TO: Mayor and Councilmembers
Gary Halbert, Interim City Manager
Shawn Hagerty, City Attorney
FROM: James Jeffries, City Clerk
DATE: June 12, 2025
SUBJ: Updated Council Meeting Materials – June 11, 2025 PUBLIC HEARING:
(6) Public Hearing for the Development of Fanita Ranch, to Consider Certifying Final Recirculated Revised Environmental Impact Report Including Second Recirculated Sections (ENV-2025-0003, AEIS 2022-4, AEIS 2017-11), and Approving the Fanita Ranch Development Plan and Development Review Permit (DR-2025-0001), Vesting Tentative Map (TM2025-0001), and Conditional Use Permits for Public Parks (CUP2025-0001 and CUP-2025-0002), and a Fire Station (CUP-2025-0003). (Planning and Building – Sawa)
The attached correspondence for above mentioned Item was received after 4:00p.m. on June 11, 2025, and was not included in the original memo.
From: Janet Mc
To: Sandi Sawa
Subject: Fanita Ranch Project and Second Recirculated Sections of the EIR Coments Date: Wednesday, June 11, 2025 4:37:09 PM
Dear Esteemed Mayor and Santee City Council,
Firstly, I am saddened that you are ignoring the Measure N VOTE results. This EIR appears to avoid the will of the voting majority and the many Santee signatures requiring a vote. Where is the General Plan Amendment? Is this informed decision making that CEQA mandates? I think not.
Second, You again skirt the intentions of the laws, ie CEQA, created to protect the sensitive habitat and the protected wildlife of the pristine Fanita Ranch land.
Third, We citizens have watched wildfires burn homes, property and endanger lives. The evacuation risks are real, exit routes are minimal, and the area schools will cause chaos with parents rushing to the area. Will gates be locked and barricaded keeping the big trailer rigs inside Santee Lakes Campground that would otherwise add to the traffic mayhem?
Finally, I have concerns for the senior citizens who may not be fully informed of the Very High Fire Hazard Zone that they may be risking their lives in. Many may be reliant on Uber type services for evacuation. Many may require frequent medications or visiting medical or daily services help that make sheltering in place not an option.
Please reject the Homefed Fanita Ranch Project. This pristine environment with all its entails and the voters of Santee deserve to have complete EIR, CEQA compliance, transparency, and safety from wildfires.
Thank You.
Sincerely,
Janet Mclees
Santee citizen, Santee voter, and Santee homeowner.
From: Meredith Stevenson
To: Sandi Sawa
Subject: RE: Comment Letter on FREIR for Fanita Ranch
Date: Wednesday, June 11, 2025 5:40:47 PM
Attachments: image001.png
image002.png
2025-6-11 Written Public Testimony re Fanita Ranch.cleaned.pdf Your attachment(s) were cleaned by Check Point Sandblast Threat Extraction.
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Good evening,
I cannot attend the meeting this evening, so I have attached written testimony here.
Please confirm receipt when possible.
Best,
Meredith
Meredith Stevenson
Staff Attorney
Center for Biological Diversity
574-309-5620
[email protected]
From: Sandi Sawa <[email protected]>
Sent: Wednesday, June 11, 2025 6:50 AM
To: Meredith Stevenson <[email protected]> Subject: RE: Comment Letter on FREIR for Fanita Ranch
Ms. Stevenson,
I am in receipt of your email and was able to download the references.
Sandi
Sandi Sawa, MPL, AICP
Director of Planning and Building/City Planner
(619) 258-4100 x 167
[email protected]
Please note my next regular day off is Friday, June 20th.
From: Meredith Stevenson <[email protected]> Sent: Tuesday, June 10, 2025 4:59 PM
To: Sandi Sawa <[email protected]>
Subject: Comment Letter on FREIR for Fanita Ranch
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Good afternoon,
Attached please find a letter from the Center for Biological Diversity regarding the FREIR for Fanita Ranch. We will also send the letter via FedEx. The references are available here and on a flash drive we will send tomorrow. Please confirm that you received the letter and were able to download the references.
