Homeowner’s Association to educate community residents as to their evacuation approach during wildfires and other similar emergencies.
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It is recognized that wildfire and other emergencies are often fluid events and that the need for evacuations are typically determined by 1) on-scene first responders, 2) a collaboration between first responders, law enforcement, and designated emergency response teams, including Office of Emergency Services and the Incident Command established for larger emergency events. As such, and consistent with all emergency evacuation plans, this Emergency Evacuation plan is to be considered a tool that supports existing pre-plans, as available for the area, and provides for citizens who are familiar with the evacuation protocol, but is subservient to emergency eventspecific directives provided by agencies managing the event.
This Emergency Evacuation Plan will be reviewed by Escondido Fire Department, San Diego County Fire Authority, and San Diego County Sheriff’s Department. Provided input and edits will be integrated resulting in a coordinated effort and collaborative plan.
9.2 Background
This Safari Highlands Ranch Evacuation Plan has been prepared based on the Unified San Diego County Emergency Services Organization and County of San Diego Operational Area Emergency Operations Plan (EOP) – Evacuation Annex. In order to establish a framework for implementing well-coordinated evacuations, the County of San Diego Office of Emergency Services (OES) developed an Evacuation Annex as part of the Area EOP (San Diego County 2014). Large-scale evacuations are complex, multi-jurisdictional efforts that require coordination between many agencies and organizations. Emergency services and other public safety organizations play key roles in ensuring that an evacuation is effective, efficient, and safe.
Evacuation during a wildfire is not necessarily directed by the fire agency, except in specific areas where fire personnel may enact evacuations on-scene. The San Diego County Sheriff’s Department, California Highway Patrol, and other cooperating law enforcement agencies have primary responsibility for evacuations. These agencies work closely within the Unified Incident Command System, with the County Office of Emergency Services, and responding fire department personnel who assess fire behavior and spread, which should ultimately guide evacuation decisions. To that end, EFD, County Fire, law enforcement, Public Works, Planning, Emergency Services Departments, and CalTrans, amongst others, have worked with a County Pre-Fire Mitigation Task Force to address wildland fire evacuation planning for San Diego County.
Safari
Highlands
San
Pasqual Rd
Valley
C
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Bear Valley
P kwy
Valley Pkwy
E. Grand Ave
Nash St
E. Lincoln Ave
ESCONDIDO
B
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Pkw
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El Norte Pkwy
Centre City Pkwy
Centre City Pkwy
78 Northern Emerg ency Evacuation Acce ss Road
Rockwoo d
Fire
Station #7
Fire
Station #2
Fire
Station #4
New Fire
Station
Zoo Road
Emergency Evac Access
Fire
Station #1
Fire
Station #3
Fire
Station #7
15 78
Navel
17Th
Calavo
David
Juniper
Mclees
Howard
Terrace
Private
Brett
Fairway
Clark
Viletta
Iris
Nicolo
Elm
Ivy
Cortez
Haas
Leah
Fine
Big Pine
Sierra
Spruce
Puebla
Fantero
Cameo
Towell
Beech
Village
Geneva
Sunrise
Dorothy
Kingston
Meadow
Harding
Fig
Emerald
Avocado
Sungold
Nordahl
Orange
Quince
Crisie
Century
Palsero
09Th
Alley
Beech
Dragt
Foxley
Albert
Beven
Norwood
Laura Juniper
Dexter
Jonah
Cimarron
Borra
Elm
Montiel
Midway
Dimaio
Tan Bob
Conway
Lemora
Nina
Lehner
Eldorado
Trellis
Alley
Scenic
Alta Vista
Matin
Railroad
Carrizo
Pauma
Timken
Sasha
14Th
Park Hill
Citrus
Danica
Laura
Blueridge
Mission
Lux
Crest
Kings
Stevens
Oasis
10Th
05Th
13Th
05Th
03Rd
06Th
03Rd
04Th
09Th
Citracado
Laslo
Carlann
Felicita
Citron
Brava
Private
Sterling
Jeremy
Del Dios
Hillstone
Redwood
Katella
York
Bernardo
Nutmeg
Stanley
Clarence
07Th
Tan Tam
Jenna
Athens
Stanley
Shay
Canter
Falconer
Ginny
Wanek
Briarwood
Glasgow
Boyle
Madison
Private
Eastbury
Acker
Leaf
Engel
Farr
Park
Iris
Private
Alley
08Th
Bellinda
Mary
Knob Hill
Gamble
Greenview
16Th
Darby
El Ku
Aster
Glenview
11Th
Montemar
Hamilton
Green Mtn
I-15 Nb
Marlynn
Cranston
Hillward
Wilson
Lorry
Skyridge
Maple
Skyline
Elmwood
Jed
Highgrove
Escondido
I-15 Nb
Sheridan
Fuerte
Lo Cascio
Overlook
Private
I-15 Nb
Sr-78 Wb
I-15 Sb
Venture
Eagle Glen
Mc Lain
Elm
Mandeville
I-15
Ivy
Thomas
Deodar
Hale
I-15
Greenwood
Miller
Ball
Felicita
Crownpoint
Caraway
15Th
Park
Colley
Chestnut
Gale
12Th
Mtn View
Private
Hubbard
Sr-78 Eb
Vermont
Eagle Lake
11Th
Via Paloma
Canyon
Rose
Oak Hill
Reed
Bahia
State
Idaho
Broadway
Mudge
Cedar
Simpson
Cita
Date
Andreasen
Vista
Private
Robyn
Gianelli
Portola
Via Cascabel
Summit
Sr-78
Dublin
Private
Ross
Industrial
Private
Viento Valle
I-15
Flint
Vinewood
Lawrence
Goldenrod
Vista Verde
Enterprise
Birch
Centennial
Citrus Hills
Borden
Upas
Daisy
Hickory
Grape
Private
Mission
Private
Private
Brotherton
Citrus
Castaneda
Anaheim
I-15
Hypoint
Glen Ridge
Reservoir
Cortina
I-15 Sb
Old
Ranch
Oak
Ridgemont
White Hawk
Private
Priva et
Mission
Private
Old Milky
Private
San Pasqual Valley
Guejito
Private
Carroll
I-15 Nb
Old Survey
Private
Private
Bandy Canyon
Slivkoff
Old Melrose Ranch
Old
Yucca
Jauregui Mtn View
Lake
San Pasqual Valley
Old Wagon
Old Manzanita
Jauregui Ranch
Private
Fire Evacuation Plan
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SOURCE: SANDAG, 2016
Date: 4/25/2017 - Last saved by: lterry - Path: Z:\Projects\j830401\MAPDOC\DOCUMENT\FPP Figs\FPP Fig 7 Fire Evac.mxd 0 0.5 1
Miles
Proposed Fire Station Location
Existing Fire Stations
Safari Highland Ranch Boundary
Major Transportation Corridor
Primary Evacuation Route
Project Access
Project Emergeny Secondary Access
FIGURE 7
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INTENTIONALLY LEFT BLANK
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It is important to note that every evacuation scenario will include some level of unique challenges, constraints, and fluid conditions that require interpretation, fast decision making, and alternatives. For example, one roadway incident that results in blockage of evacuating vehicles may require short-term or long-term changes to the evacuation process. Risk is considered high when evacuees are evacuating late, and fire encroachment is imminent. This hypothetical scenario highlights the importance of continuing to train responding agencies, model various scenarios, educate the public, and take a very conservative approach to evacuation decision timelines (early evacuation) as well as providing contingency plans.
Equally as important, the evacuation procedures should be regularly updated with lessons learned from actual evacuation events, as they were following the 2003, 2007 and 2014 San Diego County fires. The authors of this Evacuation Plan recommend that occasional updates are provided, especially following lessons learned from actual incidents, as new technologies become available that would aid in the evacuation process, and as changing landscapes and development patterns occur within and adjacent the Safari Highlands Ranch project that may impact how evacuation is accomplished. At the time of this plan’s preparation, there was no encompassing emergency evacuation plan available for the greater region. This Safari Highlands Ranch Wildland Fire Evacuation Plan is consistent with County evacuation planning and can be integrated into a regional evacuation plan when and if the area officials and stakeholders (EFD, CAL FIRE, San Diego Fire, San Diego County Fire Authority, Office of Emergency Services, San Diego Sheriff’s Department, and others) complete one.
As demonstrated during large and localized evacuations occurring throughout San Diego County over the last 15 years, an important component to successful evacuation is early assessment of the situation and early notification via managed evacuation declarations. San Diego County utilizes early warning and informational programs to help meet these important factors. Among the methods available to citizens for emergency information are radio, television, social media/internet, neighborhood patrol car PA notifications, and Reverse 911.
The Safari Highlands Ranch community residents will be strongly encouraged to register with Reverse 911, Alert San Diego, and the local Escondido Community Notification System. In addition, the community HOA will organize annual evacuation public outreach as well as maintain a fire safe page on the community Web page, including key sections of this Emergency Evacuation Plan and the FPP and links to important citizen preparedness information.
9.3 San Diego County Evacuation Planning Summary
This Wildland Fire Evacuation Plan incorporates concepts and protocols practiced throughout San Diego County. The San Diego County Evacuation Annex (2014) follows basic protocols set Fire Protection Plan
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forth in the County’s Operation Area Emergency Operations Plan and the California Master Mutual Aid Agreement, which dictate who is responsible for an evacuation effort and how regional resources will be requested and coordinated.
First responders are responsible for determining initial protective actions before EOCs and emergency management personnel have an opportunity to convene and gain situational awareness. Initial protective actions are communicated to local EOCs and necessary support agencies as soon as possible to ensure an effective, coordinated evacuation.
During an evacuation effort, the designated County Evacuation Coordinator is the Sheriff, who is also the Law Enforcement Coordinator. The Evacuation Coordinator will be assisted by other law enforcement and support agencies. Law enforcement agencies, highway/road/street departments, and public and private transportation providers will conduct evacuation operations. Procurement, regulation, and allocation of resources will be accomplished by those designated. Evacuation operations will be conducted by the following agencies:
County of San Diego Sheriff’s Department
Fire and Rescue
County Health and Human Services Agency
Department of Animal Services,
Department of Planning and Land Use
Department of Environmental Health
Department of General Services
Department of Public Works
Department of Agriculture, Weights, and Measures
Department of Parks and Recreation
The information provided in Appendix G summarizes the larger scale evacuation pre-planning undertaken by County and local agencies as well as standard evacuation pre-planning procedures and techniques including: Evacuation Objectives, Coordination Process, Response Operations, Evacuation Points and Shelters, Sheltering in Place, Evacuation Strategies, Social Aspects of Evacuation, Special Population Evacuation, Animal Evacuations, and Re-Entry Procedures.
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9.4 Safari Highlands Ranch Evacuation Road Network
Wildfire emergencies that would be most likely to include an evacuation of Safari Highlands Ranch would be large wildfires approaching from the north, northeast, or east. These fires are often wind driven and occur during declared Red Flag Warning days where low humidity and high winds facilitate fire ignition and spread. If a fire starts in the open lands to the east of the Project and is fanned by these fire weather conditions, an early evacuation of the area may occur as many as 24 or more hours prior to actual threatening conditions, depending on the location of the ignition. Fires occurring on typical weather days, even fires igniting off the local highways, have been very successfully controlled at small sizes within minutes of ignition and would not typically trigger a need to evacuate the project. Partial evacuation or temporary relocation of some neighborhoods could be an option in these cases.
If a wildfire ignited closer to the Safari Highlands Ranch community during weather that facilitates fire spread, where multiple hours are not available for evacuation, a different evacuation approach would need to be explored. It is preferred to evacuate long before a wildfire is near, and in fact, history indicates that most human fatalities from wildfires are due to late evacuations when they are overtaken on roads. Therefore, it is prudent to consider a contingency option. For example, if a wildfire is anticipated to encroach upon the community in a timeframe that is shorter than would be required to evacuate all residents, then options available to responding fire and law enforcement personnel should include 1) partial relocation where residents in perimeter homes on the north/northeast/east edge are temporarily relocated to internal areas or to the Village Core, 2) Individual neighborhood relocations where residents are temporarily relocated to the Village Core or south or east to Escondido, 3) temporary refuge where residents are instructed to remain in their homes while firefighters perform their structure protection function. This approach is consistent with San Diego County’s (2014) Evacuation approach which states “Due to the nature of the threats requiring an evacuation, there may be insufficient time to perform an early evacuation of the area and shelter-in-place instructions may need to be provided”. Although not a shelter in place community, the structures in Safari Highlands Ranch are ignition resistant, defensible and designed to require minimal resources for protection, which enables these contingency options that may not be available to other nearby communities.
The roads that will be used for ingress and egress from the Safari Highlands Ranch community are described as:
Rockwood Road – providing primary access to Safari Highlands Ranch, Rockwood Road provides a 40 foot wide paved roadway with a two designated travel lanes each a minimum of 12 feet wide, a center striped median, and turn lanes. Rockwood Road intersects Cloverdale Road, a 42 foot wide paved surface with shoulders, two designated Fire Protection Plan
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12 foot wide travel lanes and a 10 foot wide striped median that extends nearly the entire road length and will be widened for the pinch down section. At the intersection with SR78, there are four lanes provided, a straight, right and left turn lane for southbound traffic and an ingress lane for northbound traffic. This intersection will be provided dual left turn lanes for a total of five lanes.
Zoo Road – the post-project Zoo Road will be gated and will provide two 12’ foot wide unobstructed travel lanes for the approximately 1.7 miles distance from the southern project entrance to SR-78. Zoo Road intersects with the gated Old Battlefield Road which provides gated access into the Eagle Crest Golf Course community. Old Battlefield Road would only be available during an evacuation if law enforcement directed that the gate be opened and traffic be directed through to Rockwood Road and out. Zoo Road continues south past Old Battlefield Road to the west of the San Diego Safari Park parking lots, where it intersects with SR-78. The gated project access will open automatically for passage to the south.
Northern Emergency Secondary Access – the gated northern emergency access route will provide a minimum of two 12 foot wide paved travel routes with turnouts. The road extends 2.4 miles through wildland fuels and is considered an as-needed evacuation road that would be used for non-fire emergencies where evacuation using southern access points is not possible or for wildfire emergencies when evacuation is occurring at least two to three hours prior to wildfire threatening the site. The gated access will need to be opened for passage.
As evidenced by mass evacuations in San Diego County and elsewhere, even with roadways that are designed to the code requirements, it may not be possible, or necessary to move large numbers of persons at the same time. Road infrastructure throughout the United States, and including San Diego County is not designed to accommodate a short-notice, mass evacuation.
The need for evacuation plans, pre-planning, and tiered or targeted and staggered evacuations becomes very important for improving evacuation effectiveness. Among the most important factors for successful evacuations in urban settings is control of intersections downstream of the evacuation area. If intersections are controlled by law enforcement, barricades, signal control, or other means, potential backups and slowed evacuations can be minimized. Another important aspect of successful evacuation is a managed and phased evacuation declaration. Evacuating in phases, based on vulnerability, location, or other factors, enables the subsequent traffic surges on major roadway to be smoothed over a longer time frame and can be planned to result in traffic levels that flow better than when mass evacuations include large evacuation areas at the same time. This plan defers to Law Enforcement and Office of Emergency Services to appropriately phase evacuations and to consider the vulnerability of communities when making decisions. For Fire Protection Plan
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example, the Safari Highlands Ranch Community will offer its residents a high level of fire safety on site (as detailed in this Fire Protection Plan) along with options for properly equipped and trained firefighter safety zones and temporary resident on-site refuge (within their wellprotected homes) as a contingency, as discussed further in this plan.
The Safari Highlands Ranch planned community interior road network and the existing regional road system that it interconnects provide multi-directional primary and secondary emergency evacuation routes consistent with, or exceeding, most communities in this area.
Consistent with County of San Diego evacuation planning annex (2014), major ground transportation corridors in the area will be used as primary evacuation routes during an evacuation effort. The road systems were evaluated to determine the best routes for fire response equipment and “probable” evacuation routes for relocating people to designated safety areas. The primary roadways that would be used for evacuation from Safari Highlands Ranch are Rockwood Road, Cloverdale Road, emergency access Zoo Road, northern emergency secondary access road, Meadowcreek Lane, S. Hidden Trails Road, Valley and Parkway. These roads provide access to major traffic corridors including State Route 76 to the south, State Route 78 also to the south, and Interstate 15 to the west.
During an emergency evacuation from the Safari Highlands Ranch community, the primary and secondary roadways may be providing citizen egress while responding emergency vehicles are inbound. Because the roadways are all designed to meet or exceed Fire Code requirements, including 12- foot wide, unobstructed travel lanes, adequate parking, 28-foot inside radius, grade maximums, and signals at intersections, potential conflicts that reduce the roadway efficiency required for smooth evacuations are minimized.
The community’s primary evacuation routes are accessed through a series of internal neighborhood roadways, which intersect with the primary ingress/egress roads that intersect off-site primary and major evacuation routes. Based on the existing road network, the community can evacuate to the north (once off-site), south, east and west depending on the nature of the emergency.
Depending on the nature of the emergency requiring evacuation, it is anticipated that the majority of the community traffic would exit the project via Rockwood Road or Zoo Road. These are the most direct routes from the Village Core. The northern emergency access route may be used by the northerly neighborhoods, including E-1, E-2, R-4 and R-5, depending on the time available for evacuation and the need for additional movement via the northerly route. In a typical evacuation that allows several hours or more time (as experienced in 2003, 2007, and 2010 wildfires), all traffic may be directed to the south and out Rockwood Road and/or Zoo Road. If less time is available, fire and law enforcement officials may direct some neighborhoods, primarily E-1 and E-2, to utilize the northerly gated route Fire Protection Plan
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9.4.1 Evacuation Route Determination
Fire and law enforcement official will identify evacuation points before evacuation routes are announced to the public. Evacuation routes are determined based on the location and extent of the incident and include as many pre-designated transportation routes as possible. Absent direction from fire and/or law enforcement officials, residents would be advised to use the primary access road – Rockwood Road for evacuations.
9.4.2 Roadway Capacities and Maximum Evacuation Time Estimate Roadway capacity represents the maximum number of vehicles that can reasonably be accommodated on a road. Roadway capacity is typically measured in vehicles per hour and can fluctuate based on the number of available lanes, number of traffic signals, construction activity, accidents, and obstructions as well as positive effects from traffic control measures.
Each roadway classification has a different capacity based on level of service, with freeways and highways having the highest capacities. Based on traffic engineer estimates (Linscott, Law & Greenspan 2016), and using peak numbers and a conservative estimate, roads that would be the most likely available to Safari Highlands Ranch residents and their hourly capacities are:
1. Rockwood Road –2,600 vehicles/hour
2. Zoo Road - 1,900 vehicles/hour
3. Cloverdale Road – minimum 2,600 vehicles/hour
4. Northerly emergency evacuation route - 1,000 vehicles/hour Using these averages, the length of time it will take for an area to evacuate can be determined by dividing the number of vehicles that need to evacuate by the total roadway capacity. Based on Safari Highland Ranch’s estimated 550 single family homes, and assuming 2.2 cars per household (Cal Poly San Luis Obispo 2016), during an evacuation, it is calculated that up to 1,210 vehicles could be evacuating in a major incident that required full evacuation of the community, although this is a conservative estimate as that number would likely be far lower as many families would likely drive in one vehicle versus in multiple vehicles and depending on the time of day, many of these vehicles may already be off-site, such as if a fire occurred during typical work hours.
Neighboring communities within the sphere of influence of the Safari Highlands Ranch evacuation that may be evacuating in a similar time frame, depending on the type of wildfire emergency, are the 580 unit Rancho San Pasqual community (accessed via Rockwood Road and Cloverdale Road) and Fire Protection Plan
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the 80 unit Vista Monte community (accessed via Rockwood Road). Additionally, the San Pasqual Union School located off Rockwood Road would affect typical evacuations.
Based on the number of units or daily use averages (school and animal park), the estimated time requirement for evacuation was calculated.
Evacuating Vehicles per Household or Average Daily Usage Rancho San Pasqual – 580 units x 2.2 vehicles = 1,276 vehicles Vista Monte – 80 units x 2.2. vehicles = 176 vehicles
San Pasqual Union School – 560 students and staff, 180 from outside the area = estimated 200 vehicles (others are already accounted for in community estimates) Based on the combined vehicle estimates for existing communities and land uses neighboring the Safari Highlands Ranch Project during an evacuation, it is calculated that up to 1,652 vehicles in addition to the 1,210 vehicles from Safari Highlands Ranch (total of 2,862 vehicles) could be evacuating in a similar time frame during a major incident that required full evacuation of the area, although this is a conservative estimate as that number would likely be far lower as many families would likely drive in one vehicle versus in multiple vehicles and depending on the time of day, many of these vehicles may already be off-site, such as if a fire occurred during typical work hours.
Based on the internal roadway capacities, three potential egress routes, and off-site roadway capacities, and using the lowest capacity roadway (bottleneck) as the determining factor, and discounting the capacity for the possibility that traffic would move slower during some evacuations, it is estimated that between 2 to 3 hours may be necessary for a complete evacuation of Safari Highlands Ranch, the neighboring communities and the school simultaneously.
While the capacity of these roadways is adequate to facilitate the evacuation of the total number of vehicles generated by these communities/uses in an estimated one hour or less, this timeframe also assumes “wheels rolling”, actual travel time and additional time that must be considered in the evacuation process (Figure 8), including:
1. Fire detection and reporting (up to 10 minutes)
2. Dispatch and fire response (up to 10 minutes)
3. Evacuation decision (10 minutes or more)
4. Message to dispatch (5 minutes)
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5. Evacuation message dissemination (up to 45 minutes)
6. Residents to gather personal items, pets, livestock (if able) and begin evacuation travel (45 minutes)
7. Contingency time to allow for shadow evacuees, special needs population, unforeseen congestion or blockages (30 minutes)
Total minimum time that may be needed for a large-scale evacuation from the detection of a fire until the last person is out of harm’s way is 90 to 180 minutes, with variation on the size of the evacuation and the minutes required for each step.
The maximum timeframe is a very conservative estimate that may be reduced with law enforcement managing traffic flow and maximize efficiency by routing neighborhoods out the three available egress routes and then south, north, or west, as appropriate. Up to three hours for complete evacuation is not considered unusual and would be accommodated during large, wind driven wildfires from the east. Wildfires originating closer to the community would allow significantly less time for evacuation, and Safari Highlands Ranch offers decision makers with contingency options, including evacuating or relocating a portion of the community (much lower number of vehicles and faster evacuation time, proportional to the vehicle total being moved).
9.5 Safari Highlands Ranch Resident Fire/Evacuation Awareness The Safari Highlands Ranch Community HOA will be active in its outreach to residents regarding fire safety and general evacuation procedures. There are aspects of fire safety and evacuation that require a significant level of awareness by the residents and emergency services in order to reduce and/or avoid problems with an effective evacuation. Mitigating potential impediments to successful evacuations requires focused and repeated information through a strong educational outreach program. The Safari Highlands Ranch HOA will engage residents and coordinate with local fire agencies for fire safety awareness through a variety of methods.
This FPP and evacuation plan will be provided to each homeowner/HOA member as well as being accessible on the HOA Website. Annual reminder notices will be provided to each homeowner encouraging them to review the plan and be familiar with community evacuation protocols. The HOA will work with local fire agencies to hold an annual fire safety and evacuation preparedness informational meeting. The meeting will be attended by representatives of the fire agencies and important fire and evacuation information reviewed. One focus of these meetings and of the HOA’s annual message will be on the importance of each resident to prepare and be familiar with their own “Ready, Set, Go!” evacuation plan. The “Ready, Set, Go!” program is defined at: http://wildlandfirersg.org/ and information about preparing an individual Action Plan is provided in Appendix H.
