Af60A62440 — Santee City Council, September 14, 2022 (part 1 of 4)

TO: Mayor and Council Members
Marlene Best, City Manager
Shawn Hagerty, City Attorney
FROM: Annette Ortiz, CMC, City Clerk
DATE: September 14, 2022
SUBJ: Updated Council Meeting Materials – September 14, 2022 PUBLIC HEARING:
(8) Public Hearing for the Development of Fanita Ranch, to Consider Certifying Final Revised Environmental Impact Report Including Recirculated Sections of the Final Revised Environmental Impact Report (AEIS2017-11, AEIS2022-4), and Approving the Fanita Ranch Development Plan and Development Review Permit (DR2022-4), Vesting Tentative Map (TM2022-1), and Conditional Use Permits for Public Parks (P2022-1 And P2022-2), and a Fire Station (P2022-3) (Development Services – Planning)
The attached correspondence for above mentioned Item was received and is provided for your consideration.

Allen Matkins Leck Gamble Mallory & Natsis LLP
Attorneys at Law
One America Plaza
600 West Broadway, 27th Floor | San Diego, CA 92101-0903 Telephone: 619.233.1155 | Facsimile: 619.233.1158
www.allenmatkins.com
Jeffrey A. Chine
E-mail: [email protected]
Direct Dial: 619.235.1525 File Number: 186540.00009/4883-2953-7587.1 Los Angeles | Orange County | San Diego | Century City | San Francisco Allen Matkins
September 14, 2022
Santee City Council
c/o Annette Fagan Ortiz, MCA, CMC, City Clerk
10601 Magnolia Avenue
Santee, CA 92071
Email: [email protected]
Re: Tonight’s Public Hearing for Consideration of Fanita Ranch Project Dear Mayor Minto and City Councilmembers,
Our firm represents HomeFed Fanita Rancho LLC (“HomeFed”), the applicant for the above-referenced project. As the staff report explains, California is in the midst of a housing crisis and the negative consequences affect all residents of the state. To help address the unacceptable situation, this City Council in August of 2021 enacted Urgency Ordinance No. 592, the Essential Housing Program, designed to boost housing production and improve housing affordability in the City. The Fanita Ranch project is an example of the Program in action. We will not repeat the many ways in which Fanita Ranch addresses housing needs here in the City and in the region. The staff report ably describes those project attributes.

Local electorates have historically played a role in restricting the development of adequate housing to California’s detriment. As the Legislative Analyst’s Office (California Legislature’s nonpartisan fiscal and policy advisor) described, local resident opposition, growth control measures, moratoria and growth caps, and placing land use decisions before voters have presented significant barriers to housing production. (Legislative Analyst Office, Considering Changes to Streamline Local Housing Approvals (May 17, 2016), available at Considering Changes to Streamline Local Housing Approvals; California's High Housing Cost: Causes and Consequences (2015) California's High Housing Costs - Causes and Consequences, attached hereto.) The LAO emphasized that policies which either directly or indirectly limit growth by making housing project approval more difficult (e.g., by adding additional vote and approval requirements) “have been effective at limiting growth and consequently increasing housing costs.” (California's High Housing Cost: Causes and Consequences, supra, at p. 16.) It continued, “One study of growth controls enacted by California cities found that each additional growth control policy a community added was associated with a 3 percent to 5 percent increase in home prices.” (Id.)1
1 See also, Stanford Institute for Economic Policy Research. Streeter, Jialu L. (May 2022) Allen Matkins Leck Gamble Mallory & Natsis LLP
Attorneys at Law
Santee City Council
September 14, 2022

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The Legislature found that these barriers to housing production, among others, threaten the economic, environmental, and social quality of life for all Californians. (See, e.g., Gov. Code, § 65589.5, subds. (a)(1)(A)- (a)(1)(D), (a)(2)(A) – (a)(2)(L), SB 330, Sec. 2 and 3.) It therefore explicitly acted to constrain voters’ initiative and referendum powers through 2030 to ensure that housing can get built at all affordability levels. (See, SB 330.) We therefore applaud the City Council for taking bold and affirmative steps to address the housing crisis locally.

Very truly yours,
Jeffrey A. Chine
JAC:sn
cc: Chris Foulger
Kent Aden
Jeff W. O’Connor
Marlene Best, City Manager
Shawn D. Hagerty, Esq.

Amanda Daams, Esq.

Homelessness in California: Causes and Policy Considerations, SIEPR Policy Brief May 2022 v05.pdf - Google Drive [citing added costs of growth control measures and delays]; UC Berkeley Terner Center for Housing. Kok, Nils, Paavo Monkkonen and John M. Quigley (2014) Land Use Regulations and the Value of Land and Housing: An Intra-Metropolitan Analysis. Journal of Urban Economics 81(3): 136-148. [finding that cities requiring a greater number of discretionary reviews and approvals to obtain a building permit or a zone change have higher land prices, even after controlling for locational, geographic, and demographic characteristics]; McKinsey Global Institute (2016) “Closing California’s Housing Gap.” McKinsey & Company. closing-californias-housing-gap-full-report.pdf (mckinsey.com) [noting time costs can contribute 30 percent to the finished cost of a home, and estimating that California could reduce the cost of housing by more than $12 billion in just 5 years through accelerating residential project approvals times by an average of 4 months.]) From: Austin Weinman
Sent: Tuesday, September 13, 2022 3:00 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 Approval
Dear City Council members,
My name is Austin Weinman and 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 my family will have a better chance of the American Dream……owning a home! 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 I can have the opportunity to own a home.

Thank you,
Austin Weinman

From: Bill Grolz
To: Chris Jacobs
Cc: John Minto; Ronn Hall; [email protected]; Rob McNelis; [email protected] Subject: City Council 9/14//2022 Item #8 Fanita Ranch DISAPPROVE Date: Sunday, September 11, 2022 3:51:17 PM
City Council 9/14/2022 FANITA RANCH Item 8- DISAPPROVE! For the administrative record:

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, un-democratic and un-American. I strongly 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 Final Revised Environmental Impact Report remains inadequate on fire safety issues. The development application should be abandoned and the land permanently conserved through the Department of Defense military base buffer program (REPI).

Thank you,
Bill Grolz
Santee, Ca
From: Frank Landis
To: John Minto; Dustin Trotter; Ronn Hall; Laura Koval; Rob McNelis; Chris Jacobs Subject: CNPSSD comment on September 12, 2022 Santee City Council Agenda Item 8, Fanita Ranch Date: Monday, September 12, 2022 2:55:09 PM
Attachments: CNPSSD comment to Santee City Council on Fanita Ranch RFEIR 20220912.pdf CNPSSD Rebuttal on Fanita Ranch RFEIR 20220912.pdf
w29621.pdf
Dear Santee City Council members and Mr. Jacobs,
Please find attached comments and supporting documentation from CNPSSD on Agenda Item 8 (Fanita Ranch) on the 9/14/2022 hearing. Let me know if you received this email and can open the attachments.

Sincerely,
Frank Landis, PhD
Conservation Chair
CNPSSD
San Diego Chapter of the California Native Plant Society P O Box 121390
San Diego CA 92112-1390
[email protected] | www.cnpssd.org
September 12, 2022
Mayor John Minto
Councilmember Dustin Trotter
Councilmember Ronn Hall
Councilmember Laura Koval
Councilmember Rob McNelis
Santee City Hall
10601 Magnolia Avenue
Santee, California 92071
By email to: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] RE: September 12, 2022 Santee City Council Agenda Item 8, Fanita Ranch: OPPOSE Dear Santee City Council Members,
Thank you for the opportunity to comment on the draft of the Final Revised EIR (“FREIR”) for Fanita Ranch (“Project”). CNPS promotes sound plant science as the backbone of effective natural areas protection. We work closely with decision-makers, scientists, and local planners to advocate for well informed and environmentally friendly policies, regulations, and land management practices. Our focus is on California's native plants, the vegetation they form, and on lessening the damage to both people and native plants from wildfires..

We strongly urge you to vote this Project down in Item 8 Here we want to show why voting this project down will save the City a predictable, $500 million disaster:.
 Houses built to California building code are not fireproof, according to the code itself in section 7A. Fire resistant is not fireproof. The measures given in the FREIR will not make the homes fireproof, because they do not exceed code  According to a recent, independent analysis (attached and summarized below), on average 20% of code-compliant new homes have burned in California since 2007, all in extreme, wind-driven fires. The fire protection and evacuation plans proposed in the FREIR are necessary, but not sufficient, to the protect lives and property of all Fanita Ranch residents. This is obvious throughout the documents, because they quite rightly refuse to guarantee that no homes will burn.

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 The cost of cleanup, rebuilding, and rehousing displaced families comes close to $1 million per single-family home. There is substantial evidence that all these costs will come from impacts that should be analyzed under CEQA, so they cannot be ignored.  If 20% of Fanita Ranch’s single family homes burn, the damage from those alone (not including multifamily housing or other structures) will run close to $500 million. Since Santee’s City budget is closer to $50 million than $500 million, Fanita Ranch burning will have a huge impact on City finances, even if State and Federal agencies help out.  Because Santee City residents will bear the brunt of his, both in service cutbacks and higher fire insurance costs, it seems prudent to follow Measure N’s dictates and ask them if they want to assume the risk, rather than rushing to judgment now.

CEQA and Building Code Background
The key CEQA question--would the project “expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?”—does not specify that the people impacted are only the site residents, as the FREIR presumed. Someone has to pay to clean up and fix the damage, and they are impacted by this project. This was not analyzed. It needs to be analyzed, because huge wildfire losses are what are driving insurance companies to raise fire insurance rates or cancel coverage altogether. If Fanita Ranch is built, the ripple effects will be regionwide.

In the Response To Comments, the City mistakenly claimed that these economic costs need not be analyzed under CEQA. Since these are costs for cleanup, dealing with the newly homeless, and rebuilding on the site, of course there is substantial evidence these are Project impacts. Had the homes not been built, none of these problems would have occurred.

Building to code helps reduce the chance of a building burning down, but it is not intended to make buildings fireproof. Chapter 7A of the California Building Code states that “[t]he purpose of this chapter is to establish minimum standards for the protection of life and property by increasing the ability of a building located in any Fire Hazard Severity Zone within State Responsibility Areas or any Wildland-Urban Interface Fire Area to resist the intrusion of flames or burning embers projected by a vegetation fire and contributes to a systematic reduction in conflagration losses.”
Chapter 7A does not warranty that a building built to code is fireproof or even suitable for shelter in place. While we agree that sheltering in a new home might be safer than getting stuck in a car as in the tragic Paradise fire, it is a far cry from being designed for true shelter in place.

Note, again, that the $500 million in estimated damages comes from assuming that 80 percent of the homes survive an extreme, wind-driven fire, two of which have already hit the site. Fanita Ranch is so large that even small losses are catastrophic.

Incomplete Analysis of Fire Impacts in the FREIR
As noted above, the basic fire impact question is whether the project would “expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?” Per the FREIR (p. 4.18-35) “The wildland fire risk and features prescribed in the FPP (Appendix P1) have been analyzed and developed to reduce risk to acceptable levels at Fanita Ranch by applying comprehensive guidelines developed by a technical panel of 17 professional fire prevention officers and fire protection specialists and planners” and (p. 4.18-37) “The project’s redundant fire protection features, quick emergency response, evacuation routes and plans, and the contingency option of sheltering on site in

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protected spaces would ensure that people and structures would not be exposed to a significant risk of loss, injury or death involving wildland fires.” This is misleading. If there is no risk to significant damage to structures, why the elaborate evacuation plan? The analysis tries to have it both ways: that people will be efficiently evacuated, so they’re safe. and even if they can’t be evacuated, they’ll be perfectly safe in their homes, because their homes will not burn. Will any firefighter or consultant actually stand up and promise this? Of course not. The Project is proposed for a dangerous site that is mapped as “very high fire hazard” because it has burned multiple times. The people and legal entities who will be impacted by a fire on the Project site need to have a real voice in the deciding whether the Project is approved, and with what binding conditions.

In the FREIR, the fire risk was incorrectly analyzed. The Project site faces two types of wildfires, not one. While mitigation measures to both types of fires were discussed, the analysis mixes and confuses them, making the incorrect conclusion that the risks for both types were completely mitigated, when in fact only the risks of the lesser wildfire type was. Below we will start to disentangle the mess.

Two Types of Fires and Mitigating For Each
As background, not all fires are equal. Every year, California experiences many tiny fires and a few extreme monsters, a “fire ants and Godzilla” distribution. Between 2008 and 2021, California dealt with between 4,923 and 9,917 fires every year. Of these fires, only between 17 and 95 grew to burn more than 1,000 acres. This is illustrated in Wikipedia’s list of fires that were over 1,000 acres, called “Big Fires” in Table 1 on the next page.

As noted, there were only 17 to 95 “Big Fires” every year, or less than 2% of the total number of fires. Unfortunately, these 1,000 acre-plus fires burned between 75 and 99% of the total acres burned every year.

Worse, the biggest 2 to 8 fires each year (The “Godzillas”) burned over 50% of the total acreage burned in California that year. These monsters are inevitably wind-driven catastrophes that burn for days to months, whose total energy release (around 1017 joules) is on the same scale as the winds in a medium-sized hurricane. There’s a scaling problem with assuming that humans can stop this kind of energy release, even if they’re trained wildland firefighters.

This is why the metaphor of “fire ants and Godzilla” is apt. If all of the fires California firefighters deal with every year are tiny “fire ants,” the firefighting strategic equivalent of applying insecticide (building fire breaks, putting out small fires) is the best answer, and California’s firefighters are extremely good at this. At least 98% of all fires in any given year are kept to under two square miles (1,280 acres).

The problem is that “fire ant” measures don’t work on big wind-driven fires, the Godzillas, where embers can fly for miles past fire breaks to ignite spot fires. Techniques that are effective in extinguishing small fires are ineffective in dealing with wind-blown wildfires. In a majority of cases, weather changes eventually halt the biggest fires.

Thus there are two sets of necessary fire mitigation measures. For small-scale fires, having defensible space around structures, building fire breaks, clearing annual weeds away from road edges and houses, and directly fighting fires work quite well.

For big fires, the major tactics are evacuating people out of harm’s way, and using fireresistant landscaping and building techniques to minimize ignition from flying embers. As a desperation defense or in purpose-designed, code-exceeding systems, sheltering in place can work. Unfortunately, none of these are foolproof, especially sheltering in place in a building

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built to code. The Codes probably reduce risk by 80%, not 100%. They are necessary, not sufficient.

Table 1. Summary fire data from 2008 to 2021, per Wikipedia, as scraped from Cal Fire official documents. Total acres burned per year and number of fires/year are self explanatory. Wikipedia broke out fires >1000 acres, which here are labeled “Big Fires.” Invariably, only a few big fires (2-8) accounted for over 50% of the total acres burned that year in each state. The Big Fires accounted for 75-99% of all acres burned, even though they are always less than 2 percent of the number of fires in the state.

Year
Total
Acres
Burned/Yr
#Fires/Yr
Number of
“Big Fires”
(>1,000 Acres)
Number of Big
Fires that
burned >50% of
total acres/yr
Percent of
Total Acreage
Burned by Big
Fires
2008 1,593,690 4,923 95 8 92.36%
2009 422,147 9,159 38 2 96.49%
2010 109,529 6,554 17 6 63.68%
2011 168,545 7,989 24 4 87.70%
2012 869,599 7,950 43 4 82.34%
2013 601,625 9,907 28 3 87.86%
2014 625,540 7,865 37 4 84.13%
2015 893,362 8,745 23 5 77.61%
2016 669,534 7,349 33 6 75.37%
2017 1,381,405 9,133 61 7 92.97%
2018 1,893,913 8,527 58 5 83.17%
2019 259,823 7,860 36 2 99.40%
2020 4,397,809 9,917 74 5 94.70%
2021 2,569,009 8,527 39 3 97.00%
In summary, the Project’s fire protection plan has to protect against two kinds of fires, and it does have some mitigation features to protect against both. Furthermore, we agree that small fires, a category which includes the majority of the fires that have occurred on the site, are unlikely to cause damage to humans or buildings.

We disagree that the measures taken are sufficient to protect humans and property from harm by large, wind-driven fires. Since two of these monsters have burned the site, any project built on it is vulnerable, because such fires are channeled by landscapes and burn the same areas repeatedly. As the data above show, almost all losses of buildings and lives happen in the big fires. The FREIR recognizes this in its evacuation plan, but it mistakenly asserts that the measures it proposes will make insignificant the risk to property during extreme, wind-driven fires. This is a mistake, because there are no quantitative measures that demonstrate this. The risk to property is why there is an evacuation plan in the first place! Financial Impacts of Fire on the Project Site
The financial costs implicit in “acceptable levels of risk” were not analyzed in the FREIR. Again, there is substantial evidence that the costs arise from impacts that should be

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analyzed under CEQA. Financial impacts are useful for decision makers like the Santee City Council, because they allow aggregation of everything from cleanup to rehoming to rebuilding costs.

Here is an estimate of such costs. It is based on working paper 29621 published in December 2021, by two researchers from the National Bureau of Economic Research, Patrick Baylis and Judson Boomhower.1
Their work is not focused on Fanita Ranch, but rather on the benefits and costs of California’s building code with respect to wildfire losses. California’s 2007 building code is the strictest in the nation. They wanted to determine whether it actually reduced the number of homes lost to wildfires, what the costs for rebuilding a burned home in California are, whether it is cost-effective to build to the 2007 code, and cost-effective to retrofit other homes to meet modern standards. In doing this work, they compiled a detailed database of over 46,000 single-family homes in California that were damaged or destroyed by wildfires. Their analysis is useful in this case because it is impartial with respect to the FREIR, and importantly because it puts quantitative estimates on the Project’s fire risk, something largely missing from the FREIR.

Briefly, what Baylis and Boomhower discovered was that about 35% of California homes built before 1989 burned when hit by a wildfire, while homes built after 2007 burned about 20% of the time. Thus they conclude that the current building code does reduce fire risk substantially.

By their estimate, if a single-family home burns in California, it costs around $150,000 to haul away debris and clean up the site, $61,696 for the displaced family to rent a dwelling for two years while their home is rebuilt, and $766,725 to rebuild the home, for a total cost per home burned of $978,421.

How much would a wildfire hitting the proposed Fanita Ranch project cost? If we assume that 2,514 single-family homes would be built on Fanita Ranch and that 20 percent of these homes burn, we estimate that 503 homes will burn every time a major wildfire burns the Project. It would cost an estimated $75,450,000 to haul away the remnants of those homes and clean the site, an estimated $31,033,088 to house the 503 displaced families while their homes are being rebuilt, and an estimated $385,662,675 to rebuild the 503 single-family homes, for a total estimated cost of $492,145,763 per large fire.

Note that $492,145,763 is a gross underestimate of the Project’s total “acceptable risk.” It includes losses only to single-family homes, not to townhomes, condominiums, businesses, or other structures. It makes the optimistic assumption that the cost model is accurate for Santee, although San Diego County has one of the most expensive housing markets in the nation. It also does not account for the impacted rental market, long permitting times, possible litigation delays, or inflation. Among other things.

Why is this at such sharp odds from the FREIR’s conclusion? As noted in the previous section, the FREIR analysis, especially of mitigation effectiveness, is largely qualitative. It is predicated on the notion that the site has to prepare only for generic wildfires when the evidence strongly suggests that little fires and wind-driven infernos are radically different and require radically different strategies. Small fires can be fought, but in wind-driven infernos are what cause the 20% home losses.

While we present quantitative evidence that 20 percent of built-to-code homes are lost in wildfires, this shouldn’t have been news, because similar losses were reported in the Paradise,

1 Baylis, PW and J Boomhower. 2021. Mandated vs. Voluntary Adaptation to Natural Disasters: The Case of U.S. Wildfires. http://www nber.org/papers/w29621

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Woolsey, and other fires years ago. Why did the FREIR not contain an analysis of the limitations of the building code? It is the best in the US, but it does not make for fireproof homes.

Who is impacted by Project wildfire losses?
 Residents
 The owners of homes and buildings
 Workers in the businesses and other employees and contractors  Companies insuring homes, buildings, and businesses
 The City of Santee, for lost property taxes, damage and cleanup expenses, firefighting, etc.  Those who plan to minimize the amount of organic debris going into landfills (County and State)
 The area rental market (for displaced Project residents)  Stormwater facilities downstream
 State of California, who will likely be asked to make good on uninsured losses. The California Attorney General’s office has intervened in multiple fire-related CEQA cases.

Were they notified?
 Federal government, who will also likely be asked to make good on uninsured losses.

Were the proper representatives of all of these groups notified that this Project could impact them or their interests?
The widespread and unmitigated financial impacts of this Project strongly suggest that the Project needs to go before the voters. Will it? The Santee City Council may decide that a half-billion dollar financial risk is insignificant, but it is worth asking Santee’s voters if they agree.

Thank you for taking these comments. A rebuttal of the FREIRs responses to the original comments is attached, as is the paper with the research cited here.

Sincerely,
Frank Landis, PhD
Conservation Chair
California Native Plant Society, San Diego Chapter
CC: Rebuttal Letter
NBER Paper 29621
San Diego Chapter of the California Native Plant Society P O Box 121390
San Diego CA 92112-1390
[email protected] | www.cnpssd.org
September 12, 2022
Chris Jacobs, Principal Planner
Department of Development Services
City Hall, Building 4
10601 Magnolia Avenue
Santee, California 92071
Telephone: (619) 258-4100, extension 182
By email to: [email protected]
RE: Recirculated Sections of the Final Revised EIR for Fanita Ranch. REBUTTAL Dear Mr. Jacobs,
Thank you for the opportunity to offer a rebuttal to the Response to Comments on the draft of the Final Revised EIR (“FREIR”) for Fanita Ranch (“Project”). This rebuttal is submitted on behalf of the California Native Plant Society (“CNPS”) in advance of the September 14, 2022 meeting of the Santee City Council.

Aside from the rewritten introduction, the rest of the document is the comment letter.

Summarized responses to comments are interlaced as labeled, followed by rebuttals to the responses.

Please include this document in the official record for this FREIR and any other proceeding that includes the FREIR.
--Start of Rebuttal—
Fire Impacts and Incomplete Analysis
One basic fire impact question is whether the project would “expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?” Per the FREIR (p. 4.18-35) “The wildland fire risk and features prescribed in the FPP (Appendix P1) have been analyzed and developed to reduce risk to acceptable levels at Fanita Ranch by applying comprehensive guidelines developed by a technical panel of 17 professional fire prevention officers and fire protection specialists and planners” and (p. 4.18-37) “The project’s redundant fire protection features, quick emergency response, evacuation routes and plans, and the contingency option of sheltering on site in protected spaces would ensure that people and structures would not be exposed to a significant risk of loss, injury or death involving wildland fires.”
This is misleading. If there is no risk to significant risk to structures, why the elaborate evacuation plan? The analysis tries to have it both ways: that people will be efficiently

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evacuated, so they’re safe. and even if they can’t be evacuated, they’ll be perfectly safe in their homes, because their homes will not burn. Will any firefighter or consultant actually stand up and promise this? Of course not. The Project is proposed for a dangerous site that is mapped as “very high fire hazard” because it has burned multiple times. That danger needs to be understood, the risk needs to be quantified, and the people and legal entities who are impacted by a fire on the Project site need to have a real voice in the deciding whether the Project is approved, and with what binding conditions.

In the FREIR, the risk was incorrectly analyzed. The Project site faces two types of wildfires, not one. While mitigation measures to both types of fires were discussed, the analysis mixes and confuses them, making the incorrect conclusion that the risks for both types were adequately mitigated, when in fact only the risks of the lesser wildfire type was. Below we will start to disentangle the mess.

The FREIR risk analysis is also incomplete, in that it did not include financial impacts of fire. These appear to be substantial, over nine times the City of Santee’s current annual budget.

A variety of people and legal entities will be impacted by a fire on the Project site, not just the residents. Their input and concurrence is needed to help mitigate these impacts. It is unclear whether all of them were identified in the FREIR and notified of their potential vulnerability, so that they could comment on the process. These concerns are detailed below.

In the Response to Comments (RTC), O4-4, the rebuttal is “The City acknowledges the comment and notes that it raises economic, social, or political issues that do not appear to relate to any physical effect on the environment. There is no requirement under the California Environment There is no requirement under the California Environmental Quality Act (CEQA) to evaluate such economic or financial effects. This comment does not raise a significant environmental issue regarding the adequacy or accuracy of the information provided in the Recirculated Sections of the Final Revised EIR. Therefore, no further response is required.” In Rebuttal: This is a misreading of substantial evidence under CEQA, which says (section 15384(a)): “Substantial evidence” as used in these guidelines means enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached.

Whether a fair argument can be made that the project may have a significant effect on the environment is to be determined by examining the whole record before the lead agency.

Argument, speculation, unsubstantiated opinion or narrative, evidence which is clearly erroneous or inaccurate, or evidence of social or economic impacts which do not contribute to or are not caused by physical impacts on the environment does not constitute substantial evidence”
A house burning down in a wildfire is an environmental impact caused by the project building that house in that location. The costs are directly caused by the house burning down, which is caused by the project. Thus this meets the definition of “Substantial Evidence” and must be considered. It was not.

Furthermore, the impacts of burned houses directly cause waste disposal impacts (more so if toxic materials are involved, and more so still if the site is not secured before rains and burned wastes are washed into waterways). They also impact existing housing, because the newly homeless must be sheltered too. While these were summarized as costs, they are costs related to physical impacts considered under CEQA. These are also impacts that were not analyzed.

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Year
Total
Acres
Burned/Yr
#Fires/Yr
Number of
“Big Fires”
(>1,000 Acres)
Number of Big
Fires that
burned >50% of
total acres/yr
Percent of
Total Acreage
Burned by Big
Fires
2008 1,593,690 4,923 95 8 92.36%
2009 422,147 9,159 38 2 96.49%
2010 109,529 6,554 17 6 63.68%
2011 168,545 7,989 24 4 87.70%
2012 869,599 7,950 43 4 82.34%
2013 601,625 9,907 28 3 87.86%
2014 625,540 7,865 37 4 84.13%
2015 893,362 8,745 23 5 77.61%
2016 669,534 7,349 33 6 75.37%
2017 1,381,405 9,133 61 7 92.97%
2018 1,893,913 8,527 58 5 83.17%
2019 259,823 7,860 36 2 99.40%
2020 4,397,809 9,917 74 5 94.70%
2021 2,569,009 8,527 39 3 97.00%
This is why the metaphor of “fire ants and Godzilla” is apt. If all of the fires California firefighters deal with every year are tiny “fire ants,” the firefighting strategic equivalent of applying insecticide (building fire breaks, putting out small fires) is the best answer, and

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California’s firefighters are extremely good at this. At least 98% of all fires in any given year are kept to under two square miles (1,280 acres).

Unfortunately, none of these are foolproof, especially sheltering in place in a building built to code.

RTC largely concurs with this information, with the exception that embers carried on fire wind are not mentioned.

In Rebuttal, we simply note that the record for wind-thrown embers starting another fire is probably around 10 miles in the Bunyip Ridge fire in Australia, and even the Wikipedia page for the 2018 Camp Fire (https://en.wikipedia.org/wiki/Camp_Fire_ (2018)#/media/File:Camp_Fire_oli_2018312_Landsat.jpg) clearly shows a major spot fire several miles ahead of the main fire front. Any model of fire spread that fails to account for wind-thrown embers is incomplete.

Building to code helps reduce the chance of a building burning down, but it is not intended to make buildings fireproof. Chapter 7A of the California Building Code states that “[t]he purpose of this chapter is to establish minimum standards for the protection of life and property by increasing the ability of a building located in any Fire Hazard Severity Zone within State Responsibility Areas or any Wildland-Urban Interface Fire Area to resist the intrusion of flames or burning embers projected by a vegetation fire and contributes to a systematic reduction in conflagration losses.”
Chapter 7A does not warranty that a building built to code is fireproof or even suitable for shelter in place. While we agree that sheltering in a new home might be somewhat safer than getting stuck in a car as in the tragic Paradise fire, it is a far cry from designed for true shelter in place. Why was it labeled as such?
In RTC (O-4-5, O-4-8) states “the latest version of the California Building Code, specifically because they were found to perform exceptionally well to save homes from wildfire threats.” Elsewhere it is noted that the relevant fire code has been update since 2007 and the comments are on obsolete versions.

In Rebuttal, we agree that a 20% loss rate counts as saving 80% of homes. However, “exceptionally well” fails to rebut our analysis using substantive data. Our analysis is predicated on two key points, neither of which were addressed in the RTC.