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Figure 8 Evacuation Component Time Frame Estimates
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INTENTIONALLY LEFT BLANK
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The focus of the “Ready, Set, Go!” program is on public awareness and preparedness, especially for those living in the wildland-urban interface (WUI) areas. The program is designed to incorporate the local fire protection agency as part of the training and education process in order to insure that evacuation preparedness information is disseminated to those subject to the potential impact from a wildfire. There are three components to the program:
“READY” – Preparing for the Fire Threat: Take personal responsibility and prepare long before the threat of a wildfire so you and your home are ready when a wildfire occurs. Create defensible space by clearing brush away from your home as detailed in this FPP (Dudek 2015).
Use only fire-resistant landscaping and maintain the ignition resistance of your home. Assemble emergency supplies and belongings in a safe spot. Confirm you are registered for Reverse 911, AlertSanDiego, and Community Alert System. Make sure all residents residing within the home understand the plan, procedures and escape routes.
“SET” – Situational Awareness When a Fire Starts: If a wildfire occurs and there is potential for it to threaten Safari Highlands Ranch, pack your vehicle with your emergency items. Stay aware of the latest news from local media and your local fire department for updated information on the fire. If you are uncomfortable, leave the area.
“GO!” – Leave Early! Following your Action Plan provides you with knowledge of the situation and how you will approach evacuation. Leaving early, well before a wildfire is threatening your community, provides you with the least delay and results in a situation where, if a majority of neighbors also leave early, firefighters are now able to better maneuver, protect and defend structures, evacuate other residents who couldn’t leave early, and focus on citizen safety. “READY! SET! GO!” is predicated on the fact that being unprepared and attempting to flee an impending fire late (such as when the fire is physically close to the community) is dangerous and exacerbates an already confusing situation. This Safari Highlands Ranch Wildland Fire Evacuation Plan provides key information that can be integrated into the individual Action Plans, including the best available routes for them to use in the event of an emergency evacuation.
Situation awareness requires a reliable information source. One of the most effective public notification methods is Reverse 911. The San Diego County Office of Emergency Services operates the reverse 911 notification system that provides a recorded message over land line telephone systems relating to evacuation notices. In addition, the Office of Emergency Services operates a program known as “Alert San Diego” that has the capability to send emergency notifications over both land lines as well as to cell phones and via text messages. It is up to individual residents to register their cell phones for “Alert San Diego”. The registration of cell phones can be done on line at www.ReadySanDiego.com.
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In addition, Escondido provides a separate Community Notification System which allows people to register to receive email or text message notifications about urgent or other information, including events that may result in traffic delays or road closures. Anyone can subscribe at www.nixle.com and selecting “Residents” and “Sign up” This system is not affiliated with the San Diego County Reverse 9-1-1 system and is informational only. It will not be used to issue an evacuation order.
As part of the Safari Highlands Ranch resident fire awareness and evacuation readiness program, information will be delivered in a variety of methods. The HOA will be responsible to provide and distribute to each homeowner a complete copy of the project’s Fire Protection Plan and this Wildland Fire Evacuation Plan, including materials from the READY! SET! GO! Program. The HOA is also responsible for insuring the distribution of copies of the aforementioned materials to those individuals that purchase properties for re-sales and to the management of multi-family residential and other non-residential properties. The management of multi-family residential units that do not have individual unit ownership will be responsible for conducting informational sessions regarding the Fire Safety measures and Evacuation Plan details and will be responsible for making copies of the Evacuation Plans available for each unit. As with the multi-family residential properties, management of the commercial properties will be responsible for the dissemination of the Evacuation Plan information to their employees.
As part of the approval of this project, it shall be binding on the HOA to actively participate as a partner with the EFD, the SDFD, SDCFA, and the local FireSafe Council (Valley Center and/or Ramona West End Firesafe Councils) and to assist with the coordination and distribution of fire safety information they develop.
9.6 Safari Highlands Ranch Evacuation Procedures
It is estimated that the minimum amount of time needed to move the Safari Highlands Ranch population to urbanized and/or designated evacuation areas may require in excess of one hour to evacuate and up to two or more hours under varying constraints that may occur during an evacuation. This includes additional allowances for the time needed to detect and report a fire, for fire response and on-site intelligence, for Reverse 911 and in the field patrol cars announcing evacuations, and for notifying special needs citizens. Wolshon and Marchive (2007) simulated traffic flow conditions in the wildland urban interface (WUI) under a range of evacuation notice lead times and housing densities. To safely evacuate more people, they recommended that emergency managers (1) provide more lead time to evacuees and (2) control traffic levels during evacuations so that fewer vehicles are trying to exit at the same time.
Wildfire emergency response procedures will vary depending on the type of wildfire and the available time in which decision makers (Incident Command, EFD, SDFD, CAL FIRE, SDCFA, Fire Protection Plan
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SDSD, and/or County Office of Emergency Management) can assess the situation and determine the best course of action. Based on the community, it’s road network, and the related fire environment, the primary type of evacuation envisioned is an orderly, pre-planned evacuation process where people are evacuated from the Safari Highlands Ranch community to more urban areas further from an encroaching wildfire (likely to urban areas south and west) well before fire threatens. This type of evacuation must include a conservative approach to evacuating, i.e., when ignitions occur and weather is such that fires may spread rapidly, evacuations should be triggered on a conservative threshold that includes time allowances for unforeseen, but possible, events that would slow the evacuation process.
Evacuation is considered by many to offer the highest level of life protection to the public, but it can result in evacuees being placed in harm’s way if the time available for evacuation is insufficient (Cova et al. 2011). An example of this type of evacuation which is highly undesirable from a public safety perspective, is an evacuation that occurs when fire ignites close to vulnerable communities. Safari Highlands Ranch is not considered a vulnerable community, however there are vulnerable communities within the region. This type of situation is inherently dangerous because there is generally a higher threat to persons who are in a vehicle on a road when fire is burning in the immediate area than in a well-defended, ignition resistant home.
Conditions may become so poor, that the vehicle drives off the road or crashes into another vehicle, and flames and heat overcome the occupants. This scenario occurred in San Diego County during the 2003 Cedar Fire. Even though hundreds of thousands of people were successfully evacuated, a night time evacuation on Wildcat Canyon Road resulted in fatalities. A vehicle offers little shelter from a wildfire if the vehicle is situated near burning vegetation or catches fire itself. This type of evacuation must be considered a very undesirable situation by law and fire officials in all but the rarest situations where late evacuation may be safer than seeking temporary refuge in a structure (such as when there are no nearby structures, the structure(s) is/are already on fire, or when there is no other form of refuge).
The third potential type of evacuation is a hybrid of the first two. In cases where evacuation is in process and changing conditions result in a situation that is considered unsafe to continue evacuation, it may be advisable to direct evacuees to pre-planned temporary refuge locations, including their own home if it is ignition resistant and defensible, such as those at Safari Highlands Ranch. As with the second type of evacuation discussed above, this situation is considered highly undesirable, but the evacuation pre-planning must consider these potential scenarios and prepare decision makers at the IC level and at the field level for enacting a contingency to evacuation when conditions dictate.
Indications from past fires and related evacuations, in San Diego County and throughout Southern California, which have experienced increasingly more frequent and larger fires, are that Fire Protection Plan
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evacuations are largely successful, even with a generally unprepared populace. It then stands to reason that an informed and prepared populace would minimize the potential evacuation issues and related risk to levels considered acceptable from a community perspective.
Evacuation orders or notifications are often triggered established and pre-determined model buffers which are based on topography, fuel, moisture content of the fuels and wind direction.
Evacuations are initiated when a wildfire reaches or crosses one of these pre-determined buffers.
Evacuations can also be very fluid. The incident command, law enforcement and County OES would jointly enact evacuations based on fire behavior.
9.6.1 Safari Highlands Ranch Evacuation – Santa Ana Wind Conditions When compared to fire spread modeling and the time various fire ignitions would require to reach the project, a threshold of evacuation vs contingency options is delineated. As depicted in Appendices C-1 and C-5, which illustrate fire spread rates and progression during extreme fire weather (high wind, low humidity) and an ignition off the SR-76, approximately 15 miles north and east of the Safari Highlands Ranch, fire could reach the northeastern extents of the project (est. 5% of project) within 4 hours. Within 5 hours, wildfire may reach approximately 90 to 95% of the project site. These estimates are based on current conditions and would be different post project development, which would include landscapes that would not burn consistently with wildland fuels. Fire would be expected to burn around the developed areas and fuel modification zones with a slower spread rate and patchy burn with lower flame lengths and intensity.
Because the arrival time of a fire originating along the SR-76 is just under 4 hours for the northern portion of the project, and considering it may take up to 2 hours or more (depending on conditions) for a complete evacuation of all Safari Highlands Ranch residents, it is recommended that under extreme conditions, if a fire ignites along the SR-76 between Rincon and Santa Ysabel, that evacuation of the northern neighborhoods of Safari Highlands Ranch begin as quickly as possible and utilize the northern emergency egress route and the main entrance on Rockwood Road. This will enable time to move northerly residents out of the area to designated evacuation points (likely within Escondido) since this would require the movement of, at max, approximately 500 vehicles, which can be accommodated in 30 minutes to 1 hour, providing a time buffer in this conservative approach. Evacuation of the community should continue, as conditions allow and are necessitated, with the southerly neighborhoods evacuating to off-site areas in Escondido. However, if at any time fire is anticipated to threaten evacuation routes, incident managers should evaluate evacuation contingencies, including moving people to the Village Core, nearby San Pasqual Union Elementary School, or Eagle Crest Golf Course, San Diego Safari Park or temporarily refuging some or all remaining residents in their homes for the short duration that active wildfire would burn adjacent the site’s FMZs. Fire ignitions closer to Fire Protection Plan
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the Safari Highlands Ranch will likely include a shorter available timeframe for evacuations, so contingency options may be implemented on a faster timeline.
9.6.2 Safari Highlands Ranch Evacuation – Typical Summer Weather Conditions As depicted in Appendices C-2 and C-6, which illustrate fire spread rates and progression during typical Summer weather conditions (on-shore winds and average humidity) and an ignition off Wild Oak Lane approximately 1/2 mile from the northwestern project boundary, fire could reach the western boundary (est. 5% of project) within approximately 40 minutes. Within 2 hours, wildfire may reach approximately 30% of the project, all in the northern half of the property, and within 5 hours, fire may reach up to 70% of the project site. An ignition under the same weather conditions occurring off SR-78 near its intersection with Cloverdale Road would include slower fire spread due to the developed/maintained landscapes that occur in the area. Fire may not reach the project site until approximately 3 hours after ignition. After 5 hours, less than 10% of the project site is reached, all in the extreme southern and southwestern portions of the Project.
These estimates are based on current conditions and would be different for the post project development, which would include landscapes that would not burn consistently with wildland fuels. Fire would be expected to burn around the developed areas and fuel modification zones with a slower spread rate and patchy burn with even lower flame lengths and intensity.
Because the arrival time of a fire originating to the south or west of the project during typical, Summer conditions is just under 1 hour for the Wild Oak Lane scenario and approximately 3 hours for the Cloverdale Road scenario, and considering it may take up to 2 hours or more (depending on conditions) for a complete evacuation of all Safari Highlands Ranch residents – and they would be evacuating into the path of the fire, the following recommendations are considered:
1. Because a fire igniting to the north of Eagle Creek Golf Club is likely to burn toward the project and largely affect the northern half of the project, internal project relocation of the northerly neighborhoods to the Village Core or off-site to the south (not using the northern emergency secondary access road), may be considered as options. Depending on fire spread and control, the southern portion of Safari Highlands Ranch may not need to be evacuated.
This type of fire is not wind-driven and is burning in fuels with higher moisture levels, and will allow more options than a fire during high winds and low humidity.
2. Fire igniting at the SR-76 and Cloverdale Road would burn toward the project’s southern boundaries, and would likely require an immediate temporary refuge of residents on site at both the Eagle Creek Golf Course Community and Safari Highlands Ranch, as the primary evacuation route would be into the fire. Once the fire moved east and north, Eagle Crest Golf Course Community could be evacuated while Safari Highlands Ranch Fire Protection Plan
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would likely continue to refuge on site. Evacuation of Safari Highland Ranch to the South along Zoo Road would be possible for a period of up to 2 hours from ignition, so it may be possible to relocate a large number of persons via this route. It would not be recommended to utilize the northern emergency secondary access route in this scenario since it would require crossing through a fuel bed with the possibility of spot fires ahead of the main fire front.
9.6.3 Safari Highlands Ranch Evacuation Baseline
For purposes of this Evacuation Plan, the first and most logical choice for all of the residents and guests within the boundaries of the Safari Highlands Ranch Community is to adhere to the principals and practices of the “READY! SET! GO!” Program previously mentioned in this document. As part of this program, it is imperative that each resident develop a plan that is clearly understood by all family members and attends the educational and training programs sponsored by the Safari Highlands Ranch HOA and the local fire agencies. In addition, it is imperative that the “READY! SET! GO!” Program information is reviewed on a routine basis along with the accompanying maps illustrating evacuation routes, temporary evacuation points and pre-identified evacuation points. It must be kept in mind that conditions may arise that will dictate a different evacuation route than the normal roads used on a daily basis.
Residents are urged to evacuate as soon as they are notified to do so or earlier if they feel uncomfortable. Directions on evacuation routes will be provided in most cases, but when not provided, Safari Highlands Ranch residents will proceed according to known available routes away from the encroaching fire. Depending on the type of emergency and the resulting evacuation, it could take as long as two hours or more to complete a community-wide evacuation, based on nationally recognized road capacity standards and competing use of the roads by residents from other areas.
Note: this evacuation plan will require adjustment and continued coordination by the Safari Highlands Ranch HOA and/or developer and Fire/Law enforcement agencies during each of the construction phases. With each phase, the evacuation routes may be subject to changes with the addition of both primary and secondary evacuation routes.
9.6.4 Civilian and Firefighter Evacuation Contingency
As of this document’s preparation, no community in California has been directed to shelter in place during a wildland fire. Even the communities in Rancho Santa Fe, California which are designed and touted as shelter in place communities, were evacuated during the 2007 Witch Creek Fire. This is not to say that people have not successfully sheltered in place during wildfire, Fire Protection Plan
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where there are numerous examples of people sheltering in their homes, in hardened structures, in community buildings, in swimming pools, and in cleared or ignition resistant landscape open air areas. The preference will likely always be early evacuation following the “Ready, Set, Go!” model, but there exists the potential for unforeseen civilian evacuation issues, and having a contingency plan will provide direction in these situations that may result in saved lives.
Potential problems during wildfire evacuation from Safari Highlands Ranch include:
Fires that prevent safe passage along planned evacuation routes Inadequate time to safely evacuate
Fire evacuations during rush hour traffic or when large events are occurring Blocked traffic due to accidents or fallen tree(s) or power pole(s) The need to move individuals who are unable to evacuate It is recommended that a concerted pre-planning effort focus on evacuation contingency planning for civilian populations when it is considered safer to temporary seek a safer refuge than evacuation.
9.6.4.1 Safety Zones
The International Fire Service Training Association (IFTSA; Fundamentals of Wildland Fire Fighting, 3rd Edition) defines Safety Zones as areas mostly devoid of fuel, which are large enough to assure that flames and/or dangerous levels of radiant heat will not reach the firefighting personnel occupying them. Areas of bare ground, burned over areas, paved areas, and bodies of water can all be used as safety zones. The size of the area needed for a safety zone is determined by fuel types, its location on slopes and its relation to topographic features (chutes and saddles) as well as observed fire behavior. Safety zones should never be located in topographic saddles, chutes or gullies. High winds, steep slopes or heavy fuel loads may increase the area needed for a Safety Zone.
The National Wildland Fire Coordinating Groups (NWFCG), Glossary of Wildland Fire Terminology provides the following definitions for Safety Zone and Escape routes Safety Zone. An area cleared of flammable materials used for escape in the event the line is outflanked or in case a spot fire causes fuels outside the control line to render the line unsafe. In firing operations, crews progress so as to maintain a safety zone close at hand allowing the fuels inside the control line to be consumed before going ahead. Safety zones may also be constructed as integral parts of fuelbreaks; they are greatly enlarged areas which can be used with relative safety by firefighters and their equipment in the event of blowup in the vicinity.
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According to NWFCG, Safety Zone(s):
Must be survivable without a fire shelter
Can include moving back into a clean burn
May take advantage of natural features (rock areas, water, meadows) Can include Constructed sites (clear-cuts, roads, helispots) Are scouted for size and hazards
Consider the topographic location (larger if upslope) Should be larger if downwind
Should not include heavy fuels
May need to be adjusted based on site specific fire behavior The definition for a safety zone includes provisions for separation distance between the properly equipped and trained firefighter and the flames of at least four times the maximum continuous flame height. Distance separation is the radius from the center of the safety zone to the nearest fuels. For example, considering worst case 70 foot tall flame lengths that may be possible adjacent this site, then a 280 foot separation would be required, and more if there were any sitespecific features that would result in more aggressive fire behavior. In order to provide 280 feet in all directions, a minimum 7.2 acres is considered necessary for a safety zone to be considered appropriate for one 3 person engine crew during an extreme weather fire.
If one considers the ignition resistant and maintained landscaping within each of the Safari Highlands Ranch neighborhoods, along with the adjacent fuel modification zones that vary between 150 and 200 feet wide, and Chapter 7A of California Building Code compliant structures, each neighborhood’s interior roads would provide Safety Zones available to responding firefighters.
Additionally, areas such as the San Pasqual Union Elementary School, the Eagle Crest Golf Community, and the Safari Park provide opportunities for safety zones. These areas and the Safari Highlands Ranch neighborhoods as Safety Zones can be part of EFD’s and County’s pre-planning efforts, although during the fire, the identified safety zones may not be feasible due to distance, location, fire behavior, etc.
Potential safety zones likely require additional focused study by EFD and other fire and law enforcement agencies.
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9.6.4.2 Temporary Firefighter Refuge Areas
Firescope California defines a contingency plan when it is not possible to retreat to a safety zone.
This contingency includes establishment of firefighter TRA(s), which are defined as:
A preplanned area where firefighters can immediately take refuge for temporary shelter and short-term relief without using a fire shelter in the event that emergency egress to an established Safety Zone is compromised.
Examples of a TRA may include the lee side of a structure, inside of a structure, large lawn or parking areas, or cab of apparatus, amongst others. Differences between a TRA and a Safety Zone is that TRA’s are closer to the immediate firefighting area, are considered a contingency to being able to get to a Safety Zone, do not include a requirement for a large area set back four times the flame lengths of adjacent fuels, and cannot be feasibly pre-planned until firefighters arrive on-scene and size up the situation.
Firescope appropriately notes that although Safety Zones and viable Escape Routes shall always be identified in the WUI environment, they may not be immediately available should the fire behavior increase unexpectedly. Often a TRA is more accessible in the WUI environment. A TRA will provide temporary shelter and short-term relief from an approaching fire without the use of a fire shelter and allow the responders to develop an alternate plan to safely survive the increase in fire behavior.
TRAs are pre-planned areas (planned shortly after firefighters arrive on scene) where firefighters may take refuge and temporary shelter for short-term thermal relief, without using a fire shelter in the event that escape routes to an established safety zone are compromised. The major difference between a TRA and a safety zone is that a TRA requires another planned tactical action, i.e., TRAs cannot be considered the final action, but must include self-defense and a move out of the area when the fire threat subsides. A TRA should be available and identified on site at a defended structure. TRAs are NOT a substitute for a Safety Zone. TRA pre-planning is difficult, at best because they are very site and fire behavior specific. For the Safari Highland Ranch Community, TRAs would likely include navigating into any of the neighborhoods where 150 to 200 feet wide fuel modification zones provide defensible space and maintained landscapes are provided, along with ignition resistant residences and wide roads that offer numerous opportunities for TRA.
The entire developed portions of the Safari Highlands Ranch community, but especially the interior areas of neighborhoods, are considered TRAs. This is an important concept because it offers last-resort, temporary refuge of firefighters, and in a worst-case condition, residents. This approach would be consistent with Firescope California (2013) which indicates that firefighters Fire Protection Plan
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must determine if a safe evacuation is appropriate and if not, to identify safe refuge for those who cannot be evacuated, including civilians.
Each of the site’s residences that can be considered for TRA includes the following features:
Ignition Resistant Construction
150 to 200 feet wide Fuel Modification Zones around perimeter of project Annual inspections by 3rd party fuel modification zone inspectors Wide roadways with fire hydrants
Maintained landscapes and roadside fuel modification
Ember resistant vents
Interior fire sprinklers
Because there is the possibility that evacuation of the project may be less safe than temporarily refuging on-site, such as during a fast-moving, wind driven fire that ignites nearby, including temporary refuge within residences, at the Village Core, or elsewhere on site is considered a contingency plan for Safari Highlands Ranch. This concept is considered a component of the “Ready, Set, Go!” model as it provides a broader level of “readiness” should the ability to execute an early evacuation be negated by fire, road congestion, or other unforeseen issues. Note:
this approach would be considered a last-resort contingency during wildfire with the primary focus being on early evacuation.
9.7 Evacuation Plan Limitations
This Wildland Fire Evacuation Plan has been developed based on wildfire and evacuation standards and the San Diego County Evacuation Annex (San Diego County 2014) and is specifically intended as a guide for evacuations for the Safari Highlands Ranch Community. This plan provides basic evacuation information that will familiarize residents with standard evacuation preparedness protocols as well as travel route options that may be available to them during an emergency. However, because emergencies requiring evacuation have many variables and must be evaluated on a case by case basis, this plan shall be subservient to real-time law enforcement and fire personnel/ agencies’ decision making and direction during an emergency requiring evacuation.
This Evacuation Plan promotes the “Ready, Set, Go!” model, adopted by the State of California and many fire agencies statewide, including EFD. The goal is to raise agency and citizen awareness of potential evacuation issues and get a majority of the public “Ready” by Fire Protection Plan
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taking a proactive stance on preparedness, training drills, and visitor education, and evacuation planning efforts. The Safari Highlands Ranch populace will be “Set” by closely monitoring the situation whenever fire weather occurs and/or when wildland fire occurs, and elevating preplanned protocol activities and situation awareness. Lastly, officials will implement the plan and mandate that populations “Go” by executing pre-planned evacuation procedures in a conservative manner, i.e., evacuation will occur based on conservative decision points, as proposed in this evacuation plan or when directed by fire and law enforcement personnel, whichever is more conservative. The preferred alternative will always be early evacuation.
However, there may be instances when evacuation is not possible, is not considered safe, or is not an option based on changing conditions. For example, should a fire occur and make evacuation from the project ill advised, a contingency plan for residents will be available. This contingency would include moving people to pre-designated temporary refuge areas until it is safe to evacuate or the threat has been mitigated.
Ultimately, it is the intent of this Evacuation Plan to guide the implementation of evacuation procedure recommendations such that the process of evacuating people from the Safari Highlands Ranch project is facilitated in an efficient manner and according to a pre-defined evacuation protocol as well as providing a contingency option of temporarily refuging, if evacuation is considered less safe.
It is recommended that the evacuation process is carried out with a conservative approach to fire safety. This approach must include maintaining the Safari Highlands Ranch fuel modification landscape, infrastructural, and ignition resistant construction components according to the appropriate standards and embracing a “Ready, Set, Go!” stance on evacuation. Accordingly, evacuation of the wildfire areas should occur according to pre-established evacuation decision points, or as soon as they receive notice to evacuate, 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 wildland-urban interface to educate themselves on practices that will improve safety.
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10 HOMEOWNER’S ASSOCIATION WILDFIRE
EDUCATION PROGRAM
The Safari Highlands Ranch HOA will provide on-going resident education outreach regarding wildfire safety, the “Ready, Set, Go!”4
pre-planning model, and this FPP's requirements for the entire master-planned development. The community building will include site-specific wildfire information including practices that will not be allowed due to fire risk. Informational handouts, facility Web-site page, mailers, fire safe council participation, inspections, and seasonal reminders are some methods that will be used to disseminate wildfire and relocation awareness information. The HOA will coordinate with EFD and other applicable fire agencies regarding wildfire educational material/programs before printing and distribution.
The Safari Highlands Ranch residents and visitors of commercial and property facilities will be provided homeowners informational brochures at point of sale regarding wildfire and this FPP's requirements. This educational information must include maintaining the landscape and structural components according to the appropriate standards and embracing a “Ready, Set, Go ” stance on evacuation. Of particular importance in this FPP is the guidance in the types of plants that are allowed or prohibited in landscaped areas and appropriate construction within vegetation management zones.
The Safari Highlands Ranch residents will be aware of this evacuation plan as the HOA will post it on its Website and provide reminders to residents on at least an annual basis. This educational outreach will result in a populace that understands the potential for evacuations and the routes and options that may be presented to them.
4 International Fire Chiefs Association “Ready, Set, Go” website link: http://wildlandfirersg.org/ Fire Protection Plan
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11 CONCLUSION
This FPP is submitted in support of an application for project entitlement of the Safari Highlands Ranch project. It is submitted in compliance with requirements of the EFD Fire Code. The requirements in this document meet or exceed fire safety, building design elements, fuel management/modification, and landscaping recommendations of the City or provide alternative measures that meet the intent of the code. Fire and Building Codes and other local, county, and state regulations in effect at the time of each building permit application supersede these recommendations unless the FPP recommendation is more restrictive.
Where the project does not strictly comply with the Code, for top of slope setback, alternative materials and methods have been proposed that provide functional equivalency as the code intent.
The information provided herein supports the ability of the proposed structures and FMZs to withstand the predicted short duration, low to moderate intensity wildfire and ember shower that would be expected from wildfire burning in the vicinity of the site or within the site’s landscape.
The recommendations provided in this FPP have been designed specifically for the proposed construction of structures adjacent the WUI zone at the Project site. The Proposed Project site’s fire protection system includes a redundant layering of protection methods that have been shown through post-fire damage assessments to reduce risk of structural ignition.
Modern infrastructure will be provided along with implementation of the latest ignition resistant construction methods and materials. Further, all structures are required to include interior sprinklers consistent with EFD requirements. Fuel modification that is up to twice the standard width requirement will occur throughout the project site. The FMZs will be maintained annually by the HOA and inspected by a 3rd party to certify that they meet the EFD standards.
Maintenance includes removing all dead and dying materials and maintaining appropriate horizontal and vertical spacing. In addition, plants that establish or are introduced to the fuel modification zone that are not on the approved plant list will be removed.
Ultimately, it is the intent of this FPP to guide, through code and other project specific requirements, the construction of structures that are defensible from wildfire and, in turn, do not represent significant threat of ignition source for the adjacent native habitat. It must be noted that during extreme fire conditions, there are no guarantees that a given structure will not burn.
Precautions and mitigating actions identified in this report are designed to reduce the likelihood that fire would impinge upon the proposed structures. There are no guarantees that fire will not occur in the area or that fire will not damage property or cause harm to persons or their property.
Implementation of the required enhanced construction features provided by the applicable codes and the mitigating fuel modification requirements provided in this FPP will accomplish the goal Fire Protection Plan
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of this FPP to assist firefighters in their efforts to defend these structures and reduce the risk associated with this project’s WUI location.
Although the proposed development and landscape will be significantly improved in terms of ignition resistance, it should not be considered a shelter-in-place community. It is recommended that the homeowners or other occupants who may use the facilities at the Safari Highlands Ranch adopt 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. Accordingly, occupants and visitors should evacuate the area as soon as they receive notice to evacuate, or sooner, if they feel threatened by wildfire. Fire is a dynamic and somewhat unpredictable occurrence and it is important for residents to educate themselves on practices that will improve their personal safety.
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Althouse and Meade, Inc. 2016. Biological Technical Report for Safari Highlands Ranch, San Diego County, California. January 2016.
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, Utah.
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Butler, B.W., J. Cohen, D.J. Latham, R.D. Schuette, P. Spoko, K.S. Shannon, D. Jimenez, and L.S. Bradshaw. 2004. Measurements of radiant emissive power and temperatures in crown fires. Canadian Journal of Forest Research. 34:1577–1587.
CAL FIRE. 2015. Fire and Resource Assessment Program. California Department of Forestry and Fire. Website access via http://frap.cdf.ca.gov/data/frapgismaps/select.asp?theme=5.
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, CA. Gen. Tech. Rep. PSW-GTR-158. Albany, California: Pacific Southwest Research Station, Forest Service, U.S. Department of Agriculture; 85-92 Cohen, J.D. 2000. Preventing disaster: home ignitability in the wildland-urban interface. Journal of Forestry 98(3): 15-21.
Cohen, J.D. and Butler, B.W. [In press]. 1996. Modeling potential ignitions from flame radiation exposure with implications for wildland/urban interface fire management. In: Proceedings of the 13th conference on fire and forest meteorology. October 27-31; Lorne, Victoria, Australia. Fairfield, Washington: International Association of Wildland Fire.
Cohen, J.D. and Saveland, J. 1997. Structure Ignition Assessment Can Help Reduce Fire Damages in the W-UI. Fire Management Notes 57(4): 19-23.
Cohen, Jack and Steve Quarles. 2011. Structure Ignition Assessment Model; The Origins and Basis of SIAM. From presentation at the 2011 NFPA Wildland Fire - Backyard and Beyond Conference in October 2011.
County of San Diego 2010. County of San Diego Report Format and Content Requirements – Wildland Fire and Fire Protection (August 31, 2010). On-line at:
http://www.sandiegocounty.gov/dplu/docs/Fire-Guidelines.pdf Cova, T.J., Dennison, P.E., Drews, F.A. (2011) Modeling evacuate versus shelter-in-place decisions in wildfires. Sustainability, 3(10): 1662-1687. Published, 09/30/2011. http://www.mdpi.com/2071-1050/3/10/1662/
DWR (California Department of Water Resources). 2016. Website at http://cdec.water.ca.gov/ staInfo.html. Accessed website April 2016.
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Finney, M.A. 1998. FARSITE: Fire Area Simulator—model development and evaluation. Res.
Pap. RMRS-RP-4, Ogden, Utah: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 47 p.
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Conference Proceedings. 28-30 March 2006; Portland, OR. Proceedings RMRS-P-41.
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Foote, Ethan I.D.; Gilless, J. Keith. 1996. Structural survival. In: Slaughter, Rodney, ed.
California's I-zone. Sacramento, California: CFESTES; 112-121.
Grabner, K., J. Dwyer, and B. Cutter. 1994. “Validation of Behave Fire Behavior Predictions in Oak Savannas Using Five Fuel Models.” Proceedings from 11th Central Hardwood Forest Conference. 14 p.
Grabner, K.W. 1996. “Validation of BEHAVE fire behavior predictions in established oak savannas.” M.S. thesis. University of Missouri, Columbia.
Grabner, K.W., J.P. Dwyer, and B.E. Cutter. 2001. “Fuel model selection for BEHAVE in midwestern oak savannas.” Northern Journal of Applied Forestry. 18: 74–80.
Grijalva, R., R. Moore, and H. Renteria. 2008. California Fire Siege 2007: An Overview. California Department of Forestry and Fire Protection. http://www.fire.ca.gov/fire_protection/ downloads/ siege/2007/Overview_CompleteFinal.pdf
Howard, Ronald A.; North, D. Warner; Offensend, Fred L.; Smart, Charles N. 1973. Decision analysis of fire protection strategy for the Santa Monica mountains: an initial assessment.
Menlo Park, CA: Stanford Research Institute. 159 p.
Hunter, Cliff. 2007. Personal communication with Rancho Santa Fe Fire Protection District Fire Marshal following after-fire loss assessments.
Institute for Business and Home Safety (IBHS). 2008. Megafires: The Case for Mitigation. 48 pp.
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Lawson, B.D. 1972. Fire spread in lodgepole pine stands. Missoula, MT: University of Montana. 110 p. thesis.
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 W.R. Catchpole. 1995. Fire behaviour modelling in Tasmanian buttongrass moorlands. II. Fire behaviour. International Journal of Wildland Fire.
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McAlpine, R.S. and G. Xanthopoulos. 1989. Predicted vs. observed fire spread rates in Ponderosa pine fuel beds: a test of American and Canadian systems. In Proceedings 10th conference on fire and forest meteorology, April 17–21, 1989. Ottawa, Ontario. pp. 287–294.
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Quarles, Stephen, Yana Valachovic, Gary Nakamura, Glenn Nader, and Michael De Lasaux. 2010. Home Survival in Wildfire Prone Areas – Building Materials and Design Considerations. 22 pp.
Rothermel, R.C. 1983. How to Predict the Spread and Intensity of Forest and Range Fires. USDA Forest Service Gen. Tech. Report INT-143. Intermountain Forest and Range Experiment, Ogden, Utah.
Rothermel, R.C., and G.C. Rinehart. 1983. “Field procedures for verification and adjustment of fire behavior predictions.” Res. Pap. INT-142. Ogden, UT: U.S. Department of Agriculture, Forest Service, Intermountain Forest and Range Experiment Station. 25 p.
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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-GTR153. Fort Collins, Colorado: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 72 p.
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Wolshon B. and Marchive E. 2007. Planning in the Urban Wildland Interface; Moving Residential Subdivision Traffic During Wildfires. ASCE J. Urban Plann. Dev. – Special Emergency Transportation Issue. 133(1) 73-81.
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13 LIST OF PREPARERS
Michael Huff
Principal/Sr. Fire Protection Planner/Project Manager
Urban Forestry and Fire Protection Planning
Scott Eckardt
Sr. Fire Protection Planner/Fire Behavior Modeling
Urban Forestry and Fire Protection Planning
Michael Scott
Fire Protection Planner/Fire Behavior Modeling
Urban Forestry and Fire Protection Planning
Christopher LaCroix
Fire Protection Planner
Urban Forestry and Fire Protection Planning
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APPENDIX A
Representative Photographs
Appendix A
Representative Photographs
Safari Highlands Ranch
Photograph #1. Photograph #2.
Photograph #3. Photograph #4.
Photographs were taken on March 10, 2016
Photograph #5. Photograph #6.
Photograph #7. Photograph #8.
Photographs were taken on March 10, 2016
Photograph #9. Photograph #10.
Photograph #11. Photograph #12.
Photographs were taken on March 10, 2016
Photograph #13. Photograph #14.
Photograph #15. Photograph #16.
Photographs were taken on March 10, 2016
Photograph #17. Photograph #18.
Photograph #19. Photograph #20.
Photographs were taken on March 10, 2016
Photograph #21. Photograph #22.
Photograph #23. Photograph #24.
Photographs were taken on March 10, 2016
Photograph #25. Photograph #26.
Photograph #27. Photograph #28.
Photographs were taken on March 10, 2016
Photograph #29. Photograph #30.
Photograph #31. Photograph #32.
Photographs were taken on March 07, 2014
Photograph #33. Photograph #34.
Photograph #35. Photograph #36.
Photographs were taken on March 07, 2014
Photograph #37. Photograph #38.
Photograph #39. Photograph #40.
Photographs were taken on March 07, 2014
Photograph #41. Photograph #42.
Photograph #43. Photograph #44.
Photographs were taken on March 07, 2014
Photograph #45. Photograph #46.
Photograph #47. Photograph #48.
Photographs were taken on March 07, 2014
Photograph #50. Photograph #51.
Photograph #52. Photograph #53.
Photographs were taken on March 07, 2014
APPENDIX B
Fire History
APPENDIX B
Safari Highlands Ranch Vicinity Fire History
Safari Highlands Ranch Fire Protection Plan DRAFT/FINAL SOURCE: ESRI; Cal Fire 2014
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Miles
5-Mile Buffer
Project Boundary
Alarm Date
1910-1929
1930-1969
1970-1989
1990-1999
2000-2014
APPENDICES C-1
THROUGH C-6
Fire Progression Modeling
for Fall and Summer Conditions
APPENDIX C-1
FlamMap Fire Behavior Modeling - Fall Fire Arrival Time Safari Highlands Ranch Fire Protection Plan
SOURCE: LANDFIRE 2016; Dudek 2016
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Feet
Fire Progression (hours)
0 - 1
1 - 2
2 - 3
3 - 4
4 - 5
Ignition Location
Project Boundary
APPENDIX C-1
APPENDIX C-2
FlamMap Fire Behavior Modeling - Summer Fire Arrival Time Safari Highlands Ranch Fire Protection Plan
SOURCE: LANDFIRE 2016; Dudek 2016
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Feet
Fire Progression (hours)
0 - 1
1 - 2
2 - 3
3 - 4
4 - 5
Ignition Locations
Project Boundary
APPENDIX C-2
APPENDIX C-3
FlamMap Fire Behavior Modeling - Fall Fire Flame Length Safari Highlands Ranch Fire Protection Plan
SOURCE: LANDFIRE 2016; Dudek 2016
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Feet
Flame Length
Feet
n/a
0 - 4
4 - 8
8 - 11
11 - 20
20+
Project Boundary
Half Mile Buffer from Project Boundary
APPENDIX C-3
APPENDIX C-4
FlamMap Fire Behavior Modeling - Fall Fire Rate of Spread Safari Highlands Ranch Fire Protection Plan
SOURCE: LANDFIRE 2016; Dudek 2016
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Feet
Fire Rate of Spread
Feet/minute
0 - 100
100 - 200
200 - 300
300 - 400
400+
Project Boundary
Half Mile Buffer from Project Boundary
APPENDIX C-4
Note: 88 feet/minute = 1 mile per hour
APPENDIX C-5
FARSITE Fire Behavior Modeling - Fall Fire Arrival Time Safari Highlands Ranch Fire Protection Plan
SOURCE: LANDFIRE 2016; Dudek 2016
Date: 10/18/2016 - Last saved by: seckardt - Path: Z:\Projects\j830401\MAPDOC\DOCUMENT\FPP Figs\Appendix C-5 FARSITE_Fall.mxd 0 4,000 8,000
Feet
Fire Progression (hours)
0 - 1
1 - 2
2 - 3
3 - 4
4 - 5
5+
Ignition Location
Project Boundary
APPENDIX C-5
APPENDIX C-6
FARSITE Fire Behavior Modeling - Summer Fire Arrival Time Safari Highlands Ranch Fire Protection Plan
SOURCE: LANDFIRE 2016; Dudek 2016
Date: 10/17/2016 - Last saved by: seckardt - Path: Z:\Projects\j830401\MAPDOC\DOCUMENT\FPP Figs\Appendix C-6 FARSITE_Summer.mxd 0 2,000 4,000
Feet
Fire Progression (hours)
0 - 1
1 - 2
2 - 3
3 - 4
4 - 5
5+
Ignition Locations
Project Boundary
APPENDIX C-6
APPENDIX D
Fuel Modification Zones and Landscape Walls
Potential Fire Wall
Safari Highlands Boundary
Fuel Modification
Zone 1 (Irrigated)
Zone 2 (Thinned)
Manufactured Slope Zone 1 (Irrigated)
Manufactured Slope Zone 2 (Thinned)
Roadside Zone (20 Ft) (Irrigated)
Roadside Zone (50 Ft) (Irrigated)
WQ Basin (Thinned)
Access Road
Safari Highlands Ranch
Fuel Modification Zones 04 200 00 800
Feet
Date: 4/25/2017
APPENDIX D
APPENDIX E
Prohibited Plant List
Appendix E
Examples of Prohibited Plants
List prepared by Dudek and Hunt Research Corporation; 12-10-07 www.Dudek.com./ www.huntresearch.com 1
Botanical Name Common Name Comment*
Trees
Abies species Fir F
Acacia species (numerous) Acacia F, I
Agonis juniperina Juniper Myrtle F
Araucaria species (A.
heterophylla, A. araucana, A.
bidwillii)
Araucaria (Norfolk Island Pine,
Monkey Puzzle Tree, Bunya
Bunya)
F
Callistemon species (C.
citrinus, C. rosea, C.
viminalis)
Bottlebrush (Lemon, Rose,
Weeping)
F
Calocedrus decurrens Incense Cedar F
Casuarina cunninghamiana River She-Oak F
Cedrus species (C. atlantica,
C. deodara)
Cedar (Atlas, Deodar) F
Chamaecyparis species
(numerous)
False Cypress F
Cinnamomum camphora Camphor 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
Larix species (L. decidua, L.
occidentalis, L. kaempferi)
Larch (European, Japanese,
Western)
F
Leptospermum species (L.
laevigatum, L. petersonii)
Tea Tree (Australian, Tea) F
Lithocarpus densiflorus Tan Oak F
Melaleuca species (M.
linariifolia, M. nesophila, M.
quinquenervia)
Melaleuca (Flaxleaf, Pink,
Cajeput Tree)
F, I
Olea europea Olive I
Picea (numerous) Spruce F
Palm species (numerous) Palm F, I
Pinus species (P. brutia, P.
canariensis, P. b. eldarica, P.
Pine (Calabrian, Canary Island,
Mondell, Aleppo, Italian Stone,
F
Appendix E
Examples of Prohibited Plants
2 Botanical Name Common Name Comment*
halepensis, P. pinea, P.
radiata, numerous others)
Monterey)
Platycladus orientalis Oriental arborvitae F
Podocarpus species (P.
gracilior, P. macrophyllus, P.
latifolius)
Fern Pine (Fern, Yew,
Podocarpus)
F
Pseudotsuga menziesii Douglas Fir F
Schinus species (S. molle, S.
terebenthifolius)
Pepper (California and Brazilian) F, I
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
Tsuga species (T.
heterophylla, T. mertensiana)
Hemlock (Western, Mountain) 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
Arbutus menziesii Madrone F
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
Appendix E
Examples of Prohibited Plants
3 Botanical Name Common Name Comment*
Brassica species (B.
campestris, B. nigra, B. rapa)
Mustard (Field, Black, Yellow) F, I
Bromus rubens Foxtail, Red brome F, I
Castanopsis chrysophylla Giant Chinquapin F
Cardaria draba Hoary Cress I
Carpobrotus species Ice Plant, Hottentot Fig 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
Dodonaea viscosa Hopseed Bush F
Eriodictyon californicum Yerba Santa F
Eriogonum species (E.
fasciculatum)
Buckwheat (California) F
Fremontodendron species Flannel Bush F
Hedera species (H.
canariensis, H. helix)
Ivy (Algerian, English) I
Heterotheca grandiflora Telegraph Plant F
Hordeum leporinum Wild barley F, I
Juniperus species Juniper F
Lactuca serriola Prickly Lettuce I
Larix species (numerous) Larch F
Larrea tridentata Creosote bush F
Lolium multiflorum Ryegrass F, I
Lonicera japonica Japanese Honeysuckle F
Mahonia species Mahonia 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. Sumac (Poison oak, Laurel, Pink F Appendix E
Examples of Prohibited Plants
4 Botanical Name Common Name Comment*
laurina, R. lentii) Flowering)
Ricinus communis Castor Bean F, I
Rhus Lentii Pink Flowering Sumac F
Rosmarinus species Rosemary 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
Vinca major Periwinkle I
*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 Vegetation Management Zones and elsewhere in this development shall be subject to approval of the Fire Marshal.
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.
APPENDIX F
Proposed Project Plant Palette
EVERGREEN/DECID. SCREEN TREE
EVERGREEN FLOWERING GROUND COVER
EVERGREEN FLOWERING VINE
EVERGREEN SCREENING SHRUB
BOTANICAL NAME
CANDIDATE PLANT MATERIAL- STREETSCAPES,
STREET TREES AND STREET ACCENT TREES
EVERGREEN FLOWERING/ACCENT SHRUBS OR SUCCULENTS
MELALEUCA QUINQUENERVIA
LYONOTHAMNUS FLORIBUNDUS SSP
ASPLENIIFOLIUS
HYMENOSPORUM FLAVUM TRISTANIA
CONFERTA
POPULUS NIGRA ITALICA
PLATANUS RACEMOSA
PLATANUS ACERFOLIA
CUPRESSUS SEMPRIVIRENS
LIGUSTRUM LUCIDUM
FICUS SPP.
AFROCARPUS GRACILIAR
TIPUANA TIPU
METROSIDEROS EXCELSUS
POPULUS NIGRA ITALICA
ULMUS PARVIFOLIA
LIQUIDAMBER STYRACIFLUA 'PALO ALTO'
OLEA EUROPAEA
MAGNOLIA GRANDIFLORA
ARBUTUS 'MARINA'
ALNUS RHOMBILIFOLIA
PLATANUS RACEMOSA
PLATANUS ACERFOLIA
QUERCUS ILEX
QUERCUS AGRIFOLIA
QUERCUS ENGELMANIA
PYRUS 'BRADFORDI
TRISTANIA CONFERTA
FICUS SPP.
AFROCARPUS GRACILIAR
PARKS, ENTRIES,
SALIX SPP.
CERCIDIUM HYBRID ‘DESERT MUSEUM’
POPULUS SPP.
MANZANITA SPP.
TABEBUIA IMPETIGINOSA
GEIJERA PARVIFOLIA
LYONOTHAMNUS FLORIBUNDUS SSP
ASPLENIIFOLIUS
KOELREUTERIA BIPINNATA
PISTACHIA CHINENSIS
LAGERSTROEMIA INDICA
CITRUS SPP.
FRUIT SPP.
CERCIS CANADENSIS 'FOREST PANSY'
EVERGREEN VERTICAL ACCENT SHRUB
LEPTOSPERMUM LAEVIGATUM
MONARDELLA SUBGLABRA
CYATHEA COOPERI
DRACENA MARGINATA
ALOE BAINESII
HETEROMELES ARBUTIFOLIA
LEUCOPHYLUM SPP.
LEUCODENDRON SPP.
ELAEOCARPUS DECIPIENS
FREMONTODENDRON SPP
MAHONIA SPP
EUPHORBIA INGENS
MELALEUCA NESOPHILA
PITTOSPORUM TOBIRA 'VARIEGATA'
XYLOSMA CONGESTUM 'COMPACTA'
LIGUSTRUM JAPONICUM 'TEXANUM'
FIEJOA SELLOWIANA
EUGENIA UNIFLORA
RHAMNUS ILICIFOLIA
CARISSA MACROCARPA
GREWIA OCCIDENTALIS
FICUS NITIDA 'GREEN GEM'
BACCHARIS 'PIGEON POINT'
FESTUCA OVINA 'GLAUCA'
X GRAPTOVERIA
CRASSULA FALCATA
BOUGAINVILLEA SPP
SENECIO MANDRALISCAE
ECHEVERIA HYBRIDS
ARMERIA MARITIMA
ARTEMISIA 'POWIS CASTLE'
BERGENIA CRASSIFOLIA
SCAEVOLA 'MAUVE CLUSTERS'
AEONIUM 'PSEUDOTABULAEFORME'
CEANOTHUS GRISEUS HORIZONTALIS
GERANIUM SPP.
LANTANA SPP.
MYOPORUM PARVIFOLIUM
MYOPORUM PACIFICUM
AGAVE DESMETTIANA 'VARIEGATA'
AGAVE ATTENUATA
AGAVE SPP.
ALOE ARBORESCENS
ALOE SPP.
AGAPANTHUS AFRICANUS
ARMERIA MARITIMA
ABELIA GRANDIFLORA
AEONIUM ARBORIUM
ANIGOZANTHOS SPP.
BRUGMANSIA SANGUINEA
BUXUS MICROPHYLLA JAPONICA
CALLISTEMON 'LITTLE JOHN'
CAREX SPP.