1. Building Code Section 7A is not, as described above, designed to create fireproof homes, only minimal standards. That language has remained unchanged to the current year. City of Santee does not require it either.

2. The impact model is not to the 80% of homes saved by building to code, but to the 20% lost.

When 20% of a development is 503 homes burned, that is a huge, and hugely significant, impact..

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Furthermore, the RTC, like the FREIR, rests on assertions, not on substantial evidence as described above. If Santee’s building codes provides for fireproof homes, where are the data to support this? If the mitigation measures, coupled with building codes, make all homes fireproof, where are the quantitative data that show this? These data needed to be in the FREIR, and they are not.

In summary, the Project’s fire protection plan has to protect against two kinds of fires, and it does have some mitigation features to protect against both. Furthermore, we agree that small fires, a category which includes the majority of the fires that have occurred on the site, are unlikely to cause damage to humans or buildings. Resistance to small fires is necessary, not sufficient, to reduce fire risk on the site, because the majority of the risk comes from Big Fires and especially from Godzilla-scale fires like the Cedar or Witch fires of years past.

We disagree that the measures taken are sufficient to protect humans and property from harm by large, wind-driven fires. Since two of these monsters have burned the site, any project built on it is vulnerable. As the data from California show, almost all losses of buildings and lives happen in the big fires. The FREIR recognizes this in its evacuation plan, but it mistakenly asserts that the measures it proposes will reduce the risk during extreme, wind-driven fires, to “below significance.” This is a mistake, because there are no quantitative measures of safety provided, only assertions by people who have worn uniforms. What substantial, quantitative evidence exists to demonstrate what the threshold for non-significant fire impacts to people and structures is? What evidence and analysis demonstrates that the Project’s measures lower risks from big fires below this threshold?
The RTC (04-6) states that the quantitative evidence to rebut this assertion is in the FPP and other documents.

Rebuttal: The problem is that mitigating impacts below the level of significance requires a fireproof development, with effectively zero losses, given the scale of Fanita Ranch. In this case, the available data suggest that 20% of single-family homes will be lost in an extreme, wind-driven wildfire.. That is a loss of 503 single family homes, with direct impacts that may well cost $1 million per home lost to mitigate and rebuild. Thus the plans proposed still leave behind substantial, unmitigated impact. This is not a hypothetical impact, as the site’s known fire history shows that it has been burned by two wind-driven wildfires in the last century.

What Working Shelter-In-Place Looks Like
The Project proposes that buildings built to code can be used for safe shelter in place.

The code makes no such assertion. To illustrate the difference between “built to code” and “safe for shelter in place,” we need an example.

The best-known local example of a true shelter-in-place system for three thousand people is Pepperdine University,1 which has deployed their continually-updated system successfully in a number of big fires. The differences between their current version and the Proposed Project are instructive, because they demonstrate why shelter-in-place on the Project site is a last resort in a growing disaster.

Pepperdine’s sits at the mouth of fire-prone Malibu Canyon. Even when the campus was designed in the 1970s, the site was known to burn, and in fact it did burn while the buildings were under construction. Pepperdine’s problem is that many of its students don’t have cars, so

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they can’t easily evacuate down Pacific Coast Highway, even if the normal evacuation gridlock would let them leave. Because of its large and vulnerable population, the campus was designed to be fire resistant with its distinctive “Modernist Mediterranean” style, and the huge lawn surrounding it is supposed to be a fire defense. Nevertheless, the real defense is that everyone on campus shelters in the library and administration during big fires, while ten fire engines from the nearby Malibu Fire Department stand guard around those buildings. Campus staff stock emergency supplies in the shelter buildings and regularly conduct full fire drills for everyone.

The backbone of the system are the staff, not the residents, and the staff work regularly to update their safety program in concert with the City of Malibu.

This is the only large-scale shelter-in-place system we know of in Southern California.

What additional planning, staffing, resources, and structures, and coordination with the City of Santee and firefighting agencies would the Project have to add to provide safety comparable to what Pepperdine has demonstrated? This is what is needed for shelter in place.

RTC O4-7 suggests that Rancho Santa Fe and surrounding developments are a better model than Pepperdine.

Rebuttal: Unfortunately, the counterexamples are worse, because we were unable to find evidence that the residents have ever systematically tested their systems to see if they work. So far as we have been able to determine, residents in these areas routinely evacuate rather than shelter in place. Pepperdine, in contrast, has sheltered people in place at least six times during extreme, wind-drive wildfires. The key difference is that, in addition to buildings, Pepperdine has staff and systems that are in place and tested annually. Rancho Santa Fe apparently tells its residents their homes are designed for shelter-in-place, without having staff, systems, or regular community-wide drills to make sure everything is prepared for shelter-in-place. In the absence of good evidence that the Rancho Santa Fe model works, we suggest Pepperdine is a better model, especially for affordable housing.

Financial Impacts of Fire on the Project Site
The financial costs implicit in “acceptable levels of risk” were not analyzed. Why not? Here is an estimate of such costs. It is based on working paper 29621 published in December 2021, by two researchers from the National Bureau of Economic Research, Patrick Baylis and Judson Boomhower.2 Their work is not focused on Fanita Ranch, but rather on the benefits and costs of California’s building code with respect to wildfire losses. California’s 2007 building code is the strictest in the nation. They wanted to determine whether it actually reduced the number of homes lost to wildfires, what the costs for rebuilding a burned home in California are, whether it is cost-effective to build to the 2007 code, and cost-effective to retrofit other homes to meet modern standards. In doing this work, they compiled a detailed database of over 46,000 single-family homes in California that were damaged or destroyed by wildfires. Their analysis is useful in this case because it is impartial with respect to the FREIR, and importantly because it puts quantitative estimates on the Project’s fire risk, something largely missing from the FREIR.

2 Baylis, PW and J Boomhower. 2021. Mandated vs. Voluntary Adaptation to Natural Disasters: The Case of U.S. Wildfires. http://www nber.org/papers/w29621

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How much would a wildfire hitting the proposed Fanita Ranch project cost? If we assume that 2,514 single-family homes would be built on Fanita Ranch and that 20 percent of these homes burn, we estimate that 503 homes will burn every time a major wildfire burns the Project. It would cost an estimated $75,450,000 to haul away the remnants of those homes and clean the site, an estimated $31, 033,088 to house the 503 displaced families while their homes are being rebuilt, and an estimated $385,662,675 to rebuild the 503 single-family homes, for a total estimated cost of $492,145,763 per large fire.

Why is this at such sharp odds from the FREIR’s conclusion? As noted in the previous section, the FREIR analysis is largely qualitative. It is predicated on the notion that the site has to prepare only for generic wildfires when the evidence strongly suggests that little fires and wind-driven infernos are radically different and require radically different strategies. Small fires can be fought, but in wind-driven infernos, evacuation and structure design are what cause the 20% losses.

While we present quantitative evidence that 20 percent of built-to-code homes are lost in wildfires, this shouldn’t have been news, because similar losses were reported in the Paradise, Woolsey, and other fires years ago. Why did the FREIR not contain an analysis of the limitations of the building code? It is the best in the US, but it does not make for fireproof homes.

In this section, we point out that the CEQA question--would the project “expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?”—does not specify that the people impacted are only the site residents.

Someone has to pay for the damage, and they are impacted by this project. The impacts from even 20% of Fanita Ranch burning dwarf the City of Santee’s annual budget.

The RTC (O-4-8) links back to O-4-4.

Rebuttal: Already given in Rebuttal O-4-4. There is substantial evidence linking the financial costs to environmental issues that CEQA does cover, because the latter generates the former.

Again, decreasing housing loss by 80% does not decrease it below the level of significance when thousands of homes are under threat, and when the mitigations of home loss and unhousing families total around a million dollars.

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Were they notified?
 Federal government, who will also likely be asked to make good on uninsured losses.

Were the proper representatives of all of these groups notified that this Project could impact them or their interests? Which ones were left out? What is the plan to notify the ones left out? Will comments be reopened?
The widespread and unmitigated financial impacts of this Project strongly suggest that the Project needs to go before the voters. Will it? If the Santee City Council decides that a half-billion dollar financial risk is insignificant, perhaps it is worth asking the voters if they agree?
The RTC (O-4-9): does not address this, except to refer to Thematic Response 2.

In Rebuttal, The comment stands. If a Project will predictably generate costs around $500 million or more caused by its environmental impacts, then contacting those who will be burdened by those costs is necessary, the same way an adjacent property owner would be asked to comment on project noise if they will have to finance physical measures to deal with that noise. Since the City of Santee has Measure N as a mechanism to poll a large section of the population affected, putting this Project to the voters would go a some ways toward insuring that they, at least, got to weigh in.

In sum, the impacts to wildfire have not been mitigated below the level of significance by the FREIR. More work needs to be done before this document is complete. If quantitative estimates of the impacts cannot be estimated, and if the Projects impacts cannot be lowered below the level of significance, given the enormous financial risks the Project holds, it is probably more prudent to avoid the risks entirely by not building it.

The RTC response is covered in O-4-9, and does not address this summary so far as we can determine.

NEW INFORMATION: Crotch’s bumblebee (Bombus crotchii)
The following section is attached with permission of CNPS by Frank Landis, who is writing as a member of the public in this section, not representing CNPS. This happens when a review of a document turns up an omission that other groups are not advocating for. CNPS does not advocate for insects, although pollinators are critically important to the continued survival of native plants.

The issue here is Crotch’s Bumblebee (Bombus crotchii). This rare bumblebee is currently a candidate for listing under the California Endangered Species Act, and as such, it is

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entitled to the protection it would receive as if it were listed, until CDFW makes a final determination of its status.

In April, 2019, the Fish and Game Commission voted to give Crotch’s Bumblebee candidate status. That decision was legally challenged in September 2019, and overruled in November 2020. On May 31, 2022, before the FREIR was sent out for public comment, the appellate court overturned the lower court’s ruling and reinstated Crotch’s bumblebee as a candidate species.

This matters because, according to the CNDDB, Crotch’s bumblebee has been collected five times in Mission Trails and East Elliott between May 2011 and late July 2020. It was also captured in June 2010 on Miramar just south of Poway. All these collections are within about three miles of the Project site. All its known food plants are documented as occurring on the site in the May 2020 Biological Technical report for the previous DREIR on the Project. The vegetation communities described for the Project site in that document are also consistent with known Crotch’s bumblebee habitat.

Why was Crotch’s Bumblebee not surveyed for in the previous iteration of the Project EIR? This question should be answered in the response, but it is quite evident that no effort was made to survey for bees or flies for the EIR. Butterflies were the only pollinators systematically surveyed for, and the only wasp recorded was the large, obvious Tarantula Hawk that even botanists readily notice. There is no mention even of honeybees being observed in the field, let alone bumblebees. Had any attempt been made to search for bees, surely the ubiquitous presence of honeybees would have been noted!
Thus, the Project has a high likelihood of a candidate listed species on the site, and no attempt was made to survey for that species. The species’ legal condition changed before the DFEIR was issued in June, so it should have been the subject of focused surveys, and those surveys should have been performed in the last few months. This was not done, even though it is a straightforward effort.

The solution is simple: conduct focused surveys for Crotch’s bumblebee on the Project site during the appropriate season (spring and summer). If the species is present, determine if it will be impacted by the Project or not. If it will be impacted, create suitable mitigations. If existing mitigation plans already protect it, present substantial evidence that this is the case. If it is not present on the site, present evidence of a suitable search.

This species was not covered by previous litigation, nor by previous EIRs. Here I present substantial evidence to warrant a survey to determine its status on the Project site, whether the Project impacts a population, and how to avoid or mitigate any impacts as required.

RTC (O-4-9) explains the process for listing the Crotch’s Bumblebee. Then it goes on to state that it has low potential to occur onsite, due to inappropriate habitat and few records, and alleged doubts on the identification of the latter.

In Rebuttal, I disagree with the second sentence. The RTC does not accurately describe the Project’s vegetation, which from personal observation is open enough to support Crotch’s Bumblebee, as their habitat is described. All the plant genera reported as nectar sources appear on the EIR plants list. When I searched CNDDB, I found many more, and more recent, collections in the immediate vicinity than the RTC claims, and these are referred to above. Some of the specimens were collected by Dr. James Hung, who comprehensively surveyed the bees of San Diego County for his doctoral research and is widely considered a leading expert on San Diego’s bees, so likely the identifications are valid and current. The evidence strongly suggests that Crotch’s Bumblebee has a high probability of occurring on the Project site.

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Thank you for taking this rebuttal statement on the Response to Comments for CNPSSD’s comment on the Fanita Ranch FREIR. Please enter this document in the record for the FREIR and all subsequent processes that are linked to it.

Sincerely,
Frank Landis, PhD
Conservation Chair
California Native Plant Society, San Diego Chapter

NBER WORKING PAPER SERIES
MANDATED VS. VOLUNTARY ADAPTATION TO NATURAL DISASTERS:

THE CASE OF U.S. WILDFIRES
Patrick W. Baylis
Judson Boomhower
Working Paper 29621
http://www.nber.org/papers/w29621

NATIONAL BUREAU OF ECONOMIC RESEARCH
1050 Massachusetts Avenue
Cambridge, MA 02138
December 2021
We are grateful to seminar participants at the NBER EEE Spring Meeting, the UC Environment and Energy seminar, Georgetown University, and the Ostrom Workshop. Richard Carson, Julie Cullen, Meredith Fowlie, Rebecca Fraenkel, Josh Graff Zivin, Andrew Plantinga, Matt Wibbenmeyer, and Amy Work provided helpful input, and Kate Dargan, Scott Witt, and numerous county assessors and CAL FIRE staff provided guidance and helped us access data.

Kevin Winseck and Wesley Howden provided excellent research assistance. Property data were provided by Zillow through the Zillow Transaction and Assessment Dataset (ZTRAX). More information on accessing the data can be found at http://www.zillow.com/ztrax. The results and opinions are those of the authors and do not reflect the position of the Zillow Group or the National Bureau of Economic Research.

NBER working papers are circulated for discussion and comment purposes. They have not been peer-reviewed or been subject to the review by the NBER Board of Directors that accompanies official NBER publications.
© 2021 by Patrick W. Baylis and Judson Boomhower. All rights reserved. Short sections of text, not to exceed two paragraphs, may be quoted without explicit permission provided that full credit, including © notice, is given to the source.

Worldwide natural disaster losses averaged $218 billion per year during 2016– 2020, a 60% increase in real terms over the preceding 30 years.1 This trend is predicted to accelerate under future climate change. Efficient investment in adaptation is essential in the face of these escalating risks. Yet takeup of protective technologies and behaviors appears to be hindered by a constellation of market frictions. Homeowners misperceive disaster risks and thus the value of protective investments (Hallstrom and Smith 2005; Donovan, Champ, and Butry 2007; Gallagher 2014; McCoy and Walsh 2018; Bakkensen and Barrage, Forthcoming). Monitoring costs and other insurance market imperfections mean that mitigation behaviors may not be accurately reflected in property insurance prices (Kunreuther and Michel-Kerjan 2011; California Department of Insurance 2018; Wagner, Forthcoming). Public disaster spending programs may reduce private incentives for property protection (Kousky, Luttmer, and Zeckhauser 2006; Deryugina 2017; Baylis and Boomhower 2019). And in some settings, spatial externalities across neighboring properties lead to diverging private and social benefits of mitigation (Shafran 2008; Costello, Qu´erou, and Tomini 2017).

One widely-adopted approach to these market failures is to provide information and subsidies to increase voluntary takeup.2 A more controversial but increasingly common alternative is to mandate investments in resilience.3 Mandatory standards ensure wider adoption. However, if the regulator misjudges the effectiveness of the required actions, the level of the hazard, or individual risk

1. Loss data are from Munich RE and are in 2020 dollars.

2. Examples in the U.S. include the Ready campaign and Ready.gov website; the Community Rating System under the National Flood Insurance Program; the StormReady, Hurricane Protection Week, and National Tsunami Hazard Mitigation programs; the Firewise USA program; and the Community Wildfire Protection Plan program.

3. Florida has construction standards for hurricane winds, and codes also exist in various regions for winter storms and non-weather disasters such as earthquakes and tsunamis (Federal Emergency Management Agency 2020). In flood-prone areas, U.S. federal rules require homes to be elevated and some localities have imposed even stricter requirements. California, Utah, Nevada, and Pennsylvania have statewide wildfire building standards while in other states, notably Colorado, wildfire codes have been adopted at the local level (Insurance Institute for Business and Home Safety 2019). Australia, New Zealand, France, and Italy also have wildfire building codes (Intini et al. 2020). 1 preferences, some individuals may be compelled to make costly investments they would have preferred to avoid even if fully informed and fully accountable. Implementing mandatory standards is also more politically challenging.4 Despite the important differences between these instruments, there is little empirical evidence about outcomes under a mandated resilience regime compared to a counterfactual of purely voluntary takeup.

In this paper, we consider the case of wildfire building codes in California.

California has suffered over $40 billion dollars in wildfire property damages in the past 5 years. The state also has among the strictest wildfire building codes in the world. We provide the first comprehensive evaluation of the effect of these codes on own-structure survival as well as neighbor spillovers via structure to structure fire spread. We then embed these empirical estimates in an economic model to calculate net social benefits of wildfire building codes as a function of local wildfire hazard and number of close neighbors.

This analysis takes advantage of a new dataset that includes property-level data for almost all U.S. homes exposed to wildfire between 2000 and 2020. We compiled the data by requesting post-incident damage censuses from numerous emergency management agencies and individual county assessors. We merged these lists of damaged homes to assessor data for the universe of (destroyed and surviving) homes inside wildfire burn areas. The data show that even during catastrophic wildfires, more than 50% of exposed homes survive. One of the key advantages of the new data is the ability to observe and learn from these surviving homes. The property-level loss information also distinguishes the wildfire data from floods and other disasters where loss data are typically available at the zip code or Census tract level. In addition to the new loss data, the empirical work also leverages emerging tools in spatial analysis, including high-resolution aerial imagery and precise “rooftop” geocoding of structure locations.

The empirical design leverages rich variation in building code requirements

4. For example, efforts to adopt statewide wildfire building standards in Oregon and Colorado have failed politically (Sommer 2020).
2 across space and over time. The complex nature of building regulation in California creates a patchwork of wildfire standards across localities. We also observe fires in other states that do not have wildfire building codes. In all of these places, we observe homes built before and after changes in California’s codes. This identifying variation yields credible counterfactual predictions for how homes would have performed in the absence of California’s standards. Our preferred statistical model is a fixed effects regression that compares the likelihood of survival for homes of different vintages on the same residential street during the same wildfire event. These street fixed effects allow us to compare groups of homes that experience essentially identical wildfire exposures.

We find remarkable vintage effects for California homes subject to the state’s wildfire standards. A 2008 or newer home is about 16 percentage points (40%) less likely to be destroyed than a 1990 home experiencing an identical wildfire exposure. There is strong evidence that these effects are due to state and local building code changes - first after the deadly 1991 Oakland Firestorm, and again with the strengthening of wildfire codes in 2008. The observed vintage effects are highly nonlinear, appearing immediately for homes built after building code changes. There are no similar effects in areas of California not subject to these codes or in other states that lack wildfire codes.

We also find that code-induced mitigation benefits neighboring homes, consistent with reduced structure-to-structure spread. These neighbor effects are in keeping with anecdotal reports of home-to-home spread as a factor in urban conflagrations (Cohen 2000; Cohen and Stratton 2008; Cohen 2010).5 Our results imply that, all else equal, code-induced mitigation by a neighbor located less than 10 meters away (within the distance fire experts refer to as the home ignition zone) reduces a home’s likelihood of destruction during a wildfire by about 2.5 percentage points (6%). This benefit is even larger when homes have multiple close neighbors.

5. We are also aware of at least one insurance company which will not sell homeowners insurance to homes located next to a home with a wood roof in high-risk areas (Allstate Indemnity Company 2018).
3 Finally, we embed our estimates of building code benefits in an economic model and calculate the approximate net social benefits of such a policy for a random sample of California homes in wildfire hazard areas. Like other disaster risks, many homeowners are only partially insured (or in the extreme, wholly uninsured) against the full cost of replacing a structure destroyed by wildfire (Klein 2018; California Department of Insurance 2018). This means that the benefits of building codes include not only reductions in expected losses but also additional insurance value due to reduced household exposure to uninsured risk. Our calculations find that wildfire building codes deliver unambiguously positive benefits in the most fire-prone areas of the state, especially where homes are clustered closely together and thus create large risk spillovers. In areas with more moderate wildfire risk, building standards for new homes can also be justified given reasonable assumptions about household risk aversion, future increases in wildfire hazard, and/or co-benefits of building codes (such as reductions in public expenditures on wildland firefighting). On the other hand, the costs of retrofitting existing homes to meet current wildfire building standards are substantial and our analysis suggest full retrofits are only economic in areas with extreme wildfire hazard.

These results are broadly relevant to natural disaster management. In this important setting, a standards-based approach achieved substantially greater compliance with risk mitigation practices. The policy nearly halves loss risk when structures are exposed to the hazard. Moreover, a cost-benefit calculation implies that low takeup in the absence of standards is likely driven by market failures as opposed to a lack of cost-effectiveness. These facts can inform policies to mitigate other risks like floods, hurricanes, tornadoes, and heat waves, where voluntary takeup of adaptation investments also appears to be limited.

This work also has immediate implications for wildfire policy. Our results imply there are gains to be realized from strengthening building codes in other states and countries to match California’s. This evidence is relevant to current 4 proposals in Oregon, Washington, and other states.6 Meanwhile, California is moving to expand the geographic coverage of designated wildfire hazard zones and reduce the ability of local jurisdictions to opt out of recommended standards.7 Separately, new California legislation from 2020 provides financial incentives for retrofits of existing homes in wildfire-prone areas.8 The law specifically calls for support of “cost effective” retrofits, a concept for which the evidence in this study is essential. Additionally, policymakers are confronting pressing issues of insurance rate reform in response to mounting wildfire losses. One key debate is the degree to which individual investments improve structure survival and should thus be rewarded through regulated insurance discounts (California Department of Insurance 2018). This paper’s evidence on the effectiveness of such investments during real wildfires bears directly on this question.

Our work builds on previous studies of natural hazard mitigation. For wildfires, a number of engineering and forestry studies describe the effects of construction materials and vegetation management on structure resilience (Gibbons et al. 2012; Syphard et al. 2012; Syphard, Brennan, and Keeley 2014; Alexandre et al. 2016; Syphard, Brennan, and Keeley 2017; Kramer et al. 2018; Syphard and Keeley 2019). Our paper focuses on the effects of a mandatory mitigation policy, while these previous studies measure technology effectiveness (i.e., survival of homes whose owners did vs. did not choose to take mitigation measures). Two studies on the related topic of hurricanes do consider building codes, with conflicting results. Dehring and Halek (2013) is a small case study of several hundred homes during Hurricane Charley in 2004.

Simmons, Czajkowski, and Done (2018) study aggregate zip-code level data on annual insurance claims by homes built in different decades to infer benefits of hurricane building codes in Florida. In contrast, our study uses highly

6. See, e.g., Profita, Cassandra. “The Labor Day Fires Burned Towns and Homes. Oregon Has a Plan to Avoid a Repeat.” Oregon Public Broadcasting, September 7, 2021.

7. S.B. 63, 2021–2022, California. https://leginfo.legislature.ca.gov/faces/billNavClient. xhtml?bill id=202120220SB63.

8. A.B. 38, 2019–2020, California. https://leginfo.legislature.ca.gov/faces/billTextClient. xhtml?bill id=201920200AB38.
5 granular property- and event-level loss data for a large sample of wildfires covering several states. Across a range of natural hazards, a parallel engineering literature attempts to calculate the value of building codes through modeling and simulation (e.g. Federal Emergency Management Agency 2020).

Finally, our work is methodologically related to a separate literature in economics on building codes and household energy consumption (Jacobsen and Kotchen 2013; Levinson 2016).

This study makes five contributions. First, we provide the first comprehensive evaluation of the effects of wildfire building codes on structure survival. Beyond the wildfire context, this result improves our understanding of disaster resilience under standards-based vs. voluntary policies. Second, we provide the first empirical estimates of the spillover benefits of wildfire mitigation investments to neighboring properties. Third, we compile a comprehensive dataset of structure-level outcomes in wildfires across several states that, to our knowledge, is the most complete accounting in existence. This new dataset will enable future work on the economics of catastrophic wildfire risk. Fourth, we approach the topic in a causal framework with an explicit empirical design, where previous work is primarily descriptive or relies on regression adjustment.

Finally, we embed the empirical estimates in an economic model to calculate net social benefits that account for local hazard, neighbor externalities, and household risk aversion.

The rest of the paper proceeds as follows. Section 1 discusses structure survival in wildfires and California’s history of building code updates. Section 2 describes the data and spatial analysis. Section 3 outlines the empirical strategy, and Section 4 presents the results. Section 5 develops the model of net social benefits and Section 6 concludes.
1 Wildfire Building Codes in California and Other States “Unlike a flash flood or an avalanche, in which a mass engulfs objects in its path, fire spreads because the requirements for com6 bustion are satisfied at locations along the path... A wildland fire cannot spread to homes unless the homes and their adjacent surroundings meet those combustion requirements.” Jack D. Cohen, Journal of Forestry, 2000.

Established forestry and engineering evidence supports the importance of the so-called home ignition zone in determining structure resilience to wildfires.

The home ignition zone includes the design of the home itself as well as an imagined area extending 30 meters away from the structure. Fire scientists emphasize the elimination of flammable materials inside this zone (e.g., Cohen 2000, 2010; Calkin et al. 2014). This guidance applies to both vegetation around the home (“defensible space”) and the construction of the home itself, especially the roof.

Among U.S. states, California has gone the furthest in mandating takeup of wildfire resilience investments by property owners. However, the application of these codes varies throughout the state. In areas where CAL FIRE provides firefighting services (State Responsibility Area or SRA), the state directly determines building standards. Within incorporated cities and other areas with their own fire departments (Local Responsibility Area or LRA), local governments have historically had greater control over code requirements.

The development of the modern standards began with the Oakland Hills Firestorm of 1991, which killed 25 people and caused $1.5 billion in property damage. The tragedy led to a series of legislative actions during the mid-1990s that required more fire-resistant roofing and maintenance of vegetation immediately adjacent to the home. The first of these was the so-called Bates Bill of 1992 (Assembly Bill 337). Among other changes, the Bates Bill encouraged stronger building standards in LRA areas by requiring CAL FIRE to produce maps of recommended Very High Fire Hazard Severity Zones (VHFHSZ). In LRA areas, local governments could then choose whether or not to adopt these recommended hazard maps (and thus the accompanying building standards).

This designation process unfolded over several years, with hundreds of local governments adopting or rejecting CAL FIRE’s proposed VHFHSZ maps at 7 different times. According to Troy 2007, 151 of 208 local governments (73%) either adopted the VHFHSZ regulations or claimed to have promulgated equally strong existing rules.9
On the heels of the Bates Bill, Assembly Bill 3819 of 1994 increased requirements for ignition-resistant roofs. These requirements applied in all SRA areas and in the subset of LRA areas where local governments had adopted recommended VHFHSZs. Roofing materials are rated Class A, B, C, or unrated.10 Starting in 1995, the law required Class B roofs on newly-constructed or reroofed homes in regulated areas. In 1997, the requirement increased to Class A roofs in high-hazard areas (a substantial improvement in fire resistance).

Finally, Assembly Bill 423 in 1999 simplified enforcement of the new roofing codes by outlawing the use of unrated roofing materials throughout the state.

The collective effect of these mid-1990s building code reforms was to substantially increase the fire resistance of roofs on newly-constructed homes in regulated areas after about 1997. The roofing requirements also applied to existing homes, but only at the time of roof replacement. Any homeowner in a regulated area who replaced more than 50% of the roof surface in a single year was in principle obligated to comply. The defensible space provisions also applied to existing and new homes. However, in practice, the primary point of enforcement for these codes was at the time of new construction; enforcement effort for existing homes was limited (see e.g., Maclay 1997).

California strengthened its wildfire codes again in 2008 with the so-called Chapter 7A standards of the California Building Code. These requirements apply to all homes built in 2008 or later in SRA areas and in LRA areas where proposed VHFHSZ designations have been accepted. The codes apply to many dimensions of new homes. Roofs must be rated class A or B, eaves

9. For a detailed qualitative study of the determinants of local VHFHSZ adoption decisions, see Miller, Field, and Mach (2020).