COTANEASTER PARNEYII
&($127+86¶-2<&(&28/7(5·
CHAMELAUCIUM UNCINATUM
CISTUS PURPUREUS
COLEONEMA PULCHRUM
CRASSULA FALCATA
DIANELLA SPP.
DIPLACUS SPP.
DODENEA VISCOSA
ECHIUM FASTUOSUM
ESCALLONIA FRADESII
EUONYMUS SPP.
EUPHORBIA SPP.
FOUQUIERIA SPLENDENS
GAILLARDIA X GRANDIFLORA
GAURA LINDHEIMERI
GREVILLEA SPP.
GREWIA OCCIDENTALIS
HETEROMELES ARBUTIFOLIA
HESPERALOE PARVIFLORA
HEMEROCALLIS HYBRIDS
KALANCHIE BLOSSFELDIANA
GREWIA OCCIDENTALIS
CAMPSIS RADICANS
CLYTOSTOMA CALLISTEGIOIDES
PARTHENOCISSUS TRICUSPIDATA
MACFADYENA UNGUIS-CATI
CALLIANDRA INAEQUILATERA
DISTICTIS SPP.
PYROSTEGIA VENUSTA
ROSA SPP.
TRACHELOSPERMUM JASMINIODES
WISTERIA SINENSIS
DIETES VEGETA
ECHINOCACTUS GRUSONII
THYMUS PRAECOX ARCTICUS
'REITER'S'
TRACHELOSPERMUM JASMINOIDES
PELARGONIUM SPP.
HEUCHERA SANGUINEA
OSTEOSPERMUM SPP.
GAZANIA SPP.
LIRIOPE MUSCARI 'LILAC BEAUTY'
CAREX SPP.
COMMON AREAS
LANTANA SPP.
LAVANDULA SPP.
LAVATERA MARITIMA
LEPTOSPERMUM SPP.
LEUCOPHYLLUM FRUTESCENS
MELALEUCA NESOPHYLA
MYRTUS COMMUNIS 'COMPACTA'
NANDINA DOMESTICA
OPUNTIA ROBUSTA
POLYGALA X DALMAISIANA
PHORMIUM SPP.
PROTEA CYNAROIDES
PHOTINIA FRASERI
PRUNUS LYONII
5+$3+,2/(3,6¶0$-(67,&%($87<·
RHAMNUS CALIFORNICA
RUSSELIA EQUISETIFORMIS
ROMNEYA COULTERI
RHODODENDRON SPP.
ROSMARINUS SPP.
ROSA SPP.
RHUS INTEGRIFOLIA
RUSSELIA EQUISETIFORMIS
SANTOLINA VIRENS
SALVIA GREGII
SALVIA LEUCOPHYLLA
WESTRINGIA FRUTICOSA
YUCCA SPP.
RIBES SPP.
IVA HAYESIANA
CANDIDATE PLANT MATERIAL- INTERIOR SLOPES (NOT NATIVE ADJACENT)
TRANSITIONAL SLOPES AND/OR FUEL MODIFICATION (IRRIGATED)
SHRUBS AND GROUNDCOVERS
BERBERIS REPENS
CEANOTHUS SPP.
CARPENTARIA CALIFORNICA
COMAROSTAPHYLLIS DIVERSIFOLIA
GALVEZIA JUNCEA
GALVEZIA SPECIOSA
GARRYA ELLIPTICA
KECKIELLA CORDIFOLIA
RIBES SPECIOSUM
RIBES VIBURNIFOLIUM
ROSA CALIFORNIACA
HETEROMELES ARBUTIFOLIA
IVA HAYESIANA
PHILADELPHUS LEWISII
PRUNUS ILICIFOLIA
RHAMNUS CALIFORNICA
RHUS OVATA
SALVIA SPP.
TRICHOSTEMA LANATUM
VERBENA LILACINA
COAST LIVE OAK WOODLAND MIX
TREES
PLATNUS RACEMOSA
QUERCUS AGRIFOLIA
QUERCUS ENGELMANII
CERCIS OCCIDENTALLIS
ARBUTUS UNEDO
MANZINITA SPP
TRISTANIA CONFERTA
PERENNIALS
LUPINUS EXCUBITUS
MIMULUS AURANTIACUS
PENSTEMON EATONII
PENSTEMON HETEROPHYLLUS
ROMNEYA COULTERI
SALVIA SONOMENSIS
SALVIA SPATHACEA
SISYRINCHIUM BELLUM
SHRUBS AND GROUNDCOVERS
ABELIA GRANDIFLORA
ALOE SPP
AGAVE SPP
ACACIA SPP.
BOUGANVILLEA SPP.
CEANOTHUS SPP.
CARPENTARIA CALIFORNICA
COMAROSTAPHYLLIS DIVERSIFOLIA
CISTUS PURPUREUS
CISTUS SPP.
COPROSMA REPENS
COTONEASTER MICROPHYLLUS
COTONEASTER LACTEUS
DENDROMECON ARFORDII
ECHIUM FASTUOSUM
ELAEGNUS PUNGENS
GREVILLEA NOELLI
GREWIA OCCIDENTALIS
GARRYA ELLIPTICA
HETEROMELES ARBUTIFOLIA
IVA HAYESIANA
LANTANA SPP.
LAVENDULA SPP.
MELALEUCA NESOPHILA
NERIUM OLEANDER
PHOTINIA FRASERI
PRUNUS CAROLINIANA
PRUNUS ILICIFOLIA
RHAMNUS CALIFORNICA
ROSA SPP
RHUS OVATA
ROSA CALIFORNIACA
SALVIA SPP.
YUCCA SPP.
GENERAL SLOPE LANDSCAPES
TREES
PLATNUS RACEMOSA
QUERCUS AGRIFOLIA
QUERCUS ENGELMANII
CERCIS OCCIDENTALLIS
ARBUTUS UNEDO
MANZINITA SPP
TRISTANIA CONFERTA
POPULUS NIGRA ITALICA
LYONOTHAMNUS FLORIBUNDUS
SSP ASPLENIIFOLIUS
CALLISTEMON VIMINALIS
PERENNIALS/HYROSEED MIX
BROMUS MOLLIS
ENCELIA CALIFORNICA
ESCHSCHOLZIA CALIFORNICA
LOTUS SCOPARIUS
LUPINUS BICOLOR
LUPINUS SUCCULENTUS
MIMULUS PUNICEUS
MIMULUS AURANTIACUS
PENSTEMON EATONII
PENSTEMON HETEROPHYLLUS
PLANTAGO INSULARIS
SISYRINCHIUM BELLUM
EVERGREEN SCREENING SHRUB
PITTOSPORUM TOBIRA 'VARIEGATA'
XYLOSMA CONGESTUM 'COMPACTA'
LIGUSTRUM JAPONICUM 'TEXANUM'
FIEJOA SELLOWIANA
EUGENIA UNIFLORA
RHAMNUS ILICIFOLIA
CARISSA MACROCARPA
GREWIA OCCIDENTALIS
FICUS NITIDA 'GREEN GEM'
EVERGREEN FLOWERING VINE
GREWIA OCCIDENTALIS
CAMPSIS RADICANS
CLYTOSTOMA CALLISTEGIOIDES
PARTHENOCISSUS TRICUSPIDATA
MACFADYENA UNGUIS-CATI
CALLIANDRA INAEQUILATERA
DISTICTIS SPP.
PYROSTEGIA VENUSTA
ROSA SPP.
TRACHELOSPERMUM JASMINIODES
WISTERIA SINENSIS
CANDIDATE PLANT MATERIAL- SPECIFIC HABITAT REVEGETATION
CANDIDATE PLANT MATERIAL- ORCHARD TREES
CANDIDATE PLANT MATERIAL- DETENTION BASIN
CONTAINER PLANTS
HYDROSEED MIX
OPUNTIA LITTORALIS
OPUNTIA PROLIFERA
SAMBUCUS MEXICANA
CNEORIDIUM DUMOSUM
ENCELIA CALIFORNICA
ISOCOMA MENZIESII
ISOMERIS ARBOREA
KECKIELLA CORDIFOLIA
NASSELLA LEPIDA
SOLANUM XANTII
YUCCA WHIPPLEI
SOUTHERN CACTUS SCRUB COMMUNITY
ERIOPHYLLUM CONFERTIFLORUM
ESCHSCHOLZIA CALIFORNICA
GNAPHALIUM CALIFORNICUM
LUPINUS TRUNCATUS
PLAGIOBOTHRYUS NOTHOFULVUS
MIMULUS AURANTIACUS
NASSELLA LEPIDA
NASSELLA PULCHRA
PLANTAGO INSULARIS
SISYRINCHIUM BELLUM
CONTAINER PLANTS OR SEED MIX
HYDROSEED MIX
BACCHARIS GLUTINOSA
ROSA CALIFORNIACA
RUBUS URSINUS
SALIX HINDSIANA
ANEMOPSIS CALIFORNICA
ARTEMESIA DOUGLASIANA
ARTEMESIA PALMERII
ELYMUS CONDENSATUS
IVA HAYESIANA
JUNCUS ACUTUS
ORTHOCARPUS PURPURASCENS
PHACELIA CAMPANULARIA
WILLOW WOODLAND COMMUNITY
SEE ABOVE
AND/OR SELECT FUEL MOD ZONE 2 (NON-IRRIGATED)
TREES
POPULUS FREMONTII
SALIX GOODDINGOO
SALIX LAEVIGATA
SALIX LASIOLEPIS
PLATNUS RACEMOSA
QUERCUS AGRIFOLIA
CONTAINER PLANTS OR SEED MIX
HYDROSEED MIX
HETEROMELES ARBUTIFOLIA
BACCHARIS SAROTHROIDES
ENCILIA CALIFORNICA
ERIOPHYLLUM CONFERTIFLORUM
ESCHSCHOLZIA CALIFORNICA
FESTUCA MEGALURA
LOTUS SCO[RIUS
LUPINUS BICOLOR
LUPINUS SUCCULENTS
MUMULUS PUNICEUS
ORTHOCARPUS PURPURASCENS
PHACELIA CAMPANULARIA
SISYRINCHIUM BELLUM
STIPA LEPIDA
STIPA PULCHRA
COASTAL SAGE SCRUB COMMUNITY
SEE ABOVE
TREES
POPULUS FREMONTII
PLATNUS RACEMOSA
QUERCUS AGRIFOLIA
QUERCUS ENGELMANII
TREES
AVOCADO
LEMON
ORANGE
TANGERINE
LIME
GRAPEFRUIT
GUAVA
PERSIMMON
KUMQUAT
LOQUAT
CONTAINER PLANTS IN BASIN
ACORUS GRAMINEUS 'VARIEGATUS'
CAREX FLACCA
CAREX PANSA
CAREX TUMULICOLA
CHONDROPETALUM TECTORUM
DIANELLA REVOLUTA 'LITTLE REV'
FESTUCA MAIREI
JUNCUS EFFUSUS 'QUARTZ CREEK'
JUNCUS INFLEXUS 'BLUE ARROWS'
JUNCUS PATENS 'ELK BLUE'
LEYMUS CONDENSATUS 'CANYON
PRINCE'
LOMONDRA LONGIFOLIA 'BREEZE'
SESLERIA AUTUMNALIS
TREES
POPULUS FREMONTII
SALIX GOODDINGOO
SALIX LAEVIGATA
SALIX LASIOLEPIS
PLATNUS RACEMOSA
QUERCUS AGRIFOLIA
ALNUS RHOMBIFOLIA
FIG
POMEGRANATE
PLUMS
PEACH
NECTARINES
APRICOTS
PEAR
CONTAINER PLANTS ADJACENT TO BASIN/TOP OF SLOPE
BERBERIS REPENS
CEANOTHUS SPP.
CARPENTARIA CALIFORNICA
COMAROSTAPHYLLIS DIVERSIFOLIA
GALVEZIA JUNCEA
GALVEZIA SPECIOSA
GARRYA ELLIPTICA
KECKIELLA CORDIFOLIA
RIBES SPECIOSUM
RIBES VIBURNIFOLIUM
ROSA CALIFORNIACA
HETEROMELES ARBUTIFOLIA
IVA HAYESIANA
PHILADELPHUS LEWISII
PRUNUS ILICIFOLIA
RHAMNUS CALIFORNICA
RHUS OVATA
TRICHOSTEMA LANATUM
VERBENA LILACINA
APPENDIX G
Agency Evacuation Pre-Planning
Procedures and Techniques
APPENDIX G
Agency Evacuation Pre-Planning Procedures and Techniques 8304
G-1 July 2017
1.1 Evacuation Objectives
The overall objectives of emergency evacuation operations and notifications are to:
1. Expedite the movement of persons from hazardous areas;
2. Institute access control measures to prevent unauthorized persons from entering vacated, or partially vacated areas;
3. Provide for evacuation to appropriate transportation points, evacuation points, and shelters;
4. Provide adequate means of transportation for persons with disabilities, the elderly, other persons with access and functional needs, and persons without vehicles;
5. Provide for the procurement, allocation, and use of necessary transportation and law enforcement resources by means of mutual aid or other agreements;
6. Control evacuation traffic;
7. Account for the needs of individuals with household pets and service animals prior to, during, and following a major disaster or emergency;
8. Provide initial notification, ongoing, and re-entry communications to the public through the Joint Information Center (JIC); and
9. Assure the safe re-entry of the evacuated persons.
The San Diego Sheriff’s Department (SDSD) is the lead agency for evacuations of the unincorporated areas of San Diego County, including Deer Springs Fire Protection District and the Newland Sierra project. The SDSD, as part of a Unified Command, assesses and evaluates the need for evacuations, and orders evacuations according to established procedures.
Additionally, as part of the Unified Command, the SDSD identifies available and appropriate evacuation routes and coordinate evacuation traffic management with the California Department of Transportation (Caltrans), the California Highway Patrol (CHP), other supporting agencies, and jurisdictions.
The decision to evacuate an area is not made lightly and there is a significant impact to public safety and the economy. The following process describes how emergency evacuation decisions are coordinated, allowing emergency managers and other supporting response organizations to make collaborative decisions.
Appendix G (Continued)
8304
G-2 July 2017
1.2 Evacuation Coordination Process
1. If the emergency only impacts a local jurisdiction, the decision to evacuate will be made at the local jurisdiction level with regional collaboration considerations. a. Based on the information gathered, local jurisdictions will generally make the determination on whether to evacuate communities as the need arises, on a case-bycase scenario basis. b. The decision to evacuate will depend entirely upon the nature, scope, and severity of the emergency; the number of people affected; and what actions are necessary to protect the public.
c. Local jurisdictions may activate their Emergency Operations Center (EOC) and conduct evacuations according to procedures outline in their Emergency Operations Plan (EOP).
d. The EOC may make recommendations on whether a jurisdiction should evacuate and may help coordinate the evacuation effort.
e. The Evacuation Annex is automatically activated when an incident occurs requiring an evacuation effort that impacts two or more jurisdictions. f. The EOC will coordinate with fire, law enforcement, public health, and other relevant support agencies to obtain recommendations on protective actions. g. The EOC will coordinate with jurisdictional emergency management personnel and other public safety personnel. The Policy Group within the EOC will coordinate will other officials from jurisdictions within the OA to identify command decisions, including:
i. Gaining regional situational awareness
ii. Determining response status
iii. Reviewing status of initial protective actions
iv. Considering additional protective actions
v. Evaluating public information needs
vi. Determining next steps
vii. Establishing a regular time to share updates
h. The EOC will coordinate emergency public information to citizens in accordance with established procedures.
i. The EOC may support coordinating the evacuation response according to the EOP, including:
Appendix G (Continued)
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i. Providing transportation for those who need assistance ii. Provide support for people with disabilities and other access and functional needs iii. Coordinate and communicate with the private sector, community groups, and faith based organizations to utilize their services and resources available to support the response
iv. Providing shelter for evacuees
1.3 Evacuation Response Operations
An evacuation of any area requires significant coordination among numerous public, private, and community/non-profit organizations. Wildfire evacuations will typically allow time for responders to conduct evacuation notification in advance of an immediate threat to life safety; giving residents time to gather belongings and make arrangements for evacuation. On the other hand, other threats, including wildfires igniting nearby, may occur with little or no notice and certain evacuation response operations will not be feasible (for example, establishing contra flow requires between 24 to 72 hours to be implemented; a no-notice event will not allow for contra flow to be established). Evacuation assistance of specific segments of the population may also not be feasible.
1.3.1 Evacuation Points and Shelters
When the SDSD implements an evacuation order, they coordinate with the responding fire agency, the EOC, and others to decide on a location to use as a Temporary Evacuation Point (TEP). The SDSD Dispatch Center will utilize the AlertSanDiego system to direct evacuees to the established TEP or shelter. These evacuation points will serve as temporary safe zones for evacuees and will provide basic needs such as food, water, and restrooms. If there are residents unable to evacuate and need transportation assistance to get to a TEP or shelter, the SDSD may establish transportation points to collect and transport people without transportation resources to evacuation points. These points should be large, well known sites such as shopping centers, libraries, and schools. Transportation should be accessible to all populations, including people with disabilities and other access and functional needs.
The Pets Evacuation and Transportation Standards Act of 2006 amends the Stafford Act, and requires evacuation plans to take into account the needs of individuals with household pets and service animals, prior to, during, and following a major disaster or emergency.
The San Diego County Department of Animal Services (DAS) has plans in place to transport and shelter pets in a disaster under Annex O of the OA EOP, including the Animal Control Mutual Aid Agreement. Animal Control Officers, the San Diego Humane Society, and private animal Appendix G (Continued)
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care shelters will assist in the rescue, transport, and sheltering of small and large animals. In addition, potential volunteer resources and private groups should be identified and tracked in WebEOC. Only non-emergency resources and personnel, such as public and private animal services agencies, will be used to rescue and transport animals during an evacuation effort.
In most cases, DAS and the OA EOC will coordinate and attempt to co-locate animal shelters with people shelters.
1.3.2 Shelter-in-Place
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 short time rather than travel outdoors. 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.
The decision on whether to evacuate or shelter-in-place is carefully considered with the timing and nature of the incident (San Diego County 2014). 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. Safari Highlands Ranch provides decision makers with the option of temporarily sheltering the population, or portions thereof.
1.4 Available Evacuation Strategies
There are many evacuation strategies that are available that can be implemented during an evacuation effort to enhance traffic flow and reduce the overall evacuation time. These strategies include contra-flow, traffic signal coordination, closure of off and on-ramps, Intelligent Transportation Systems, segregation of pedestrian and vehicle traffic, exclusive bus routes, phased evacuation, phased release of parking facilities, use of designated markings, road barriers, and use of the San Diego Freeway Patrol Service. These methods are summarized below and would be used by law enforcement agencies as necessary to meet evacuation objectives.
1.4.1 Intersection Control
Experience with evacuations and input from law enforcement personnel experienced with conducting wildfire evacuations indicates that a key factor for maintaining traffic movement out of evacuation areas is “controlling the intersections”. This includes intersections downstream, Appendix G (Continued)
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possibly including the primary intersections along SR-78, Cloverdale Lane and internal Escondido streets along Valley Parkway. Typically, available law enforcement personnel may be a limiting factor on how well the intersections are controlled.
Intersections must be controlled by law enforcement personnel early, while they are still open.
Once an intersection becomes gridlocked, it is almost impossible to re-open traffic flow (public hearing presentation by Orange County Sheriff’s Department 2013). Therefore, intersections along the detailed Safari Highlands Ranch evacuation routes are critical to keep open and flowing traffic south and eastward. Keeping these roads flowing will provide for fast evacuation of the Safari Highlands Ranch Project as well as other communities in the area.
1.4.2 Contra-Flow Operations
Contra-flow is a tactic in which one or more lanes of a roadway are reversed to allow for an increase of traffic flow in one direction. Contra-flow can be implemented for highway and arterial roadways, however, the divided north bound and south bound directions, accesscontrolled configurations, and lack of signals on highways make these roadways ideal for contraflow operations. An important consideration in the development of contra-flow plans is the identification of inception and termination points for the corridor. Congestion at these points can significantly reduce the effectiveness of these operations. Effective implementation of these plans includes the deployment of appropriate signage, signals, and barriers as well as the use of CHP and San Diego Sheriff’s Department personnel. For safety considerations, contra-flow operations should only be performed during daylight hours. In addition, an emergency return lane must also be designated.
1.4.3 Traffic Signal Coordination and Timing
Traffic signal coordination and timing plans are intended to maximize traffic flow in the outbound direction during an evacuation effort. Depending on the extent of the evacuation, coordination may be necessary both locally and regionally to re-time the traffic signal systems.
1.4.4 Closure of On and Off-Ramps
Closure of outbound on-ramps on designated evacuation routes (such as I-15) will reduce congestion on these roadways resulting from traffic originating at intermediate locations between evacuation origins and destinations. In addition to reducing congestion, closure of outbound onramps will also help eliminate entrance queuing. Closure of off-ramps will ensure evacuees remain on designated evacuation routes. These tactics will require coordinated efforts between CHP, Caltrans, Sheriff’s, and other emergency personnel to place and staff barricades at the tops of such ramps throughout the evacuation route.
Appendix G (Continued)
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1.4.5 Intelligent Transportation Systems
Intelligent Transportation Systems include a broad range of technologically based tools that enable transportation and emergency managers to monitor traffic conditions, respond to capacityreducing events, and provide real-time road conditions. San Diego is equipped with numerous forms of Intelligent Transportation Systems technologies including roadway electronic surveillance, automatic vehicle location, Changeable Message Signs, and Highway Advisory Radio. These types of technologies provide real-time information to the San Diego Transportation Management Center. The San Diego Transportation Management Center integrates Caltrans Traffic Operations, Caltrans Maintenance, and CHP Communications into a unified, co-located communication and command center. The Transportation Management Center functions to provide communications, surveillance, and computer infrastructure required for coordinated transportation management. Using Intelligent Transportation Systems technologies, the Transportation Management Center can quickly detect, verify, and respond to incidents, such as recommending a different evacuation route due to congestion.
1.4.6 Segregation of Pedestrian and Vehicle Traffic
Although not anticipated for wildfire evacuations, this strategy will designate certain urban roadways as pedestrian only. This will provide separation between vehicles and pedestrians during an evacuation, thus reducing confusion and increasing the efficiency and safety of the evacuation.
1.4.7 Exclusive Bus Routes
This strategy involves the designation of certain lanes within an evacuation route exclusively for buses or other large capacity or high occupancy vehicles. Exclusive bus routes may also be established along alternative evacuation routes. The implementation of this strategy will help support and expedite transportation point operations and can greatly increase the number of people that can be evacuated within a set period of time.
1.4.8 Phased Evacuation
The purpose of a phased evacuation is to reduce congestion and transportation demand on designated evacuation routes by controlling access to evacuation routes in stages and sections.
This strategy can also be used to prioritize the evacuation of certain communities that are in proximity to the immediate danger.
Appendix G (Continued)
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1.4.9 Use of Designated Markings
Designated markings and signs will play a key role in accomplishing a safe and efficient evacuation. Signs, flags, and other markings can be used to provide guidance and information to evacuees en-route.
1.4.10 Road Barriers
Road barriers are used in conjunction with other transportation strategies to ensure evacuees remain on designated evacuation routes or are blocked from entering closed areas.
Roadblocks and barricades
A variety of methods are used to stop or divert traffic. Roadblocks and barriers include a number of different technologies:
≠ Tape barriers
≠ Portable signs
≠ Cones
≠ Barrels
≠ DOT Type II rail barricades: must be at least 3 feet high with two rails 2 feet in length.
≠ DOT Type III rail barricades: must be at least 5 feet high and have three rails that are at least 3 feet long.