10. These ratings are earned through laboratory testing; for example, the Class A test involves placing a 12-inch by 12-inch burning brand on the roof material under high wind conditions. The material must not ignite for 90 minutes. 8 and exterior siding must be fire resistant, vents must covered by a fine wire mesh to resist ember intrusion, windows and doors must resist fire for at least 20 minutes, and decks and other building appendages must be built of noncombustible materials. Chapter 7A also includes additional requirements for defensible space.

The damage data collected for this study also include wildfires in Arizona, Colorado, Oregon, and Washington. None of these had statewide wildfire building standards at the time of the included fires (Insurance Institute for Business and Home Safety 2019). Some local governments – particularly in Colorado – have adopted local standards that include a diverse mix of rules about roofs, other construction materials, and/or defensible space. Our empirical analysis excludes a small number of fires in the comparison states that overlap areas known to have local wildfire building standards.11
While the non-California homes in this study are not subject to mandatory standards, they are targeted by a range of information and incentive programs that seek to increase voluntary home hardening. Programs active in these states include FireWise USA (National Fire Protection Association), the Community Wildfire Protection Plan program (United States Forest Service and Department of Interior), the Fire Adapted Communities Coalition (numerous public agencies and NGOs), the Ready, Set, Go! program (International Association of Fire Chiefs), and numerous other initiatives. 2 Data and Spatial Analysis
This section describes the construction of the database of wildfire damages, property tax assessment information, and structure locations.

11. These are the 2012 Waldo Canyon Fire, 2013 Black Forest Fire, and 2018 Mile Marker 117 Fire in El Paso County, Colorado (Quarles et al. 2013) and the 2012 High Park Fire and 2020 Cameron Peak Fire in Larimer County, Colorado (Larimer County 2020). 9 2.1 Homes and Damage Data
Damage Inspection Data
We sought to assemble as comprehensive a database as possible of administrative records for homes destroyed or damaged by wildfire in the United States.

For recent wildfires in California, this information is managed by CAL FIRE.

For earlier California fires and for fires in other states, we contacted individual county assessors (who track these damages in order to update property tax assessments) and other agencies to request historical records of structure damages. To our knowledge, the resulting database is the most complete accounting that exists of U.S. homes lost to wildfire.

California 2013–2020 : In California, the CAL FIRE Damage Inspection (DINS) database is a census of destroyed and damaged homes following significant wildfire incidents during 2013–2020. The data include street address and assessor parcel number (APN); limited structure characteristics; and for some fires, an additional sample of undamaged homes. The damage variable has four levels: destroyed (> 50% damage), major (26–50%), minor (10–25%), and affected (1%–9%). Of these, “destroyed” is the most commonly reported damage category and the only category that appears consistently across all fires. The lack of partially-destroyed structures is consistent with case study observations in Cohen (2000) and subsequent research. We thus follow the literature and focus on “destroyed” as our primary outcome.

California 2003–2013 : Data for pre-2013 wildfires in California come from two sources. For the 2003 and 2007 San Diego fire storms, we received damage assessment data from San Diego County. For other counties, CAL FIRE staff provided us with a large collection of unformatted historical damage assessment reports that we compiled and standardized to be usable for research.

Other States: Using ICS-209 incident reports, we identified the 15 counties in states other than California with the greatest number of structures lost to wildfire since 2010. We then contacted county assessors in each of these 10 counties to request damage data. We have successfully received structure-level damage data from 11 of these 15 counties.

Appendix Table 6 includes the full list of wildfires in the dataset.

Property Tax Assessment Data
We merge the damage records to comprehensive assessment data for all U.S. homes from the Zillow ZTRAX database. The ZTRAX data include information on year built, effective year built (in the case of remodels), building square footage, and other property characteristics. The merge from damage data to ZTRAX uses assessor parcel numbers, and we validate the accuracy of this merge by comparing street addresses across the two datasets. We restrict the data to include only single family homes, which account for most properties inside the wildfire perimeters in our sample. For each incident, we merge the damage data to the most recent historical assessment data from the pre-fire period. In other words, we merge to the population of single family homes that existed immediately prior to the start of the fire. Appendix Table 6 shows the number of single family homes inside of each wildfire perimeter and the share destroyed.

2.2 Spatial Analysis and Dataset Construction
Identifying Structure Rooftop Locations
This study uses the physical locations of the homes in the data in two ways.

First, homes must be spatially assigned to building code jurisdictions and to wildfire burned areas. Second, the measurement of spillovers across properties requires precise distances between neighboring structures. The street address-based geocoding methods typically used in academic research are not sufficiently detailed for this second purpose, which requires accurate structure locations at a meter scale. We solved this challenge by combining several spatial datasets to identify precise rooftop locations. First, we limit the population of ZTRAX homes to all homes in zip codes where at least one home was destroyed. We then merge these ZTRAX records to parcel boundary maps 11 from county assessors using assessor parcel numbers. This yields a parcel polygon for each home. We then use comprehensive building footprint maps from Microsoft to identify the largest structure overlaying each parcel.12 We call this location the “footprint location.” Figure 1 shows an example for Redding, California in the area of the 2018 Carr Fire. Gray lines are parcel boundaries from the Shasta County Assessor. Blue polygons are building footprints. The purple and yellow markers show the assigned rooftop locations for each structure. Yellow markers show homes that are reported as destroyed in the damage data.

This rooftop geocoding method generates highly accurate locations, but it is dependent on the availability of high-quality parcel boundary GIS data. In areas where such data are not available (representing 13% of homes in the final analysis dataset), we instead geocode home locations using the ESRI StreetMap Premium geolocator, a commercially-available address-based product. Our quality checking shows that these locations (henceforth “addressbased locations”) are generally reliable to the parcel level but not always to the structure rooftop level. Appendix Section C describes the geocoding in more detail.

Validating Locations and Damage Reports
We quality check the calculated property locations and the damage report data using high-resolution aerial imagery from NearMap. The base image in Figure 1 shows an example. The detailed imagery allows us to manually confirm the accuracy of structure locations, which closely coincide with the blue building footprints in the figure. In addition, the NearMap imagery includes post-fire surveys for many of the incidents in our database. Figure 1 illustrates how destroyed properties are readily visible in these surveys, which allows us to confirm the accuracy and completeness of the damage data. Appendix Table 4 reports accuracy rates in a random sample of homes. For damage reports, 99%

12. The Microsoft U.S. Building Footprints Database is publicly available at https:
//github.com/microsoft/USBuildingFootprints.
12 of reported outcomes match the ground truth imagery. For rooftop locations, 98% of the assigned structure locations are on top of the structure rooftop in the ground truth imagery (with 99%+ accuracy in densely developed areas).

Locations that rely on street address based geocoding tended to be accurate to the parcel but not always to the actual structure rooftop – about 75% of these assigned locations are on top of the structure rooftop in the ground truth imagery.

Spatial Merge to Wildfire Perimeters and Code Jurisdictions We restrict the dataset to homes located within final wildfire perimeters (plus a 20-meter buffer). Depending on the state and time period, these digital perimeter maps come from the California Forest and Range Assessment Program (FRAP), the Monitoring Trends in Burn Severity (MTBS) dataset, or the National Interagency Fire Center (NIFC). We merge the homes data to spatial data on fire protection responsibility (SRA vs. LRA) and designated fire hazard (FHSZ) that together determine building codes in a given location in California. We use historical GIS maps provided by CAL FIRE to assign homes to code regimes according to the codes in effect when the home was built.13
Calculating Distances Between Neighboring Homes
We construct two measures of distance between homes. The first is the minimum distance between the building footprint polygons associated with the two structures (henceforth the “wall-to-wall” distance). This measure is only available for homes where we assign locations based on building footprints.

The second metric uses the distance between assigned point locations, which are available for all homes in the dataset. We call this metric the “centroid to centroid” distance because these points are meant to correspond to the center of the roof. The wall to wall distance is our preferred measure because it more

13. For SRA/LRA boundaries, the historical map data include updates in 1990, 1996, 2003, 2005, and annually from 2010–2020. For FHSZ, the historical map data include updates in 1985, 1998, 2007, and 2008.
13 accurately captures space between homes and because the footprint-geocoded locations are more accurate than the address-based location points (Appendix Table 4). Our main estimates of neighbor spillovers use the restricted sample of homes for which wall to wall distances are available. For robustness, we also show specifications that use centroid to centroid distances and the full sample of homes.

We identify up to 15 nearest neighbors within one kilometer for each home in the final dataset. Panel (b) of Figure 1 shows two examples. Each image shows wall-to-wall distances (in meters) from the structure marked “0”. Appendix Table 2 summarizes the distribution of number of neighbors at various distances.

Data Summary
The final dataset includes 55,408 single family homes exposed to 112 wildfires in California, Arizona, Colorado, Oregon, and Washington between 2003 and 2020. Thirty-nine percent of these were destroyed. Appendix Figure 1 shows the distribution of year built and fraction destroyed by year built for the full dataset. Appendix Table 6 reports the number of exposed and destroyed homes for each fire.
3 Empirical Strategy
This section describes the empirical design used to measure the effect of wildfire building codes on structure survival. To fix ideas, Figure 2 provides an example of the merged dataset for the 2018 Woolsey Fire in Los Angeles County.

The green and purple markers indicate locations of surviving and destroyed single family homes inside the final fire perimeter. The street map data give a sense of development density. The intensity of losses varies significantly within the burned area. Near Malibu, a large share of affected homes were lost. Further north, however, there are several areas where most homes inside the fire perimeter escaped destruction. These differences reflect varying fire 14 conditions, firefighter response times, landscape vulnerability, structure characteristics, and potentially numerous other factors. This heterogeneity adds noise to empirical analysis of structure survival. It may also introduce bias if year built or other structure traits vary similarly within burned areas. We address these challenges using an empirical design that compares the likelihood of survival for homes of different vintages on the same residential street during the same wildfire. We attribute these vintage effects to building codes by comparing vintage effects across jurisdictions with and without wildfire building codes.

3.1 Treatment Groups
Throughout the rest of the paper, we consider three types of jurisdiction. The first is SRA, where compliance with California building codes was mandatory. The second is LRA areas that were ever recommended by CAL FIRE as VHFHSZ areas (henceforth, “LRA-VHFHSZ”). To be clear, this group includes all proposed VHFHSZ regardless of whether local governments accepted the designation. There is no centralized database that records local VHFHSZ adoption decisions, but Troy (2007) reports high rates of adoption.14 The final treatment group is areas without wildfire building codes (henceforth, “no-codes”). This includes LRA areas in California that were never recommended for consideration as VHFHSZ, as well as fires in areas of Arizona, Colorado, Oregon, and Washington without any state or local wildfire building codes. Appendix Table 1 reports the number of homes in each treatment group.

14. In addition, historical news accounts show that cities that rejected the official VHFHSZ designation often still adopted the underlying code requirements in the recommended areas.

This seems to have been an attempt to achieve the state-recommended resilience requirements while avoiding the VHFHSZ label due to fears about property values (Sullivan 1995; Snyder 1995; Stewart 1995; Yost 1996; Grad 1996). One state fire official’s response: “We didn’t care if they called it a nuclear-free zone, as long as they adopted the regulations” (Maclay 1997).
15 3.2 Own-structure survival
Event study figures
We begin the regression analysis with the following event study-style model for home i on street s exposed to wildfire incident f. We estimate this model separately for the SRA, LRA-VHFHSZ, and no-codes groups. 1[Destroyed]isf =
vX=V
v=v0
βvD
v
i + γsf + Xiα + isf (1)
The outcome variable is equal to one for destroyed homes and zero otherwise.

The V variables D
v0
i
, ..., DV
i
are indicator variables equal to one if house i’s
year built falls into bin v. The main parameters of interest are the coefficients β that correspond to these vintage bins. These give the effect of each vintage on probability of survival when exposed to wildfire. The street fixed effects γsf include separate indicator variables for each street name-zip code combination within fire perimeter f. These fixed effects sweep away arbitrary patterns of damage across streets within the fire perimeter, so that the model is identified by average differences in survival between homes of different vintages on the same street. We also estimate models with finer and coarser fixed effects, including models with incident instead of street fixed effects.

The additional control variables Xiinclude controls for wildfire vulnerability at the home site. These include ground slope, aspect, and vegetation type from LANDFIRE (Rollins 2009). Some specifications also include property characteristics (lot size, building square footage, number of bedrooms).

Difference in differences
We summarize the overall effects of the wildfire building standards using a difference-in-differences (DiD) model that pools jurisdictions and time periods.

We divide the sample into 3 time periods: before 1998; 1998–2007; and 2008 onwards. The latter two periods correspond to the end of the mid-1990s roofing 16 reforms and the introduction of the Chapter 7A requirements.

3.3 Structure to structure spread
To measure the effect of code-driven mitigation on likelihood of structure-tostructure spread, we estimate the effect of building vintage on likelihood of survival for neighboring homes. Our regression models are of the form, 1[Destroyed]isf =
X
J
j=1
ρjNoCodej +
X
J
j=1
φjCodej +
X
V
v=v0
βvD
v
i +γsf + Xiα+isf
(2)
Like Equation (1), this specification controls for own year of construction and street-by-incident fixed effects. The additional regressors NoCodej and Codej are the number of neighbors within various distance bins j that were built before and after wildfire building codes. Homes are considered post-code in 1998 in SRA areas and in the year the area was first recommended as a VHFHSZ in LRA VHFHSZ areas. The coefficients ρj and φjfor j = 1, ..., J give the effect of these neighbors on own-structure survival. Our preferred specification uses 10-meter bins of wall-to-wall distance. For robustness, we also estimate a specification using centroid to centroid distances. With this latter measure, we define the closest bin as 0-30 meters because 30 meters roughly corresponds to 10 meters of wall-to-wall distance.15 We apply some additional sample exclusions when estimating Equation 2: The sample is restricted to California since we can only reliably calculate footprint locations for California homes.

We further drop condominiums and townhomes to focus on detached single family homes.

This regression identifies the causal effect of code-induced mitigation by neighboring homes if the code regime for neighboring homes is uncorrelated with other determinants of structure- and neighborhood-level risk. This assumption is bolstered by the street fixed effects, which focus on highly local variation.

15. The median building footprint area in the sample is 260 m2. A hypothetical circular roof would thus have a radius of 9.1 meters and the centroid-to-centroid distance between two such homes would be 18.2 + wall-to-wall distance.
17 Intuitively, this specification compares homes on the same street during the same wildfire whose nearest neighbors were built in different years. One might still worry, however, that even within these narrow comparisons and even after controlling for own age, the age of a home’s neighbors may still be correlated with other wildfire risk factors. We address this concern by exploring estimates for homes located slightly further away as a placebo check. Properties located 50 to 100 meters away are outside of the 30-meter home ignition zone and so present more limited direct ignition threat, but should otherwise be subject to the same potential omitted variables as directly adjacent homes. 4 Results and Discussion

4.1 Own-structure survival

4.1.1 Graphical Evidence
Figure 3 shows the raw mean of Destroyed for State Responsibility Area homes according to year of construction. About 35% of exposed homes built prior to the mid-1990s were destroyed. These destruction probabilities begin to fall for homes built after the mid-1990s, decreasing quickly to about 20%. This sharp improvement in resilience corresponds in time to the post-Oakland Firestorm building reforms.

There is also some evidence in Figure 3 that homes built before about 1980 may be less likely to be destroyed than homes built just prior to the roof requirements. This may reflect the fact these older homes are more likely to have been re-roofed at least once after the mid-1990s and complied with the requirement for ignition-resistant materials at roof replacement. This pattern would imply a replacement cycle of about 30-40 years. Actual data on roof service lifetimes is scarce, but this period is within the range proposed by the National Association of Home Builders and other sources (National Association of Home Builders 2007). To the extent that some pre-building code homes may be re-roofed with code-compliant materials, our estimates of building code effects are conservative.
18 Appendix Figure 2 shows that homes built before and after the building code changes are otherwise comparable. There are no meaningful changes in sitelevel predictors of fire risk, like ground slope, or in structure characteristics such as building square footage.

Figure 4 presents the event study estimates from Equation (1). The top panel shows homes in SRA, where WUI building codes are mandatory. The markers show estimates and 95% confidence intervals for two-year vintage bins.

The omitted bin is 1987-1988, so that these estimates can be interpreted as percentage-point differences in likelihood of destruction relative to a 1987 home. The vintage effects are flat prior to about 1993, and then begin to decrease clearly during the 1995–1999 period. The point estimates suggest additional reductions in loss probability following the adoption of the Chapter 7A codes in 2008, although the small number of homes in those bins leads to somewhat noisy vintage estimates. The overall difference in loss probability between a 1987 home and a 2008+ home is about 15 percentage points.

The middle panel shows homes in LRA areas that CAL FIRE recommended for Very High Fire Hazard Severity Zone designation. These areas again show flat trends in resilience prior to the 1991 Oakland Firestorm and subsequent Bates Bill. After the Bates Bill takes effect, the figure shows steady improvements that persist for about 12 years. The slope of these improvements appears more gradual than in SRA areas, which would be consistent with varied timing of adoption of the recommended codes across hundreds of individual municipalities. The post-2008 estimates are again noisy but imply further improvements in resilience following adoption of the Chapter 7A bulding codes.

Finally, the bottom panel of Figure 4 shows vintage effects for homes in areas not subject to California’s codes. This includes fires in areas of Arizona, Colorado, Oregon, and Washington with no state or local wildfire building codes. It also includes LRA areas in California that were never recommended as Very High Fire Hazard Severity Zones. There are relatively few homes in these groups (Appendix Table 1), so we pool them together and use wider ten-year vintage bins to increase precision. Unlike the top two panels, there 19 is little evidence of improved resilience for homes built since the mid 1990s in areas without wildfire building codes.

4.1.2 Difference-in-Differences Estimates and Robustness Checks The regression estimates in Table 1 summarize the effects of building code regimes on structure resilience. We show estimates for SRA, LRA-VHFHSZ, and no-codes areas. The various group by time period estimates can be interpreted as percentage point differences in likelihood of destruction relative to the reference category, which is pre-1998 homes in no-code areas. Column (1) shows the results with street by fire fixed effects. The near-zero coefficient on SRA ∗ Before 1998 implies that SRA homes built before the end of the mid1990s building codes reforms perform similarly to homes of the same vintage in no-code areas. In contrast, SRA homes built during 1998–2007 or 2008–2016 perform 11.2 percentage points and 15.9 percentage points better, respectively.

Differencing the pre-post differences across code areas yields a DiD estimate of 13.1 percentage points. The same pattern exists for LRA VHFHSZ areas, with no difference before 1998 and substantial improvements in the post-code periods. The DiD estimate for LRA VHFHSZ areas is 12.2 percentage points.

Lastly, these improvements are smaller or absent in the no-codes comparison group, where homes built in the latter two time periods show only minor improvements that are not statistically distinguishable from zero. This is further evidence that the improvements in the code areas are due to building codes as opposed to other time-varying factors. The regression also includes controls for topography and vegetation. As expected, slope steepness at the home site increases vulnerability. A home on a 10 degree slope would be six percentage points less likely to survive than an otherwise-identical home on flat ground.

This specification also includes fixed effects for the dominant vegetation type in the area of the home.16
The remaining columns of Table 1 explore alternative specifications. Col16. We assign vegetation types as the most common fuel model in a 25-meter radius around the home.
20 umn (2) adds building characteristics from the assessor data. Building square footage, number of bedrooms, and lot size do not appear to have meaningful effects on survival after controlling for year built and street. Home characteristics data are missing for about 20% of homes, which shrinks the sample in this third column. The final three columns show different sets of fixed effects. Column (3) includes separate fixed effects for each group of 100 adjacent homes on each street (ordered by house number). This specification addresses a potential concern that some streets in the sample include many hundreds of homes. The more granular fixed effects do not materially change the estimates. Column (4) groups homes on the same street and side of the street, assuming that house numbers follow the convention of odd and even numbers on opposite sides. This specification also does not change the results. Finally, Column (5) omits the street fixed effects and instead uses incident fixed effects. These incident dummies absorb fire-specific severity and arbitrary time trends in preparedness, but unlike the street fixed effects they do not adjust for differences between exposed homes within the same wildfire incident. The point estimates are slightly larger in SRA areas and slightly smaller in LRA VHFHSZ areas. Notably, the R2 with incident fixed effects is smaller than with street fixed effects (0.39 vs 0.63). This difference implies that the street fixed effects remove variation in fire severity and other factors within incidents that might otherwise threaten identification. Nevertheless, the estimates are broadly stable across specifications. None of the estimated effects in Columns (2) through (5) are statistically different from those in Column (1).

In principle, the street fixed effects design could underestimate the effect of building codes due to the spillover benefits that we document in the next section. If code-induced investments also benefit nearby pre-code homes, the difference in outcomes between post-code and pre-code homes will understate the true effect of codes on survival.17 This attenuation could be exacerbated by street fixed effects, which by construction are focused on homes located relatively close to each other. Such reasoning might lead one to prefer incident

17. This is a violation of the Stable Unit Treatment Value Assumption, or SUTVA (Rubin 1980).
21 fixed effects. In practice, as we show in the next section, spillovers are highly localized and are small compared to the own-resilience effects. In the spirit of exhaustiveness, Appendix Table 3 investigates the quantitative significance of SUTVA concerns by controlling directly for the number of pre- and post-code near neighbors in the street fixed effects regression. Ultimately, the differences in the estimated building code effects across these approaches – street fixed effects, incident fixed effects, and street fixed effects directly controlling for spillovers – are small enough that the various results are not statistically different.

4.2 Spillovers to neighboring properties
This section discusses the spillover benefits of code-induced mitigation to neighboring homes. Figure 5 shows regression results for Equation (2). The top panel shows effects of the presence of pre-code neighbors at various wall-towall distances. One or more pre-code neighbors within 0-10 meters increases own-structure loss probability during a wildfire by about 3 percentage points.

These effects attenuate with distance, going to zero at 30-40 meters. Notably, this is the distance that wildfire managers consider to be the home ignition zone - the distance within which flammable material presents a risk of structure ignition (Cohen 2000, 2010; Calkin et al. 2014). The near-zero estimates beyond 40 meters bolster the validity of our research design. If our estimates for the nearest neighbors were biased by omitted predictors of resilience that co-vary within neighborhoods, one would expect that bias to also appear in estimates for homes another few dozen meters away (Figure 1b provides a useful illustration of these small distances).

The bottom panel shows the estimates for post-code neighbors. The confidence intervals for these estimates are wider since we observe fewer post-code homes. However, the point estimates suggest that the presence of close neighbors built under WUI building codes does not increase own-structure loss probability. There is also no implied effect of further-away post-code neighbors on own survival, offering additional placebo evidence to support the identifying 22 assumptions behind this regression.

Table 2 reports regression estimates for near neighbors that allow effects to vary with the number of neighbors. Column (1) considers neighbors at a wallto-wall distance of less than 10 meters. A single pre-code neighbor increases own-structure loss risk by 2 percentage points. Two or more pre-code near neighbors increases the effect to 3.1 percentage points. This latter category mostly represents the effect of homes with two neighbors, given that very few homes have more than two neighbors within 10 meters (Appendix Table 2).

The estimated effects of nearby post-code neighbors are close to zero. Column (2) shows the same regression using a restricted sample of areas where our measured distances between homes are likely to be particularly accurate. This sample includes denser areas (homes with at least 10 neighbors within a 200 meter radius; see Appendix Table 4) and fires since 2013 (for older incidents, it is more likely that parcel boundaries have changed since the fire). The estimated risk posed by pre-code neighbors is slightly larger in this specification, perhaps due to measurement error in wall-to-wall distances in the full sample.

The estimates for post-code neighbors are again zero. As another robustness check, Columns (3) and (4) present similar results based on the centroid-tocentroid distance measure. One pre-code neighbor within 30 meters of centroid distance – roughly equivalent to 10 meters of wall distance – increases own loss risk by 2.6 percentage points, and two or more increases risk by 5 percentage points. Again, the point estimates for post-code neighbors are much smaller and close to zero.
5 Net Social Benefits of Building Standards
The empirical results show that compared to reliance on voluntary action alone, California’s wildfire building codes substantially reduced average structure loss risk during a wildfire. They also reduced the risk to a close neighbor’s home. Having documented these large resilience benefits, we now embed the results in a simple economic model in order to benchmark the approximate net social benefits of wildfire building codes. We use our estimates to explore 23 the minimum annual disaster probability at which universal mitigation investment is welfare-improving, given various values of neighborhood density and household risk aversion. This exercise is intentionally simple and abstracts from many theoretical and practical details that warrant investigation in future work.18

5.1 An Empirical Model of Hazard Mitigation
N identical individuals own homes in a neighborhood with an annual probability p F of a disaster. In the event of a disaster, each home i’s baseline probability of destruction is p
D
0 . Up-front investment in a binary mitigation measure with cost m by homeowner i reduces own loss risk during a disaster by τii and also reduces loss risk by τji for a subset of neighbors j 6= i (for example, in our application τji is non-zero for neighbors within some distance of home i and zero for the remaining homes). Mitigation benefits are additive so that a home’s destruction probability during a disaster is p
D
i = p
D
0 − Miτii −
P
j6=i Mj τij ,
where Mi ∈ {0, 1} is the homeowner’s binary mitigation decision. We capture myopia with perceived disaster probabilities ˆp F
i ≤ p
F
. These perceived
probabilities vary across households.

Consistent with stylized facts (e.g., Klein (2018)), disaster losses are partially insured: destruction of the home imposes insured losses L I
for the insurer and
uninsured losses L
U
for the homeowner. We initially assume frictionless property insurance markets that offer coverage at actuarially fair annual premia ki = p
F pD
i L
I
. The coexistence of uninsured risk exposure and actuarially fair premiums reflects uninsurable losses (for example, mental and emotional distress) and/or household myopia. The exposition in this section uses a static model with no discounting. Our actual calculations assume that households discount future costs and benefits at a 5% annual rate.

We define two potential measures of net benefit, risk-neutral cost effectiveness and expected utility benefit. Risk-neutral cost effectiveness is simply the

18. A more detailed theoretical treatment of private risk mitigation can be found in Costello, Qu´erou, and Tomini (2017).
24 difference in expected cost with and without mitigation. Expected utility benefit accounts for additional benefits from reduced exposure to uninsured risk.

Appendix Section D presents a sketch of the expected utility model. Actually calculating expected utility requires strong assumptions about households’ risk aversion, permanent income, ability to smooth across time periods, and other factors. We focus the derivation in this section on risk-neutral cost effectiveness (hereafter, “cost effectiveness”). We note that cost effectiveness is a lower bound on net benefits as long as homeowners are not risk-loving.

Total expected cost across households is,
X
N
i=1
[p
F
(p
D
0 −
X
N
j=1
Mj τij )(L
I + LU
) + Mim] (3)
The social benefit of mitigation by a homeowner is the sum of private and external benefits (reduced loss probability) minus mitigation costs, p
F
(τii +
X
j6=i
τji)(L
I + LU
) − m (4)
In contrast, a homeowner’s perceived change in private expected losses with mitigation is,
pˆ
F
i
τii(L
I + LU
) − m (5)
The presence of internalities (ˆp
F
i
) and externalities (τji) means that Expression
(5) is weakly less than Expression (4). If households minimize perceived private expected cost, the voluntary takeup rate will be,
µ =
1 N
X
N
i=1
1[ˆp
F
i
τii(L
I + LU
) ≥ m] (6)
which depends on the distribution of perceived probabilities. Assuming ˆp F
i
is
independently distributed, total actual expected costs under voluntary takeup are PN
i=1[p
F
(p
D
0 −
PN
j=1 µτij )(L
I + LU
) + µm].

Now consider a policy requiring mitigation by all households. Total expected 25 cost is given by setting Mi = 1 for all households in Expression (3). The difference in expected cost under the mandate vs. the voluntary regime is, (1 − µ)
h
p
F
[
X
N
i=1
X
N
j=1
τij (L
I + LU
)] − Nmi(7)
The Samuelson (1954)-style expression inside the outer brackets is the sum of private and external mitigation benefits minus total mitigation costs. The factor of (1 − µ) reflects takeup by a fraction µ of the population without the mandate. A mandate weakly reduces total expected cost if the social value of mitigation (Expression 4) is positive and strictly increases expected cost if the social value of mitigation is negative.

Before proceeding, it is worth noting some restrictions in this model. We assume additive mitigation benefits. There is some support for this in the data - for example, the approximate linearity of risk spillovers for one vs. two near neighbors in Table 2. A more complex model could instead allow the benefits of mitigation to vary with mitigation effort by others, so that mitigation becomes a strategic game between homeowners.19 We also assume identical homes and homeowners within the neighborhood and independently distributed perceived disaster probabilities. We explore heterogeneity in fire risk and neighborhood density across neighborhoods (zip codes) in the empirical implementation. Expanding the model to allow for greater heterogeneity within neighborhoods would allow a more nuanced exploration of the distribution of net benefits. We see these extensions as useful areas for future work, but prefer this simple and transparent model for the purposes of benchmarking approximate net benefits.