≠ Concrete or water-filled barricades (manual)
≠ Automated vehicle barricades
≠ Manual swinging gate barricades
These devices can be set in place without staffing or staffed (labor and time intensive) by traffic guides or law enforcement personnel (traffic control). In general, un-staffed and removable barricades are not very effective as drivers can circumvent them rather easily. The importance of maintaining intersections flowing traffic will supersede the possibility of using these types of barricades during most evacuations.
1.5 Social Aspects of Wildfire Evacuation
Orderly movement of people is the result of planning, training, education, and awareness, all of which are promoted in San Diego County. Evacuation has been the standard term used for Appendix G (Continued)
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emergency movement of people and implies imminent or threatening danger. The term in this Wildland Fire Evacuation Plan, and under the “Ready, Set, Go!” concept, indicates that there is a perceived threat to persons and movement out of the area is necessary, but will occur according to a pre-planned and practiced protocol, reducing the potential for panic.
Citizen reactions may vary during an evacuation event, although several studies indicate that orderly movement during wildfire and other emergencies is not typically unmanageable.
Evacuation can be made even less problematic through diligent public education and emergency personnel training and familiarity. Social science research literature indicates that reactions to warnings follow certain behavior patterns that are defined by people’s perceptions (Aguirre 1994, Drabek 1991, Fitzpatrick and Mileti 1994, Gordon 2006, Collins 2004) and are not unpredictable. In summary, warnings received from credible sources by people who are aware (or have been made aware) of the potential risk, have the effect of an orderly decision process that typically results in successful evacuation. This success is heightened when evacuations are practiced (Quarentelli and Dynes 1977; Lindell and Perry 2004) as will occur within the Safari Highlands Ranch project. Further, in all but the rarest circumstances, evacuees will be receiving information from credible sources during an evacuation. Further, it would be anticipated that law enforcement and/or fire personnel would be on site to help direct traffic and would be viewed by evacuees as knowledgeable and credible. The importance of training these personnel cannot be understated and annual education and training regarding fire safety and evacuation events will be essential for successful future evacuations.
1.5.1 Evacuation of Special Populations
Vogt (1990 and 1991) defines special populations as those groups of people who, because of their special situations or needs, require different planning strategies from those of the general population. Special needs populations include those in institutions or special facilities, those with disabilities in homes, those who need care, children, and others who cannot provide for their own evacuation if necessitated. The special needs population is concentrated in facilities, but is also widespread in terms of facility locations and those who live in residences. Special needs populations in Newland Sierra include the hearing or visually impaired, foreign speaking, visitors passing through the area, temporary visitors such as day workers, and the nonambulatory confined to residences either temporarily or permanently.
Tourists and temporary visitors may not have knowledge of the area’s fire hazard, they may not know how to react in a fire emergency, and they may not understand what they are being told to do. Conversely, this segment of the population would typically be easier to evacuate quickly as they have no possession or pets that they would need to prepare. They can get in their cars and be directed out of the area.
Appendix G (Continued)
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The reasons why special needs populations may fail to respond to warnings to take protective actions is that they may require special transportation while others require different types of warnings or technologies to receive a warning. Some groups must rely on care-givers to hear the warning and respond.
Safari Highlands Ranch Approach:
The Safari Highlands Ranch community will be advised of their need to register as a special needs resident, as applicable, so that accommodations for their transportation or other special requirements can be provided during an emergency evacuation.
1.5.2 Animal Evacuations
Animal evacuations present a host of challenges that may affect the overall successful movement of people and their possessions out of harm’s way. For example, livestock owners do not always have the means to load and trailer their livestock out of the area. Further, most wildfire evacuation relief shelters or commercial lodging facilities do not allow people to bring in pets or other animals. Sorensen and Vogt (2006) indicate that an issue receiving increasing attention is what evacuees do with pets or other animals such as livestock when they leave their homes and whether having pets or animals impacts their decision to evacuate.
The Safari Highlands Ranch project will not accommodate livestock of any type on-site, however the trails and trail access points could conceivably include horses during an evacuation notice. Household pets will be a common occurrence.
Safari Highlands Ranch Approach:
≠ Develop a strong outreach program for pet owners so they understand their responsibilities and that they will not likely be allowed re-entry once evacuated. ≠ Develop a registration for owners of animals who cannot evacuate them without assistance so that volunteer organizations or individuals, can provide resources. ≠ Notice horse owners who utilize the Safari Highlands Ranch trailheads of the fire dangers and their responsibility to register with the aviour alert programs and evacuate when given notice.
1.5.3 Re-Entry Procedures
An important component of evacuations that was not executed well during past San Diego County evacuations is that of allowing citizens to re-enter their neighborhoods. Guidance and procedures to ensure a coordinated, safe, and orderly re-entry into impacted communities following an incident is provided in the County of San Diego Re-Entry Protocol.
Appendix G (Continued)
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Re-entry will be initiated by the Incident Commander/Unified Command of the Incident Management Team, with the support of the Director of Emergency Services, the OA EOC Director, and the Operations Section Chief at the OA EOC. In most cases the OA EOC will remain activated until full re-entry is complete. In the event that the OA EOC has been deactivated, the Incident Commander or the Liaison Officer of the Incident Management Team will initiate re-entry procedures.
The Incident Commander will designate a Re-Entry Coordinator and the Operations Section Chief of the OA EOC will coordinate with and support the re-entry coordinator. The Re-Entry Coordinator is responsible for coordinating the re-entry procedures with all involved agencies and ensuring effective communication. Priorities for re-entry include:
The impacted areas must be thoroughly investigated to ensure it is safe for residents to return and normal operations have been restored. This assessment will include verification that:
The public will be notified of the re-entry status through the notification measures previously mentioned in this annex, including SDCountyEmergency.com, SDEmergency App for smart phones, emergency broadcast radio, television, press releases, informational phone lines such as 2-1-1, community briefings, and informational updates at shelters.
Once evacuees are permitted to return, it is important that procedures are established to properly identify residents and critical support personnel, as well as ensure the legitimacy of contractors, insurance adjustors, and other personnel. Re-entry points should be staffed by law enforcement personnel.
1.6 LIMITATIONS
During extreme fire weather conditions, there are no guarantees that a given structure will not burn or that evacuations will be successful all of the time. Wildfires may occur in the area that could damage property or harm persons. However, successful implementation of the recommendations outlined in this Evacuation Plan will provide for an informed populace, preplanned and practiced fire and law enforcement personnel, and informed evacuation officials.
The Newland Sierra community is designed specifically to be resistant to wildfire ignition and perform as a fire adapted project, offering fire and law officials additional options for resident safety than are available from less defensible communities.
This Wildland Fire Evacuation Plan does not provide a guarantee that all persons will be safe at all times because of the recommendations proposed. There are many variables that may influence overall safety. This Plan provides a summary for implementation of standard evacuation protocols, suggested roadway enhancements, and public outreach, which should result in reduced wildfire related risk and hazard. Even then, fire can compromise the procedures through various, unpredictable ways. The goal is to reduce the likelihood that the Appendix G (Continued)
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system is compromised through implementation of the elements of this Plan and regular occurring program maintenance and updates.
1.7 REFERENCES
Aguirre. D.B. 1994. Planning warning evacuation, and search and rescue: A review of the social science research literature. College Station, Tx. Texas A&M University, Hazard Reduction Recovery Center.
Collins, S. L. 2004. Evaluation of Evacuation Planning in Wildland-Urban Interface Environments. Executive Analysis of Fire Service Operations in Emergency Management. Applied Research project submitted to the National Fire Academy as part of the Executive Fire Officer Program. 44 pp.
Drabek, T.E. 1991. Anticipating organizational evacuations: disaster planning by managers of tourist-oriented private firms. International Journal of Mass Emergencies and Disasters. 9, (2), 219-245.
Fitzpatrick, C. and Mileti, D.S. 1994. Public Risk Communication. In Dynes R. R. and Tierney, K.J. (Eds) 1994. Disasters, Collective Behavior, and Social Organization. Newark University of Delaware Press, 71-98.
Gordon, R. 2006. Acute Responses to Emergencies: findings and observations of 20 years in the field. The Australian Journal of Emergency Management, Vol. 21, No. 1, February 2006. 23 pp.
Lindell, M.K. and Perry, R.W. 2004. Communicating Environmental Risk in Multiethnic Communities. Thousand Oaks, California: Sage Publications.
Sorensen, John and Barbara Vogt. 2006. Interactive Emergency Evacuation Guidebook. Prepared for the Protective Action IPT – Chemical Stockpile Emergency Preparedness Program.
Vogt, B. (1990) Evacuation Of Institutionalized And Specialized Populations, ORNL/SUB-7685/1 & T23. Oak Ridge, TN: Oak Ridge National Laboratory.
Vogt, B. (1991) Issues in nursing home evacuations, International Journal of Mass Emergencies and Disasters, 9, 247-265.
Appendix G (Continued)
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INTENTIONALLY LEFT BLANK
APPENDIX H
Ready, Set, Go! Wildfire Action Plan
Exhibit 6
Griffin Cove Transportation Consulting, PLLC
P.O. Box 956 Mackinac Island, MI 49757 Phone: (906) 847-8276 July 22, 2022
Mr. Peter J. Broderick
Center for Biological Diversity
351 California Street, Suite 600
San Francisco, California 94104
Subject: Fanita Ranch Project – Santee, California
Recirculated Sections of Final Revised Environmental Impact Report Dear Mr. Broderick:
The City of Santee, California, has recently recirculated certain sections of the final environmental impact report (FEIR) for the proposed Fanita Ranch project (“Project”) in that city. This recirculation was in response to a Superior Court determination that the FEIR previously certified by the city was inadequate, in part due to deficiencies in its consideration of the ability to safely evacuate the Project site in the event of a wildfire.
Griffin Cove Transportation Consulting, PLLC (GCTC) has completed a review of the recirculated documentation concerning the wildfire evacuation issue. (Reference: Harris & Associates, Recirculated Sections of Final Revised Environmental Impact Report – Fanita Ranch Project, June 2022.) Of particular interest in this review are the following documents contained within the recirculated material:
• Section 4.18 - Wildfire
• Appendix P1 – Fire Protection Plan (Reference: Dudek, Revised Fanita Ranch Fire Protection Plan, Revised May 2022.)
• Appendix P2 – Wildland Fire Evacuation Plan (Reference: Dudek, Wildland Fire Evacuation Plan for the Fanita Ranch Community, May 2022.)
• Wildland Fire Evacuation Plan Appendix D (Reference: Chen Ryan Associates, Memorandum Report to HomeFed Fanita Rancho, LLC, “Fanita Ranch Project Fire Evacuation Analysis – Technical Memorandum,” May 25, 2022.)
Our review focused on the technical adequacy of the evacuation analysis presented in these documents, including the detailed procedures and conclusions documented in the Fire Protection Plan (FPP), the Wildland Fire Evacuation Plan (WFEP), and the Chen Ryan technical memorandum.
BACKGROUND
The proposed 2,638-acre Fanita Ranch project would be located in the northern portion of the City of Santee in San Diego County, California. The proposed project would consist of 2,949 residential dwelling units, 80,000 square feet of commercial space, a K – 8 school, parks, open space, and agricultural uses.
Vehicular access is proposed via the northerly extension of two existing roadways: Fanita Parkway and Cuyamaca Street. The current Project proposal also includes the extension of Magnolia Avenue from its current terminus to meet Cuyamaca Street a short distance south of the Project site boundary. The Magnolia Avenue extension, which was eliminated from the Project a short time prior to certification of the EIR by the City of Santee, has been restored to the Project.
Mr. Peter J. Broderick
July 22, 2022
Griffin Cove Transportation Consulting, PLLC
REVIEW OF RECIRCULATED SECTIONS OF FINAL REVISED ENVIRONMENTAL IMPACT REPORT
Our review of the documents listed above revealed several issues affecting the validity of the analysis results and conclusions. Those issues are presented below.
1. Flawed Evaluation of New Significance Threshold – Section 4.18 - Wildfire addresses a new significance threshold, as follows:
Threshold 6: Wildland Fires - Would implementation of the proposed project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? (RSFREIR, p. 4.18-35)
Pertinent issues related to wildland fire evacuation are discussed in Section 4.18 – Wildfire beginning at p. 4.18-44. That discussion relies heavily upon information presented in Appendix P1 – Fire Protection Plan, Appendix P2 – Wildland Fire Evacuation Plan, and the Chen Ryan technical memorandum, and concludes that the Project will have a less than significant impact. However, no meaningful support was provided for this determination.
In fact, it appears that no significance criterion or performance standard was established or applied in making the determination that the Project would have a “less than significant” impact with respect to evacuation. In this regard, the Chen Ryan Associates evacuation time memorandum (p. 19) acknowledges:
Neither CEQA nor the City has adopted numerical time standards for determining whether an evacuation timeframe is appropriate.
Similarly, the Fire Protection Plan presented in Appendix P2 (p. 3) claims:
However, it must be clear that there is no evacuation timeframe threshold that Projects must meet in order to avoid a CEQA impact or to be consistent with codes, regulations or policies This raises an obvious question: If the city as Lead Agency has no established standard within CEQA, how was it determined that the Project’s impact was less than significant? Section 4.18 and the associated appendices repeatedly make the claim that the evacuation times derived by Chen Ryan conform to some sort of established guideline. For example, the Fire Protection Plan (Appendix P2, p. 3) says:
The evacuation times modeled for Fanita Ranch are well within acceptable guideline evacuation times.
In addition, Section 4.18 - Wildfire concludes (p. 4.18-46):
. . . the evacuation time would be up to approximately 1.3 hours, which is considered a reasonable time frame (Rohde & Associates 2019-2021; SFD 2022; Appendix P1).
However, a detailed review of the evaluation of this new threshold reveals the flawed approach to this issue, which led to the faulty “less than significant” conclusion.
Mr. Peter J. Broderick
July 22, 2022
Griffin Cove Transportation Consulting, PLLC
The Rohde & Associates documents referenced above are fire services operational assessments completed with respect to two other San Diego County projects.1, 2 Careful review of those documents revealed no statement regarding what constitutes an acceptable or reasonable time frame.
Despite the claim that the Project’s evacuation times are “well within acceptable guideline evacuation times,” no such guidelines are presented in any of the documentation. In fact, it appears that this conclusion is based on a misinterpretation of statements in the two referenced Rohde documents.
Specifically, the WFEP incorrectly claims that the Federal Emergency Management Agency (FEMA) has established 1.5 hours as an evacuation guideline (WFEP, p. 34). That conclusion is simply not correct. What the Rohde documents actually say:
• Otay Ranch Village Resort, Village 13: “. . . the community can be evacuated in approximately
1.5 to 2 hours, according to general evacuation estimates published for urban areas by the Federal Emergency Management Agency.”
• Otay Ranch Village 14: “This finding is also consistent with estimates published for urban areas by the Federal Emergency Management Agency.”
Thus, the two Rohde documents simply say that the evacuation time findings presented in those documents are “consistent” with “general evacuation estimates” published by FEMA. These are not FEMA guidelines; in fact, there is no indication that FEMA has provided any guideline as to what constitutes an acceptable evacuation time.
It is simply disingenuous, therefore, to suggest that the Rohde documents provide any sort of FEMAsanctioned guideline or standard. Further, it is not possible to derive any conclusion regarding Projectrelated significance based on the information provided. Absent an adopted standard of significance regarding acceptable evacuation times, no determination is possible as to the magnitude of the Projectrelated impact.
2. Evacuation Analysis Results Lack Credibility – The documents referenced above present a newlycompleted analysis of evacuation times, which was completed by Chen Ryan Associates and is presented as Appendix D to the WFEP (Appendix P2). That analysis evaluated nine scenarios ranging from a claimed “Most Probable Evacuation” involving 1,885 vehicles to a total/mass evacuation scenario labeled “Existing Land Uses Plus Project with Magnolia Avenue Extension” (24,956 vehicles).
Between those two extremes were a pair of “targeted” evacuation scenarios involving smaller geographic areas. The resulting evacuation times ranged from 19 minutes to 1 hour, 57 minutes. Those results are summarized in “Table 2 – Evacuation Time Summary – All Scenarios” in the Chen Ryan memorandum (p. 18).
The validity of the 19-minute finding is highly questionable. First, we note that it represents less than eight percent of total number of potential evacuating vehicles in the study area (i.e., 1,885 vehicles out of a total of 24,956). Moreover, as described in greater detail below, it ignores up to three hours needed for pre-evacuation preparation and potentially substantial volumes of ambient traffic that are likely to be on the study area road system at the time an evacuation is initiated.
1 Rohde & Associates, Otay Ranch Village Resort Village 13 Fire Services Operational Assessment, Feb. 1, 2020. 2 Rohde & Associates, Otay Ranch Village 14 and Planning Areas 16/19 Fire Services Operational Assessment, March 11, 2020
Mr. Peter J. Broderick
July 22, 2022
Griffin Cove Transportation Consulting, PLLC
Also, the incremental evacuation times associated with addition of the project are questionable.
Comparison of Scenarios 1 and 9 indicates that in the case of a mass evacuation, over 7,000 Projectrelated vehicles could be evacuated in only 39 additional minutes. The results for the targeted evacuation scenarios are even more noteworthy, as the Project-related incremental evacuation time is claimed to be only 7 or 8 minutes for those scenarios.
For further perspective, the additional 8 minutes of “1/8-mile” targeted evacuation time relates to an additional 3,637 Project-related vehicles in the evacuating traffic stream. In contrast, the additional 7 minutes associated with the “1/4-mile” targeted evacuation results from the addition of 4,419 projectrelated vehicles. This indicates that 782 additional vehicles can be evacuated 1 minute quicker, which seems unlikely. For ease of reference, the pertinent results are summarized in Table 1.
Table 1
Incremental Evacuation Time Summary
Scenario
Evacuating
Vehicles
Evacuation
Time
1 – Existing Land Uses 17,924 1 Hour, 18 Minutes
9 – Existing Land Uses + Project with Magnolia
Avenue Extension 24,956 1 Hour, 57 Minutes
Project Increment 7,032 39 Minutes
5 – Existing Land Use with Targeted Evacuation (1/8
Mile) 10,706 1 Hour, 9 Minutes
6 – Existing Land Use with Targeted Evacuation (1/8
Mile) + Project with Magnolia Avenue Extension 14,343 1 Hour, 17 Minutes Project Increment 3,637 8 Minutes
7– Existing Land Use with Targeted Evacuation (1/4
Mile) 11,391 1 Hour, 11 Minutes
8 – Existing Land Use with Targeted Evacuation (1/4
Mile) + Project with Magnolia Avenue Extension 15,810 1 Hour, 18 Minutes Project Increment 4,419 7 Minutes
Reference: Chen Ryan, Table 2 – Evacuation Time Summary – All Scenarios, p. 18.
3. Evacuation Times are Incomplete and Misleading – The Chen Ryan technical memorandum presented as WFEP Appendix D documents an analysis of estimated evacuation times under various scenarios.
However, the evacuation times presented there are incomplete and, therefore, misleading. In particular, the estimated evacuation times represent only the travel time beginning when evacuees leave home.
They ignore all of the other time-consuming tasks associated with preparation for an evacuation.
Included in this pre-evacuation period are public notification times, mobilization times (as people prepare to evacuate), and other activities, which are particularly critical with respect to fires that start in close proximity to the proposed Project.
Mr. Peter J. Broderick
July 22, 2022
Griffin Cove Transportation Consulting, PLLC
Those additional tasks are commonly detailed in other Dudek fire protection plans, but are not included in this one, although p. 34 of the WFEP specifically mentions “the amount of mobilization time” as a factor affecting the evacuation time.
For example, the Fire Protection Plan prepared by Dudek for the Harvest Hills project in Escondido, California (December 2020) provided a detailed listing of time requirements for various pre-evacuation activities totaling 125 minutes (i.e., just over two hours), plus an additional 30 minutes of “contingency time,” leading to a total of 155 minutes (2.6 hours) for pre-evacuation activities. That plan went on to say:
Total minimum time that may be needed for a large-scale evacuation from the detection of a fire until the last person is out of harm’s way is 90 to 180 minutes.3 This pre-evacuation period of up to three hours is in addition to the travel time estimates presented in the Fanita Ranch documents. Thus, when Section 4.18 says, “. . . the evacuation time would be up to approximately 1.3 hours,” what it actually means is the evacuation time would be up to 4.3 hours, a substantial increase over the claimed time period.
In summary, consideration of the full spectrum of evacuation-related activities and associated time requirements, combined with the failure to establish a meaningful standard of significance (as discussed above) clearly suggest that it is inappropriate to conclude that the Project will have a less than significant impact with respect to wildland fire evacuation.
4. Failure to Account for Ambient Traffic – The evacuation time analysis presented as WFEP Appendix D failed to account for ambient or background traffic that is already on the nearby road system when the need for an evacuation is declared. Although the analysis included traffic generated within the evacuation area (associated with existing land uses and the proposed project), no traffic generated from outside the area that might be passing through the area or is in the area for business or social reasons was considered.
This omission is not insignificant. The transportation impact analysis prepared for the Project provides existing traffic volumes for roads in the vicinity of the Project.4 Specifically, Table 4-1 (p. 26) in that document provides this information. Although traffic volumes in the immediate vicinity of the Project are not extremely high, it must be recognized that the evacuation plan has defined “safety” as occurring once evacuees reach Mission Gorge Road.
According to the LLG report, Cuyamaca Street carries almost 22,000 vehicles per day (VPD) just north of Mission Gorge Road (i.e., between Town Center Parkway and Mission Gorge Road). To the north of that, evacuees would have to travel though the segment of Cuyamaca Street between River Park Drive and Town Center Parkway; that road segment has an average daily traffic value of 26,690 VPD, according to LLG.
Similarly, Project evacuees using Magnolia Avenue will potentially encounter substantial traffic as they approach Mission Gorge Road. According to LLG, the road segment just north of Mission Gorge Road has an average daily traffic value of 25,830 VPD.
3 Dudek, Fire Protection Plan – Harvest Hills, Prepared for City of Escondido Fire Department, Revised December 2020.
4 Linscott Law & Greenspan, Transportation Impact Analysis – Fanita Ranch, March 25, 2020.
Mr. Peter J. Broderick
July 22, 2022
Griffin Cove Transportation Consulting, PLLC
Of course, the volume of traffic on these roads when the need for an evacuation is declared is dependent upon many factors, but the fact remains that an analysis that simply pretends this traffic does not exist is not valid. Such an analysis understates the travel time associated with the evacuation and potentially leads to a false conclusion regarding the significance of Project-related impacts.
5. Traffic Simulation Analysis Scenarios – The evacuation travel time estimates presented in the various recirculated documents assume that both of the primary evacuation routes (i.e. Fanita Parkway and Cuyamaca Street) will be available when needed for evacuation purposes. Further, all of the “with Project” scenarios assume the availability of Magnolia Avenue. No analysis is presented that reflects the possibility that any of these roads might be unavailable due to the proximity of the wildfire that is the cause of the evacuation. Given that the most likely direction of approach for a wildfire is from the north and/or east, it is not unreasonable to consider the potential that Cuyamaca Street and/or Magnolia Avenue might not be available to serve as an evacuation route. The analysis should address such a case, so as to establish whether Fanita Parkway alone would be adequate to accommodate evacuating traffic safely.
6. Traffic Simulation Analysis Parameters – The evacuation travel time estimates derived by Chen Ryan are based, at least in part, on a traffic simulation process. (Uncertainties regarding the specific analysis methodology are discussed in greater detail below.) Because traffic simulation is largely a “black box” procedure, little information is provided that would allow the public to fully understand the analysis procedures and to judge the validity of the results. Given that the primary objective of any CEQA document is to inform the public, this deficiency is critical. Among the specific areas of concern are the following:
• As noted above, although the evacuation travel time analysis included traffic generated within the evacuation area, it is not clear if the analysis included the “shadow evacuees” referenced in Section
4.18 – Wildfire (p. 4.18-44) and the FPP (p. 39). Those individuals are described as:
. . . up to approximately 25 percent of evacuees who decided to leave the area despite not being asked to evacuate off site . . .
The traffic demand associated with these evacuees is potentially substantial, and must be taken into account.
• No information is provided with respect to the roadway capacities assumed in the evacuation time analysis. Does the analysis accurately reflect the constraints associated with the fact that the Project’s only two direct connections to the regional road system (i.e., Fanita Parkway and Cuyamaca Street) will each be limited to two lanes (one in each direction) at and immediately south of the Project site? Of course, only one lane (i.e., the southbound lane) will be available to serve evacuating traffic, as the northbound lane must be reserved for emergency vehicles approaching the Project. Obviously, this is a key parameter in determining how quickly and how well traffic will flow.
• Another key assumption in the analysis concerns the form of intersection traffic control employed at the critical intersections along the evacuation routes. According to the Chen Ryan report (p. 4), the “major intersections” were assumed to be controlled by first responders or law enforcement. (No information is provided regarding assumed traffic control at non-major intersections.) This suggests that those major intersections were assumed to be free flowing, which is certainly a “best Mr. Peter J. Broderick
July 22, 2022
Griffin Cove Transportation Consulting, PLLC
case” assumption that might not reflect the reality of an emergency situation under which extraordinary demands are placed upon first responders and law enforcement officers. • Did the analysis account for the possibility that roads would be obscured by smoke or that visible nearby flames or blowing embers might affect driver behavior? These factors would have the effect of reducing effective road capacity and increasing evacuation travel time, as well as to increase the likelihood that incidents such as crashes will occur along the evacuation route, which could potentially block the evacuation route altogether. This possibility is acknowledged in the WFEP, which says (p. 14):
. . . a roadway incident may block evacuating vehicles, requiring temporary or permanent rerouting of traffic.
The WFEP further acknowledges (p. 31):
Conditions may become so poor that the vehicle drives off the road or crashes into another vehicle, or that flames and heat overcome the occupants. This scenario has occurred in San Diego County during the 2003 Cedar Fire [which burned a large portion of the Project site (Section 4.18 - Wildfire, p. 4.18-5)] and in the 2017 northern California wildfires.
• It is unclear how traffic was loaded onto the road network in the evacuation traffic analysis. For example, no description is provided with respect to how much traffic was assigned to Fanita Parkway, how much to Cuyamaca Street and, in turn, how much to Magnolia Avenue from Cuyamaca Street. Section 4.18 (p. 4.18-34) says:
. . . the majority of the community traffic would exit the proposed project via Cuyamaca Street or Magnolia Avenue via Cuyamaca Street.
Did the traffic analysis reflect this?
Or did it reflect the following statements from the WFEP (pp. 1-2)? During an evacuation, roughly the western 50% of the Fanita Commons and Orchard Village and the northern 50% of the Vineyard Village would be anticipated to utilize Fanita Parkway to exit the Project site. . . . Evacuation traffic from the eastern 50% of the Fanita Commons and Orchard Village and roughly 75% of the Vineyard Village would be anticipated to utilize these routes for evacuation [Cuyamaca Street, Magnolia Avenue, Princess Joann Road, Woodglen Vista Drive, and El Nopal].
Or did it employ one of the previous traffic distributions documented in the Second Errata to the Final Revised Environmental Impact Report or the Draft Revised Environmental Impact Report, as summarized in Table 2 below?
Mr. Peter J. Broderick
July 22, 2022
Griffin Cove Transportation Consulting, PLLC
Table 2
Previous Project Trip Distribution Assumptions
Street
Trip Distribution Percentage
Second Errata1 DREIR2
Princess Joann Rd. 10% 5%
Woodglen Vista Dr. 5% 5%
El Nopal 5% 10%
Cuyamaca Street
Project Site to Princess Joann Rd. 53% 53%
Princess Joann Rd. to Woodglen Vista Dr. 43% 48%
Woodglen Vista Dr. to El Nopal 38% 43%
Magnolia Avenue
Princess Joann Rd. to Woodglen Vista Dr. 10% 5%
Woodglen Vista Dr. to El Nopal 15% 10%
Notes:
1 Source: Harris & Associates, Second Errata to the Final Revised Environmental Impact Report – Fanita Ranch Project, Volume IV, September 2020.
2 Source: Harris & Associates, Draft Revised Environmental Impact Report – Fanita Ranch Project, May 2020.
• In addition to questions regarding the assumed geographic distribution of evacuating traffic, it is unclear what was assumed in terms of the temporal distribution of traffic. Was all traffic assumed to enter the roadway system at the same time, or was some version of a phased traffic assignment assumed? In regard to this, we note that the two Rohde & Associates “fire service operational assessments” referred to above both include a version of the following statement:
Historical evacuation experience during past San Diego County wildfires has found limited participation by large percentiles of affected populations to evacuation warnings until late in evacuation periods, leading to traffic congestion during peak threat times.5,6
This delayed reaction on the part of potential evacuees must be reflected in the analysis.
Further, the Chen Ryan report (p. 18, with a similar statement at p. 19) says:
Populations located in closer proximity to the safe zone will safely evacuate sooner than the calculated evacuation time. . . . Since the Project is located at the northern most [sic] end of the City of Santee and evacuated residents would travel south, traffic from existing neighborhoods would most likely have arrived at the safe zone by the time traffic from the proposed Project arrived at key intersections.
This statement suggests that the analysis reflects the mistaken notion that residents and others will evacuate immediately upon receiving notification of the need to depart. In reality, as evidenced by the Rohde statements, some portion of the residents located closer to the safe zone will, in fact,
5 Rohde, Otay Ranch Village Resort Village 13 Fire Services Operational Assessment, Feb. 1, 2020, p. 12. 6 Rohde, Otay Ranch Village 14 and Planning Areas 16/19 Fire Services Operational Assessment, March 11, 2020, p. 15.
Mr. Peter J. Broderick
July 22, 2022
Griffin Cove Transportation Consulting, PLLC
delay their departure from home, thereby adding to the traffic demand directly associated with Project-related vehicles as those vehicles pass through the area. In fact, it is reasonable to assume that persons located closer to the safe zone (and, therefore, probably farther from the wildfire) will be initially reluctant to evacuate, increasing the likelihood that they will enter the evacuating traffic stream created by Project vehicles.
In addition, if the analysis assumed that traffic will enter the evacuation in a uniform manner, so that the added traffic will be spread out relatively evenly over time, this represents another deficiency. Simply put, vehicles do not flow smoothly and uniformly, especially in the course of evacuating during an emergency. Instead, sudden surges in traffic would occur during an evacuation; it is extremely unlikely that traffic would be evenly distributed over time. That is, there will be variable pulses in traffic demand, just as there are in everyday traffic flows. These surges in demand will contribute to substantial instability within the evacuating traffic stream. It is not clear whether this characteristic of traffic flow is adequately reflected in the analysis. • The Chen Ryan report is unclear with respect to the actual methodology employed in determining the travel times. Page 16 of that document indicates that the evacuation time was calculated using the following equation:
Evacuation Time = (Evacuation Population / Average Vehicle Occupancy) / Roadway Capacity In contrast, the following page says evacuation events were analyzed using traffic simulations employing the VISSIM software package. These two approaches are vastly different, and the actual approach employed is critical.
The use of the equation presented above is particularly problematical, as this calculation does not, in fact, provide a measure of evacuation time. In order to provide an indication of time (and, in particular, the travel time associated with an evacuation), there must be a distance component in the calculation. In other words, the calculation must answer the question, “How long will it take me to get from Point A (e.g., my home in the proposed Project) to Point B (e.g., a safe location some distance from the wildfire)?” That distance component is lacking from the calculation.
In reality, the calculation described in the Chen Ryan document provides a volume/capacity (V/C) ratio for a given point on a given road. In other words, it is simply a calculation of the volume (V) of traffic estimated to be at a specific location on a particular road divided by the assumed capacity (C) of that road. (In the equation, the traffic volume is calculated by dividing the total number of people by the average number of persons per vehicle.)
It would be completely inappropriate to translate the results of this calculation into a travel time value. This is a particular issue when the calculation results exceed 1.00. For example, a calculation result of 1.50 that was interpreted to indicate a travel time of 1.50 hours or 90 minutes would represent a substantial deficiency in the analysis.
We note that seven of the nine analysis scenarios addressed in the Chen Ryan report had derived travel times in excess of one hour. Based on the discussion presented above, this suggests calculation results in excess of 1.00. As one example, the WFEP (p. 33) describes the evacuation times as “1.3 hours under a mass evacuation scenario and up to 1.2 hours under a targeted or phased evacuation scenario.”
Mr. Peter J. Broderick
July 22, 2022
Griffin Cove Transportation Consulting, PLLC
However, as we pointed out above, the actual result of this calculation is a V/C ratio, not a time value, so when the formula shown above provides a result of 1.3, what it is really finding is that the traffic demand is equivalent to 1.3 times the capacity of the road (i.e., it has a V/C ratio of 1.3), not that the travel time is 1.3 hours. In other words, the traffic demand is 30 percent greater than the capacity of the road.
To provide additional perspective regarding traffic operations, the quality of flow on a road is described in terms of “level of service” (LOS), which ranges from LOS A (free-flowing conditions) to LOS F (highly congested; V/C > 1.00). A V/C ratio of 1.30 indicates operation substantially in excess of the road’s capacity and, by definition, represents LOS F. According to the Highway Capacity Manual (Transportation Research Board, Sixth Edition, 2016, p. 12-18):
Oversaturated conditions are represented by LOS F. LOS F describes unstable flow. . . . breakdown occurs when the ratio of existing demand to actual capacity, or of forecast demand to estimated capacity, exceeds 1.00.
Unstable flow will be manifested in high levels of congestion and stop-and-go traffic, which will increase not only the time needed to evacuate, but also the levels of stress and anxiety for evacuees.
The following graphic illustrates the relationship between LOS and travel speed. As shown, when a roadway reaches LOS F (i.e., V/C > 1.00), the operating speed rapidly declines.
The speed reduction illustrated here will directly translate into increased evacuation travel time.
Travel speed is not linearly related to V/C ratio, particularly when traffic demand is near or beyond the road’s capacity. Instead, the higher the V/C ratio, the greater the level of traffic flow instability and congestion, with stop-and-go operation and increasing levels of driver frustration and stress.
In summary, the equation presented in the Chen Ryan memorandum does not provide a measure of travel time and to interpret it as such is a substantial deficiency in the analysis. This is a particular Speed decreases when V/C > 1.00
Mr. Peter J. Broderick
July 22, 2022
Griffin Cove Transportation Consulting, PLLC
problem when the calculation result exceeds 1.00, as would appear to be the case in seven of the nine analysis scenarios.
CONCLUSION
Our review of the Recirculated Sections of Final Revised Environmental Impact Report completed in connection with the proposed Fanita Ranch project in Santee, California revealed a variety of issues regarding the accuracy and adequacy of the analysis related to evacuations from wildland fires. The deficiencies we have identified raise significant questions as to the validity of the conclusions presented in that document with respect to Project-related impacts.
We believe the recirculated document failed to remedy the previously-identified shortcomings concerning the feasibility of safely evacuating the Project in the event of a wildland fire. Although the current documents address an additional significance threshold regarding wildland fires, no meaningful significance criterion has been established against which to judge the Project-related impact, particularly with respect to evacuation times. In addition, we have raised a number of questions regarding the methodologies employed in the evacuation time analysis, including apparent misinterpretations of the results of an equation that apparently served as a key element of that analysis.
We hope this information is useful. If you have questions concerning any of the items presented here or would like to discuss them further, please feel free to contact me at (906) 847-8276.
Sincerely,
GRIFFIN COVE TRANSPORTATION CONSULTING, PLLC
Neal K. Liddicoat, P.E.
Principal
Attachment
EXPERIENCE
Over the course of the past 45 years, Neal Liddicoat has conducted numerous analyses of complex traffic and transportation issues. He is a licensed Civil Engineer in California, a licensed Professional Engineer in Michigan, a long-standing member of the American Society of Civil Engineers, and a Fellow of the Institute of Transportation Engineers. For a number of years, he served as instructor for the traffic engineering portion of the Civil Engineering licensing exam review course conducted by the Sacramento chapter of ASCE. He has particular expertise in the analysis of traffic operations at major event centers, at which large volumes of traffic arrive and depart in short periods of time. Among the event centers for which he has been primarily responsible for detailed traffic analyses are Crypto.com Arena (formerly Staples Center Arena) in Los Angeles; an 80,000-seat stadium for the Los Angeles Raiders (which was never built, as the team returned to Oakland); Sutter Health Park, a 14,000-seat baseball stadium in West Sacramento; Disney’s California Adventure in Anaheim; and major expansions of the Los Angeles and Anaheim convention centers. He was invited to participate as a member of expert panels reviewing traffic operations plans for the Rose Bowl in Pasadena, California, and State Farm Stadium in Glendale, Arizona. The traffic operations principles in these analyses are similar to those that apply to wildfire evacuation planning and, as such, he Mr. Peter J. Broderick
July 22, 2022
Griffin Cove Transportation Consulting, PLLC
is frequently retained to provide expert comments on the evacuation effects of large-scale residential and mixed use projects like Fanita Ranch, primarily in the San Diego region. As a result of these comments, lead agencies often make revisions or alterations to the projects or the environmental analysis to improve evacuation safety.
Griffin Cove Transportation Consulting, PLLC
ATTACHMENT
PROFESSIONAL RESUME
FOR
NEAL K. LIDDICOAT, P.E.
NEAL K. LIDDICOAT, P.E.
PRINCIPAL
Griffin Cove Transportation Consulting, PLLC
Education
BSCE / Michigan State University, 1977
Graduate Studies, University of Tennessee,
1977 – 1980
Professional Affiliations
Institute of Transportation Engineers – Fellow
American Society of Civil Engineers – Member
Registrations
California – Civil Engineer C35005
Michigan – Professional Engineer 6201037605
Mr. Liddicoat has 45 years of experience in the analysis of a broad range of traffic engineering, parking, and transportation planning issues, for both public and private sector clients. He has conducted traffic and parking analyses for a wide variety of development proposals, including office buildings, retail/ commercial centers, multiplex cinemas, and residential projects. He has a particular expertise in the analysis of unique development proposals, including stadiums, arenas, convention centers, theme parks, and other facilities where large numbers of vehicles and pedestrians converge in a short period of time.
Mr. Liddicoat has developed and presented seminars on technical procedures and quality control in the conduct of traffic impact analyses, both in-house and as a co-instructor for the UCLA Extension Public Policy Program. For several years, he served as instructor for the traffic engineering portion of the Civil Engineering licensing exam review course conducted by the Sacramento chapter of the American Society of Civil Engineers. Significant traffic impact analysis experience includes the following selected projects:
• Folsom, CA – Over 50 traffic analyses, including:
o Folsom Heights Mixed-Use
o Broadstone Estates
o Bidwell Pointe Residential
o Serenade Senior Housing
o Commons at Prairie City
o Country House Memory Care
o Prospect Ridge Residential
• STAPLES Center Traffic Impact Analysis, Los
Angeles, CA
• Sacramento City College Transportation Master
Plan Analysis, Sacramento, CA
• Raley Field Traffic and Parking Analysis, West
Sacramento, CA
• Convention Center Traffic & Parking Studies,
Sacramento, Los Angeles, and Anaheim, CA
• Disney’s “California Adventure” Preliminary
Traffic Analysis, Anaheim, CA
• Warner Bros. Studios Master Plan, Burbank, CA
• Elk Grove Boulevard Master Plan, Elk Grove, CA
• CSUS Bicycle/Pedestrian Study, Sacramento, CA
• SR 99/Twin Cities Road Traffic Operations, Galt, CA
• Thunder Valley Casino, Placer County, CA
Mr. Liddicoat is frequently called upon to serve as an expert “peer reviewer” for traffic impact analyses prepared by others. In that role, he has commented on the technical adequacy of traffic studies for a variety of projects, including retail centers, office complexes, and mixed-use master plans. His recent experience as a peer reviewer includes the following selected projects:
• Materials Recovery Facility, Irwindale, CA
• LAX Landside Access Modernization, Los Angeles, CA
• Granite Bay Circulation Study, Placer County, CA
• Oil Exploration Zoning Ordinance, Kern County, CA
• State Route 85 Express Lanes, Santa Clara Co., CA
• Vacaville General Plan, Vacaville, CA
• Martis Valley West Specific Plan, Placer County, CA
• LAX Terminals 2/3 Modernization, Los Angeles, CA
• Town & Country Hotel/Convention Ctr, San Diego, CA
• University Community Plan, San Diego, CA
• Canyon Springs Residential, Truckee, CA
• Fresno General Plan, Fresno, CA
• Saddle Crest Homes, Orange County, CA
• Brentwood Manor Hotel, Los Angeles, CA
• Highway 43/198 Retail Center, Hanford, CA
• Village at Squaw Valley, Placer County, CA
• Bridgepointe Master Plan Amendment, San Mateo, CA
• Frog’s Leap Winery, Napa County, CA
NEAL K. LIDDICOAT, P.E.
PRINCIPAL
Griffin Cove Transportation Consulting, PLLC
Additional recent peer reviewer experience includes the following projects:
• Los Angeles International Airport (LAX) Airfield
and Terminal Modernization, Los Angeles, CA
• Scarlett Winery, Napa County, CA
• Terra Vi Lodge Yosemite Wildfire Evacuation Plan,
Tuolumne County, CA
• Church of the Woods Evacuation Plan, Rimforest,
CA
• Otay Ranch Village 14 and Planning Areas 16/19
Wildfire Evacuation Plans, San Diego County, CA
• Warner Ranch Evacuation Plan, San Diego County,
CA
• Harmony Grove Village South Wildfire Evacuation
Plan, San Diego County, CA
• The Ranch Project, Antioch, CA
• Rancho La Habra Specific Plan, La Habra, CA
• Safari Highlands Ranch Wildfire Evacuation Plan
and Citywide Sphere of Influence Update,
Escondido, CA
• El Toro, 100-Acre Parcel Development Plan -
Irvine, CA
• Trails at Carmel Mountain Ranch Final EIR &
Wildfire Evacuation Plan, San Diego, CA
• Staglin Family Vineyards, Napa County, CA
• Yosemite Under Canvas Wildfire Evacuation Plan,
Tuolumne County, CA
• Fanita Ranch Wildfire Evacuation Plan, Santee, CA
• Otay Ranch Resort Village 13 Alternative H Wildfire
Evacuation Plans, San Diego County, CA
• Estero Trail Easement Project, Sonoma County, CA
• Faria/Southwest Hills Annexation, Pittsburg, CA
• The Village Student Housing Project, Arcata, CA
• Tulare Pilot Flying J, Tulare, CA
• Davidon/Scott Ranch General Plan Amendment,
Rezoning, and Vesting Tentative Map, Petaluma, CA
• John Adams Academy, El Dorado Hills, CA
• Centennial Project Draft Environmental Impact Report, Los Angeles County, CA
• VillaSport Athletic Club and Spa Project,
Roseville, CA
From: ann z moore < >
Sent: Wednesday, September 14, 2022 1:52 PM
To: Dustin Trotter <[email protected]>; John Minto <[email protected]>; Ronn Hall <[email protected]>; Laura Koval <[email protected]>; Rob McNelis <[email protected]>; Chris Jacobs <[email protected]> Subject: Fanita Ranch
Dear City Council and Mr. Jacobs,
Please respect the will of Santee resident voters. Residents rejected Fanita Ranch sprawl in a landslide referendum vote in 1999. In 2020, residents voted to protect the Santee General Plan from inconsistent sprawl developments like Fanita Ranch. In March 2022, the court ruled against Fanita Ranch for the 4th time, once again aligning with the will of voters.
Campaign contributions should not be able to buy amendments to Santee’s General Plan or exempt developers from the democratic will of Santee voters.
The people of Santee passed Measure N to assure Santee residents make the final decision at the ballot on Fanita Ranch and any other projects that violate the Santee General Plan.
City maneuvers attempting to prevent a vote of the people on the Fanita Ranch project are unethical, anti-democracy and anti-American. Please re-notice the Revised Environmental Impact Report to recognize the legal authority of Santee residents.
Placing a 3,000-unit project with significant traffic impacts into a Cal Fire identified severe fire hazard zone is a significant risk to new residents and to existing residents that must use the same routes for evacuation. The development application should be abandoned and the land permanently conserved through the Department of Defense military base buffer program (REPI).
Thank you
Ann Z Moore
Santee, CA 92071
From: Calistia Griebel
Sent: Wednesday, September 14, 2022 4:35 PM
To: Chris Jacobs <[email protected]>; Ronn Hall <[email protected]>; Laura Koval <[email protected]>; Rob McNelis <[email protected]>; John Minto <[email protected]>; Dustin Trotter <[email protected]> Subject: Disapprove Fanita Ranch, Item 8
Dear Mr. Jacobs and City Council,
Santee residents passed Measure N and qualified a referendum to assure Santee residents would be able to vote on Fanita Ranch.
Item 8 approval of Fanita Ranch with the illegal exclusion of a public vote on the Fanita Ranch project is unethical and un-American.
I urge you to vote NO against the Fanita Ranch project.
Santee is already overcrowded and our existing infrastructure cannot sustain a 3000 unit residential project in a severe fire hazard zone designated by Cal-Fire. This brings high risk to all of our residents and reduced quality of life.
Santee residents do not want or need Fanita Ranch and the problems it will bring to the area. Let the residents vote and make their voice heard please. Fanita Ranch is not in the best interest of the City of Santee.
Thank you,
Calistia Griebel
September 14, 2022
Sent via email [with references provided via FTP]
Santee City Council
City Hall
10601 Magnolia Ave.
Santee, CA 92071
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
Chris Jacobs
Principal Planner
Department of Development Services
City of Santee
City Hall, Building 4
10601 Magnolia Avenue
Santee, California 92071
(619) 258-4100, ext. 182
[email protected]
Re: Final Recirculated Sections of the Final Revised Environmental Impact Report for Fanita Ranch, SCH# 2005061118
Dear Councilmembers and Mr. Jacob:
This letter is submitted on behalf of the Center for Biological Diversity (Center), Preserve Wild Santee, Endangered Habitats League, and the California Chaparral Institute regarding the Final Recirculated Sections of the Final Revised Environmental Impact Report (Final REIR) for Fanita Ranch (Project) (State Clearinghouse No. 2005061118), in advance of the September 14, 2022, City Council meeting.
The Center has participated extensively in the administrative process leading up to the City Council’s September 14, 2022, consideration of the Project and associated approvals. On July 13, 2020, the Center commented on the Draft EIR, and on September 13, 2020, followed up with comments on the Final EIR for the Project. The Center successfully litigated the City’s failure to disclose and analyze the Project’s wildfire-related hazards under the California
September 14, 2022
Environmental Quality Act (CEQA). Most recently, the Center submitted comments to the City Planning Department on the Draft Recirculated Environmental Impact Report (Draft REIR) for the Project, which are incorporated herein by reference.
The Center is a non-profit, public interest environmental organization dedicated to the protection of native species and their habitats through science, policy, and environmental law.
The Center has over 1.7 million members and online activists throughout California and the United States. The Center has worked for many years to protect imperiled plants and wildlife, open space, air and water quality, and overall quality of life for people in Santee and throughout San Diego County.
As an initial matter, we strongly object to the City’s decision to make the Final REIR and associated documents available for public review a mere three business days before the final hearing on the Project. Hundreds of pages of new analysis and technical reports were made public at the last minute under the City’s Response to Comments, depriving the public and decision-makers of the time necessary to review, understand, and comment on the new materials.