5.2 Implementation
We implement the model for a random sample of 100,000 homes in 424 California zip codes in wildfire hazard areas. Each zip code is modeled as a separate

19. Shafran (2008) develops such a model for vegetation maintenance in wildfire areas. 26 neighborhood with its own fire probability and number of close neighbors affected by risk spillovers.

Mitigation Benefits
The empirical results in Section 4 allow us to estimate τii and τij . The reduced form estimates of the effect of building codes on structure survival can be seen as intent-to-treat estimates of the effect of mitigation investment. Given a rate of voluntary takeup for the bundle of mitigation measures in the building code, the standard Wald estimator gives τii and τij as the ratio of the reduced form estimates and the difference in takeup rates in the codes and no-codes areas.20 In the theoretical model, voluntary takeup µ depends on beliefs about fire risk and might thus be expected to vary between neighborhoods. In practice, survey data on voluntary mitigation is scarce and the available data do not allow us to calculate neighborhood-specific voluntary takeup rates. Our base calculation uses a voluntary takeup rate of one-third. Appendix Section E describes how we calculate this takeup rate based on CAL FIRE inspections of destroyed and surviving homes for a sample of recent California wildfires, including caveats about limitations of the data (which is nevertheless the best existing survey evidence for our purposes).

Our reduced form estimate for own survival benefit for SRA homes implies a value of τii of 0.195 ( .13.1
1−0.33 = 0.195). For τij , our reduced form estimate of neighbor benefits in Table 2 is 2.3 percentage points for neighbors up to 10 meters away in wall-to-wall distance (and close to zero beyond 10 meters). The effect also appears approximately linear in number of neighbors that mitigate, at least over the limited range of number of neighbors that we can observe in the data. Thus, our estimate of τij is 0.034 for each neighbor within 10 meters (
−.0.023
1−0.33 = −0.034) and zero for all further-away neighbors.21

20. See e.g., Angrist and Pischke (2009) p. 127-133. This calculation assumes perfect compliance by homes subject to codes and a homogeneous effect of mitigation on structure survival.

21. In principle, mitigation at further-away homes also benefits home i through potential “domino effects”: a near neighbor becomes less likely to ignite due to action by that neighbor’s neighbor. Our estimates imply that these effects are small on average (on the order of 27 Sampling at-risk homes
Unlike the empirical analysis of building code effects, which uses homes located inside historical wildfire perimeters, the net benefits calculation considers a group of homes sampled randomly from all California homes in fire hazard areas. To construct this sample, we start from all California homes in designated wildfire severity zones (SRA or LRA) and filter out zip codes containing fewer than 100 homes. We then randomly draw min(n, 250) homes from each remaining zip code where n is the number of homes in the zip code. This yields a sample of 100,230 homes subject to wildfire building codes in 424 zip codes.

We identify each home’s annual wildfire exposure probability p F using data
from the United States Forest Service (USFS) Wildfire Risk to Communities project. This measure captures the annual probability of moderate to severe wildfire exposure (Scott et al. 2020).22 We also identify each home’s number of neighbors within 30 meters of centroid to centroid distance. This roughly corresponds to the number of neighbors within 10 meters of wall-to-wall distance (see footnote 15) and is less demanding to calculate in this new random sample of homes.

Costs and Losses
Our main estimates of mitigation costs come from Headwaters Economics (2018). That study uses construction estimating tools from R.S. Means to calculate the additional cost to build a home that complies with California’s Chapter 7A wildfire code. Overall, that study reports zero cost difference between code-compliant and standard designs. This counter-intuitive result arises because one aspect of code-compliant construction (exterior siding) is substantially less expensive than standard designs. These savings offset increased costs for roofing, landscaping, and other areas. Our main estimate of

0.0342).

22. We use the product of Burn Probability (the total annual wildfire probability) and Flame Length Exceedance Probability 4 (conditional on any fire, the probability that the fire will reach moderate or greater threat status).
28 code compliance costs ignores savings from code-compliant siding on the theory that owners would make this choice even without standards. This gives a cost estimate of $15,660. We also report results using alternative cost estimates from the National Association of Home Builders. Their estimated wildfire code compliance costs for newly-built California homes include a low scenario of $7,868 and a high scenario of $29,429 (Home Innovation Research Labs 2020).23 Finally, we show a “retrofit” scenario based on Headwaters Economics’ estimate of $62,760 to fully replace roofing and exterior walls on an existing home.

Our assumed losses for a home destroyed by wildfire include rebuilding costs, belongings and contents of the home, alternative living costs while the home is rebuilt, and costs for debris removal and hazardous waste cleanup. Rebuilding, contents, and alternative living arrangements costs come from the FEMA Hazus model (Federal Emergency Management Agency 2021). We match as closely as possible the characteristics of the model home used to estimate code compliance costs in Headwaters Economics (2018).24 We regionally adjust these costs to California using geographic adjustment factors from R.S. Means provided in the Hazus model. The resulting cost of reconstruction and contents losses is $766,725. The Hazus cost for alternative living arrangements and disruption (e.g., moving costs) for 24 months is $61,696. For debris removal (which is borne by homeowners) and hazardous waste cleanup (borne by governments), we add a total of $150,000.25
We assume that mitigation investments have a protective lifetime of 40 years.

23. These are costs to meet the International Wildland Urban Interface Code, which is similar to the Chapter 7A code. In the low scenario, we ignore $3,839 of gross savings from code-compliant siding as we do for Headwaters Economics (2018).

24. The model home in Headwaters Economics (2018) is a 2,500 square-foot single-story home with 2-car garage constructed in Montana for $140 per square foot. We use Hazus cost estimates for the same size, number of stories, and garage in the “custom” construction class, the closest corresponding cost category.

25. For cleanup and debris removal costs, see Klein (2018); Lewis, Sukey, “Cleaning Up:

Inside the Wildfire Debris Removal Job That Cost Taxpayers $1.3 Billion.” The California Report, July 19, 2018; and Bizjak, Tony, “State’s Effort to Clean Up After the Camp Fire is Off to a Rocky Start”, Sacramento Bee, January 13, 2019. 29 In the absence of mitigation investment, the probability of loss when exposed to wildfire for a home with no close neighbors is 44%.26 Households discount future costs and benefits at 5% per year.

5.3 Results of Net Benefit Calculation
Figure 6 illustrates the results of this calculation. The scatter plot shows zip code-level averages of annual wildfire hazard and number of near neighbors.

The wildfire hazard reaches strikingly high levels: several zip codes face annual event probabilities above 2% per year, implying a significant wildfire exposure every 50 years on average. The color scale shows the social benefit of mitigation investment in each zip code following Expression (4). The dashed black line shows a threshold for positive net benefits of building standards. Homes to the right of this line have lower expected costs with mitigation investments than without. The threshold bends to the left as the average number of neighbors increases due to the spillover benefits of mitigation across properties. For a home with zero near neighbors, the break-even annual wildfire hazard is about

0.45%. The break-even annual hazard for a home with 1 near neighbor is

0.39% and for a home with 4 near neighbors it is 0.27%.

These cost effectiveness estimates are a lower bound on the net benefits of universal mitigation. One important reason for this is that many homeowners are substantially underinsured for natural disaster losses. Mitigation investments yield additional welfare benefits by reducing exposure to uninsured risk. Even for properties covered by homeowners insurance, Klein (2018) reports that coverage limits for wildfire-destroyed properties are often up to 50% below actual losses. Table 3 reports break-even annual wildfire probabilities for a home with

1.2 near neighbors (the sample mean) based on the expected utility model in Appendix Section D. Although this model requires additional strong assumptions, these back-of-the-envelope numbers depict how risk aversion might affect program benefits. For example, if code compliance costs $15,660, a homeowner

26. The approximate destruction probability for SRA homes under current codes is 0.4 − .156 = .244 (Table 1). Combined with the own-structure mitigation effect, this gives the implied loss probability in the absence of mitigation: .244 + .195 = 0.44. 30 with a coefficient of relative risk aversion of 5 and an insurance policy covering two thirds of total losses would be better off investing in mitigation wherever the annual probability of a damaging wildfire exceeds 0.33%.27 Table 3 also reports results using other estimates of mitigation cost. The zero net cost estimate from Headwaters Economics (2018) leads to positive benefits for any level of hazard. The two additional estimates from Home Innovation Research Labs (2020) bracket the main cost estimate. Finally, the estimated retrofit cost of $62,760 results in much higher break-even hazard levels for existing homes. This kind of full retrofit to existing homes appears to generate positive benefits only for a handful of areas with extreme fire hazard.

Beyond risk aversion, WUI building codes likely have additional benefits that are not included in our calculations. These include reductions in public expenditures on firefighting during large wildfires (Baylis and Boomhower 2019), reduced demand for public assistance among fire victims (Deryugina 2017), avoided emotional and mental distress, and less need for public safety power shutoffs that interrupt electricity service during high fire-risk periods.28 Moreover, if imperfections in property insurance markets cause premiums to systematically exceed expected damages, then mitigation becomes more attractive because it reduces the risk which must be insured in the imperfect insurance market. Scientists also agree that annual wildfire probabilities are increasing throughout North America such that net benefits of WUI building codes will grow in the future. On the other hand, a more detailed analysis would need to consider possible heterogeneity in household net benefits. If some individuals have very high perceived private costs of choosing fire resistant materials and landscaping (perhaps due to strong aesthetic preferences), building standards could be costly for these households.

27. Studies of the property insurance market generally report high implied levels of relative risk aversion. Cohen and Einav (2007) and Sydnor (2010) examine deductible choices in auto and homeowners insurance respectively and find double-digit values for the mean household across a variety of specifications. Evidence from other markets suggests values closer to the low single digits (e.g., Gertner 1993; Chetty 2006).

28. For a systematic review of catastrophic wildfire costs, see Feo et al. (2020). 31 In summary, our empirical estimates and model calculations suggest that wildfire building codes yield unambiguous benefits in the most fire-prone areas of California, especially when homes are clustered closely together such that there are large risk spillovers. For areas with lower fire risk, the sign of net benefits is more sensitive to modeling choices and the assumed co-benefits of building codes. Further work on the cost-effectiveness of wildfire mitigation measures in low- and moderate-risk areas is an important area for additional research.
6 Conclusion
Efficient investment in adaptation is essential in the face of rapidly accelerating disaster losses. Yet takeup of protective technologies and behaviors is thought to be constrained by misperception of risk, insurance market failures, spatial externalities, and other frictions. The pressing question facing researchers and policymakers is how to best respond to these market barriers. One suite of policies focuses on increasing voluntary takeup through information or subsidies. Another option is to override individual decisions and mandate certain investments in hazard areas. These policies may differ substantially in their effects and their political acceptability.

This study contributes evidence on the effects and net economic benefits of a mandatory adaptation policy. We provide the first comprehensive empirical evaluation of California’s strict wildfire building codes. The analysis uses a new dataset of property-level data on U.S. homes destroyed by wildfire that was created for this study. The new data combine nationwide property characteristics information with post-fire damage assessment records collected from numerous local and state agencies. This resource has three important advantages: it collects and harmonizes previously disparate damage data; it contains a complete record of homes that survive as well as homes that are destroyed; and unlike data for floods and other losses, it is reported at the individual property level. Beyond this study, the new data will enable additional important research on disaster losses.
32 The empirical analysis in this study is bolstered by our ability to observe differences in building code regimes over time, across jurisdictions within California, and between California and other states. The empirical strategy isolates the effect of building code changes using a fixed effects design that compares outcomes for pre- and post-code homes on the same residential street. This approach narrows the comparison to homes experiencing essentially identical wildfire exposures.

The results show that compared to reliance on voluntary action alone, California’s wildfire building codes reduced average structure loss risk during a wildfire by 16 percentage points, or about a 40% reduction. They also reduced the risk to a close neighbor’s home by about 2 percentage points or 6%. These striking results imply materially different levels of resilience in communities with and without such codes. Moreover, the spatial externalities provide a classic rationale for public policy intervention even if homeowners were fully informed and rational about wildfire risk.

Having documented these large resilience benefits, we then show how the empirical results can be embedded in an economic model that accounts for mitigation costs, spatial spillovers, and risk preferences. We use our results and other values from the literature to provide a back-of-the-envelope approximation of the minimum annual wildfire risk at which universal mitigation generates positive net benefits. In the most fire-prone areas of California, the calculation shows large net benefits of building codes for new homes. Given the high cost of fully retrofitting existing homes to modern standards, full retrofits do not pass a benefit-cost test in most areas. An important task for future research is to identify individual low-cost investments that can cost-effectively improve the resilience of existing homes in high hazard areas.

In summary, the data show that an adaptation mandate substantially improved resilience to wildfires and a cost-benefit approximation suggests that low takeup without standards is more likely driven by market failures than by fully-informed individual decisionmaking. These results are immediately applicable to policy debates in the U.S., Canada, Australia, the European 33 Union, and other jurisdictions that are seeking to respond to escalating wildfire risk. More broadly, these facts should be of interest to policymakers and researchers confronting other hazards like floods, hurricanes, and heat waves where voluntary takeup of self-protective investments seems to be constrained by similar barriers. As climate change continues to increase disaster losses, this type of research on the role of public policy and market incentives in shaping adaptation is increasingly urgent.

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(a) Roof Locations and Damage Reports
(b) Distance Between Structures
Notes: Best viewed in color. (Panel a) Homes affected by the Carr Fire (2018). Markers are geocoded structure locations. Green square markers are structures reported as destroyed in the damage inspection data; yellow circular markers are all other homes in the data. The background image is aerial imagery before and after the Carr Fire from NearMap. Blue building shapes and gray parcel outlines are the building footprint data and assessor parcel boundary data used to identify structure locations (see text for details). (Panel b) Examples of calculated distances between structure walls. Images are pre-fire aerial imagery of homes affected by the Thomas Fire (2017) and Tubbs Fire (2017). Figure shows the wall-to-wall distance from the structure marked ‘0’ to the other homes.

Figure 2: Merged data example: Structure-level outcomes in the Woolsey Fire Notes: Best viewed in color. Example of merged inspection, assessor, and fire perimeter data for one fire in our dataset. Markers indicate the locations of single family homes inside the final Woolsey Fire perimeter (shown in red). Purple homes are reported destroyed in damage inspection data; green homes are all remaining homes in the ZTRAX assessment data. Street map data are from Open Street Map.
41 Table 1: Regression estimates of building code effects on own survival (1) (2) (3) (4) (5)
SRA * Before 1998 -0.022 -0.045 -0.027 -0.021 -0.029
(0.033) (0.041) (0.029) (0.037) (0.020)
SRA * 1998–2007 -0.112∗∗∗ -0.138∗∗∗ -0.117∗∗∗ -0.113∗∗∗ -0.160∗∗∗ (0.034) (0.043) (0.031) (0.039) (0.022)
SRA * 2008–2016 -0.159∗∗∗ -0.190∗∗∗ -0.164∗∗∗ -0.151∗∗∗ -0.204∗∗∗ (0.036) (0.044) (0.033) (0.041) (0.027)
LRA VHFHSZ * Before 1998 -0.031 -0.048 -0.038 -0.028 -0.005 (0.033) (0.050) (0.030) (0.037) (0.021)
LRA VHFHSZ * 1998–2007 -0.121∗∗∗ -0.142∗∗∗ -0.126∗∗∗ -0.127∗∗∗ -0.095∗∗∗ (0.034) (0.048) (0.032) (0.038) (0.025)
LRA VHFHSZ * 2008–2016 -0.159∗∗∗ -0.178∗∗∗ -0.162∗∗∗ -0.163∗∗∗ -0.130∗∗∗ (0.037) (0.050) (0.035) (0.041) (0.030)
No Codes * 1998–2007 -0.038 -0.029 -0.045∗-0.044∗-0.035 (0.025) (0.026) (0.026) (0.024) (0.030)
No Codes * 2008–2016 -0.006 0.035 0.012 -0.010 -0.071
(0.033) (0.040) (0.041) (0.033) (0.044)
Ground slope (degrees) 0.006∗∗∗ 0.005∗∗∗ 0.006∗∗∗ 0.006∗∗∗ 0.005∗∗∗ (0.001) (0.001) (0.001) (0.001) (0.001)
Lot size (acres) -0.000
(0.000)
Building square feet -0.000
(0.000)
Bedrooms 0.001
(0.003)
Street FE X X
Fuel model FE X X X X X
Street X 100 homes FE X
Street X side of street FE X
Incident FE X
Observations 48,843 38,991 48,843 48,843 48,843
R
2 0.62 0.63 0.63 0.66 0.39
Dep. Var. Mean 0.41 0.46 0.41 0.41 0.41
Notes: Table shows estimates and standard errors from five separate OLS regressions. The outcome variable is an indicator for Destroyed. Street fixed effects includes separate dummies for each streetby-incident. Incident fixed effects are dummies for each wildfire. Fuel model fixed effects are dummies for Anderson fire behavior fuel models. Standard errors are clustered by street. 46 Table 2: Neighbor Effects
Destroyed
(1) (2) (3) (4)
1 pre-code nearby homes 0.020∗∗∗ 0.023∗∗∗ 0.026∗∗∗ 0.027∗∗∗ (0.007) (0.007) (0.007) (0.007)
2+ pre-code nearby homes 0.031∗∗∗ 0.039∗∗∗ 0.050∗∗∗ 0.051∗∗∗ (0.009) (0.010) (0.009) (0.009)
1 post-code nearby home 0.001 0.002 0.010 0.001
(0.013) (0.013) (0.012) (0.013)
2+ post-code nearby homes -0.001 0.001 0.003 -0.009
(0.016) (0.018) (0.018) (0.021)
Own Year Built X X X X
Topography X X X X
Street FE X X X X
Observations 38,226 23,564 44,923 26,842
R
2 0.64 0.68 0.63 0.68
Distances Walls Walls Centroids Centroids
Subsample X X
Dep. Var. Mean 0.40 0.49 0.40 0.51
Notes: Table shows estimates and standard errors from 4 separate OLS regressions.

The outcome variable is an indicator for Destroyed, and each regression also includes dummy variables for own year built (in four year bins) and street-by-incident fixed effects. Columns (1) and (2) use wall-to-wall distances to assign neighbors, while Columns (3) and (4) use the centroid-to-centroid distance measure. Columns (1) and (3) use the full sample of single family homes, while columns (2) and (4) use a subsample in areas where our distance measures are likely to be particularly accurate. See text for details.

Standard errors are clustered by street.
47 Table 3: Break-even Hazard under Risk Aversion and Alternative Costs Insured % 100 67 33
γ = 2 γ = 5 γ = 2 γ = 5
Cost Estimate Source
New Home
$ 0 HE-Low 0 0 0 0 0
$ 4,029 NAHB-Low 0.10% 0.09% 0.08% 0.08% 0.05%
$15,660 HE 0.38% 0.36% 0.33% 0.30% 0.20%
$29,429 NAHB-High 0.71% 0.68% 0.63% 0.58% 0.41%
Retrofit
$62,760 HE 1.50% 1.46% 1.40% 1.33% 1.15%
Notes: Table shows estimated minimum annual wildfire probability for which building standards yield positive net benefits under various assumptions about cost, share of losses insured, and risk aversion. Probabilities are reported as percentages (e.g., 0.32% per year). For partial insurance scenarios, γ is the coefficient of relative risk aversion.

Calculations assume 1.2 near neighbors. See text for details of these calculations.

Source code HE represents Headwaters Economics (2018) and NAHB represents Home Innovation Research Labs (2020).
48 From: Bill and Carolyn Mills
Sent: Tuesday, September 13, 2022 8:44 AM
To: Rob McNelis <[email protected]>
Subject: Fanita Ranch-Vote NO
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 Final Revised Environmental Impact Report remains inadequate on fire safety issues. The development application should be abandoned and the land permanently conserved through the Department of Defense military base buffer program ,
Thank you,
Carolyn Mills
Santee Resident since 1970
From: Catherine Jewell
To: Chris Jacobs
Subject: Objection to Fanita Ranch development
Date: Sunday, September 11, 2022 2:33:40 PM
Dear Mr. Jacobs, We object to a city council illegal approval of the Fanita Ranch project scheduled on 9/14/22. Why are Fanita Ranch project approvals on the meeting agenda? Reapproval 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? 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. Please include our objection in the Administrative Record for the project, Thank you, Catherine & Steve Jewell
9/12/2022
Dear Mr. Jacobs and City Council,
Measure N passed by the people of Santee qualified a referendum to assure Santee residents were allowed to make the final decision at the ballot on Fanita Ranch.

Approving Item 8 for approval regarding Fanita Ranch with the illegal exclusion of a public vote on the Fanita Ranch project are unethical, antidemocracy 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).

Please save Santee from this disastrous housing project aimed at making money for the builders and their backers. This project is unsafe but ultimately a calamity for the wilderness that is fading away before our eyes, the flowers, wildlife and land can’t be reclaimed once lost to concrete. I urge you to VOTE NO on Item 8.

Thank you,
Robert and Charnelle Merrill
Just East County citizens
From: cheryl goldsmith
To: Dustin Trotter; John Minto; Ronn Hall; Laura Koval; Rob McNelis; Chris Jacobs Subject: Fanita Ranch
Date: Monday, September 12, 2022 7:52:41 AM
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
From: Christina Kaylor
To: Dustin Trotter; John Minto; Ronn Hall; Laura Koval; Rob McNelis; Chris Jacobs Subject: Fanita Ranch
Date: Tuesday, September 13, 2022 6:16:41 AM
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.

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,
Christina Kaylor
Get Outlook for Android
From: C wootton
To: Chris Jacobs; Ronn Hall; Laura Koval; Rob McNel s; John Minto; Dustin Trotter Subject: Please vote No to stop the Fanita Ranch Project Date: Wednesday, September 14, 2022 12:44:03 PM
Dear Mayor Minto, Council Members, and Mr Jacobs,
Please vote No to stop the Fanita Ranch Project

WILDFIRES/WUI
First and foremost, much of the Fanita Ranch project is surrounded by Wildland Urban Interface The more people are invited in, the more likely it is that fires will break out
To quote Sierra Club (see link below), “Most fires are caused by people especially in the wildland urban interface (WUI) all it takes is one spark from a smoke out back, a discarded cigarette, a campfire, fireworks, a car accident, a barbecue Fires can start when a spark is caused by a lawn mower striking a rock, a faulty electrical box, a fire pit, a candle, faulty or downed power lines that come with urban sprawl ” http://sandiegosierraclub org/get-involved/conservation/our-priorities/ QUESTIONS: How will you ensure that fires started by people using trails or having accidents be put out quickly before wildfires can be started especially during Santa Ana seasons and high heat conditions? How often will you maintain areas to make sure sprinklers are in good shape, wood fencing and other burnable structures are not built and fire pits or barbecues are not used, especially during fire season? POTENTIAL DAMAGE ADJACENT PRESERVE and WILDLIFE
The Goodan Ranch and Sycamore canyon preserve is home to the San Diego thorn-mint, on the Federal endangered species list and covered in the San Diego Multiple Species Conservation Plan NCCP There are many endangered species located in this preserve Golden Eagles have been found here Mountain lions were detected in 2008 specifically because preserves are part of a large contiguous tract of undeveloped land This provides suitable conditions for this wide ranging species QUESTIONS: How will you ensure that people from Fanita Ranch will not ride vehicle’s and bikes or otherwise destroy this adjacent preserve? People will be encroaching into territories of endangered species, including golden eagles and possibly mountain lions Have the protectors of Goodan Ranch / Sycamore Canyon Preserve been made aware of the proximity of residence to their preserve? Do they approve of this proximity?
https://sdmmp com/upload/SDMMP_Repository/0/93mzxyg1f7sdk6hbp482cvrw0q5nj pdf p 30 , 42, 44-5 it also interferes with the wildlife corridors for many different animals and plant species Endangered bird species are along Santee Lakes Golden eagles avoid populated areas and trails, how can this preserve actually protect them? http://www sandiegoeco org/special-species-campaign-to-save-san-diego-countys-golden-eagles/

DWELLINGS LOCATED AMIDST WILD LIFE
People will also have more contact with wildlife Most people actually do not want contact with wildlife They do not want to encounter mountain lions, coyotes, raccoons, possums, skunks, bats, rabbits, etc Most do not want to encounter rats and mice In fact, there will be poisoning of rats and mice Because rats and mice will probably end up being poisoned, prey animals are more likely to have an affect on the larger group of predators that are roaming in the preserves, especially to the north This could include hawks, golden eagles, skunks, mountain lions, foxes, and people’s very own pets
QUESTION: How can the poisoning of rats and mice be avoided?

VERNAL POOLS
Fanita Ranch has vernal pool habitats, and supports many rare plants and animals San Diego fairy shrimp, and willowy monardella ” City, county, state and federal laws officially protect vernal pools See:
https://www biologicaldiversity org/news/press releases/2012/fanita-ranch-10-19-2012 html How will you ensure that no sites will be harmed?

GOLDEN EAGLES
There has been a Bald Eagle siting at Santee Lakes last year according to various sources There have been Golden Eagles, state listed fully protected species around and within Fanita Ranch is over the years Golden eagles have been observed flying over the project area over the years In 1992, EIR Biological Tech Report (BTR) did detect Golden Eagle on the ranch The present Bio does not However, The EIR BTR says “All of these flights are assumed to have been transit flights and likely not foraging efforts.” This is an assumption not a scientific fact The project will destroy Golden Eagle foraging habitat so must be mitigated Lights and new associated power lines may cause problems Golden eagles have been electrocuted by power lines QUESTIONS: How do you intend to completely avoid impacts, not mitigate them? What kind of mitigation will you provide as compensation for mitigating Eagle foraging habitat The analysis must include GOEA activity per USFWS requirements of a 10 mi radius How will these issues mitigated? Injury/death cannot be mitigated, must be avoided How will this be done? There will be loss and there must be avoidance of foraging habitats
https://books google com/books?id=L15igJ-uhkoC&pg=SA66-PA17&lpg=SA66- PA17&dq=golden+eagles+fanita+ranch&source=bl&ots=N5PO7uilwi&sig=ACfU3U36YPb547k4FMZvOkCiSabYvNPiw&hl=en&sa=X&ved=2ahUKEwiS5P NpMfqAhU7Ap0JHa6DAlgQ6AEwFXoECBoQAQ#v=onepage&q=golden%20eagles%20fanita%20ranch&f=false https://groups io/g/SanDiegoRegionBirding/message/9253
http://www santeelakes com/wp-content/uploads/2016/10/NEWBirdlist2016 pdf

OTHER ENDANGERED SPECIES
“Fanita Ranch provides habitat for 21 mammal species, 22 species of reptiles and amphibians, and twenty-nine species of butterflies and over 100 bird species Fanita Ranch is an essential biological reservoir and serves as a strategic biological linkage to adjacent open spaces within the Multiple Species Conservation Program in San Diego County ” The endangered Quino checkerspot and Hermes butterflies, and least Bell’s vireo bird are located here The southern portion of Fanita Ranch has the bulk of 39 pair of Coastal California gnatcatcher and 40 individuals Coastal California gnatcatcher is on the federally threatened bird species list
The endangered Hermes butterflies have been documented in north Santee, where the project would be Furthermore, USFWS is looking for restoration and reintroduction sites for these butterflies https://www fws gov/carlsbad/documents/HCB SSA V1 pdf (P 25) QUESTIONS: How do you plan to help the protection, restoration and reintroduction effort for these endangered beings? https://preservewildsantee org/fanita-ranch/

MOUNTAIN LION
There have been mountain lion sittings in San Diego County Although many older are tagged, younger lions may not be The mountain lion is protected as a CESA species, the EIR incorrectly denotes it without such status QUESTIONS: Has this project provided compensatory mitigation as required, including cumulative impacts due to increasing humanwildlife interaction? With all of the trails that will be sculpted through these wildlands, animal contact could result in loss of this wildlife How will this issue be addressed?
Scripting of mitigation to the future cannot be permitted without performance standards, success criteria, enforcement, guarantee of enforcement and restoration funding, etc Please explain how you intend to do so https://sdmmp com/upload/SDMMP Repository/0/93mzxyg1f7sdk6hbp482cvrw0q5nj pdf p 42 http://www sdparks org/content/sdparks/en/AboutUs/mountain-lions html

GROUND TRUTHING ANALYSIS IS REQUIRED
Also for ALL the above wildlife, models were used in lieu of ground-truthing Models are not good enough because they tell nothing about abundance, breeding, movement, status, density, seasonal use, etc

DEFERRING MIGITATION DETAILS TO THE FUTURE
In several Instances, scripting mitigation details are deferred largely to the future This is not good enough, there are court cases supporting this
ARCHEOLOGICAL / HERITAGE / Kumayaay sites
There are archeological/heritage/Kumeyaay grinding stone sites See the following links QUESTION: The Revised EIR discloses that the required consultation with tribes has NOT been concluded When and how will all sites be mapped out and identified? How will you ensure that no sites will be harmed? When will consultation with Tribes be concluded? https://www cityofsanteeca gov/home/showdocument?id=18999 https://www keepsandiegomoving com/Libraries/Bike Projects/Appendix E Cultural Resources Technical Report sflb ashx Thanks!
Take care, be safe and well,
Regards, Cynthia Wootton
San Diego 92119
Sent from my iPhone
From: C wootton
Sent: Wednesday, September 14, 2022 12:15 AM
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: Please vote No to stop the Fanita Ranch Project Dear Mayor Minto, Council Members, and Mr. Jacobs,
Please vote No to stop the Fanita Ranch Project.