The City also failed to respond to the Center’s July 25, 2022 comments on the Draft REIR, which included over 40 references documenting the best available science on fire risk and evacuation planning and expert comments. The City’s failure in this regard violated CEQA and the CEQA Guidelines and severely hindered the Center’s ability to provide feedback to the City Council before the City’s consideration of the Project.
Given the voluminous nature of the new material, which includes significant new information, and the extremely limited time the City has provided for the public to review it, the Center has been unable to fully review and respond. Despite the lack of adequate time to review and comment on the documentation, it is clear that approval of the Project would violate CEQA, the California Planning and Zoning Law, the California Subdivision Map Act, and the California Elections Code. These comments provide responses to some points raised in the Final REIR but are not exhaustive.
I. THE FINAL REIR DOES NOT REMEDY THE DRAFT REIR’S FAILURE
TO ADEQUATELY ANALYZE AND MITIGATE WILDFIRE-RELATED
IMPACTS.
The Final REIR, like the Draft REIR, fails to provide the required evidentiary support for its conclusion that the proposed Project would not expose people or structures to a significant risk of loss, injury, or death from wildland fires.
The Center provided substantial evidence that roads, sprawl development, and increased human presence in the wildland-urban interface can have severe impacts on ignition risk.
Scientific studies—including those relied upon in the Final REIR—continue to highlight the consistent and unambiguous threat of placing communities in high fire-prone areas. The Final REIR does not contest the veracity of these studies. Indeed, the City agrees that the evidence unambiguously shows that lower-density housing poses an increased ignition risk. (Thematic Response to Comments 4c.)
September 14, 2022
Rather than acknowledge that this Project entails these same risks, the Final REIR attempts to conceal any threat by suggesting, absent evidence, that this Project is actually “higher-density.” (Thematic Response to Comments 4c.) The City concludes that, since “lowerdensity housing is a larger ignition issue than higher-density communities,” this Project poses no ignition risk. (Thematic Response to Comments 4c.) The City’s reasoning fails for three reasons.
First, the City still fails to provide any evidence showing that this Project is “higher density,” and this unsupported conclusion is belied by the City’s own description of the Project. (See FEIR at 4.18-24, 4.18-25, Fire Protection Plan (FPP), Figure 3A.) In touting the Project’s housing mix, the City describes the Project footprint as primarily low-density, with “866 medium density residential units, 1,203 low density residential units, 445 active adult residential units, and 435 residential units in the Village Center.” (RTC Thematic Response 3, p. 7.) The EIR’s Fire Protection Plan (FPP) describes the development as “clustered” into 3 villages, two of which are “low density” housing separated by open space corridors. (FPP, p. 7-8.) Second, the City’s conclusion ignores the more nuanced relationship between housing patterns and fire risk, which we presented with evidence to the City in our comment letter. While low- and intermediate-density housing is most at risk, density is not the only relevant factor; location within the larger landscape and configuration within the development also drive fire risk. (See Syphard and Keeley 2020; Syphard et al. 2013.) Other development configurations – such as intermediate and clustered high densities adjacent to wildlands – have also been proven to result in increased ignition risk. That the City believes it could have devised a riskier Project does not relieve the City of its obligation to consider whether this Project will result in an increased risk of wildfire.
Third, the Final REIR continues to assert, absent adequate support, that code compliance and “ignition-resistant” construction (fuel modification zones, landscaping, fire station, and public outreach) would protect adjacent communities from Project-related fires. (Thematic Response to Comments 4c.) The City parades a laundry list of design features—such as “dense” development and 100-foot fuel modification zones—that will make the project “ignition resistant” and thereby reduce fire intensity. (Thematic Response to Comments 4d.) But the Final REIR provides little evidence of how these design features will perform under modern, winddriven firestorms. Instead, the City cites to studies from prior to 2008, and many from decades earlier. (Ibid.) The City’s claim regarding the effectiveness of new building codes in today’s fires is left completely unsupported, but for “personal communications” with its own hired consultant. (Ibid.)
As we explained in our prior comments, with abundant evidentiary support, neither code compliance nor fire hardening are sufficient to protect people from the significant risks posed by wildfires. The evidence shows that so-called “ignition-resistant” structures have performed only marginally better than older structures. Most structure loss occurs due to embers, which are carried by the wind and blown inside or against structures, often miles ahead of any flames. (Moritz 2014.) Even in houses with ignition-resistant roofs, siding, and landscaping, fires still ignite on the other flammable goods that accompany human development: wooden decks or play structures, RVs, boats, lawn furniture, or piles of leaves or debris. (Guerin 2018.) In the 2018 Thomas Fire, for example, 92 percent of destroyed structures had fire-resistant exteriors, and 97
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percent had fire-resistant roofs. (Reax Engineering, p. 9.) In the 2018 Camp Fire, only 13 percent of structures built after 2008 survived. (St. John. 2018.) And in the 2017 Tubbs Fire, the Fountaingrove subdivision was built to fire-resistant standards and fared no better than older structures. (Parkinson 2018; Hickman 2018.)
And as all Californians have experienced in the last five years, climate change increases the likelihood that extreme firestorms will result from any particular ignition. (Radeloff 2018; CAL FIRE 2022 [as of 2022, 15 of the 20 most destructive fires in California history have taken place since 2015].) Climate change is linked to extreme high winds, low humidity, high temperatures, and reduced rainfall. (Moritz 2014, Fuller 2018, Bransford 2018.) All these factors result in increased fire severity, including increased wind-driven ember attacks. These firestorms can overwhelm even “ignition-resistant” communities like the one proposed here.
The REIR ignores the mounting body of evidence that the ability to “outbuild” catastrophic wildfires is severely limited by a changing climate. It references one 2015 study by Syphard and Keeley to suggest that “no large fires in the County since 1990 were determined to have been started within a nearby master planned, ignition-resistant subdivision or neighborhood.” (Thematic Response to Comments 4c.) The study makes no mention of master planned, ignition-resistant communities. It confirms that bringing more people and structures to the wildland-urban interface, regardless of the building materials employed, increases the frequency of ignitions: “substantial population growth has resulted in massive expansion of the wildland–urban interface (WUI), which in turn has led to a surge in the number and areal extent of human-caused ignitions.” (Syphard and Keeley 2015.) It observed that, ignition location is “generally concentrated in proximity to human infrastructure” and that in San Diego County, “[d]istance to roads and structure density” were the biggest predictors of ignition risk. (Syphard and Keeley 2015.) The study concluded that, “not surprisingly,” most ignitions in San Diego County occur close to roads and within the WUI. (Syphard and Keeley 2015.) The City also references a 2016 Syphard and Keeley to support its claim that “the mere presence of new development in the WUI does not equate to increases in fire ignition or acres burned.” (Thematic Response to Comments 4c.) The City misrepresents the study’s findings.
The study observed that fire frequency, as compared to population growth, increased most of the 20th century, peaked in 1980, and then steadily decreased until 2016. (Syphard and Keeley 2016.) The study explained that “as both population and development expand into wildland areas, ignitions increase up to a point at which the area of development, or, impervious surface, far exceeds the area of wildland, and at that point, the relationship becomes negative.” (Syphard and Keeley 2016.) In other words, introducing low- and intermediate-density development into the WUI does undoubtedly increase ignition risk. But once the population further builds out, such that paved surfaces actually exceed non-paved surfaces (like in cities), then the ignition risk decreases. And while the study does note that the development of modern building codes may have attributed to the observed decline in frequency of ignitions, Syphard’s research has confirmed that “residential losses to wildfire have escalated despite enormous investments in wildland fuel manipulation, improvements in fire-safe codes and building regulations, and advanced fire suppression tactics.” (Syphard 2012; emphasis added.)
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The scientific evidence is mounting; bringing people into contact with wildlands, especially via low and intermediate-density development, greatly increases the risk that a wildfire may ignite. The City provides no basis from which to conclude that introducing 9,000 additional people, over 4,000 vehicles, thousands of structures, and numerous roads – all of which would not otherwise be there – into direct contact with flammable wildlands will not increase wildfire risk.1
II. THE FINAL REIR FAILS TO ADEQUATELY DISCLOSE, ANALYZE, AND MITIGATE THE PROJECT’S IMPACTS TO EVACUATION.
A. The WFEP ignores the realities of large-scale evacuation efforts.
What is clear from the past several years of California megafires is that these fires are extremely difficult, if not impossible to stop; the only choice is to get people out of harm’s way.
As the City notes, evacuations hardly go according to plan, and wildfires can reach sizes that quickly overwhelm preexisting plans. The City in its response to comments acknowledges the challenging realities of a large-scale evacuation effort:
- “An important component to successful evacuation is early assessment of the situation and early notification.” (Thematic Response to Comments 4a.) - “The main factors affecting the timing and routing of evacuations are those related to the nature of the wildfire.” (Thematic Response to Comments 4a.) - “A key component of evacuations is the weather. Windy, low humidity days (Red Flag Warning days) are far more prone to result in vegetation ignition escape and spread, resulting in far more sensitive evacuation trigger thresholds.” (Thematic Response to Comments 4a.)
Many commenters, including the Center and the REAX Engineering Reports, noted that all nine scenarios in the City’s evacuation modelling fail to account for these realities, and instead rely on assumptions so flawed that the Final REIR’s results offer little insight.
For instance, although early assessment and notification are an important part of a successful evacuation, all nine scenarios do not account for the time needed to detect a fire, report a fire, for fire response, for evacuation notifications, for mobilization of the public (as people prepare to evacuate), or for notifying special needs citizens. The City offered no response or explanation for excluding these estimations in its total. (Thematic Response to Comments 4a.) Similarly, the City agrees that the nature of the wildfire and wildfire spread are the primary 1 Lacking an honest assessment of the fire risk, the Final REIR also fails to account for the cascading impacts that result from an increased fire risk – degraded habitat (Jennings 2018, Keeley 2005, Keeley 2006), altered fire regimes (Syphard 2009), and respiratory and cardiovascular impacts from poor air quality. (Delfino 2009, Kunzli 2006, Liu 2015, Phuleria 2015, Rappold 2012, Reid 2016.)
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factors affecting timing and the route of evacuations, which led the City to acknowledge that “[e]vacuation routes that are considered acceptable when a wildfire is distant may be considered unsafe when a wildfire is in closer proximity.” (Thematic Response to Comments 4a.) Inexplicably, all nine scenarios assume a fire originates far away from the Project site, omitting any study of whether the City’s proposed evacuation routes would be “acceptable” should a fire ignite closer to the Project site.
Our letter, together with the REAX Engineering Reports, provided substantial evidence that the City relied on flawed methodology and inaccurate assumptions in evaluating the Project’s evacuation impacts. The Final REIR does nothing to resolve these concerns, and the City’s responses only confirm that it disregarded the realities of an evacuation. Because it relied on plainly false assumptions, the Final REIR did not adequately address the Project’s potential to expose people or structures to a significant risk of loss, injury or death from fires ignited inside or near the Project area. Consequently, the EIR lacks the evidentiary basis to support its conclusion that wildland fire-related impacts would be less than significant.
B. The Final REIR Omits Key Assumptions Underlying its Evacuation Analysis.
The San Diego Superior Court found that the City’s original evacuation analysis for the Project was deficient under CEQA, in part, because the City had failed to provide key data underlying its evacuation analysis. (Final Writ and Judgment.) Without time estimates and the number of vehicles exiting the Project, the Court reasoned, it was “not clear…whether a ‘staggered’ evacuation would be adequate to safely evacuate residents and the surrounding community.” (Ibid.) The Court found the lack of adequate information and support for the agency’s methodology to be problematic and ordered the City to provide this relevant information. (Ibid.) The Court then invalidated the Project approvals and ordered the City to study whether the Project would expose people to a significant risk of loss, injury, or death involving wildland fires.
The Final REIR’s evacuation analysis still omits fundamental information supporting its analysis. The Wildland Fire Evacuation Plan (WFEP) used the following equation (provided in the County of San Diego – Operational Area Emergency Operations Plan – Annex Q Evacuation Plan) to model the Project’s evacuation times:
Evacuation Time = (Evacuation Population / Average Vehicle Occupancy) / Roadway Capacity
The WFEP discloses the evacuation population and number of vehicles evacuating. (WFEP, Appendix D at 13.) The WFEP presents the final evacuation times. (WFEP, Appendix D at 18.) But the WFEP offers no information on the third variable in its analysis: roadway capacity. The WFEP’s results remain a black box; the public has no way to independently verify, and comment upon, the results. The City’s responses did not fill in this clear analytical gap. The Final REIR still does not contain “sufficient detail to enable those who did not participate in the preparation to understand and to consider meaningfully” the evacuation impact. (Sierra Club v.
County of Fresno (2018) 6 Cal.5th 502, 516.)
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From there, the City makes no effort to connect this approximately 19-minute to 2-hour evacuation time frame to whether the Project would create a significant safety risk. In response to concerns that the Project offered no basis by which to conclude that the estimated evacuation times would allow people to safely evacuate, the City focused on Santee’s “extremely high success rate” in past evacuations and “technological advancements.” (Thematic Response to Comments 4b.) The City asks the public to trust its conclusion, without any standard by which to independently assess the City’s findings.
The San Diego Superior Court ordered the City to analyze whether residents could “safely evacuate” from the Project, by studying whether the Project would expose people to a significant risk of loss, injury, or death involving wildland fires. The Final REIR still provides no evidentiary basis for the assumption that the modelled evacuation times would not do so.
C. The Final REIR defends the fiction of a “surgical” evacuation.
The Project REIR presents an analysis of evacuation times, evaluating nine scenarios ranging from a claimed “Most Probable Evacuation” involving 1,885 vehicles to a total/mass evacuation scenario labeled “Existing Land Uses Plus Project with Magnolia Avenue Extension,” involving 24,956 vehicles. (WFEP, Appendix D at 13.) Between those two extremes are “targeted” scenarios involving “surgical” evacuations, resulting in evacuation times from 19 minutes to 1 hour, 57 minutes. (Ibid.) For these “surgical” evacuations, the WFEP assumes that only perimeter homes in the Project will evacuate. Under the evacuation scenario the REIR describes as “most probable,” for example, the REIR assumes only those residents on the outermost block of the very northern edge of the Project development would evacuate:
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(WFEP Appendix D, Figure 3A and Figure 3B.)
The City provides no evidence that such targeted evacuations are happening anywhere in the state, or that the City could successfully execute such a targeted evacuation. Neither the Unified San Diego County Emergency Services Organization nor the County of San Diego Operational Area Emergency Operations Plan – Evacuation Annex Q suggest the use of these precise evacuations in the event of wildfire.
One need only look to the live evacuation orders for active wildfires in California to see that perimeter evacuation is a myth. On September 5, 2022, the Fairview fire ignited east of Hemet and quickly exploded to more than 2,000 acres. (Ding 2022.) Two people were killed, and one severely injured in the fast-moving blaze. (Ibid.) The following evacuation order was issued over at least 100 square miles:
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2 The Mosquito Fire, which erupted last week near Lake Tahoe, in the midst of “record-breaking fuels” and “historically dry fuels,” has forced thousands to evacuate. (Toohey 2022.) As of last Friday, CAL FIRE issued the following evacuation orders along 12 miles of the Placer County boundary:
2 San Diego authorities issue real-time maps of evacuation orders. This map for the Fairview Fire was pulled on September 9, 2022, at approximately 2:27 pm. Since these maps are updated constantly to give residents real-time information, this map is no longer available online. (https://emergencymap.sandiegocounty.gov/index.html.)
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3 These evacuations show that law enforcement do not parse block by block, especially in fastchanging situations. (Smith 2022.) Fires cross rivers, traverse highways, and send embers miles ahead of the flames. (Toohey 2022, Gabbert 2022, Hamilton 2018.) It is foolish to assume – absent the proven effectiveness of a surgical evacuation – that this City can rely on such evacuations to keep Project and downwind residents safe. (Lundstrom 2018.) The REIR evaluates the impacts to evacuation in bite size pieces; it chopped a massive project—entailing a 17 percent increase in the City’s population – into little ones, each with a minimal impact, to avoid full environmental disclosure. (CEQA Guidelines §15003(h); Bozung v. LAFCO (1975) 13 Cal.3d 263, 283; California Unions for Reliable Energy v Mojave Desert Air Quality Mgmt. Dist. (2009) 178 Cal.App.4th 1225, 1249.) This study amounts to improper piecemealing.
Determining whether an evacuation can be successfully accomplished is the first step in evaluating whether the Project would pose a threat to public safety. (CEQA Guidelines § 15126.2(a).) The aforementioned information is precisely what must be considered in order to determine whether an evacuation can be successfully accomplished.
III. PROJECT APPROVAL WOULD VIOLATE STATE PLANNING AND
ZONING LAW AND THE SUBDIVISION MAP ACT, IN ADDITION TO
CEQA.
3 This map for the Mosquito Fire was pulled on September 9, 2022, at approximately 2:35 pm. Because these maps are updated regularly to give residents real-time information, this particular map is no longer available online. (https://www.fire.ca.gov/incidents/2022/9/6/mosquito-fire/#evacuation-map.)
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The Project is inconsistent with the General Plan adopted by the City of Santee. The Project proposes residential development on land clearly designated as Specific Plan or PD— Planned Development or HL—Hillside Limited Residential and R1– Low Density Residential. (Santee General Plan, p. 1-3; Santee 2022.) The Specific Plan land use designation requires preparation of a specific plan for future development of those areas. (City of Santee 2022.) Yet the project evaluated in the REIR expressly purports not to include a specific plan, and proposes a higher density development than what the General Plan allows. Furthermore, the General Plan’s Land Use Element sets forth requirements specific to the Fanita Ranch site including, but not limited to: traffic, transportation, and roadway improvements; minimum lot sizes, planning requirements, park dedication, and specific amenities. (Santee General Plan, Land Use Element at 1-29 to 1-31.)4Yet, the proposed Project does not comport with these requirements. (Tellingly, because the Project was inconsistent with the Santee General Plan, the City originally sought a general plan amendment for the Project.)
Under the State Planning and Zoning Law (Gov. Code § 65000 et seq.), development approvals, including zoning ordinances, development agreements, subdivision maps, and “other plan[s]” must be consistent with the applicable general plan (Gov. Code §§ 65860(a), 65867.5(b), 65567, 65359). Because the Project is inconsistent with the General Plan’s land use requirements for development on the site, approving the Project as proposed would violate the State Planning and Zoning Law and Subdivision Map Act.
Separately, the REIR’s failure to disclose the Project’s inconsistency with the General Plan violates CEQA. CEQA requires that agencies analyze a project’s consistency with applicable land use plans. (Napa Citizens for Honest Gov. v. Napa County Bd. Of Supervisors (2001) 91 Cal.App.4th 342, 386-87; CEQA Guidelines § 15125(d); CEQA Guidelines Appendix G, § X.) Inconsistencies with plans that were enacted to protect the environment are significant impacts in themselves and can be evidence of other significant impacts. As described above, the Project is inconsistent with the City’s General Plan. But the REIR fails to acknowledge these inconsistencies and therefore fails to consider the environmental impacts that would follow from developing this area contrary to the General Plan. This undermines the REIR as an informational document and violates CEQA (See Communities for a Better Environment v. South Coast Air Quality Management Dist. (2010) 48 Cal.4th 310, 322).
The City contends that its designation of the Project as an “Essential Housing Project” obviates the need to analyze consistency and comply with the General Plan. (See REIR at 3-1.) The City is wrong. The City created its “Essential Housing Project” designation process through Santee Ordinance No. 592 (2021).5
The City now asserts that Ordinance No. 592 permits it to determine that certain projects are deemed automatically consistent with the General Plan. Not so. The general plan is a local agency’s “constitution” for all future development within the jurisdiction, and located at the top of the hierarchy of local government law regulating land use. (DeVita v. County of Napa (1995) 9 Cal.4th 763, 773.) Local agencies may not usurp the General 4 Available at: https://www.cityofsanteeca.gov/home/showpublisheddocument/7191/636336569667170000 (accessed September 13, 2022).
5 The Ordinance was improperly adopted as an “urgency” ordinance, but failed to comply with state law requirements for the adoption of urgency ordinances.
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Plan’s primacy through ordinance.6 The City’s “Essential Housing Program” cannot supplant or excuse away state law requirements that the Project be consistent with the General Plan.
IV. PROJECT APPROVAL WOULD VIOLATE THE CITY’S OWN VOTERAPPROVAL REQUIREMENT (MEASURE N).
In November 2020, the voters of the City of Santee adopted the Santee General Plan Protection Initiative, which became known as “Measure N.”7 Measure N amended the General Plan “to require a vote of the people for certain development projects.” (Measure N, Section
1.A.) Under the measure’s Policy 12.1:
No General Plan amendment, Planned Development Area or new Specific Planning Area shall be adopted which would:
1) increase the residential density permitted by law,
2) change, alter, or increase the General Plan Residential Land Use categories if the change intensifies use; or
3) change any residential designation to commercial or industrial designation on any property, or visa versa, if the change intensifies use; unless and until such action is approved and adopted by the voters of the City at a special or general election, or approved first by the City Council and then adopted by the voters in such an election.
The City and the Project proponent’s attempt to strip the legislative approvals from the Project is a transparent attempt to circumvent this requirement of Measure N and to deprive the voters of their right to approve or disapprove of the Project.
V. PROJECT APPROVAL WOULD VIOLATE THE ELECTIONS CODE.
As explained in greater detail in the Center’s June 8, 2022 letter to the City [attached as Exhibit A], on September 23, 2020, by Resolution 094-2020, the City Council adopted a General Plan Amendment for the Fanita Ranch Project. On October 29, 2020, the voters of the City of Santee filed a referendum petition with the City Clerk’s office seeking a vote to overturn Resolution 094-2020 and thereby rescind the General Plan Amendment. On January 13, 2021, the City Council decided not to repeal the General Plan Amendment, and instead adopted Resolution 006-2021, which submitted the referendum to the voters at the November 8, 2022 General Municipal Election. On January 23, 2021, the City Clerk presented the Certificate of Sufficiency for the Referendum to the City Council.
On April 26, 2022, after finding that the City violated state law when it approved the Fanita Ranch Project without conducting the requisite environmental review, the San Diego 6 Ordinance No. 592 did not (and did not purport to) amend the City’s General Plan. 7 A copy of the full text of the initiative is available at: https://preservewildsantee.org/wpcontent/uploads/2018/05/Santee-General-Plan-Protection-Initiative-Final-submitted-04062018.pdf (last accessed September 13, 2022).
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Superior Court ordered the City to rescind all project approvals for the Fanita Ranch Project, including Resolution No. 94-2020, the subject of the referendum. On May 25, 2022, the City Council repealed Resolution 094-2020 in response to the Court’s order.
Once a qualified referendum is presented to a city, the city has a ministerial duty to either repeal the underlying legislation or place the referendum on the ballot. (Elec. Code, § 9241, Widders v. Furchtenicht (2008) 167 Cal.App.4th 769, 775.) It cannot escape this mandatory duty absent a court order. (Id. at 779.) Critically, whether the referendum is passed by a vote of the people or the city repeals the underlying legislation, the city is barred from enacting similar legislation for one year, either from the date of rescission or the date the vote becomes effective. (Elec. Code, § 9241.) This stay provision temporarily reverts legislative power over the particular subject matter to the people, and the legislative body may not violate that stay by enacting essentially the same legislation on the same subject matter. (Lindelli v. Town of San Anselmo (2003) 111 Cal.App.4th 1099, 1110.)