This project is in a high fire zone with poor evacuation.

Fires affect neighborhoods near Santee and Mission Trails Regional Park. Mission Trails is a cherished recreational center for people all over San Diego. It’s ancient trees provide shade during hot summer month. Two mature trees “can produce enough oxygen for a family of four for a year….An average tree can absorb…twice the amount of carbon dioxide produced by an average car’s annual mileage.”
Fires diminish air quality throughout San Diego while they burn and afterwards when burned trees no longer help reduce our smog, pollution and GHG. Fires can spread to neighboring homes. Traffic and evacuation does not only affect Santee, residents, it affects all the residents around the area who shop and use transit in Santee and their friends and families. Opposition to Fanita Ranch is widespread by residents throughout San Diego County.

I live in San Diego, adjacent to Santee and MTRP. I have dear friends in Santee, I shop there, I often use Highway 52. This affects me as it does many other people.

Thanks!
Take care, be well and safe, Cynthia
Sent from my iPad

From: Dana Gavis
To: Dustin Trotter; John Minto; Ronn Hall; Laura Koval; Rob McNelis; Chris Jacobs Subject: Fanita Ranch
Date: Sunday, September 11, 2022 10:02:19 AM
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.

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

Marni Borg September 13, 2022
Principal Environmental Planner
Development Services Department
Santee, CA 92071
Dear Ms. Borg,
Dudek has reviewed the updated San Diego County Operational Area Emergency Operations Plan and Annex Q Evacuation (adopted August 30, 2022) for consistency with the Fanita Ranch Evacuation and Fire Protection Plans.

The updated EOP Annex Q, which is most applicable, provides clarifications to previous versions and additional details to assist agencies responsible for preparing evacuation plans and managing evacuations. Our review did not identify new content that conflicts with the Fanita Ranch Evacuation Plan, Fire Protection Plan or their approach or intent. Based on this review, it is our opinion that the provided Fanita Ranch fire and evacuation analysis are valid and none of the analysis or conclusions of these technical reports requires updating.

The updated EOP and Annex Q may be viewed in their entirety at this Web location:
https://www.sandiegocounty.gov/content/sdc/oes/emergency_management/oes_jl_oparea.html

Please let me know if you have any questions or need any additional information.

Sincerely,
Dudek Fire Protection Planning Team
____________________________________
Michael Huff
Principal Fire Protection Planner
cc: Jeff O’Connor, Homefed Corporation
Marni Borg September 13, 2022
Principal Environmental Planner
Development Services Department
Dear Ms. Borg,
This letter provides Dudek’s Fire Protection Planning Team’s response to the comment letter provided by REAX Engineering on August 30, 2022, after the close of the CEQA comment period. Although the comment letter was not provided within the comment period, it raises several concerns that are addressed in the following paragraphs.

Introductory paragraphs on page 1 do not require response.

In summary, the provided comments do not raise new issues that have not already been adequately addressed in the Recirculated Sections of the Final Revised EIR. As such, Dudek’s findings and conclusions as provided in the Project’s FPP (REIR Appendix P1) remain unchanged. The Project is considered defensible from wildfire and if needed, the Project can be evacuated due to the options provided to evacuation managers.

Comment #1: Item 1 and 1.1 (pages 2 through 5); comment suggests that the FPP’s fire history analysis did not include all historic ignitions and that the commenter’s inquiry looking at 3 - and 1-mile radii showed more ignitions. The comment suggests that these additional distant ignitions highlight the frequency of ignitions near the project site and the potential for those ignitions to spread into the Project Site and surrounding communities. The comment provides three supporting graphics.

Response #1: The comment is inaccurate regarding the fire history provided in the FPP and alleged limitations regarding the radius used in that document. As stated in the FPP, Dudek utilized a 3-mile buffer for fire history, using the most complete record of fire ignitions available (CAL FIRE Fire and Resource Assessment Program). While the comment provides ignition data from other sources, these sources focus on ignitions that did not develop into wildfires above 10 acres. The ignitions that matter most are those that escape initial containment efforts and that is why they are the focus of the FPP’s analysis. The number of fires recorded to occur within 3 miles of Fanita Ranch is not an unusually high number of fires. Most areas of California have had numerous wildfires occur within three miles. The comment also inaccurately summarizes FPP Table 2, which specifically indicates that it is limited to listing 10-acre + fires from the CAL FIRE database occurring within 3 miles of the Project site, along with those that burned onto the site. It does not purport to present all ignitions. Further, the fire history recited, using the various sources for ignitions actually disproves the commenter’s main suggestion that distant ignitions result in fires that spread toward and may threaten the project site and surrounding communities. . The comment indicates that there are many more small ignitions not recorded because they all remained below 10 acres in size, which supports the fact that vegetation ignitions do not typically turn into larger wildfire events. In California, 95% of ignitions are controlled below 10 acres1.

Comment #2: Item 1.2 (page 5); comment summarizes Santa Ana winds and their effects on fire behavior.

The comment suggests that given the project’s location within a Very High Fire Hazard Severity Zone (VHFHSZ), the evacuation strategy of the project could be overwhelmed.

Response #2: The comment’s summary of Santa Ana winds is generally accurate. However, it must be clear that the VHFHSZ are established via modeling by CAL FIRE that incorporates a site’s fire environment, including fuels, terrain, and weather (Santa Ana winds included). Fire hazard severity zones have been established to ensure that new development occurring within these areas is built to a level of fire protection that is acceptable to fire agencies, specifically, building to the ignition resistant requirements of the California Building Code’s Chapter 7A and incorporation of access, water, response and defensible space. Thus, the fire hazard severity zone has already contemplated future development and the site specific FPP prepared for the Project conducts an even more robust evaluation of the fire environment and the protective features that are appropriate for a defensible community. The hazard ratings have nothing to do with whether an area can be developed or not, but do signify a higher level of fire safety is necessary. This is similar to seismic ratings - where builders need to include seismic features to make buildings safer when they are located within fault zone areas. In addition, the evacuation strategy is not anticipated to be overwhelmed because it has been contemplated, modeled, coordinated with SFD, and features built in (roadside FMZ, coordinated fire outreach, public education) that provide evacuation managers with flexibility and options. The evacuation strategy cannot be overwhelmed because it is designed to be flexible and enable an adaptive approach with a contingency of on-site, temporary sheltering, if needed.

Comment #3: Item 1.3 (no response required), 1.3.1 indicates a reference to an incorrect table in FPP Appendix B and questions the FPP’s fire behavior modeling wind inputs, suggesting that the FPP results are not able to be recreated.

The comment focuses on wind as a fire behavior modeling input variable and questions the use of 20-foot wind speeds as inputs in the BehavePlus modeling effort conducted in support of the FPP.

Response #3: As stated on page B-6 of FPP Appendix B, the County of San Diego Department of Planning and Land Use developed guidelines to identify acceptable fire behavior modeling weather inputs. These guidelines identify required wind speed inputs for modeling and state that wind measurements are recorded at 20 feet above the ground.

This wind measurement height is standard and consistent among data recorded at remote automated weather stations (RAWS) throughout the country. As noted by the commenter, mid-flame wind speeds are needed to calculate fire behavior outputs in BehavePlus. This is achieved by adjusting 20-foot wind speed values before entering them into the BehavePlus software or entering 20-foot wind speed values and a wind adjustment factor (WAF) into the BehavePlus software simultaneously. Dudek utilized the latter approach, entering a WAF of 0.4 for all BehavePlus modeling runs conducted in support of the FPP. The commenter attempted to recreate modeling efforts using BehavePlus and utilized WAFs identified in a document published by the National Wildfire Coordinating Group (NWCG), specifically using a WAF of 0.6 for chaparral and a WAF of 0.4 for sagebrush in their BehavePlus model runs, which resulted in higher flame length values than those resulting from the analysis conducted for the FPP. Dudek correctly utilized an averaged WAF of 0.4 for all model runs based on the long-term, localized experience of the fire behavior analyst. This WAF was selected to represent vegetation located in mid-slope and top of slope locations on the project site. As identified in the NWCG document identified by the commenter, such slope locations would result in WAFs of

0.3 (mid-slope) and 0.5 (top of slope). The average of these two values (0.4) was used to support preparation of the FPP for the project site. The modeling outputs do not underestimate fire behavior during a Santa Ana wind event. The modeling is repeatable, uses inputs from credible sources, and a WAF that is reasonable and logical and therefore, no adjustments are proposed for the modeling results.
1 CAL FIRE, Scott McLean, Orange County Register, September 14, 2017; “Over the last 40 years, there is a surprising trend with California wildfires”
TO: Marni Borg
SUBJECT: RESPONSE TO AUGUST 30, 2022 REAX ENGINEERING

COMMENT LETTER
3 Comment #4: Item 1.3.2 (pages 7 and 8) correctly summarizes the FPP’s terrain discussion. The comment also suggests that the FPP did not adequately consider the area’s terrain in the modeling, stating that only terrain within and immediately adjacent to the parcels were considered. The comment provides a figure (Figure 6) illustrating the site’s slopes.

Response #4: The comment is inaccurate. Dudek modeled the entire Fanita Ranch, which includes large areas beyond the development footprint. Further, fire behavior modeling is based on the premise that it is the terrain (and fuels) directly adjacent to a Project that have the largest potential effect on a project’s buildings. This stands to reason, as the closer fuels and steep slopes are, without mitigating measures, the more likely they could develop flames and heat that could intersect buildings or the built environment. However, Fanita Ranch has been designed with wide FMZs around its perimeters, pushing the nearest unmaintained vegetation and steep slopes away to the point that flame lengths in the unmaintained vegetation are less than half the width of the provided FMZ. The distant landscapes and fuels up to a few miles away may impact a community through the ember cast they can produce, but those potential threats have been comprehensively evaluated and addressed for Fanita Ranch’s proposed buildings and landscapes.

Comment #5: Item 1.3.3 (page 8) expresses disagreement with the FPP’s classification of the development site as non-burnable within the fire behavior models. It also suggests incorrectly that the FPP only models fuels within the Project parcels, ignoring surrounding fuels.

Response #5: Classifying fire-hardened, ignition resistant projects like Fanita Ranch as non-burnable from a wildfire fire behavior modeling effort is standard and supported by after-action reports that indicate wildfire does not burn through these master-planned, fire protected communities like it may through older, less maintained and ignition resistant communities. Wildfire burns into the wide FMZs and is starved of fuel. Embers do not have readily ignitable fuel sources to ignite fires that burn through the community. The use of non-burnable in the Fanita Ranch footprint is considered appropriate and no changes are proposed to the modeling or modeling results. Further, the FPP modeled fuels well beyond the project’s immediate adjacency. The entire Fanita Ranch was modeled with FlamMap and then specific areas with BehavePlus, both of which are often-used models with reliable fire behavior predictive capabilities.

Comment #6: Item 1.4 (page 8) focuses on human caused ignitions and claims that any new development increases the ignition risk and potential that the community’s protections will be overcome.

Response #6: The comment cherry-picks from the FPP and takes umbrage with conclusions regarding human caused ignition statements made within a study referenced in the FPP. The comment wrongly suggests that the FPP does not consider the potential for human-caused ignitions. In fact, the FPP reads:

Humans (i.e., human related activities or human created features, services (i.e., powerlines and electrical equipment), or processes) are responsible for the majority of California wildfires (Syphard et al. 2007, 2008; Romero-Calcerrada et al. 2008). Certain human activities result in sparks, flames, or heat that may ignite vegetative fuels without proper prevention measures in place. These ignitions predominantly occur as accidents, but may also be purposeful, such as in the case of arson. Equipment and powerlines cause the most fires in San Diego County. After that, roadways are a particularly high source for wildfire ignitions due to high usage and vehicle-caused fires (catalytic converter failure, overheated brakes, dragging chains, tossed cigarette, and others) (Romero-Calcerrada et al 2008)). In Southern California, and San Diego County, the population living at, working in, or traveling through the wildland urban interface is vast and provides a TO: Marni Borg
SUBJECT: RESPONSE TO AUGUST 30, 2022 REAX ENGINEERING

COMMENT LETTER
4 significant opportunity for ignitions every day. However, it is a relatively rare event when a wildfire occurs, and an even rarer event when a wildfire escapes initial containment efforts. Approximately 90 to 95 percent of wildfires are controlled below 10 acres (CAL FIRE 2019; Santa Barbara County Fire Department 2019).

Research indicates that the type of dense, master planned developments, like Fanita Ranch, are not associated with increased vegetation ignitions. Syphard and Keeley (2015) summarize all wildfire ignitions included in the CALFIRE Fire and Resource Assessment Program (FRAP) database dating back over 100 years. They found that in San Diego County, equipment-caused fires were by far the most numerous -- and these also accounted for most of the area burned -- followed closely by the area burned by powerline fires.

Ignitions classified as equipment caused frequently resulted from exhaust or sparks from power saws or other equipment with gas or electrical motors, such as lawn mowers, trimmers or tractors and associated with lower density housing. In San Diego County, ignitions were more likely to occur close to roads and structures, and at intermediate structure densities.

As exhibits 1 through 3 illustrate, housing density directly influences susceptibility to fire because in higher density developments, there is one interface (the community perimeter) with the wildlands whereas lower density development creates more structural exposure to wildlands, less or no ongoing landscape maintenance (an intermix rather than interface), and consequently more difficulty for limited fire resources to protect well-spaced homes.

The FPP then goes on to correctly cite Keeley for the premise that high-density housing and housing built in an ignition resistant manner poses a lower risk of ignitions than low-density housing.

In sum, the comment fails to recognize that the data does not support a finding of increases in human caused ignitions from fire hardened, master planned communities like Fanita Ranch that provide protections from accidental ignitions spreading off-site. Recirculated Sections of Final Revised EIR Thematic Response 4c, d, and e provides details on how the project’s system of protections has a dual role of protecting the community while minimizing on-site ignitions and creating layers of protections so that accidental ignitions do not spread off-site into open space. The comment also ignores the fact that the Fanita Ranch is currently surrounded on at least two sides by roads, development and other humans and human related ignition sources, and arguably on all sides due to the land uses occurring within the greater fuel bed around the Project. Because of this, ignition sources in the area already exist. The Project is, however, actively working to reduce potential new ignition sources and prevent fire spread, both for the Project and for the property-adjacent neighborhoods, through its provided protection requirements (See Recirculated Sections of Final Revised EIR, Thematic Response 4c, d, and e for details).

Comment #7: Item 1.5 (page 9) mischaracterizes standard limitation language to question whether the proposed Project’s ability to provide safe refuge sites will be possible.

Response #7: The comment utilizes standard limitation of analysis language required for this type of risk analysis.

As stated in the FPP, it is clear that new, ignition resistant buildings, especially those within a large community will not be subject to a high probability of igniting. The FPP states that “When properly implemented on an ongoing basis, the fire protection strategies proposed in this FPP would significantly reduce the potential fire threat to the community and its structures and would assist the SFD in responding to emergencies within and adjacent the Proposed Project Site. The Fanita Ranch 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.” This statement is strong endorsement that the fire protection approach has been designed to protect the community’s structures and is required to be maintained to function as intended. Because of this design and ongoing maintenance, the TO: Marni Borg
SUBJECT: RESPONSE TO AUGUST 30, 2022 REAX ENGINEERING

COMMENT LETTER
5 Project can be compared with other master planned communities with some of the same fire protection features that have been challenged by extreme weather wildfire and performed as anticipated and would provide the ability to temporarily refuge residents on-site. Refer to RTC 5 above for examples.

Comment #8: Item 1.6 (page 9). The comment states that Chapter 7A (CBC) is a minimum code requirement for structures in very high fire hazard severity zones and suggests the FPP’s limitation language conflicts with the Project’s ability to withstand wildfire.

Response #8: The comment undervalues the protections provided by CBC Chapter 7A. Each of the ignition resistant requirements of Chapter 7A have been thoroughly examined and are the result of After-Action studies (post wildfire assessments) to determine why structures were lost or saved and to then address the vulnerabilities. The requirements of Chapter 7A have been determined to address the primary reasons why buildings are lost by incorporating construction materials and methods that have proven to protect against direct flame impingement, convective or radiant heating, and embers. These requirements are reviewed and updated, as needed, every three years, to ensure that best practices continue to be implemented during the fire code adoption cycle. While there are no guarantees that a structure will not burn, the measures and features provided for Fanita Ranch are cutting edge for protecting communities from wildfire and are anticipated by professional fire protection planners and Santee Fire Department to provide the protections necessary for this development given its fire environment. This is similar to the measures provided for earthquake protection. When a building is constructed within an area considered potentially at risk of seismic activity, the building must be constructed to a higher level of protection.

Comment #9: Item 1.7 and provided table (page 9) utilizes specific post-fire data from Ventura following the Thomas Fire to suggest that homes that had some fire protection features and were damaged or lost indicates that the Project’s protection and availability to temporary refuge people on-site may become untenable.

Response #9: The comment utilizes Thomas Fire information that is generic and provides no context for whether the damaged or lost buildings were built to Chapter 7A requirements AND included wide, maintained FMZ, or were individual homes in rural areas or part of protected, master planned communities. This lack of detail allows the information to be presented as if the damaged or lost homes were comparable to those that would be built within Fanita Ranch with its system of fire protection. This is not the case. For example, the presence of an eave vent screen does not equate to having ember resistant vents that are designed specifically to keep embers out. Embers are the #1 cause for structure loss and Fanita Ranch focuses on addressing this issue. The homes lost in the Thomas Fire did not have these specialized vents. Per Figure 1 that follows, data2 from the Thomas Fire that is more appropriate for comparing with Fanita Ranch indicates that there were 855 total structures affected. The number of homes damaged or lost that were built after 2010 (which includes CBC Chapter 7A requirements) to a higher ignition resistance totals 6 buildings. The number of homes damaged or lost that were built before 2010 totals 848 buildings. Therefore, less than 1 percent (0.7%) of the affected buildings were built to ignition resistant standards that are closer to those required at Fanita Ranch compared to the greater number of older, more vulnerable homes without similar fire hardening that were lost. It is not certain that the 0.7% of homes affected were built to the same robust level with the same multi- layered fire protection approach as Fanita Ranch, but the results are clear that newer, ignition resistant communities and structures perform very well against wildfire, particularly where a part of protected master planned communities.
2 State Fire Marshall’s Data as provided by Bob Raymer, PE, Mechanical Engineer with California Building Industry Association analysis.

TO: Marni Borg
SUBJECT: RESPONSE TO AUGUST 30, 2022 REAX ENGINEERING

COMMENT LETTER
6 Comment #10: Item 2.1 (page 10) compares the Project with the evacuation that occurred during the Camp Fire in Paradise. It further questions the Wildland Fire Evacuation Plan’s approach and assumptions as well as communications during an evacuation.

Response #10: The comment compares evacuations at Fanita Ranch, a fire hardened, ignition resistant community within a shrub dominated landscape that is approximately one mile from urbanized areas with Paradise, California which is a community built primarily in the mid 1900’s within a forest landscape and approximately 12 miles from lower fuel landscapes. These are vastly different conditions and comparisons between these two communities results in major differences in wildfire behavior and how evacuations are managed. Please refer to Recirculated Sections of Final Revised EIR, Thematic Response 4e specifically for a comparison to Camp Fire and Paradise, as well as Response 4a and b for details regarding wildfire behaviorand how evacuations are managed. The primary evacuation scenarios are modeled and how messaging/direction are provided are explained in detail within the Wildland Fire Evacuation Plan.

TO: Marni Borg
SUBJECT: RESPONSE TO AUGUST 30, 2022 REAX ENGINEERING

COMMENT LETTER
7 Comment #11: Item 2.2 (page 10) questions the WFEP’s shelter in place contingency, the level of planning detail for shelter in place scenarios, and then incorrectly quotes from the WFEP regarding Safety Zones.

Response #11: The level of planning within a project-level evacuation plan is intentionally provided at generic levels as every evacuation event is unique, fluid, and is best managed by incident managers in coordination with in-thefield personnel. Technology available for evacuation management in San Diego County is robust and evacuations are managed to move those at risk, per Recirculated Sections of Final Revised EIR, Thematic Response 4a and b.

Regarding the shelter in place structures, most of the buildings on site can be considered to include the required ignition resistance and other protections to be used, as a contingency, as a temporary refuge. The shelter in place sites would be designated as such during a wildfire evacuation event by the SFD or law enforcement agency involved with evacuation management. The WFEP indicates that there are several locations where shelter in place could be successfully completed, including the school, the village, large parks, and others, but the appropriate use of these areas would be determined, as needed, during the event. Each of these sites will be far from the wildland areas, surrounded by urbanized development, and highly defensible. The comment confuses Safety Zones (which are for firefighters) with shelter in place sites. Please refer to the Project’s WFEP for details regarding Safety Zones and there intended use. Although no community has been directed to shelter in place, it is critical to have this option available as a contingency plan, as an option if an evacuation is interrupted. This is a differentiator for new communities that is not available in older, more vulnerable communities.

Comment #12: Item 2.3 (pages 10 and 11) suggests that the WFEP’s limitation language suggests that evacuation will rely on human factors, and that relying on human factors in a fire hazard severity zone will be dangerous.

Response #12: The comment regarding the WFEP’s standard limitations/no guarantees ignores the fact that the vast majority of neighborhoods within a fire hazard severity zone and/or WUI area do not include evacuation plans or organized approaches to evacuation, relying entirely on the emergency management system to facilitate evacuations. Taking a proactive approach to evacuation, the Project provides a multi-layered, vetted plan and providing flexibility and optionality for those managing the event. The emergency managers will be working with a community population that is more aware and prepared than most because the Project is conditioned to require the HOA to provide ongoing outreach. More evacuation awareness and readiness will not result in more confusion than one that is not aware. The evacuation component is a highly managed, practiced system of coordination between many agencies. SD County evacuations are very successful and getting more and more efficient with investments in resources and technology. In addition, SFD has analyzed and is comfortable with the community’s protection and evacuations plans. Further, any community that is adjacent to Fanita Ranch today is subject to potential for wildfire, but they are not nearly as protected from it as Fanita Ranch is. Most of the Fanita Ranch project’s built-in protections are "passive", that is, they do not rely on ongoing human actions; for example, construction methods and materials, fire resistant landscape, hardscape, automatic sprinklers.

Comment #13: Item 2.4 (page 11) claims that the WFEP has not addressed evacuations that may impact existing communities downstream of the Project and that an evacuation that affects one of these communities will include all of them.

Response #13: The comment is incorrect. Wildfire scenarios that were developed with input and coordination from the SFD as the most probable scenarios were evaluated. This included scenarios where Project and existing communities were affected, and targeted populations were evacuated. Evacuations occur via targeted messaging and in the field direction. This is done to minimize potential vehicle congestion and to focus on moving those who TO: Marni Borg
SUBJECT: RESPONSE TO AUGUST 30, 2022 REAX ENGINEERING

COMMENT LETTER
8 need to be moved vs moving larger populations when it is unnecessary. Please refer to the WFEP and its technical analysis provided by Chen Ryan Associates for details (Appendix D to Appendix P2 of Recirculated Sections). Also, please refer to Recirculated Sections of Final Revised EIR, Thematic Response 4a and b for evacuation procedure details.

Comment #14: Item 2.5 and Figures 8 and 9 (pages 11, 12 and 13) asserts that the FPP did not evaluate a fire ignition within the Project or adjacent to the Project under Santa Ana wind conditions and that in the opinion of the commenter, the increase in ignition probability from the Project significantly increases risk and potential wildfire exposure for downwind communities. The comment provides fire spread modeling results graphics.

Response #14: The comment’s provided modeling is not realistic as they assume the fire spreads through the Fanita Ranch community as if it was consistent with the unmaintained open space fuels. This is not the case and is supported by many examples of how modified fuels, maintained landscapes, pavement, hardened buildings do not spread wildfire as indicated in the comment’s maps. Please refer to RTC 5 above for examples. Figure 8 indicates an ignition north of the Project. It is not clear how this is a Project ignition and Dudek’s fire behavior modeling included ignitions to the north/northeast of the Project. Figure 9 also incorrectly models a fire burning through hardened landscapes. The western leg of this fire spread is possible, but in this case, evacuations would simply be to relocate potentially threatened areas to other on-site areas and/or off-site via the 2nd access. The comment’s conclusions regarding safety of area residents and the potential for increased risk is opinion unsubstantiated by facts. The FPP and WFEP have comprehensively evaluated the site, its fire environment, the types of wildfires that may occur, and how evacuations would be managed. In any event, the evacuation traffic model analysis provided by Chen Ryan Associates (Exhibit D to Appendix P2 of Recirculated Sections) considered evacuations from nearby existing neighborhoods together with the project. In each case, the conclusions were that the project is defensible, provides protections for existing neighborhoods, and that evacuations of the Project and the existing community can be managed and completed successfully. Please refer to Recirculated Sections of Final Revised EIR Thematic Response 4a, b, c, d for more details regarding evacuation, shelter in place, and fire protection.

Comment #15: Summary and Concluding Remarks (page 13) indicates that the comment letter highlights several deficiencies in the Recirculated Sections of Final Revised EIR and its analysis, that the FPP does not adequately address ignition probability increases, the additional evacuation traffic’s threat to surrounding communities, and that the FPP acknowledges the likely recurrence of wildfire in the area, and how the Project is justified.

Response #15: Per responses to each of the provided comments, the opinion that deficiencies have been identified in the Recirculated Sections of Final Revised EIR’s analysis are unfounded. The FPP analyzed and addressed the potential for increased ignitions and appropriate mitigation measures/features were provided as Project conditions to minimize the potential for on-site ignitions and for the potential of an accidental ignition escaping through the wide FMZs into off-site fuels. The FPP further contemplated that if such an ignition escaped and threatened downwind communities, FMZ would be critical for protecting structures. Thus, the FPP requires FMZs be provided for neighboring communities. As noted, the ignition sources and wildfire risk exist today via existing roads, human populations and land uses that surround the Fanita Ranch, so the Project provides a large fuel break on the landscape and provides a FMZ immediately adjacent these communities as an additional fire safety feature.

In contrast to the comment’s opinion, the WFEP comprehensively evaluates evacuations, including those that may affect existing communities. Lastly, the FPP analysis has considered the fire return interval (instead of ignoring it) and based on the findings, designed a project that can withstand the types and frequency of wildfire the data TO: Marni Borg
SUBJECT: RESPONSE TO AUGUST 30, 2022 REAX ENGINEERING

COMMENT LETTER
9 indicates may occur. This effort of addressing identified issues results in development of a safer, more defensible community that is provided fire protection at a level appropriate for the wildfires that may occur in its vicinity.

As indicated by these responses, the concerns raised by the commenter are addressed and do not raise any new, unanalyzed issues. The conclusions and findings of the Recirculated Sections of Final Revised EIR are confirmed.

Thank you for the opportunity to submit this response letter.