By certifying the REIR and approving the Project, the City is adopting “essentially the same” approvals that it repealed in May 2022 as a result of the Court’s writ and judgment, and— according to the City—consistent with Elections Code section 9241’s option of repeal in place of referring to the voters. The REIR makes clear that the Project that is being proposed for the City’s consideration and approval is identical in every material way to the Project repealed in May 2022. Courts have consistently rejected local agencies’ efforts to circumvent section 9241’s one-year stay provision by merely reworking the underlying approvals. (See Martin v. Smith (1959) 176 Cal.App.2d 115 [after a referendum petition challenged the commercial lease of public land, city’s passage of a new resolution which altered the length of the lease and the affected land violated one-year provision]; see also Lindelli v. Town of San Anselmo (2003) 111 Cal.App.4th 1099, 1110.) In doing so, courts look at the “fundamental principle” of the legislative actions with which voters were concerned. (Martin, 176 Cal.App.2d at 120.) Here, the proponents of the Fanita Ranch referendum expressed objections to Resolution 94-2020, including that it is a “massive sprawl project” with “significant documented traffic, fire safety, and environmental impacts”; that it is “irresponsible” to place thousands of residents in a high fire risk area; concern over “jammed roads for evacuation and daily commutes”; and “unavoidable impacts on our streets and highways.”8
These animating concerns apply with equal
force to the Project once more being brought before the City Council. Contriving to strip this development project of its original General Plan Amendment component while preserving its particulars (such as the unit count, footprint, and nearly every other relevant aspect of the Project) does not permit the City to ignore Elections Code section 9241’s one-year stay requirement. If it certifies the REIR and approves the Project prior to the expiration of this period, it will do so in violation of the Elections Code.
VI. SIGNIFICANT NEW INFORMATION REGARDING BIOLOGICAL
IMPACTS MEANS THAT THE EIR MUST BE RECIRCULATED.
8 Stop Fanita Ranch Vote NO on Nov 8th, https://www.stopfanitaranch.com/act-today (last visited September 13, 2022).
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CDFW identified the Crotch bumble bee as a candidate species for eventual listing under the California Endangered Species Act (“CESA”) in June 2019 and subsequently provided notice of this determination and an evaluation report. (California Fish and Game Commission 2019, CDFW 2019; see also Xerces Society 2018.)9
Nonetheless, the 2020 FEIR downplayed the
Crotch’s likelihood of occurrence on the site, disagreeing with the Center’s comment that the bee occurs on the site (see 2020 FEIR at 4-O6-62 to -64.). However, the iNaturalist database includes two recent observations of Crotch’s bumble bee in Santee, including one from March 15, 2020 on the Project site10; the second observation is from June 3, 2021 in Mast Park11. The observation was identified as a Crotch’s bumble bee by John Ascher, a taxonomic expert and a former curator at the American Natural History Museum, and is designated “Research Grade” (accuracy is highly reliable and may be used for scientific research).
This high-quality evidence of the presence of a protected species onsite is “significant new information” requiring recirculation of the EIR. Moreover, the EIR’s and REIR’s failure to properly evaluate or disclose the species’ presence on the site or the Project’s impacts to it means that the environmental documents did not properly disclose the environmental baseline conditions on the Project site, did not adequately analyze the extent or significance of impacts to the species, and therefore did not consider or adopt mitigation to reduce these impacts. The 2020 FEIR also stated that “the legality of listing the bees is currently in litigation.” (2020 FEIR at 4- O6-62 to -64.) As noted, this litigation has been resolved, with the Court of Appeal determining that invertebrates such as the Crotch’s bumble bee are covered under CESA. The EIR and/or REIR should be revised to include this information, after the City has taken the necessary steps (such as conducting protocol surveys for the Crotch’s bumblebee) to consider and disclose this impact.
VII. CONCLUSION
This REIR, with its glaring deficiencies, cannot properly form the basis of a final EIR.
The City also has failed to name the California Department of Transportation (“CalTrans”) and the California Public Utilities Commission as responsible agencies with discretionary approval over crucial aspects of the Project, including the Magnolia extension at issue in the prior litigation. (RTC-S2-4, RTC-O1-1.) In light of the shortcomings described above, the City should decline to approve the Project, postpone approval until these agencies have had the opportunity to review the REIR and provide feedback to the City, and, at a minimum, recirculate the EIR for additional review and public comment. The City must also allow the voters of the City of Santee to exercise their right to approve or disapprove of the Project at the ballot.
Because of the possibility that the Center will be required to pursue legal remedies in order to ensure that the City complies with its legal obligations including those arising under CEQA, we would like to remind the City of its statutory duty to maintain and preserve all 9 Although the Fish and Game Commission’s candidacy determination was subject to legal challenge on the grounds that the commission lacked statutory authority to list the species under the California Endangered Species Act (“CESA”), the Court of Appeal ruled in favor of the Commission in a published opinion. (Almond Alliance of California v. Fish & Game Com. (2022) 79 Cal.App.5th 337.) 10 https://www.inaturalist.org/observations/40049520 [attached as Exhibit B]. 11 https://www.inaturalist.org/observations/81486959 [attached as Exhibit C].
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documents and communications that may constitute part of the “administrative record” of this proceeding. (Pub. Res. Code § 21167.6(e); Golden Door Properties, LLC v. Superior Court (2020) 53 Cal.App.5th 733.) The administrative record encompasses any and all documents and communications that relate to any and all actions taken by the City with respect to the Project, and includes “pretty much everything that ever came near a proposed [project] or [] the agency’s compliance with CEQA . . . .” (County of Orange v. Superior Court (2003) 113 Cal.App.4th 1,
8.) The administrative record further includes all correspondence, emails, and text messages sent to or received by the City’s representatives or employees, that relate to the Project, including any correspondence, emails, and text messages sent between the City’s representatives or employees and the Project applicant’s representatives or employees. Maintenance and preservation of the administrative record requires that, inter alia, the City (1) suspend all data destruction policies; and (2) preserve all relevant hardware unless an exact replica of each file is made.
Please add the Center to your notice list for all future updates to the Project and do not hesitate to contact the Center with any questions at the number or email listed below.
Sincerely,
Peter J. Broderick
Senior Attorney, Center for Biological Diversity
1212 Broadway, Suite #800
Oakland, CA 94612
Tel: (510) 844-7100
[email protected]
Hallie Kutak
Staff Attorney | Senior Conservation Advocate
Center for Biological Diversity
1212 Broadway, Suite #800
Oakland, CA 94612
Tel: (510) 844-7117
[email protected]
September 14, 2022
References
Bransford, S. (2018, July 27). As Carr Fire Kills 2 in California, Firefighters Reflect on a Job Now ‘Twice as Violent.’ New York Times.
California Department of Fire and Forestry Protection. (2022). Top 20 Most Destructive California Wildfires.
California Deparment of Fish and Wildlife (CDFW). (2019). Evaluation of the Petition from the Xerces Society, Defenders of Wildlife, and the Center for Food Safety to List Four Species of Bumble Bees as Endangered under the California Endangered Species Act. Availabe at:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=166804&inline California Fish and Game Commission. (2019). California Fish and Game Commission Notice of Findings: Crotch Bumble Bee (Bombus crotchii), Franklin’s Bumble Bee (Bombus franklini), Suckley Cuckoo Bumble Bee (Bombus suckleyi), and Western Bumble Bee (Bombus occidentalis occidentalis). Available at:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=170351&inline City of Santee (2003). City of Santee General Plan 2000-2020, Land Use Element. Available at:
https://www.cityofsanteeca.gov/services/development-services/planning-andzoningservices/general-plan.
Ding, J. (2022, September 5). Two dead, multiple structures burn as fast-moving fire near Hemet explodes. Los Angeles Times. Available at: https://www.latimes.com/california/story/2022- 09-05/brush-fire-spreads-near-hemet.
Fuller, T. (2018, November 9). ‘The Whole World Was on Fire’: Infernos Choke California, Piling on the Grief. New York Times.
Gabbert, B. (2022, August 31). Border 32 Fire southeast of San Diego prompts evacuations.
Wildfire Today.
Guerin, E. (2018, December 10). New houses, built to fire code, burned down anyway in Southern California’s 2017 Thomas Fire. KPCC.
Hamilton, M. (2018, November 13). As toll mounts from Malibu to Thousand Oaks, how did the Woolsey fire become a monster? Los Angeles Times.
Hickman, M. (2018, August 27). Limiting suburban sprawl can ease the devastation of wildfire.
Mother Nature.
Moritz, M., Batllori, E., Bradtsock, R., Gill, M., Handmer, J., Hessburg, P., Leonard, J., McCaffrey, S., Odion, D., Schoennagel, T., and Syphard, A. (2014). Learning to coexist with wildfire. Nature. 2014 Nov 6; 515(7525):58-66.
September 14, 2022
Parkinson, P. (2018). We came, we planned, we were wrong. Northern News.
Smith. H. (2022, September 7). California fires killing people before they can escape their homes, making seconds count. Los Angeles Times.
St. John, P. (2018, December 30). Here’s how Paradise ignored warnings and became a deathtrap. Los Angeles Times.
Syphard, A. D. and Keeley, J. E. (2020). Factors Associated with Structure Loss in the 2013–2018 California Wildfires. Fire, 2019, 2, 49.
Syphard, A. D., Keeley, J. E., Massada, A., Brennan, T. B., Radeloff, V. (2012). Housing Arrangement and Location Determine the Likelihood of Housing Loss Due to Wildfire.
PLoS ONE, 7(3): e33954.
Syphard, A. D., Massada, A. B., Butsic, V., & Keeley, J. E. (2013). Land use planning and wildfire : Development policies influence future probability of housing loss. PLoS ONE, 8(8), e71708. https://doi.org/10.1371/journal.pone.0071708 Toohey, G. (2022, September 13). Mosquito fire grows past 50,000 acres in ‘historically dry’ brush as another blaze ignites west of Tahoe. Los Angeles Times.
Xerces Society et al. (2018). A Petition to the State of California Fish and Game Commission.
Available at: https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=161902&inline.
Exhibit A
June 8, 2022
Sent via email
City Council
City of Santee
10601 Magnolia Ave.
Santee, CA 92071
[email protected]
Re: Fanita Ranch Referendum (Agenda Item #10, June 8, 2022 City Council Meeting) Dear Mayor Minto and City Councilmembers:
These comments are submitted on behalf of the Center for Biological Diversity (the “Center”) regarding the City’s proposed repeal of Resolution No. 006-2021 (Agenda Item #10, June 8, 2022 City Council Meeting), which repeal would remove the voter referendum on the Fanita Ranch Project General Plan Amendment from the November 2022 ballot. The City should not deprive the voters of the opportunity to vote on the Fanita Ranch Project General Plan Amendment in November.
The Center is a non-profit, public interest environmental organization dedicated to the protection of native species and their habitats through science, policy, and environmental law. The Center has over 68,000 members and online activists throughout California and the United States.
The Center has worked for many years to protect imperiled plants and wildlife, open space, air and water quality, and overall quality of life for people in the City of Santee.
On September 23, 2020, by Resolution 094-2020, the City Council adopted a General Plan Amendment for the Fanita Ranch Project. On October 29, 2020, the voters of the City of Santee filed a referendum petition with the City Clerk’s office seeking a vote to overturn Resolution 094-2020 and thereby rescind the General Plan Amendment. On January 13, 2021, the City Council decided not to repeal the General Plan Amendment, and instead adopted Resolution 006-2021, which submitted the referendum to the voters at the November 8, 2022 General Municipal Election.
On April 26, 2022, after finding that the City violated state law when it approved the Fanita Ranch Project without conducting the requisite environmental review, the San Diego Superior Court ordered the City to rescind all project approvals for the Fanita Ranch Project, including Resolution No. 94-2020, the subject of the referendum. On May 25, 2022, the City Council repealed Resolution 094-2020 in response to the Court’s order.
The City now apparently wishes to avoid holding a vote on the Fanita Ranch Project—a vote it already committed to when it decided in January 13, 2021 to submit the referendum to the voters.
The City’s Staff Report justifies this attempt to avoid voter accountability by urging that a June 8, 2022
referendum vote would be a “meaningless act,” “legally moot,” and “without purpose” because the City has already repealed the subject General Plan Amendment under court order. The conclusion is wrong in several respects. First, the City lacks the discretionary authority to conclude that a qualifying referendum is moot. (See Widders v. Furchtenicht (2008) 167 Cal.App.4th 769, 779 [submitting qualifying measures to the voters is a ministerial act].) Additionally, the referendum vote will, in fact, have a legal effect: if voters disapprove of the General Plan Amendment (as is likely), the City will be prohibited by law from enacting similar legislation for one year from the date of the election. (Elec. Code § 9241.) Finally, allowing the voting public to weigh in on the Fanita Ranch Project through an up-or-down vote is a key aspect of participatory decision-making and serves the underlying democratic purpose of California’s constitutionally authorized voter referendum process.
As the City is aware, Santee voters referended a prior City-approved development on the site of the Fanita Ranch Project in the late 1990s.
The City cannot use its failure to comply with the law when it adopted the General Plan Amendment for the Fanita Ranch Project as a justification avoiding voter accountability and the City’s obligations under the Elections Code, which arose after the City decided to place the referendum on the November 2022 ballot. The referendum should remain on the ballot.
Given the possibility that the Center will be required to pursue legal remedies in order to ensure that the County complies with its legal obligations we would like to remind the City of its statutory duty to maintain and preserve all documents and communications that may constitute part of the administrative record of this proceeding. Please include the Center on your notice list for all future City activity relating to the Fanita Ranch Project and do not hesitate to contact the Center with any questions at the number or email listed below .
Sincerely,
Peter J. Broderick,
Attorney
Center for Biological Diversity
1212 Broadway, Suite #800
Oakland, CA 94612
Tel: (510) 844-7100
[email protected]
CC: [email protected]
[email protected]
[email protected]
[email protected]
[email protected]
EXHIBIT B
EXHIBIT C
From: Beth Frice >
Sent: Wednesday, September 14, 2022 5:57 PM
To: Chris Jacobs <[email protected]>; Ronn Hall <[email protected]>; Laura Koval <[email protected]>; Rob McNelis <[email protected]>; John Minto <[email protected]>; Dustin Trotter <[email protected]> Subject: Fanita Ranch, Item 8 - Disapprove!
Dear Mr. Jacobs and City Council,
The people of Santee passed Measure N and qualified a referendum to assure Santee residents make the final decision at the ballot on Fanita Ranch.
Item 8 approval of Fanita Ranch with the illegal exclusion of a public vote on the Fanita Ranch project is unethical, anti-democracy and anti-American. I urge you to vote against it.
Placing a 3,000-unit project with significant traffic impacts into a Cal Fire identified severe fire hazard zone is a significant risk to new residents and to existing residents that must use the same routes for evacuation. The development application should be abandoned and the land permanently conserved through the Department of Defense military base buffer program (REPI).
Thank you,
Elizabeth Frice
From: Erin D.
To: Chris Jacobs
Subject: Opposition to Fanita Ranch/ Sept 14th CIty Council Meeting Date: Wednesday, September 14, 2022 3:21:32 PM
Hello,
This email is my legal and written testament to the opposition of the approval of the Fanita Ranch Development that the City Council of Santee may try to approve. Measures by voters and citizens of Santee were undertaken to make the approval of building this development go to voters of Santee residents via a ballot vote. It seems that this is not being followed.
Given this, it seems the City of Santee is engaging in unethical and potentially illegal behaviors in regards to City/Government protocol. This email is to be on record that I disapprove and am aware of the City Council's failure to send this decision to the voters.
Research and experts by official fire studies and environmentalists have clearly highlighted that this area of potential build is a high-fire zone; yet, it seems that the city of Santee, the City Council, and developers of Fanita Ranch are putting profits before safety and the agreed-upon voter referendum regarding this matter. This is not okay.
In addition, the city roads and infrastructure are not adequately designed to handle the traffic of nearly 3,000 more homes. Proceeding with this development is putting the city of Santee and current residents at risk.
Again, as a voting resident of Santee for over 19 years, I oppose this development. The City Council should be sending this matter to a vote by registered voters as was recently agreed upon in the court system. To not send this matter to a citizen vote seems that this City Council is pandering to the developers of Fanita Ranch and does not value the "voice" of Santee's citizens.
I as a citizen often wonder if the developers of Fanita Ranch are giving financial "perks" to those on the City Council Board and City officials to "push" this project "through," while ignoring the majority of Santee residents' who disapprove of this project.
This email is again, legal testament and opposition to the approval and potential development of Fanita Ranch.
With Sincerity and Frustration,
Dr. Erin Doherty
Santee Resident since 2003
*This email has been sent prior to the Sept 14th, 2022 City Council meeting which is discussing the approval of Fanita Ranch. I wish it to be recorded in city records in case of potential legal concerns against the city of Santee.
From: Iliana Sonntag
Sent: Wednesday, September 14, 2022 2:09 PM
To: Rob McNelis <[email protected]>
Subject: Fanita Ranch vote
Mr. McNelis,
I object to the city council's illegal approval of the Fanita Ranch project scheduled on 9/14/22. Why are Fanita Ranch project approvals on the meeting agenda? Re-approval is not permitted for at least one year after the city rescinded project approvals in May of 2022.
The project must face Santee voters. When will it do so? We have a say in what happens in our community and a legal right to vote on this proposal.
The City “Essential Housing Certification” appears to be a sham and a ruse devised to circumvent the citizens of Santee who hold ultimate land use authority. There is no urgency to place luxury housing in a severe fire hazard zone or to further gridlock Santee streets with over 26,000 new vehicle trips per day.
The state is in a major drought and climate emergency and there should be NO new housing built.
Please include my objection in the Administrative Record for the project. I totally disapprove of this action.
Thank you,
Iliana M Sonntag
Santee resident
East Elliott, Santee Lakes East
From: [email protected] <[email protected]> Sent: Wednesday, September 14, 2022 7:45 AM
To: Rob McNelis <[email protected]>
Subject:
Message submitted from the <Santee, CA> website.
Site Visitor Name: Lisa McKean
Site Visitor Email:
Please vote NO on the Fanita Ranch housing project
From: Mark Cafferty <[email protected]>
Sent: Wednesday, September 14, 2022 4:39 PM
To: John Minto <[email protected]>; Rob McNelis <[email protected]>; Laura Koval <[email protected]>; Ronn Hall <[email protected]>; Dustin Trotter <[email protected]>; Chris Jacobs <[email protected]> Subject: Fanita Ranch
Dear Santee Mayor, Councilmembers, and City Planning Leadership:
On behalf of the San Diego Regional EDC, please accept this letter as a show of support for the construction of additional housing opportunities brought by Fanita Ranch.
The EDC is an independently funded non-profit organization, with a mission to maximize the San Diego region’s economic prosperity and global competitiveness. The availability of housing is a throughline in the work we do and imperative to the health and prosperity of the residents of our region and the economic viability of the member companies we represent.
Last year, we saw almost 60,000 new jobs created across the region, but added less than 10,000 new housing units. Year after year, this continued underbuilding has led to skyrocketing housing prices, and many residents have been priced out of the market as a function of the undersupply. Approval of additional and responsible residential development will help address this shortfall of housing and position regional employers to better meet the needs of our growing workforce.
Thank you in advance for your thoughtful consideration.
Sincerely,
Mark Cafferty
Mark Cafferty | President & CEO
San Diego Regional EDC |
o|619 234 8484
530 B Street • Suite 700 • San Diego, CA 92101
Join us at our Annual Dinner!
From: Melissa Stern
Sent: Wednesday, September 14, 2022 10:32 AM
To: Dustin Trotter <[email protected]>; Ronn Hall <[email protected]>; Laura Koval <[email protected]>; Rob McNelis <[email protected]>; John Minto <[email protected]>
Cc: Chris Jacobs <[email protected]>
Subject: Please Approve Fanita Ranch
Dear City Council members,
This email is to show my support of Fanita Ranch. Fanita Ranch has been planned for too many years. It’s time to approve it so more families will have the opportunity to own a home here in San Diego County. We are in a severe housing crisis and this project provides the much needed housing that we desperately need. I have reviewed the information on Fanita and it looks awesome.
HomeFed has been developing Master Planned communities in San Diego County for 25 years. They know how to create a community that people want to call home.
The amenities that are planned are incredible. Miles of trails, a walkable sustainable community is exactly what we are looking for. Acres and acres of parks and an organic farm are fantastic. Please approve Fanita Ranch so more San Diegans will be able to own a home.
Thank you,
Melissa Stern
San Diego Resident
From: michael mcsweeney
To: Chris Jacobs
Subject: Fw: Failure Notice
Date: Wednesday, September 14, 2022 3:41:52 PM
Attachments: Fanita Ranch letter.pdf
Dear Mr. Jacobs:
Last evening I tested positive for Covid and will be unable to testify before your City Council this evening.
Attached is my message to your Mayor and Councilmembers. Would you be so kind as to provide each of them with my letter (attached)?
Thank you,
Michael McSweeney
From: Steven Thong
To: Chris Jacobs
Cc: Mitchell Tsai; Reza Bonachea Mohamadzadeh; Maria Sarmiento; Malou Reyes; Jonathan Montano; Rebekah Youngblood; Hind Baki; Barrie Brown Martinez
Subject: SWRCC - [City of Santee, Fanita Ranch] - Comment Letter Date: Wednesday, September 14, 2022 2:54:51 PM
Attachments: 20220914 SWRCC Santee FanitaRanch CommentLtr v4 Complete.pdf Good Afternoon Chris Jacobs,
Please see the attached Comment Letter for the City of Santee's 09/14/22 Planning Commission Meeting for Item Agenda No. 8, Fanita Ranch.
Additionally, please confirm receipt of this email and attachment.
Best,
Steven
--
Steven Thong
Paralegal
Mitchell M. Tsai, Attorney At Law
139 South Hudson Avenue Suite 200
Pasadena, CA 91101
Phone: (626) 314-3821
Fax: (626) 389-5414
Email: [email protected]
Website: http://www.mitchtsailaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages accompanying it, may contain confidential information that is legally privileged If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this message is STRICTLY PROHIBITED and may violate applicable laws including the Electronic Communications Privacy Act If you have received this transmission in error, please immediately notify us by reply e-mail at Steven@mitchtsailaw com or by telephone at (626) 314-3821 and destroy the original transmission and its attachments without reading them or saving them to disk Thank you P: (626) 381-9248
F: (626) 389-5414
E: [email protected]
Mitchell M. Tsai
Attorney At Law
139 South Hudson Avenue
Suite 200
Pasadena, California 91101
VIA E-MAIL
September 14, 2022
Chris Jacobs, Principal Planner
Department of Development Services
City Hall, Building 4
10601 Magnolia Avenue
Santee, CA 92071
(619) 258-4100 x182
[email protected]
RE: Southwest Regional Council of Carpenters’ Comments on the City of Santee Fanita Ranch Final Environmental Impact Report (SCH No. 2005061118) – Agenda Item No. 8
Dear Honorable Council Members and Mr. Jacobs:
On behalf of the Southwest Regional Council of Carpenters (“SWRCC” or “Southwest Carpenters”), my Office is submitting these comments regarding the City of Santee (“City” or “Lead Agency”) Revised Final Environmental Impact Report (“RFEIR,” “FEIR,” or “EIR”) (SCH No. 2005061118) for Fanita Ranch Project (“Project”). These comments are to apprise the City of the potential environmental impacts of the Project and the issues inherent in the FEIR. The Project aims to develop roughly 2,638 acres of land in the northern portion of the City and will include up to 3,008 residential units and up to 80,000 square feet of commercial space, parks, trails, and a habitat preserve, to name several of its elements.
SWRCC is a labor union representing more than 57,000 union carpenters in six states, including California, and has a strong interest in well-ordered land use planning, addressing the environmental impacts of development projects, and equitable economic development.
Individual members of SWRCC live, work, and recreate in the City and surrounding communities and would be directly affected by the Project’s environmental impacts.
SWRCC expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearing and proceeding related to this Project.
Gov. Code, § 65009, subd. (b); Pub. Resources Code, § 21177, subd. (a); see Bakersfield City of Santee – Fanita Ranch
September 14, 2022