Sincerely,
Dudek Fire Protection Planning Team:

Michael Huff
Principal Fire Protection Planner
Att.:
cc: Jeff O’Connor, HomeFed Corporation.
1 1921 University Ave. ▪ Berkeley, CA 94704 ▪ Phone 510-387-2155 Chris Lautenberger
[email protected]
30 August 2022
Peter Broderick, Urban Wildlands Program
Center for Biological Diversity
PO Box 11374
Portland, OR 97211
Subject: Fire risk impacts on evacuation of Fanita Ranch Dear Mr. Broderick,
At your request, Reax Engineering Inc. (Reax) has reviewed the following documents associated with the Draft Final Environmental Impact Report (EIR) for the proposed development of Fanita Ranch in the County of San Diego, California:
 Appendix P-1, Fanita Ranch Fire Protection Plan, June 2022 (FPP)  Appendix P-2, Wildland Fire Evacuation Plan, June 2022 (WFEP)  Draft Environmental Impact Report, June 2022 (EIR), specifically Section 4.18 (Wildfire)  Exhibit 6, Fanita Ranch Project – Santee, California, Recirculated Sections of Final Revised Environmental Impact Report, Griffin Cove Transportation Consulting, PLLC, July 2022 We have analyzed potential fire/life safety impacts of this planned development based on the claims and responses provided in the listed documents. A summary of our findings is provided herein, organized by section of the Fire Protection Plan or Wildland Fire Evacuation Plan. 2 Figure 1. Development footprint of Fanita Ranch from FPP Figure 3a

1. Appendix P-1 Fanita Ranch Fire Protection Plan

1.1 On page 17 of the Fire Protection Plan the concept of analyzing past fire history to gain insight into potential future fires is introduced:

Fire history information evaluated in relation to Fanita Ranch, as described in section 2.2.6 of the Fanita Ranch FPP, indicates that much of the site’s vegetation last burned in 2003.

As such, the property’s vegetation is still considered in recovery, with younger plants and reduced fuel loading, but over time, without disturbance, would be expected to increase in biomass.

The topic is revisited in greater depth in Section 2.2.7 on page 22:

Fire history represented in this FPP utilizes the Fire and Resource Assessment Program (FRAP) database. FRAP summarizes fire perimeter data dating to the late 1800’s, but which is incomplete due to the fact that it includes only fires over 10 acres in size and has incomplete perimeter data, especially for the first half of the 20th century (Syphard and Keeley 2016). However, the data does provide a summary of recorded fires and can be used to show whether large fires have occurred in the project area, which indicates whether they may be possible in the future.

The FPP identifies 15 historical fires that have burned within the project site boundaries since 1910.

These fires are summarized in FPP Table 2 which is replicated below as Figure 2. 3 Figure 2. FPP Table 2 showing 3-mile fire history from 1910 to present It is important to understand that the fires listed above are only those fires that were large enough to be recorded in CAL FIRE’s perimeter database. Since 2002, the CAL FIRE perimeter database has included brush fires only 50 acres in size or larger. However, fires less than 50 acres in size are certainly large enough to trigger an evacuation and destroy structures. Additionally, the fires in FPP Table 2 appear to be only those fires that encroached on the project site. However, we found that since 1970, 32 fires in the CAL FIRE perimeter database have burned within 3 miles of the project site (Figure 3) and 17 fires have burned within 1 mile of the project site (Figure 4). Additionally, we analyzed the United States Forest Service Fire Occurrence Database1
and found that between 1992 and 2018, there
were 19 ignitions within 3 miles of the project site and 6 ignitions within 1 mile of the project site (Figure 5). This highlights the frequency of ignitions near the project site and the potential for those ignitions to spread into the Project Site and surrounding communities. 1 https://www.fs.usda.gov/rds/archive/Catalog/RDS-2013-0009.5 4 Figure 3. Fire history within 3 miles of the project site since 1970 Figure 4. Fire history within 1 mile of the project site since 1970 5 Figure 5. Fire Occurrence Database ignitions within 1 and 3 miles of the project site

1.2 The effects of Santa Ana winds (or Santa Anas for short) on fire behavior in Southern California cannot be overstated. Santa Anas are winds that occur when high pressure forms in the Great Basin (Western Utah, much of Nevada, and the Eastern border of California) with lower pressure off the Southern California coast. As air travels westward from the Great Basin, the air rises in elevation over the mountain ranges and dries as a result of orographic lift. As air then descends from these high elevations, the air’s temperature rises dramatically (approximately 5 degrees Fahrenheit for every 1000 feet decrease in elevation). This rise in temperature is accompanied by a drop in humidity, further drying the air.

The seasonality of the Santa Ana winds exacerbates the fire risks in Southern California. Southern California typically sees little precipitation between May and November, which is when herbaceous surface fuels are completely cured and live woody fuel moisture (i.e. water in shrub-like vegetation) approaches annual lows. Santa Ana winds typically occur in October, November, and December after months of dry conditions. Santa Ana winds may gust to 60 miles per hour or higher. Santa Anas pose major safety concerns for the Fanita Ranch development. As the FPP notes, much of the existing vegetation on the Project site is mixed chaparral, which exhibits rapid rates of fire spread and is conducive to spotting.

These conditions are, in part, why CAL FIRE has classified the area planned for development as a Very High Fire Hazard Severity Zone (FHSZ), the highest wildland fire risk designation in California. Given past fire and ignition history, the annual nature of Santa Ana winds, and the location within Very High FHSZs, it is possible that the evacuation strategy of the proposed development at Fanita Ranch could be overwhelmed under severe fire weather conditions.

1.3 Section 4 and Appendix B of the FPP describe fire modelling that was conducted as part of the Draft Environmental Impact Report. The FPP uses this fire modelling under various weather conditions to provide estimated spread rates and flame lengths that are in turn used to assess the efficacy of planned fuel management zones and other fire protection features. The primary inputs that affect fire modelling 6 are wind speed, topography, and fuels (including representative fuel models and moisture content). The analysis of each of these components in the FPP is addressed below.

1.3.1 Wind In the project area, the primary driver of fire risk is Santa Ana wind events which are often with low relative humidity (less than 10 percent). The FPP used 41 mph as an upper limit on sustained wind speed based on the County of San Diego Wildland Fire and Fire Protection Report Format and Requirements2
. County requirements list summer, Santa Ana, and peak conditions as distinct weather scenarios that must be included in the report. Peak conditions in the County requirements were set at the highest wind speed recorded by a RAWS during the 2003 Cedar Fire.

Footnote 1 on page B-10 mentions peak wind gusts recorded by Fire Behavior Analysts (FBAN) on the Cedar Fire. The footnote goes on to describe how peak wind gusts for the Project Site were used in BehavePlus modeling. The note also contains a reference to the incorrect table as Table 9 does not exist and Peak Weather fine dead fuel moistures are located in Table 3 of the FPP.

Fire Behavior Analysts recorded peak wind gusts up to 50 mph during the Cedar Fire. Using Table 9 Peak Weather fine dead fuel moisture values and observed wildfire peak gusts for the Project Vicinity, the BehavePlus modeling efforts would result in flame lengths of 66.1 feet, spread rates of 10.1 mph, and fireline intensities reaching up to 51,337 Btu/ft/s. Viable airborne embers could be carried downwind for 2.8 miles and ignite receptive fuels.

Since midflame wind speed, not 20-ft wind gust, is typically used in fire behavior calculations developed with BehavePlus it is not clear how wind gust was taken into account in the FPP. The confusion regarding wind inputs is compounded by the fact that Table 4 of the FPP, which lists weather variables from County of San Diego Standards, includes 20-ft wind speeds. This lack of clarity in data inputs and methodology impedes substantiation of the results presented in the FPP.

Nevertheless, we attempted to recreate the FPP’s BehavePlus modelling runs based on the data provided in Appendix B – Fire Behavior Analysis of the FPP. As noted earlier, conversion from 20-ft flame speeds to midflame wind speeds had to be performed manually as it was not provided in the Fire Behavior Analysis. Adjustment factors from the National Wildfire Coordinating Group (NWCG) were used and are shown in Table 1.

Table 1. NWCG 20-ft Wind Speed Adjustment Factors3
Fuel Model Adjustment Factor
4 (Chaparral) 0.6
1, 3, 5 (Short grass, Long grass, Brush) 0.4
Using the Summer and Peak weather variables from Table 4 of the FPP, the Summer 20-ft wind speed of 19 mph was converted to midflame wind speeds of 11.4 mph in chaparral and 7.6 mph in sagebrush. Likewise, the Peak 41 mph 20-ft wind speed was converted to a midflame wind speeds of 17.6 mph in chaparral and 16.4 mph in sagebrush. The scenario conditions described in Table 8 were replicated to the extent possible, and our results are reported alongside the results provided in the FPP to facilitate comparison (Table 2-Table 5).
2 https://www.sandiegocounty.gov/pds/docs/Fire-Report-Format.pdf 3 https://www.nwcg.gov/course/ffm/fire-behavior/82-midflame-windspeed 7 Table 2. Scenario 1 results comparison – peak weather, 25-35% slope FPP Current
Slope (%) 25-35 25 30 35
Flame Length (ft) 66.1 84.9 85.1 85.3
Spread Rate (mph) 10.1 17.5 17.6 17.7
Table 3. Scenario 2 results comparison – peak weather, 35% slope FPP Current
Chaparral Sage-chaparral Chaparral Sage-chaparral
Flame Length (ft) 63.9-66.1 38.9-40.4 85.3 40.4
Spread Rate (mph) 9.4-10.1 5.4-5.8 17.7 5.8
Table 4. Scenario 3 results comparison – summer weather, 25% slope FPP Current
Flame Length (ft) 19.4 19.4
Spread Rate (mph) 1.4 1.4
Table 5. Scenario 2 results comparison – summer weather, 37% slope FPP Current
Chaparral Sage-chaparral Chaparral Sage-chaparral
Flame Length (ft) 28.2 18.0 39.8 19.9
Spread Rate (mph) 1.8 1.2 3.9 1.5
As the above tables show, without thorough documentation of inputs we were unable to reproduce the fire behavior outputs presented in the FPP and it’s not possible to determine where the discrepancies arise. However, the comparison does show that the flame lengths and spread rates in the FPP may be underestimating fire behavior typical of the Project Site in certain scenarios, particularly Santa Ana winds.

1.3.2 Topography Fires spread faster upslope than on flat ground, and firefighting efforts are hindered by steep slopes. Areas adjacent to the project footprint include complex terrain, with onsite elevations ranging from approximately 140 feet to 300 feet above mean sea level. Most of the terrain is moderate with steep hillsides and ridges that separate the site’s sub-drainages. Slopes on the site range from 0% to 32%. The fire modelling in the FPP assigned slope values between 35 to 37% slope.

Slope must be considered in the context of the surrounding terrain, which contains slopes of up to 40% (Figure 6). By analyzing slope only within and immediately adjacent to the project parcels instead of the greater landscape context, the FPP understates the potential role that the surrounding terrain has on fire spread and control from ignitions both inside and outside the project boundaries. 8 Figure 6. Slopes within the project site

1.3.3 Fuels The fire behavior modeling in the FPP relies on species composition information to estimate climax fuel conditions. This was done to assess how current fuel conditions compare to potential future, post-development conditions. Fuels within areas proposed for conversion to development (e.g., roads, driveways, structures) were classified as non-burnable post-development. Based on the results of the fire modelling, the FPP concluded that converting flammable fuels into development would decrease fire risk and result in a fire that burns around the Project site, not through it.

Naturally, with structures defined as non-burnable in the fuel model, the model does not allow the structures to burn, thereby guaranteeing the FPP’s conclusion that converting “ignitable fuels” into “lower flammability landscape” reduces fire spread.

The FPP only maps fuels within the project parcels. However, when assessing potential fire/life safety impacts of a planned development, it is also important to assess fuels adjacent to the project footprint because fires ignited within the project footprint may spread into adjacent wildland or wildland urban interface areas. By analyzing vegetation only within the project parcels, the FPP does not address the potential role of the surrounding fuels on fire spread.

1.4 Contrary to the claims made within the FPP, new development in the wildland urban interface (WUI) does increase ignition probability because it increases the presence of humans, a primary cause of fires in Southern California, relative to the pre-development condition. The FPP makes several references to a paper authored by Syphard and Keeley4
to support a stance that high-density housing poses lower risk of ignitions than low-density housing. That article states “We investigated the most common ignition causes in two southern California sub-regions, where humans are responsible for more than 95% of all fires…”. The FPP indicated on page 25 that “…lower density housing poses a higher ignition risk than higher density communities.” However, it fails to mention that housing of any density increases probability of ignition as compared to undeveloped areas because of the introduction of humans and 4 Syphard, A.D. and Keeley, J.E., “Location, timing and extent of wildfire vary by cause of ignition,” International Journal of Wildland Fire 24: 37-47 (2015).
9 their vehicles into areas where they were previously absent. As the probability of ignition increases so too does the risk that an ignition will overcome the community’s defensive measures and evacuation plans.

1.5 The FPP states on page 36 that “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…”. From this statement, it is unclear how the FPP proposes to guarantee that shelter-in-place buildings will not be one of the structures that burn during extreme fire weather conditions. If it cannot be demonstrated that shelter-in-place structures will resist extreme fire weather conditions, then this is not a viable alternative to evacuation.

1.6 Adherence to Building Code Chapter 7A is a requirement for all new construction within Very High Fire Hazard Severity Zones (FHSZ). This is a minimum code requirement for structures that are subject to elevated probability of exposure to wildfire. The FPP acknowledges on page 87 that the potential for structure loss cannot be completely negated even by meeting minimum Chapter 7A requirements:

While these standards would provide a high level of protection to structures in this development, and would be expected to reduce the potential for ordering evacuations in a wildfire, there is no guarantee that compliance with these standards would prevent damage or destruction of structures by fire in all cases. Nevertheless, the analysis indicates that the potential risk is considered acceptable according to CEQA thresholds and industry standards.

1.7 The damage inspection report from the 2017 Thomas Fire5 broke down the construction of all buildings
damaged or destroyed during the fire in Ventura and Santa Barbara Counties (Figure 7). By referencing the damages table for the City of Ventura, it is seen that the majority of destroyed structures were of fire-resistant construction, had multi-pane windows, and had eave vent screens. Although not a majority, a significant number of the structures damaged or destroyed had enclosed eaves. Data from the Thomas Fire losses indicate that ignition resistant construction may not always be a sufficient defense against wildfires spreading under extreme conditions. Should a fire breach the structural fire resistance of the Project, and the Thomas Fire losses indicate this is possible, the shelter-in-place strategy becomes untenable and interior roadways may become impassable.

Figure 7. Table of damaged/destroyed home construction details from Thomas Incident Damage Inspection Report5
5 Mitchell, C., Pivaroff, N., Mepani, V., Meyer, T., “Thomas Incident Damage Inspection Report CAVNC 103156,” 10 2. Fanita Ranch Wildland Fire Evacuation Plan

2.1. The WFEP states on page 25:
…the primary (first) type of evacuation envisioned is an orderly, pre-planned evacuation process where people are evacuated from the Fanita Ranch community to urban areas further from an encroaching wildfire (likely to urban areas south, west, or north) well before fire threatens.

An orderly, pre-planned evacuation well before fire threatens is an ideal scenario, but reality is often not ideal. For example, during the Camp Fire evacuation, several evacuees had no choice but to abandon their vehicles and flee on foot while surrounded by flames6 , and multiple fatalities occurred when
people were trapped in their cars. The WFEP makes little accommodation for the inherent ambiguity of emergency situations when detailing possible evacuation scenarios (page 25). Nor does it address how changes in evacuation strategy, say from full evacuation to shelter-in-place, would be communicated to residents. Timely, efficient communication from authorities is imperative to protect occupants and the likelihood that an evacuation strategy would need to change under extreme fire conditions is high. The WFEP does not discuss how changes in evacuation strategy would be communicated to residents.

2.2. The WFEP does not evaluate contingency shelter-in-place/temporary refuge locations. Since rapid fire spread could prevent full evacuation due to time and road volume constraints, it is important that the community and first responders be provided with acceptable contingent means of safety. The WFEP mentions certain events when shelter-in-place strategies were successfully utilized (page 21).

However, these were not planned shelter-in-place events, but rather options of last resort as wildfire overran occupants. There is no discussion as far as how shelter-in-place operations would be conducted, no evaluation of the safety and adequacy of the shelter-in-place refuge areas, and no assessment provided for feasibility of accessing the proposed shelter-in-place locations under various fire scenarios. The WFEP states on page 28 that the shelter structures would include the same level of ignition resistance and landscape maintenance as the rest of the development, before going on to state that “during the fire, the identified safety zones may not be feasible due to distance, location, fire behavior, etc.”

Given the dynamic nature of fire, acknowledgement that contingency shelter-in-place locations may not be feasible calls into question the viability of such strategies. If the shelters cannot be reached by occupants or firefighters in the event of an emergency, their existence is irrelevant and not to be relied upon as a means of protecting people. Finally, it is important to point out that the WFEP acknowledges on page 21 that no community in California has been directed to shelter in place during a wildland fire, even communities which were designed as shelter-in-place communities such as Rancho Santa Fe.

2.3. The Wildland Fire Evacuation Plan concludes on page 36 stating: “This Wildland Fire Evacuation Program does not provide a guarantee that all persons will be safe at all times because of the recommendations proposed” and that “There are many variables that may influence overall safety”.

The conclusion goes on to recommend that,
…the evacuation process is carried out with a conservative approach to fire safety. This approach must include maintaining the Fanita Ranch fuel modification landscape, infrastructural, and ignition resistant construction components […]. Fire is a dynamic and somewhat unpredictable occurrence, and it is important for anyone living at the wildlandurban interface to educate themselves on practices that will improve safety. 6 https://abc7news.com/camp-fire-video-bodycam-of-evacuations/4850913/ 11 These statements imply that the responsibility of a “conservative approach to fire safety” relies on human factors and actions including maintenance and education, post-construction of the proposed development. The Proposed Project lies adjacent to Very High FHSZ and therefore will subject its occupants to a high probability of exposure to wildfire; it is not sufficient to assume that human factors, which are even more dynamic and unpredictable than fire itself and directly involved in evacuation decision making, will ultimately be the deciding factor between life and death when building in an area with such known risks.

2.4. An unaddressed fire safety impact of Fanita Ranch is that a fire which necessitates evacuation of the project site will also necessitate an evacuation of the surrounding developments. WFEP page 21 states:

Depending on the nature of the emergency requiring evacuation, it is anticipated that the majority of the community traffic would exit the project via Cuyamaca Street or Magnolia Avenue. These are the most direct routes for the Fanita Ranch Community.

Fanita Parkway may be used by the western portion of the Fanita Parkway Community, depending on the time available for evacuation and the need for additional movement via the southerly route. In a typical evacuation that allows several hours or more time (as experienced for most areas during the 2003, 2007, 2014, 2016, and 2017 wildfires), all traffic may be directed to the south and out Cuyamaca Street and/or Magnolia Avenue.

Because the egress roads from Fanita Ranch will merge with existing major evacuation routes along Cuyamaca St., Magnolia Ave., and Fanita Pkwy, the road network must not only be capable of routing Fanita Ranch residents but also the residents from nearby neighborhoods. A wildland fire that requires evacuation of one of these developments will require evacuation of all of them; to treat evacuation of the individual developments as separate, unrelated events neglects the fact that evacuating residents from these developments will rely on the same road network.

2.5. Under Santa Ana winds, a fire ignited within or adjacent to the project footprint would spread toward population centers to the southwest of the project site. Potential impacts, especially evacuation impacts, to communities around the proposed Project from fires igniting both within and outside the project site under Santa Ana wind conditions are not addressed in the FPP. To qualitatively illustrate potential impacts to the means of egress in and around the project site, 2 hours of fire spread was modeled with FlamMap under Santa Ana conditions with a wind speed of 30 mph out of the northeast.

Modeled fire perimeters are shown in Figure 8 and Figure 9. Both scenarios would likely trigger evacuation protocols for Fanita Ranch and the surrounding communities. 12 Figure 8. Offsite ignition that impacts evacuation routes under Santa Ana winds.

Figure 9. Onsite ignition that impacts evacuation routes under Santa Ana winds.

The FPP does not adequately address adjacent communities’ increased fire risk from the Fanita Ranch development. Instead, the DEIR and FPP conclude that the project would mitigate any increase in ignition sources with irrigated areas, fuel modification zones, and additional human presence and that the project, due to these irrigated areas, zones, and additional human presence, would improve fire safety for residents 13 and adjacent communities. I do not agree with this conclusion because a fire ignited in the project site under Santa Ana winds could easily spread Southwest toward population centers through complex, steep terrain and highly flammable chaparral and coastal scrub vegetation types, at rates of several miles per hour with spotting distances more than 1 mile ahead of the flame front. With these spotting distances, embers would be largely unimpeded by fuel modification zones, irrigated areas, etc. Thus, the increase in ignition probability associated with the project has a significant negative impact on adjacent communities’ risk from fire and adjacent communities’ exposure to significant injury or death during an evacuation.

Summary and Concluding Remarks
This letter highlights several deficiencies in the environmental documentation for the planned Fanita Ranch development. I have also reviewed Neal Liddicoat’s July 22, 2022 report on the project, and I agree with his comments.

The Fire Protection Plan does not adequately address the increase in ignition probability caused by the project or the threat to surrounding communities caused by additional traffic during an evacuation. Indeed, the FPP reaches acknowledges on page 25:

Based on Fanita Ranch fire history data for the project vicinity, fire return intervals range between one and twenty-five years, indicating significant wildfire potential in the region and the potential for the Proposed Project site to be subject to occasional wildfire encroachment, most likely from the large expanses of open space to the north and east.

It is difficult to understand how this conclusion justifies construction of a major development. It is imperative that the County take these findings of critical fire risk impacts into account.

Sincerely,
Christopher W. Lautenberger, PhD, PE
Chris Lautenberger Reax Engineering, Inc. Page 1 of 10
Chris Lautenberger, PhD, PE
Reax Engineering, Inc.
1921 University Ave.

Berkeley, CA 94704
510-387-2155
[email protected]
Professional Profile
Chris Lautenberger is a co-founder of Reax Engineering, a fire protection engineering and fire science firm with offices in Berkeley and Auburn, CA. He is a licensed Fire Protection Engineer with expertise in fire science, fire dynamics, fire modelling, and forensic fire reconstruction. Lautenberger’s professional activities involve applying fire dynamics and combustion principles to analyze various aspects of fire and combustion processes, ranging from smallscale smoldering combustion to large-scale wildland fire dynamics. He has published on several aspects of combustion and fire, including flammability, pyrolysis, ignition, fire spread, and fire modeling. Lautenberger has over 20 years of experience applying fire dynamics calculations and fire models in support of scientific research, fire protection engineering design, and forensic fire reconstruction. Chris has developed computer models to analyze trajectories and ignition potential of metallic and woody particles generated by conductor clashing and interactions between vegetation and overhead electrical utilities, wildland fire propagation, and wildland fire risk. Lautenberger has provided expert testimony at deposition and trial on more than 25 occasions on litigation matters related to both wildland and structure fires, including several fires with losses in excess of $100M. Dr. Lautenberger has co-taught Masters-level courses in Fire Dynamics and Fire Modeling in the Department of Fire Protection Engineering at California Polytechnic State University, San Luis Obispo.

Professional Licensure
Licensed Professional Engineer, State of California, # FP1676 (Fire Protection Engineering) Education
PhD – Mechanical Engineering, University of California at Berkeley, January 2003 - December 2007  Dissertation title: “A Generalized Pyrolysis Model for Combustible Solids”  Major field: Combustion
 Minor fields: Wildland Fire Science and Fluid Dynamics MS – Fire Protection Engineering, Worcester Polytechnic Institute, January 2000 - December 2001  Thesis title: “CFD Simulation of Soot Formation and Flame Radiation” BS – Mechanical Engineering, Worcester Polytechnic Institute, August 1995 - December 1999 Professional Experience
8/08 – present Reax Engineering Inc. Berkeley, CA and Auburn, CA Founding Partner and Principal Engineer Representative projects:
 California Public Utilities Commission (CPUC) High Fire Threat District Mapping: Co-led (along with Pacific Gas & Electric and San Diego Gas & Electric) the Peer Development Panel tasked by the CPUC with developing high fire threat districts that identify areas where overhead electrical utilities present elevated or extreme risks of igniting damaging wildland or wildland urban interface fires. This map was adopted by the CPUC for regulatory purposes in 2018 and is currently used to promulgate regulations related to electrical utility fire safety in California.  Next Generation Open Source Wildfire Models for Grid Resiliency: Currently leading the realtime wildfire spread and risk forecasting component of this $5M project recently funded by the California Energy Commission. This project provides utilities and other stakeholders with realtime forecasts of active wildland fires as well as landscape-scale burn probabilities up to one week in the future. It also models ignition probability, fire size, and impacts from utility-caused Chris Lautenberger Reax Engineering, Inc. Page 2 of 10
fires under forecasted wind and weather conditions to inform proactive de-energization decisions.
 Utility-associated fire risk mapping: Reax has mapped utility-associated fire risk over more than 500,000 square miles of service territory in the US and Canada on behalf of eight utilities.

These techniques leverage numerical weather prediction, fire spread modeling, and high performance computing to generate high resolution maps of powerline fire risk that are then used internally for system hardening and proactive de-energization decisions.  Moonlight Fire (United States v. Sierra Pacific Industries et al.): Conducted NFPA 921 origin and cause hypothesis testing using fire science and fire modelling in the $1B litigation surrounding the 2007 Moonlight Fire. Modeled initial fire spread and plume dynamics. Exposed a critical error in opposing expert’s fire model that invalidated his opinions.  San Mateo Bridge Limousine Fire: Analyzed ignition and spread of a limousine fire that killed five women as they traveled across the San Mateo Bridge. Modeled initial fire spread using Computational Fluid Dynamics (CFD) and small-scale materials flammability data to quantify available safe egress time and time to incapacitation.
 Roseville Galleria Fire: Analyzed ignition, initial spread, and effect of automatic sprinkler system failure on the outcome of the 2010 Roseville Galleria Fire that destroyed several stores, led to partial collapse of the roof and caused over $50M in damage to a shopping mall in Northern California.
 Modelling manufacturing of Ceramic Matrix Composites (CMCs). Working in conjunction with United Technologies and Pratt & Whitney in a project funded by the Air Force Research Laboratory, adapted Gpyro (a generalized pyrolysis for combustible solids) to model pyrolysis of ceramic matrix composites used in aircraft engines during manufacturing.

Selected wildland fire hazard analysis and modeling project work:
 Determined maximum reasonably foreseeable Santa Ana wind speed in Malibu Canyon using wind modeling and pole-mounted anemometers installed specifically for this project  High resolution smoke plume modeling to assess potential for Libby Amphibole Asbestos (LAA) to be transported by large-scale wildland fires
 Developed de-energization criteria and associated weather monitoring analytics for utilities in California and Nevada
 Analyzed fire hazard/risk associated with major housing developments in San Diego County including Otay Ranch and Newland Sierra
 Developed ELMFIRE (Eulerian Level Set Model of Fire Spread), a parallelized model for simulating wildland fire spread and quantifying wildland fire risk via Monte Carlo simulation  Conducted high resolution wind/weather modeling to analyze historical fire weather in Southern California
 Assisted utility clients with data requests and analytics associated with preparation of Senate Bill 209 Wildfire Mitigation Plans
Selected wildland fire forensic reconstructions and analyses:
 Reconstruction of initial spread of the 2011 Bastrop Complex Fire (Bastrop, TX)  Analyzed ignition dynamics associated with the 2012 Sheep Fire near Lucille, ID  Analysis of ignition, initial spread, and smoke transport from the 2009 Murrindindi Bushfire (Victoria, Australia)
 Simulation of smoke transport from the 2010 Crown Fire near Palmdale, CA  Reconstruction of the spread of the 2008 Iron Complex Fire in Northern California and assessment of the impact of firing activities on timber loss in private inholdings  Calculation of trajectory and temperature histories of metallic particles allegedly generated by clashing between aluminum and copper electrical conductors and analysis of grass-fire ignition potential, initial spread rate, and plume dynamics (Victoria, Australia)  Analysis of wildland fires ignited by exhaust particles from a locomotive including analysis of particle trajectories and fuel ignitability (Victoria, Australia) Chris Lautenberger Reax Engineering, Inc. Page 3 of 10
Selected structure and vehicle fire forensic reconstructions and analyses:
 Analysis of a methane generation, transport, and ignition from decomposing manure in a fatal pig barn fire
 Analysis of diesel fuel ignitability by hot surfaces in a fracking rig fire  Reconstruction of fatal apartment fire where smoke alarms failed to activate (Long Beach, CA)  Reconstruction of fatal fire in manufactured home including time to smoke alarm activation and analysis of available safe egress time (Castleberry, AL)  Analysis of crude oil ignitability and time to incapacitation in a fatal fire where the cab of a truck was engulfed in flames from burning crude oil released during an accident.  Analysis of ignitability of water/antifreeze mixture discharged from residential sprinkler system, analysis of initial fire spread, and assessment of burn injuries (Herriman, UT)  Origin hypothesis testing for fatal alleged arson fire (Calcasieu Parish, Louisiana)  Fire cause hypothesis testing and analysis of residential LPG explosion for alleged arson fire (Round Mountain, CA)
 Analysis of role of inoperable fire hydrant on manual fire suppression efforts and associated property damage during total loss fire in residential apartment building (Atlanta, GA)  Reconstruction of fatal apartment fire: inter-apartment fire spread, time to smoke alarm activation, identification of contributory building code issues (Carrboro, NC) Selected Fire Protection Engineering project work:
 Calculation of Light Rail Vehicle heat release rates in the San Francisco Central Subway using fire growth modeling and fire testing (San Francisco, CA)  Analysis of rail vehicle design fires, testing, and modeling for Los Angeles County Metropolitan Transit Authority (Los Angeles, CA)
 Material property estimation for fire development modeling in new rail vehicle  Development of automatic sprinkler protection criteria and analysis of flammable liquids processes at semiconductor plant (Santa Rosa, CA)
 Application of computer fire modeling and egress modeling to determine appropriate smoke exhaust rate for atrium at Marist College (Poughkeepsie, NY)  Analysis of wildland urban interface fire and life safety concerns at proposed subdivisions in Oakland, CA, St. Helena, CA, and Encinitas, CA
 Sizing of atrium smoke exhaust rate in the new Student Union Building at San Jose State University (San Jose, CA)
 Development of a model for ignition of HEPA filters by embers at the Hanford nuclear waste treatment plant (Richland, WA)
 Modeling smoke and heat detector activation to develop a request for alternate means of protection at a large theater (Cincinnati, OH)
 Analysis of atrium smoke control system in residential highrise (Dallas, TX) Selected thermal sciences & general project work:
 Heat transfer analysis and pyrolysis modeling for municipal solid waste to energy incineration technology
 Thermo-chemical analysis and heat transfer modeling of biomass torrefaction (low temperature pyrolysis) reactor
 Detailed Computational Fluid Dynamics (CFD) modeling of fluid flow and heat transfer in a rotary kiln biochar reactor
 CFD-based furnace modeling, heat transfer analysis, and pyrolysis modeling of proposed screw auger wood chip pyrolysis reactor
 Development of a comprehensive three-dimensional computational model for predicting heat release and emissions from charcoal combustion
 Flammability and thermal property assessment of new wall board product  CFD modeling of blast wave from a bird bomb
 Thermodynamic analysis of non-traditional methods for carbon capture and sequestration  Calculation of overhead electrical utility catenary curves and excursions in high winds  Atmospheric dispersion modeling of pollutant transport using EPA’s AERMOD software Chris Lautenberger Reax Engineering, Inc. Page 4 of 10
12/10 – 2021 California Polytechnic State University, San Luis Obispo Instructor  Fire Protection Engineering Instructor in Cal Poly’s Masters degree program  Teaching responsibilities include FPE 502 Fire Dynamics and FPE 504 Fire Modeling 12/07 – 2/11 University of California at Berkeley Post Doctoral Researcher  Conducted research on NSF Grant 0730556, “Tackling CFD Modeling of Flame Spread on Practical Solid Combustibles”
 Assessed predictive capabilities of Fire Dynamics Simulator (FDS) for simulating flame spread and fire growth
 Modified subroutines to improve predictive capabilities of FDS for flame spread modeling  Developed pyrolysis model and material property estimation techniques needed to simulate the pyrolysis of real-world solid fuels
 Developed computer model for ignition of fuel beds by hot particles and fire brands to predict ignition of fuel beds and initiation of spot fires
1/02 – 6/08 Arup Fire San Francisco, CA Fire Protection Engineer  Assisted clients with fire safety design and achieving code compliance or performance-based solutions for hospitals, casinos, malls, libraries, schools, museums, airports, and offices  Assessed fire performance of buildings using fire modeling and egress analyses in support of alternate methods of design
 Developed and programmed a CFAST-based Monte-Carlo fire simulator  Simulated fire development in a rail vehicle and calibrated the model with large-scale experimental fire test data
 Representative projects include Wynn Las Vegas, Hard Rock Hotel and Casino Las Vegas, Kaiser Permanente templates, New Los Angeles Federal Courthouse, San Mateo Public Library, California Academy of Sciences, Bay Area Rapid Transit (BART) Montgomery Street Station, and Seattle Public Library
10/00 – 12/01 FM Global Research (formerly Factory Mutual Research Corporation) Norwood, MA  Examined existing soot formation and oxidation models in the literature and used this research to postulate a new engineering soot model that is compatible with FDS  Worked with FM Global and NIST scientists to add this new model for soot formation and oxidation to FDS, and performed simulations of laminar and turbulent diffusion flames 5/00 – 8/00 Code Consultants, Inc. Saint Louis, MO
 Responsible for examining proposed building designs for compliance with relevant codes  Performed engineering analyses to support equivalencies Dissertation and Thesis
1/03 – 12/07 PhD Dissertation University of California, Berkeley  Developed a generalized pyrolysis/material decomposition model (Gpyro) to simulate the gasification, pyrolysis, and combustion of condensed-phase fuels  Developed an optimization technique that uses a genetic algorithm to extract material pyrolysis properties needed for simulation of solid-phase pyrolysis from bench-scale fire tests  Performed FDS-based simulations of ignition, flame spread, and fire growth in normal and reduced gravity environments as part of a NASA-sponsored project 9/00 – 12/01 MS Thesis Worcester Polytechnic Institute
 Developed a model for soot formation/oxidation in non-premixed flames  Implemented model in FDS to calculate soot formation and flame radiation 8/98 – 5/99 Major Qualifying Project (MQP) Worcester Polytechnic Institute  Developed an experimental program and ran several real-scale room/corner fire tests in WPI’s room calorimeter to evaluate the flame spread characteristics of composite wall linings Chris Lautenberger Reax Engineering, Inc. Page 5 of 10
Peer Reviewed Publications

1. Lautenberger, C., de Ris, J., Dembsey, N.A., Barnett, J.R. & Baum, H.R., “A Simplified Model for Soot Formation and Oxidation in CFD Simulation of Non-premixed Hydrocarbon Flames,” Fire Safety Journal 40:
141-176 (2005).

2. Lautenberger, C., Zhou, Y.Y. & Fernandez-Pello, A.C., “Numerical Modeling of Convective Effects on Piloted Ignition of Composite Materials,” Combustion Science and Technology 177: 1231-1252 (2005).

3. Lautenberger, C. & Fernandez-Pello, A.C., “Approximate Analytical Solutions for the Transient Mass Loss Rate and Piloted Ignition Time of a Radiatively Heated Solid in the High Heat Flux Limit,” Fire Safety Science 8: 445- 456 (2005).

4. Lautenberger, C., Rein, G. & Fernandez-Pello, A.C., “Application of a Genetic Algorithm to Estimate Material Properties for Fire Modeling from Bench-Scale Fire Test Data,” Fire Safety Journal 41: 204-214 (2006).

5. Rein, G., Lautenberger, C., Fernandez-Pello, A.C., Torero, J.L. & Urban, D.L., “Application of Genetic Algorithms and Thermogravimetry to Determine the Kinetics of Polyurethane Foam in Smoldering Combustion,” Combustion and Flame 146: 95-108 (2006).

6. Rich, D., Lautenberger, C., Torero, J.L., Quintiere, J.G. & Fernandez-Pello, C., “Mass Flux of Combustible Solids at Piloted Ignition,” Proceedings of the Combustion Institute 31: 2653-2660 (2007).

7. Kwon, J.-W., Dembsey, N.A., & Lautenberger, C.W., “Evaluation of FDS v4: Upward Flame Spread,” Fire Technology 43: 255-284 (2007).

8. Avila, M.B., Dembsey, N.A., Kim, M.E., Lautenberger, C., & Dore, C., “Fire Characteristics of Polyester FRP composites with Different Glass Contents,” Composites Research Journal 2: 1-14 (2008).

9. Lautenberger, C., Kim, E., Dembsey, N. & Fernandez-Pello, C., “The Role of Decomposition Kinetics in Pyrolysis Modeling – Application to a Fire Retardant Polyester Composite,” Fire Safety Science 9: 1201-1212 (2008).

10. Dodd, A.B., Lautenberger, C. & Fernandez-Pello, A.C., “Numerical Examination of Two-Dimensional Smolder Structure in Polyurethane Foam,” Proceedings of the Combustion Institute 32: 2497-2504 (2009).

11. Lautenberger, C. & Fernandez-Pello, A.C., “Generalized Pyrolysis Model for Combustible Solids,” Fire Safety Journal 44: 819-839 (2009).

12. Lautenberger, C. & Fernandez-Pello, A.C., “A Model for the Oxidative Pyrolysis of Wood,” Combustion and Flame 156: 1503-1513 (2009).

13. Hadden, R., Scott, S., Lautenberger, C., & Fernandez-Pello, A.C., “Ignition of Combustible Fuel Beds by Hot Particles: an Experimental and Theoretical Study,” Fire Technology 47: 341-355 (2011).

14. Fereres, S., Lautenberger, C., Fernandez-Pello, C., Urban, D.L., & Ruff, G.A., “Mass Loss Rate at Ignition in Reduced Pressure Environments,” Combustion and Flame 158: 1301-1306 (2011).

15. Lautenberger, C. & Fernandez-Pello, C., “Optimization Algorithms for Material Pyrolysis Property Estimation,” Fire Safety Science 10: 751-764 (2011).

16. Dodd, A.B., Lautenberger, C., & Fernandez-Pello, A.C., “Computational Modeling of Smolder Combustion and Spontaneous Transition to Flaming,” Combustion and Flame 159: 448–461 (2012).

17. Matala, A., Lautenberger, C., & Hostikka, S., “Generalized direct method for pyrolysis kinetics parameter estimation and comparison to existing methods,” Journal of Fire Sciences 30: 339-356 (2012).

18. Fereres, S., Lautenberger, C., Fernandez-Pello, A.C., Urban, D.L., and Ruff, G.A., “Understanding ambient pressure effects on piloted ignition through numerical modeling,” Combustion and Flame 159: 3544–3553 (2012).

19. Wong, W., Alston, J., Lautenberger, C., and Dembsey, N., “CFD Flame Spread Model Validation: Multicomponent Data Set Framework,” Journal of Fire Protection Engineering 23: 85-134 (2013).

20. Lautenberger, C., “Wildland Fire Modeling with an Eulerian Level Set Method and Automated Calibration,” Fire Safety Journal 62: 289-298 (2013).

21. Lautenberger, C., “Gpyro3D: A Three Dimensional Generalized Pyrolysis Model,” Fire Safety Science 11: 193- 207 (2014).

22. Fernandez-Pello, A.C., Lautenberger, C., Rich, D., Zak, C., Urban, J., Hadden, R., Scott, S., and Fereres, S., “Spot fire ignition of natural fuel beds by hot metal particles, embers, and sparks,” Combustion Science and Technology 187: 269-295 (2015).

23. Yashwanth, B.L., Shotorban, B., Mahalingam, S., Lautenberger, C.W., and Weise, D.R., “A numerical investigation of the influence of radiation and moisture content on pyrolysis and ignition of a leaf-like fuel element,” Combustion and Flame 163: 301–316 (2016).

24. Lautenberger, C., “Mapping Areas at Elevated Risk of Large-Scale Structure Loss Using Monte Carlo Simulation and Wildland Fire Modeling,” Fire Safety Journal 91: 768-775 (2017).

25. Fawaz, M., Lautenberger, C., and Bond, T., “Prediction of organic aerosol precursor emission from the pyrolysis of thermally thick wood,” Fuel 269: 117333 (2020).

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Book Chapters

1. Lautenberger, C., Torero, J.L. & Fernandez-Pello, A.C., “Understanding Materials Flammability,” in Flammability Testing of Materials Used in Construction, Transport and Mining, Edited by V. Apte, Woodhead Publishing, Cambridge, UK pp. 1-21, 2006.

2. Lautenberger, C. & Fernandez-Pello, A.C., “Pyrolysis Modeling, Thermal Decomposition, and Transport Processes in Combustible Solids,” in Transport Phenomena in Fires, Edited by M. Faghri and B. Sunden, WIT Press, Billerica, MA pp. 209-248, 2008.

3. Lautenberger, C. & Fernandez-Pello, A.C., “Spotting Ignition of fuel beds by firebrands,” in Computational Methods and Experimental Measurements XIV, Edited by C.A. Brebbia and G.M. Carlomango, WIT Press, Billerica, MA pp. 603-612, 2009.

4. Lautenberger, C. & Hostikka, S., “Large Scale Fire Modeling,” in Flame Retardancy of Polymeric Materials, Second Edition, Edited by C.A. Wilkie and A.B. Morgan, Marcel Dekker pp. 551 – 585, 2010.

5. Lautenberger, C., Tien, C.L., Lee, K.Y., and Stretton, A.J., “Radiation Heat Transfer,” in SFPE Handbook of Fire Protection Engineering, 5th Edition, Springer, pp. 102-137 (2016).

6. Lautenberger, C., “Pyrolysis,” in Encyclopedia of Wildfires and Wildland-Urban Interface (WUI) Fires, Ed.

Manzello, S.L., Springer (2018).

Selected Conference Publications and Technical Reports

1. Beyler, C., Hunt, S., Lattimer, B., Iqbal, N., Lautenberger, C., Dembsey, N., Barnett, J., Janssens, M., & Dillon, S. “Prediction of ISO 9705 Room/Corner Test Results”. United States Department of Transportation. United States Coast Guard Research and Development Center. Washington, DC. 1999.

2. Lautenberger, C., Stevanovic, A., Rich, D., & Torero, J., “Effect of Material Composition on Ignition Delay of Composites,” Composites 2003, Anaheim CA, October 2003.

3. Lautenberger, C., Stevanovic, A., Rich, D., Torero, J. & Fernandez-Pello, A.C., “An Experimental and Theoretical Study on the Ignition Delay Time of Composite Materials,” Western States Section/The Combustion Institute, Los Angeles CA, October 2003.

4. Rein, G., Lautenberger, C., Fernandez-Pello, A.C., Torero, J.L. & Urban, D.L., “Derivation of the Kinetics Parameters of Polyurethane Foam Using Genetic Algorithms,” Fourth Joint Meeting of the US Sections of the Combustion Institute, Philadelphia PA, March 2005.

5. Rein, G., Lautenberger, C. & Fernandez-Pello, A.C., “On the Derivation of Polyurethane Kinetics Parameters Using Genetic Algorithms and its Application to Smoldering Combustion,” Fourth International Conference on Computational Heat and Mass Transfer, Paris France, Vol. 1 pp. 578-584, May 2005.

6. Rein, G., Lautenberger, C. & Fernandez-Pello, A.C., “Using Genetic Algorithms to Derive the Parameters of Solid-Phase Combustion from Experiments,” 20th International Colloquium on the Dynamics of Explosions and Reactive Systems, Montreal, Canada, August 2005.

7. Rich, D., Lautenberger, C., McAllister, S. & Fernandez-Pello, A.C., “Microgravity Flame Spread Rates Over Samples of Polymer and Polymer/Glass Composites,” Western States Section/The Combustion Institute, Boise ID, March 2006.

8. Coles, A., Wolski, A., Lautenberger, C.W., & Dembsey, N.A., “Building Code Requirements for Performance Based Designs and Fire Modeling”, Composites 2006, St. Louis, MO, October 2006.

9. Lautenberger, C., McAllister, S., Rich, D., & Fernandez-Pello, C., “Modeling the Effect of Environmental Variables on Opposed-Flow Flame Spread Rates with FDS,” International Congress on Fire Safety in Tall Buildings, Santander, Spain, October 2006.

10. McAllister, S., Rich, D., Lautenberger, C., & Fernandez-Pello, C., “Modeling Microgravity and Normal Gravity Opposed Flame Spread over Polymer/Glass Composites,” 45th AIAA Aerospace Sciences Meeting and Exhibit, Reno, NV, January 2007, AIAA Paper 2007-740.

11. Lautenberger, C., McAllister, S., Rich, D., & Fernandez-Pello, C., “Effect of Environmental Variables on Flame Spread Rates in Microgravity,” 45th AIAA Aerospace Sciences Meeting and Exhibit, Reno, NV, January 2007, AIAA Paper 2007-383.

12. Chatterjee, P., de Ris, J.L., & Lautenberger, C.W., “A General Combustion Model for Radiation Dominated Nonpremixed Flames,” Fifth International Seminar on Fire and Explosion Hazards, Edinburgh, UK, 2007.

13. McAllister, S., Rich, D., Lautenberger, C., Fernandez-Pello, C. & Yuan, Z.G., “Modeling Microgravity and Normal Gravity Flame Spread Rates over Samples of Polymer and Polymer/Glass Composites,” Fifth International Seminar on Fire and Explosion Hazards, Edinburgh, UK, April 2007.

14. Lautenberger, C. & Fernandez-Pello, C., “A Generalized Pyrolysis Model for Combustible Solids,” Fifth International Seminar on Fire and Explosion Hazards, Edinburgh, UK, April 2007.

Chris Lautenberger Reax Engineering, Inc. Page 7 of 10

15. Coles, A., Wolski, A., & Lautenberger, C., “Using Fire Dynamics Simulator for Fire Growth Modeling,” Interflam 2007, London, UK, September 2007.

16. Dembsey, N., Avila, M., Kim, E., Lautenberger, C., & Dore, C., “Fire Characteristics of Polyester FRP Composites with Different Glass Contents,” Composites & Polycon 2007 Tampa, FL, October 2007.

17. Lautenberger, C. & Fernandez-Pello, A.C., “Modeling Ignition of Combustible Fuel Beds by Embers and Heated Particles,” Forest Fires 2008, 2008.

18. Coles, A., Lautenberger, C., Wolski, A., Smits, B., & Wong, K., “Using Computer Fire Modeling to Reproduce and Predict FRP Composite Fire Performance,” Composites & Polycon 2009, 2009.

19. Kim, E., Dembsey, N., & Lautenberger, C., “Parameter Estimation for Pyrolysis Modeling Applied to Polyester FRP Composites with Different Glass Contents,” Fire and Materials 2009, 2009.

20. Lautenberger, C., Wong, W., Dembsey, N., Coles, A., & Fernandez-Pello, C., “Large-Scale Turbulent Flame Spread Modeling with FDS5 on Charring and Noncharring Materials,” Fire and Materials 2009, 2009.

21. Coles, A., Wolski, A., & Lautenberger, C., “Predicting Design Fires in Rail Vehicles,” 13th International Symposium on Aerodynamics and Ventilation of Vehicle Tunnels (ISAVVT 13), 2009.

22. Dodd, A.B., Lautenberger, C., & Fernandez-Pello, A.C. “Numerical Modeling of Smoldering Combustion and Transition to Flaming,” Sixth US National Combustion Meeting, University of Michigan, Ann Arbor, MI, 2009.

23. Scott, S, Hadden, R., Fereres, S., Lautenberger, C., & Fernandez-Pello, A.C., “Ignition of Combustible Fuel Beds by Embers and Heated Particles,” Western States Section/The Combustion Institute, Irvine, CA, October 2009.

24. Fereres, S., Lautenberger, C., Fernandez-Pello, C., Urban, D., & Ruff, G., “Effect of Ambient Pressure on Mass Loss Rate at Piloted Ignition,” Western States Section/The Combustion Institute, Boulder, CO, March 2010.

25. Lautenberger, C., Rich, D., Kramer, M., Fernandez-Pello, C., and Stephens, S., “Communication Infrastructure Provider Assets in the Wildland Setting: CIP Fire Threat Map,” June 9, 2010.

26. Lautenberger, C., Wong, W.C., Coles, A., Dembsey, N., & Fernandez-Pello, C., “Comprehensive Data Set for Validation of Fire Growth Models: Experiments and Modeling,” Interflam 2010, Nottingham, UK, July 2010.

27. Thiry, A., Suzanne, M., Bellivier, A., Bazin, H., Coppalle, A., & Lautenberger, C., “Different Approaches for Fire Source Modeling – Application to Arcueil Experiments,” Interflam 2010, Nottingham, UK, July 2010.

28. Dodd, A., Lautenberger, C., Fernandez-Pello, C., & Putzeys, O., “Examination of the Spontaneous Transition from Smoldering to Flaming: Comparison of Simulations and Experiments,” Interflam 2010, Nottingham, UK, July 2010.

29. Fereres, S., Lautenberger, C., Fernandez-Pello, C., Ruff, G., & Urban, D., “Modeling the effect of ambient variables on piloted ignition of solid combustible materials,” Seventh US National Combustion Meeting, March 2011.

30. Matala, A., Lautenberger, C., & Hostikka, S., “Direct method for estimation of pyrolysis kinetics and comparison to existing methods,” Seventh US National Combustion Meeting, March 2011.

31. Lautenberger, C., “Modeling Wildland Fire Spread Using an Eulerian Level Set Method and High Resolution Numerical Weather Prediction,” International Congress on Fire Computer Modeling, October 2012, Santander, Spain.

32. Lautenberger, C., Sexton, S., & Rich, D., “Understanding Long Term Low Temperature Ignition of Wood,” International Symposium on Fire Investigation Science and Technology, College Park, MD, September 22-24, 2014, p. 361.

33. Zicherman, J., Lautenberger, C., & Wolski, A., “Challenges in Establishing Design Fires for Passenger Rail Vehicles,” Proceedings of Fire and Materials 2015, Interscience Communications, February 2-4 2015, San Francisco, CA, pp. 749 – 764.

Short Courses

1. Lawrence Livermore National Laboratories Fire Modeling Short Course – A Short Course Presented to Fire Protection Engineers. Co-taught, with Professor James Milke (University of Maryland) and Professor Frederick Mowrer (California Polytechnic State University), a 3-day short course on fire dynamics and fire modeling for Lawrence Livermore and Lawrence Berkeley National Laboratories employees (March 20 – 22, 2012).

2. First Asia-Pacific Combustion Institute Summer School – Fundamental Combustion Problems in Fire. Co-taught sessions related to fire science and pyrolysis modelling in Valparaiso, Chile (November 11 – 15, 2019).

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Selected Presentations and Invited Lectures

1. “A Practical CFD Model for Soot Formation and Flame Radiation,” International Conference on Engineered Fire Protection Design, San Francisco, CA, June 13, 2001.

2. “Effect of Material Composition on Ignition Delay of Composites,” Composites 2003 Convention and Trade Show, Anaheim, CA, October 2, 2003.

3. “Experimental and Theoretical Study on Ignition Delay of Composites,” Western States Section of the Combustion Institute Fall 2003 Meeting, Los Angeles, CA, October 20, 2003.

4. “Approximate Analytical Solutions for the Transient Mass Loss Rate and Piloted Ignition Time of a Radiatively Heated Solid in the High Heat Flux Limit,” The Eighth International Symposium on Fire Safety Science, Beijing, China, September 20, 2005.

5. “Effect of Environmental Variables on Flame Spread Rates in Microgravity,” 45th AIAA Aerospace Sciences Meeting and Exhibit, Reno, NV, January 8, 2007.

6. “Generalized Pyrolysis Model for Combustible Solids,” 2007 Annual Fire Conference, National Institute of Standards and Technology, Gaithersburg, MD, April 4, 2007.

7. “Generalized Pyrolysis Model for Combustible Solids,” 5th International Seminar on Fire and Explosions Hazards, Edinburgh, UK, April 24, 2007.

8. “Generalized Pyrolysis Model for Combustible Solids,” FM Global Research, Norwood, MA, June 19, 2007 (invited seminar).

9. “Pyrolysis Modeling – What Level of Accuracy is Needed to Match Current Gas-Phase Accuracy?,” The Ninth International Symposium on Fire Safety Science, Fire Spread Modeling Workshop, Karlsruhe, Germany, September 21, 2008 (invited presentation).

10. “Estimating Material Properties for Numerical Pyrolysis Modeling from Laboratory Experiments,” The Ninth International Symposium on Fire Safety Science, Karlsruhe, Germany, September 21, 2008 (invited presentation).

11. “The Role of Decomposition Kinetics in Pyrolysis Modeling – Application to a Fire Retardant Polyester Composite,” The Ninth International Symposium on Fire Safety Science, Karlsruhe, Germany, September 26, 2008.

12. “Fire Growth Modeling in Buildings – Where We Are and Where We Need to Be,” IIE Seminar, University of Edinburgh, Edinburgh, UK, October 30, 2008 (invited seminar).

13. “Some Unsolved Problems in Fire Dynamics: The Needed Physics and Mathematics,” Mathematical Problems in Fire Safety Engineering Joint Workshop, Edinburgh, UK, October 31, 2008 (invited seminar).

14. “Large-Scale Turbulent Flame Spread Modeling with FDS5 on Charring and Noncharring Materials,” Fire and Materials 2009, San Francisco, CA, January 26, 2009.

15. “Fire Growth Modeling: Small-Scale Flammability Tests to Large Scale Fire Behavior,” ASTM E5 Research Review, Vancouver, BC, June 15, 2009 (invited presentation).

16. “Optimization Algorithms for Material Pyrolysis Property Estimation,” The Tenth International Symposium on Fire Safety Science, College Park, MD, June 21, 2011.

17. “The Role of Fire Science, Fire Dynamics, and Fire Modeling in Testing Forensic Fire Investigation Hypotheses,” IIE Seminar, University of Edinburgh, Edinburgh, UK, August 20, 2012 (invited seminar).

18. “Modeling Wildland Fire Spread Using an Eulerian Level Set Method and High Resolution Numerical Weather Prediction,” International Congress on Fire Computer Modeling, October 19, 2012, Santander, Spain.

19. “Gpyro3D: A Three Dimensional Generalized Pyrolysis Model,” The Eleventh International Symposium on Fire Safety Science, Christchurch, New Zealand, February 10, 2014.

20. “Understanding Long Term Low Temperature Ignition of Wood,” International Symposium on Fire Investigation Science and Technology, College Park, MD, September 22, 2014.

21. “Current Status of Applied Fire Dynamics Simulations,” 2015 Northern California/Nevada SFPE Fire Protection Engineering Seminar, San Ramon, CA, April 8, 2015 (invited seminar).

22. “Identifying Areas with Elevated Risk of Large-Scale Structure Loss from Wildland Fires,” The 12th International Symposium on Fire Safety Science, Lund, Sweden, June 14, 2017.

23. “Wildfire Modeling and Risk of Potential Structure Loss,” 2018 Annual Society of Fire Protection Engineers Greater Atlanta Chapter Fire Safety Conference, Duluth, GA, March 14, 2018.

24. “Wildfire Modeling and Risk of Potential Structure Loss,” 2018 Northern California / Nevada Society of Fire Protection Engineers Seminar, San Ramon, CA, March 28, 2018.

25. “Smoke Alarm Failures: Owner/Landlord Responsibility,” 2018 Inner Circle of Investigators Seminar, Newport Beach, CA, October 4, 2018.

26. “California’s 2017 Wildfires: What Happened? And Can we Map Areas Where it Could Happen Again?,” 2018 Society of Fire Protection Engineers Annual Conference & Expo, Nashville, TN, October 29, 2018.

Chris Lautenberger Reax Engineering, Inc. Page 9 of 10

27. “Applications and Limitations of Current-generation 2D Wildfire Models,” National Institute of Standards and Technology (NIST) Large Outdoor Fire Modelling Workshop, Gaithersburg, MD, March 18, 2019.

28. “Automated Real-time Ensemble Fire Forecasting in California,” 6th International Wildland Fire Behavior and Fuels Conference, Albuquerque, NM, May 1, 2019.

29. “California’s October 2017 Wildfires: What Happened, and Can We Map Areas Where It Could Happen Again?,” Society of Fire Protection Engineers Webinar Series, May 13, 2019.

30. Applications and Limitations of Current-generation 2D Wildfire Spread Models in the Utility Sector,” California Utility Forecasters Meeting, Irwindale, CA, June 25, 2019.

31. “Mapping Wildland Fire Risk in the Western US Using Fire Modeling and Monte Carlo Simulation,” FM Global Research Forum, Norwood, MA, June 28, 2019.

32. “Automated Real-time Ensemble Fire Forecasting in the Continental US,” National Academies Workshop:

Modeling and Simulation of Fires, Berkeley, CA, October 7, 2019.

33. “Automated Real-Time Fire Forecasting in California: A Mid-season Assessment,” 2019 Society of Fire Protection Engineers Annual Conference & Expo, Phoenix, AZ, October 15, 2019.

34. “Emerging Technologies for Detecting, Mapping, and Forecasting the Spread of Wildfires,” 2019 National Wildfire Litigation Conference, Bastrop, TX, October 20, 2019.

35. “Overview of Wildland Fire Science and Basic Methods for Modeling Spread,” Environmental Governance and Climate Resilience course, Stanford University, January 21, 2020.

36. “Automated Real-Time Fire Spread and Risk Forecasting,” Northwest Hydroelectric Association 2020 Annual Conference, Seattle, WA, February 19, 2020.

Publication and Presentation Awards
 Best Paper Overall at Composites & Polycon 2007, Tampa, FL, October 2007 for Dembsey, N. et al., “Fire Characteristics of Polyester FRP Composites with Different Glass Contents,” presented by N. Dembsey.  Best paper (second prize) at the Fifth International Seminar on Fire and Explosion Hazards, Edinburgh, UK, April 2007 for Lautenberger, C. & Fernandez-Pello, C., “Generalized Pyrolysis Model for Simulating Charring, Intumescent, Smoldering, and Noncharring Gasification,” presented by C. Lautenberger.  2011 International Association for Fire Safety Science Best Thesis Award (Americas Region) for 2007 PhD Dissertation entitled “Generalized Pyrolysis Model for Combustible Solids”. This IAFSS award recognizes the best research dissertation at the PhD and Masters levels in the field of fire safety science and engineering that was completed between 2007 and 2010.
 International Association for Fire Safety Science Best Paper Award (honorable mention) for 2008 paper entitled “The Role of Decomposition Kinetics in Pyrolysis Modeling – Application to a Fire Retardant Polyester Composite,” by Lautenberger, C., Kim, E., Dembsey, N. & Fernandez-Pello, C. [Fire Safety Science 9: 1201-1212 (2008)].
 2014 Society of Fire Protection Engineer’s Jack Bono Award for the paper from Volume 23 of the Journal of Fire Protection Engineering that has most contributed to the advancement and application of professional Fire Protection Engineering for the paper entitled “CFD Flame Spread Model Validation: Multi-component Data Set Framework,” by Wong, W., Alston, J., Lautenberger, C., and Dembsey, N., [Journal of Fire Protection Engineering 23: 85-134 (2013)].
 2017 Philip Thomas Medal of Excellence. This is awarded to the author(s) of the best paper presented at the previous International Association for Fire Safety Science (IAFSS) Symposium. It is based on five criteria that are used to identify the best paper: pertinence, utility, significance, rationality, and eloquence.

Conference/Journal Advisory Boards/Technical Committees  Associate Editor of Fire Technology, 2014 - present
 Member of Scientific Advisory Board for International Congress on Combustion and Fire Dynamics, Santander, Spain, October 2010
 Member of Technical Program Committee (Compartment Fires) for the Tenth International Symposium on Fire Safety Science (IAFSS Symposium), College Park, MD, June 2011  Member of Scientific Advisory Board for International Congress on Fire Computer Modeling, Santander, Spain, October 2012
Chris Lautenberger Reax Engineering, Inc. Page 10 of 10 Journal Referee / Peer Review
 Advances in Engineering Software
 Advances in Materials Science and Engineering
 Applied Thermal Engineering
 Artificial Intelligence Review
 Asia-Oceania Symposium on Fire Science and Technology  Brazilian Journal of Chemical Engineering
 Chemical Engineering Science
 Combustion and Flame
 Combustion Science and Technology
 Construction and Building Materials
 Earth and Space Science
 Ecological Modeling
 Energy & Fuels
 Engineering Science and Technology
 Experimental Thermal and Fluid Science
 Express Polymer Letters
 Fire and Materials
 Fire Safety Journal
 Fire Safety Science (IAFSS Symposia)
 Fire Technology
 Frontiers Mechanical Engineering
 Fuel Processing Technology
 Industrial & Engineering Chemistry Research
 International Colloquium on the Dynamics of Explosions and Reactive Systems  International Journal of Computational Fluid Dynamics  International Journal of Heat and Mass Transfer
 International Journal of Thermal Sciences
 International Journal of Wildland Fire
 Journal of Advances in Modeling Earth Systems
 Journal of Computational Science
 Journal of Fire Protection Engineering
 Journal of Fire Sciences
 Proceedings of the Combustion Institute
 Science of the Total Environment
 Thermochimica Acta

From: gary brooks
To: Dustin Trotter; John Minto; Ronn Hall; Laura Koval; Rob McNelis; Chris Jacobs Subject: Fanita Ranch
Date: Saturday, September 10, 2022 3:36:17 PM
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.

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
Gary N Brooks
Sent from my iPhone

From: heather murray
To: Dustin Trotter; John Minto; Ronn Hall; Laura Koval; Rob McNelis; Chris Jacobs Subject: Fanita Ranch
Date: Sunday, September 11, 2022 7:27:15 PM
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.

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
Sent from my iPhone
From: Janet Garvin
To: Chris Jacobs
Cc: John Minto; Ronn Hall; [email protected]; Laura Koval; Rob McNelis Subject: City Council 9/14/2022 FANITA RANCH Item 8- DISAPPROVE! Date: Sunday, September 11, 2022 3:40:01 PM
City Council 9/14/2022 FANITA RANCH Item 8- DISAPPROVE! Again for the administrative record:

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, un-democratic and un-American. I strongly urge you to vote against it.

Thank you,
Janet Garvin

From: Janice
To: Chris Jacobs
Subject: Fanita Ranch
Date: Monday, September 12, 2022 10:06:53 AM
I don't usually get involved in any kind of politics but the building of 3000 more homes just blows my mind. How can anyone believe this is good for Santee? Have you "tried" to drive down Mission Gorge & been stopped at every light? Have you "tried" to park at any of the stores in town & have to park a mile away? Have you "tried" to shop later in the day & not only can't find a place to park but the lines inside are very long? When were you able to water your lawn or wash your car? When were you able to keep your air conditioning at a temp where you are comfortable? I'm just one little person living in Santee that hates how it's grown & how you have to find alternate streets to Mission Gorge because it's always so full of traffic. I hate to sit at every red light & sometimes thru two cycles if the traffic is really bad. Where are you living that you haven't noticed just how bad it's gotten here? Have you seen 52 in the morning?
I worked in Santee in 1980 when there was very little here. I thought about buying here but there was nothing in town (places to shop) so I lived elsewhere. Forward to 2004 when I moved here. Now there are plenty of places to shop & freeways to get here & there. I had to buy a mobile home because now I'm retired & can't afford a home here. Had I known just how bad it was going to get, I would've looked at other places to buy. Now I can't afford to move & I'm not happy with the way things are. To even think about 3000+ more people & possibly 6000 more cars just makes me angry & sick. What are you doing to what was once a beautiful little city? Please reconsider & take care of those residents who are already here. We need more water & electricity & somebody to time the lights so we can actually drive across town easily. You are ruining Santee.
-"-
//^^\\
(/(_._)\)
_/"*"\_
(/_)^(_\)
Miss Hannah
RIP
A man may smile & bid you hail yet wish you to the devil; but when a good dog wags his tail, you know he's on the level. Anon From: CPB
To: Chris Jacobs
Subject: Fanita Ranch
Date: Friday, September 9, 2022 12:35:47 PM
Dear Mr Jacobs,
I object to the city council decision to proceed with 2949 to 3009 homes plus commercial use, parks and a farm . As a resident of Santee for 38 years I ask that the city use the general plan. I think the city council ignores the residence concerns regarding fires, water, and electric usage all of which we are being asked to conserve.

It’s amazing that our council ignores us and denies our request for us to vote on this issue . It’s a concern when Home Fed donates to this council election efforts for election. This council is still working on a theater after many years of waiting . This
Council only works for what serves there interest and not for its citizens! Janis Barnhart
Sent from my iPad
From: Jason Page
To: Dustin Trotter; John Minto; Ronn Hall; Laura Koval; Rob McNelis; Chris Jacobs Subject: Fanita Ranch
Date: Monday, September 12, 2022 7:33:28 PM
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.

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
Jason Page
Santee, CA 92071
Sent from my iPhone

From: [email protected] <[email protected]> Sent: Tuesday, September 13, 2022 7:18 PM
To: Rob McNelis <[email protected]>
Subject:

Message submitted from the <Santee, CA> website.

Site Visitor Name: Julie Leonard
Site Visitor Email:

NO ON FANITA RANCH! IT IS WRONG FOR SANTEE. THE VOTING PUBLIC DOESN'T WANT IT. GIVE US A CHANCE TO VOTE ON IT. WE WILL REMEMBER HOW YOU VOTE. DO THE RIGHT THING. NO ON FANITA RANCH!

From: Kelsey Tyler
To: Chris Jacobs
Subject: RE: Fanita Ranch Final EIR
Date: Monday, September 12, 2022 2:12:29 PM
Dear Mr. Jacobs,
I object to a city council 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. 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.

Please include my objection in the Administrative Record for the project, Thank you,
Kelsey Tyler
From: Kelsey Tyler
To: Dustin Trotter; John Minto; Ronn Hall; Laura Koval; Rob McNelis; Chris Jacobs Subject: Fanita Ranch
Date: Monday, September 12, 2022 2:15:03 PM
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, antidemocracy 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,
Kelsey Tyler
From: Kim Sullivan
To: Chris Jacobs; Ronn Hall; Laura Koval; Rob McNelis; John Minto; Dustin Trotter Subject: Fanita Ranch issue - Item 8
Date: Tuesday, September 13, 2022 9:58:02 AM
Dear Mr. Jacobs and City Council,
Please vote NO on item 8.

I am very disappointed to hear that the Fanita Ranch issue continues to plague the city of Santee. Even with the passage of Measure N, and the court's upholding Santee voters' majority opinion and ordering to stop the Fanita Ranch development, it seems that the city council is scheming to bring it back again.

I don't normally deal in local politics, but I am appalled by the city's behavior here. Please note that I am not opposed to all new development, and, in fact, live in the new Weston development.

However, it is highly irresponsible to build a 3000-unit project here based on some crackpot plan to "shelter in place" in the likely event of future wildfire. And we all know that it is not responsible at all to expect evacuation to be possible within our current infrastructure (including freeways and highways).

I agree with saner folks who state that the Fanita development application should be abandoned and the land permanently conserved through the Department of Defense military base buffer program (REPI).

Again, please vote no on Item 8, and know that even though you are actively attempting to exclude the public, we are watching... and voting in elections.

Thank you for reading this,
Kim Sullivan
Santee CA 92071
From:

Sent: Tuesday, September 13, 2022 6:28 PM
To: Ronn Hall <[email protected]>; John Minto <[email protected]>; Rob McNelis <[email protected]>; [email protected]; Laura Koval <[email protected]>; Chris Jacobs <[email protected]> Cc:

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-democratic, 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).

I am requesting return notice that this email has been received by you and The City of Santee.

Sincerely,
Laurey A. Lewis
From: Laurie Lucie
To: Chris Jacobs; Ronn Hall; Laura Koval; Rob McNelis; John Minto; Dustin Trotter Subject: Fanita Ranch, Item 8
Date: Saturday, September 10, 2022 5:28:25 PM
RE: 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.

The development application should be abandoned and the land permanently conserved through the Department of Defense military base buffer program (REPI).

Thank you,
Laurie Lucie
Santee, CA 92071
From: LEE SHANNON
To: Dustin Trotter; John Minto; Ronn Hall; Laura Koval; Rob McNelis; Chris Jacobs Subject: Fanita Ranch
Date: Saturday, September 10, 2022 4:47:20 PM
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.

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
Lee Shannon
Sent from my iPhone
From: Lennea Brown
Sent: Tuesday, September 13, 2022 9:00 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
Attachment: Fanita Ranch Letter from Santee Resident Brown Dear Mr. Jacobs and City Council,
My letter regarding Fanita Ranch, Item 8, on the September 14, 2022 agenda is attached.

I urge you to vote against approval.

Thank you,
Lennea Brown
Santee Resident

From: Lori Scribner
To: Chris Jacobs
Subject: September 14 City Council Meeting Agenda
Date: Tuesday, September 13, 2022 6:09:18 PM
Chris:

I OBJECT to item #8 on the agenda for September 14.

Sincerely,
Lori Scribner
From: Lory Garcia
To: Dustin Trotter; John Minto; Ronn Hall; Laura Koval; Rob McNelis; Chris Jacobs Subject: Fanita Ranch
Date: Sunday, September 11, 2022 10:43:57 AM
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.

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
Sent from my iPhone
From: Luce L
To: Chris Jacobs
Subject: Fanita Ranch OPPOSITION
Date: Saturday, September 10, 2022 11:41:05 PM
RE: Fanita Ranch Final EIR Dear Mr. Jacobs, I object to a city council 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? 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. Please include my objection in the Administrative Record for the project

From: Margaret Field
To: Chris Jacobs
Subject: Fanita Ranch- Disapprove!
Date: Saturday, September 10, 2022 5:45:50 PM
Dear Mr. Jacobs,
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.

The development application should be abandoned and the land permanently conserved through the Department of Defense military base buffer program (REPI).

Thank you,
--
Dr. Margaret Field
Professor, American Indian Studies
San Diego State University
From: Marie Weber
To: Chris Jacobs; Laura Koval
Subject: Fw: Fanita Ranch 9/14/22 Santee City Council Meeting Date: Monday, September 12, 2022 6:55:04 PM
Dr Mr Jacobs and Ms Koval,
I have questions and concerns regarding Fanita Ranch:
- Doesn't Council have to wait a year from Spring 2022 to reapprove the project? - When is the vote by Santee residents?
- How can Ordinance #592 possibly relate to Fanita Ranch? - Please explain the "current and immediate threat to the public health, safety or welfare" regarding housing.
- How is "the preservation of public peace" related to housing in Santee? - What other cities in San Diego County have enacted a similar ordinance? Santee needs 1,219 units of housing per SANDAG. In the proposed Fanita Ranch development, -How many units will be extremely low income? (203 needed) -How many units will be very low income? (203 needed)
-How many units will be low income? (200 needed)
-How many will be moderate income? (188 needed)
Finally, California wants cities to build housing near public transportation hubs. -What public transportation will Fanita Ranch offer?
The approval of Fanita Ranch at this time appears illegal and highly unethical.

Please include my objection in the record for the Fanita Ranch project.

Sincerely, Marie Weber (Santee resident, district 3)
From: MARSHA MACDONALD
To: Chris Jacobs; Ronn Hall; Laura Koval; John Minto; Dustin Trotter Subject: Please stop Fanita Ranch Project
Date: Saturday, September 10, 2022 5:56:02 PM
Importance: High
Dear Mr. Jacobs and City Council,
It is my understanding that the people of Santee passed Measure N and qualified a referendum to assure that Santee residents make the final decision at the ballot regarding Fanita Ranch.

It is my understanding that Item 8 approval of Fanita with the illegal exclusion of a public vote on the Fanita Ranch project was illegal and is unethical, antidemocratic.

I urge you to please 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 and existing residents and to that must use the same severely congested routes for evacuation.

As reported in March of this year (2022) in the San Diego Union Tribune, "Judge halts 3,000-home project in Santee over wildfire concerns."
And as reported in May of this year (2022) in the San Diego Union Tribune, "The Santee City Council has formally thrown out approval of the long-planned Fanita Ranch housing project, after a judge ruled the proposal didn’t adequately consider how new homes could affect wildfire evacuations. The five-member group voted unanimously last week to overturn six resolutions and two ordinances that had given the green light to around 3,000 homes in the hills beyond Santee Lakes."
The Final Revised Environmental Impact Report remains inadequate on fire safety issues.

What has changed?
And massive wildfires aside, the freeway infrastructure cannot possibly support some 3,000 to 9,000+ more cars that come hand-in-hand with such a huge development project--our freeway infrastructure cannot adequately support the existing amount of workday daily traffic
Lastly, one of the treasures about Santee is its being adjacent to Mission Trails park, its rolling hills, Santee Lakes, annual tree planting---it is a city that prides itself on the environment. That environment will be vastly impaired by such a huge development.

The development application should be abandoned and the land permanently conserved through the Department of Defense military base buffer program (REPI).

Thank you,
Marsha MacDonald
Fiona Way
Santee, CA
From: Marsha
To: Dustin Trotter; John Minto; Ronn Hall; Laura Koval; Rob McNelis; Chris Jacobs Subject: Fanita Ranch
Date: Sunday, September 11, 2022 5:21:31 AM
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.

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
Marsha Taylor
From: martin johnson
To: Chris Jacobs
Subject: The application to develop Finita Ranch
Date: Tuesday, September 13, 2022 11:11:46 AM
To: Chris Jacobs, Santee Principal Planner,
We have lived in Santee for 35 years at 10508 Cadwell Road. We have been asked to evacuate our home 3 times for fires. If the wind was blowing in the opposite direction we would have lost our homes. The evacuation routes are very limited in this area , adding 3000 homes is only making it a worse fire hazard. There are other properties that are safe, consider building there, do not build in a fire trap. A lot of us here in Fanita Ranch have had our fire insurance cancelled after a drone evaluation stating severe fire hazard, in fact, our fire insurance doubled. My wife and I want to vote on this issue, the city council does not have the right to deny us to vote on this matter, they may have the right to appeal the outcome, they need to listen to the residents.

Another concern is, will this meet the Governors requirements on affordable housing, all I see is high end community, same as the Weston project across from Westhills. With this being in a fire zone and personally experiencing a recent high insurance rate hike, I don't see how that area would qualify as affordable housing.

Sincerely Martin and Susan Johnson,
From:

To: Chris Jacobs
Subject: Fanita Ranch
Date: Tuesday, September 13, 2022 2:32:29 PM
Attachments: cty council.docx
Hello Chris,
Thanks to a neighbor, I received the Public Hearing Notice City Council Meeting regarding the Fanita Ranch Project on September 11th. I can not attend the meeting scheduled for tomorrow so I've attached a note summing up my comments about this project
Thanks for your consideration,
Marty Smothermon
September 11, 2022
Re: Fanita Ranch
Dear City Council Members:

When my family & I moved from a suburb of Detroit to Strathmore Drive 52 year ago, Santee was a safe and stable neighborhood. Time marches on and as my children became more independent, they discovered the wonders of Sycamore Canyon and to this day continue to go hiking in the hills, still enjoying the treasure that is ingrained on them as a place to respect and love.

It is a travesty to destroy these beautiful hills and animal habitats. Just a few weeks ago my next-door neighbor’s ring camera recorded a group of 3 deer near their driveway. Coyotes still wander the neighborhood, and the owls and hawks are calling in the sky.

The State of California is a crisis mode with a severe drought and although, solar panels are helping, the power grids are strained every summer when there is a heatwave and outages occur. This development adds to these problems.

Most Santee residents do not work within the city limits and families need more than one income, so they commute to other communities. When you consider the round trips to work plus the day-to-day errands that we all do, there is a potential of 25,000 added cars driving through our town almost every day. We already see traffic grid lock here every morning and afternoon.

Other than added income for the city, and if approved, what added value does this development bring to the community at large?
What are the evacuation plans for a wildfire situation? Increased pollutants, more worries about potable water, huge burdens on existing power grids, destruction of natural animal habitats. These are NOT GOOD THINGS. Please vote NO.

Marty Smothermon
Santee Resident

From: Mad Matt
To: Chris Jacobs
Subject: Fanita Ranch
Date: Saturday, September 10, 2022 2:47:21 PM
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.

Furthermore, there is no housing crisis as described as your urgency ordinance 592 claims.

There are plenty of homes available and population is decreasing in the state. 592 is not relevant and FR 8s not a required housing project.

The payoffs that the council members have received to ram this through are borde4line criminal and the council members that stand to profit from this need to be exposed.

Thank you,
Matt Cantor
From: michele perchez
To: Chris Jacobs
Subject: RE: Fanita Ranch REIR comments response
Date: Tuesday, September 13, 2022 8:38:27 PM
Here is my rebuttal to the responses to my comments in the REIR. Please submit into the Public Record. Thank you.

Response 168-2. I disagree that development of the area will not increase fire risk from homeless encampments. It is well documented that humans are the main cause of wildfires, so more access to the area is likely to result in more fires. All of the fire safety and precautions do not change the risk associated with more people coming to the area.

Response 172-1. My comment saying that increased fire hazard severity increases the risk and to make contrary statement is illogical is reliant on the common sense analysis that wildland fires could result in direct and indirect loss (meaning, of property), injury (meaning, of human and pet lives), and death life (human and pet).

Response 199-2. Not sure I see how a project under the Essential Housing Ordinance needs to occur on the Fanita Ranch project, when there are other properties available within the City limits.

Michele Perchez
Santee, CA
From: michele perchez
To: Chris Jacobs
Subject: RE: comments to thematic response 2 Fanita Ranch EIR Date: Tuesday, September 13, 2022 8:04:52 PM
RE: Thematic Response 2: Referendum and Measure N applicability Please admit the following into the public record for Fanita Ranch FREIR document. Thank you.

The assertion of the following portions of the document are meant to justify the denial of a public vote on the Fanita Ranch project, a project that exceeds the density requirements of the property (Policy 12.1, 12.2 of Measure N). As such, it is subject to Measure N, which was passed by the voters in the 2020 General Election.

As the project is in a high fire severity zone designation, the project is subject to voter approval since it does pose an “imminent threat to the health and safety of persons residing in or within the immediate vicinity of, the subject area”. Declaring the project falls under “Essential Housing”, does not erase this fact, no matter any safety measures in place or planned otherwise. Safety measures do not erase the high fire severity zone designation.

Alternative sites for “Essential Housing” do exist within the City, as identified at yearly meetings during which city staff identifies potential housing locations.

The City continues to use a variety of “catch all” statements to release itself of any responsibility to it’s constituents, such as the following: “to the extent any councilmember may have implied the proposed project is seeking a General Plan amendment and, for that reason, is subject to public vote, they were either mistaken or misquoted” (Thematic Response 2 document), and “This Ordinance shall remain in effect until August 25,2026, and may be extended by the City Council.” (Essential Housing Ordinance).

Michele Perchez
Santee, CA

From: michelle janica
Sent: Monday, September 12, 2022 2:01 PM
To: Annette Ortiz <[email protected]>
Subject: Fanita Ranch
Greetings!
I would like to express my support in the new proposed development of Fanita Ranch.

My husband and I were born and raised in San Diego and moved to AZ in 2002. We have since moved back and heard about this development and we are excited and hope it goes through.

We are ready to make Santee our forever home and this development is Amazing!
Please know we support it 100%.

Sincerely,
Robert and Michelle Janica
Santee CA 92071
From: Mike Deacon
To: Chris Jacobs
Subject: No on Fanita Ranch vote
Date: Saturday, September 10, 2022 4:38:28 PM
Dear Mr. Jacobs,
I object to a city council 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? 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.

Please include my objection in the Administrative Record for the project, Thank you,
Mike Deacon
-----Original Message-----
From: Nancy Hauser
Sent: Tuesday, September 13, 2022 12:04 AM
To: Rob McNelis <[email protected]>; Laura Koval <[email protected]>; Ronn Hall <[email protected]>; John Minto <[email protected]>; Dustin Trotter <[email protected]>
Subject: Fanita Ranch
Dear City Council,
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.

Thank you,
Nancy Bennett-Hauser
Vista del Verde HOA
Sent from my iPhone
From: Pat Parmer
To: Chris Jacobs
Subject: Opposition to Fanita Ranch
Date: Tuesday, September 13, 2022 3:19:26 PM
Dear Mr. Jacobs and City Council
We strongly oppose your decision to circumvent the will of your citizens.

The people of Santee passed Measure N and qualified a referendum to assure Santee residents make the decision at the ballot box on Fanita Ranch.

Now more than ever, placing a 3,000 unit project with traffic impacts into a Cal Fire severe hazard zone
is a significant risk to new and existing residents that must use the same routes for evacuation.

Please support the citizens of Santee in deciding the fate of this project.

Thank you, Pat and Scott Parmer

From: Ricardo Jackiewicz
To: Chris Jacobs
Subject: Fanita Ranch Draft EIR
Date: Monday, September 12, 2022 8:12:02 AM
From: Ricardo Jackiewicz
9/12/2022
Dear Mr. Jacobs,
I object to a city council illegal approval of the Fanita Ranch project scheduled on 9/14/22. Why are Fanita
Ranch project approvals on the meeting agenda? Reapproval 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?
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.

Please include my objection in the Administrative
Record for the project,
Thank you,

From: Will Rhatigan
To: Chris Jacobs; Ronn Hall; Laura Koval; Rob McNelis; John Minto; Dustin Trotter Subject: Fanita Ranch, Item 8 - Dissaprove!
Date: Tuesday, September 13, 2022 11:21:42 AM
Dear Mr. Jacobs and City Council,
The San Diego County Bicycle Coalition works to create a San Diego region where riding a bike is a healthy, practical, and convenient transportation choice for as many people as possible. We know that walkable, bikeable communities are better for people's health, the economic bottom lines of cities, and the environment. There is broad recognition of this fact in San Diego County, from SANDAG to most city governments in the region. For these reasons, we are disturbed that that Fanita Ranch Development is still on the table to move forward.

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).

Moreover, this destructive sprawl development would go against every principle of smart, environmentally sustainable growth imaginable. We urge you to vote against it.

Sincerely,
--
William Rhatigan (he/him/his)
Advocacy Director
San Diego County Bicycle Coalition
[email protected] // 617-775-9112
Advocate. Educate. Celebrate!

From: scott sheridan
Sent: Tuesday, September 13, 2022 3:06 PM
To: John Minto <[email protected]>; Rob McNelis <[email protected]>; Laura Koval <[email protected]>; Ronn Hall <[email protected]>; [email protected]; Chris Jacobs <[email protected]> Subject: Fanita Ranch Development
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 my family will have a better chance of the American Dream……owning a home! 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.

Thank you,
Scott Sheridan
From: Shelle824
To: Chris Jacobs
Subject: Fajita Ranch
Date: Friday, September 9, 2022 2:03:26 PM
Dear Mr Jacobs,
I object to a city counsel illegal approval of the Fanita Ranch project scheduled on 9/1422. 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? 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 26k new vehicle trips per day! Please include my objection in the Administrative Record for the project.

Very Respectfully,
Shelley Waider
Santee, Ca 92071
Sent from my iPad

From: Gladys "Tuloa" Sanchez
To: Clerk Info; John Minto; Ronn Hall; Laura Koval; Rob McNelis; Dustin Trotter Cc: Duncan McFetridge; Joseph D. Petta
Subject: September 14, 2022 - City Council Agenda Item re Fanita Ranch Project Date: Wednesday, September 14, 2022 9:56:45 AM
Attachments: CNFF Ltr re Measure N (9-14-22)(1564295.1).pdf Good morning,
Please confirm receipt of the attached correspondence in regards to the September 14, 2022 City Council meeting agenda item concerning approval of the Fanita Ranch Project.

Best,
Tuloa Sanchez
Gladys "Tuloa" Sanchez
Legal Secretary
Shute, Mihaly & Weinberger LLP
396 Hayes Street
San Francisco, CA 94102-4421
p: 415/552-7272 x |
www.smwlaw.com | A San Francisco Green Business

396 HAYES STREET, SAN FRANCISCO, CA 94102
T: (415) 552-7272 F: (415) 552-5816
www.smwlaw.com
JOSEPH D. PETTA
Attorney
[email protected]
September 14, 2022
Via Electronic Mail Only
City Clerk, Mayor and Members of the City Council
City of Santee
10601 Magnolia Ave.

Santee, CA 92071
[email protected]
Re: September 14, 2022 City Council Agenda Item re Fanita Ranch Project Dear City Council:

On behalf of the Cleveland National Forest Foundation and Save our Forests and Ranchlands, we submit these comments on the Council’s September 14, 2022 agenda item concerning the proposed approval of the Fanita Ranch Project. The City’s assertion that Ordinance No. 592 (the “Ordinance”) “deemed” the Project consistent with the City’s General Plan, and thus that the City’s Measure N does not require a popular vote on the Project, is contrary to black letter law. As explained below, the Ordinance is invalid, and reliance on the Ordinance to approve the Project would be a clear violation of state law.

The Ordinance is obviously an illegal work-around to avoid Measure N’s popular vote requirement. Measure N amended the City’s General Plan and mandates that any general plan amendment that would intensify land use over current General Plan levels must go to a vote of the people. The City purports to have adopted an “urgency” ordinance in 2021, Ordinance No. 592, to create a process whereby projects that City staff determines are “Essential Housing Projects” are automatically “deemed” compliant with the General Plan. As explained in the Final EIR for the Project, the Ordinance’s intended effect was to give City staff unilateral power to decide which projects are subject to Measure N’s popular vote requirement, and which projects are not. This is contrary to Measure N’s intent to “require a vote of the people on certain development projects,” and to give voters a “right to vote on controversial projects that threaten overdevelopment.” Measure N, § 1 (Purpose and Findings).

City Clerk, Mayor and Members of the City Council
City of Santee
September 14, 2022

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Santee City Council
September 14, 2022