Thank you,
Meredith Stevenson
Staff Attorney
Center for Biological Diversity
574-309-5620
[email protected]
Public Testimony – Meredith Stevenson
City of Santee City Council Meeting, June 11, 2025
Re: Fanita Ranch, Agenda Item #6
Thank you for the opportunity to comment on the Fanita Ranch Project. I am unable to attend in person this evening and was disappointed to find that the City inexplicably will not accept comment from attendees who are participating remotely. So I am submitting my comments in writing instead.
I am a staff attorney with the Center for Biological Diversity (the “Center”), and I previously sent more extensive written comments to the City on the Second Recirculated Final Revised Environmental Impact Report (“2025 FREIR”) for the Fanita Ranch Project (the “Project”).
In short, the Center remains concerned that the 2025 FREIR fails to properly disclose, analyze, and mitigate the Project’s wildfire risks in light of new information from the recent 2025 Eaton and Palisades Fires (“LA Fires”). These fires started and quickly spread under similar conditions to those at the Project site, fueled by Santa Ana winds, steep topography, and dry vegetation.
Despite confirming that a Very High Fire Hazard Severity Zone now covers the entire Project site, the FREIR overlooks new information brought to light by the recent LA Fires, as well as other recent fires, indicating heightened wildfire ignition and public safety risks and fails to adopt feasible mitigation measures to reduce or avoid the Project’s fire safety impacts.
In particular, the Center’s previous comments focused on the Project’s 445 age-restricted units, which will house an older population more vulnerable to these wildfire risks. The Center provided new information from the LA Fires regarding evacuation challenges for this population, including older residents’ unwillingness to evacuate the LA Fires, their difficulties due to physical constraints, logistical challenges for older residents, immediate health risks to older evacuees, and new information regarding health risks of wildfire smoke. Nevertheless, the City failed to respond to these concerns, let alone adequately assess and mitigate these reasonably foreseeable impacts, placing hundreds of residents at risk.
As we previously explained, the Project remains inconsistent with the applicable General Plan policies that guide development on the site. The Project’s inclusion of 445 so-called “Active Adult” units does not qualify the Project for the State Density Bonus Law, and, even if it did, the State Density Bonus Law does not require or authorize cities and counties to waive or ignore all applicable general plan policies with which a proposed project is inconsistent. If the City wishes to approve the Project as proposed, it should do so by way of an amendment to the General Plan, and should accordingly put the decision to a vote of the citizens of Santee, as required by Measure N. The City’s attempt to thwart the will of the voters by depriving them of this vote violates due process and the state constitutional right of initiative.
We ask the City Council not to approve the Project until it has taken into account pertinent new information from the LA Fires and other recent studies regarding fire behavior and mitigated accordingly. The Center would welcome an opportunity to meet with City representatives to address these concerns.
Sincerely,
Meredith Stevenson
From: michele perchez
To: Sandi Sawa
Subject: Re: second recirculated sections of final EIR Fanita Ranch project (SCH#200506118) Date: Wednesday, June 11, 2025 4:20:10 PM
Dear Director Sawa,
Please add my response to the comments found in the final EIR for the Fanita Ranch project to be voted on at tonight's meeting. Thank you.
The following are responses to my comment made April 2025: I110-1: The comment states that the Fanita Ranch Project (proposed project) would place senior housing in an elevated fire hazard severity zone. It also requests acknowledgment of Measure N and the Santee voters’ right to control zoning of Fanita Ranch. Please refer to Thematic Response 1, Recirculation and Scope of Review Claims; Thematic Response 2, Wildfire Risk; and Thematic Response 3, No Public Vote Requirement. This comment does not raise a significant environmental issue regarding the adequacy or accuracy of the information provided in the Second Recirculated Sections of the Final Revised Environmental Impact Report for the proposed project.
Therefore, no further response is required.
I believe a response is required for the fire risk not adequately addressed for all subpopulations that will inhabit the parcels of the Fanita Ranch project, specifically the special needs individuals that require assistance and/or extended time periods for successful evacuation (senior populations definitely, likely others that are unknown). In this case, the project fails to ensure adequate fire safety evacuation plans.
Additionally, it is reasonable to assume we are at far greater risk, as demonstrated by exacerbated effects of increased planet warming, that the recent fires in Los Angeles are a likely scenario for consideration when planning any project, whether in Santee or other area within the State of California. It is unwise to ignore these new circumstances.
I believe the City still should let the voter's decide whether the project goes forward or not (use of voter measures and referenda). The City's use of the EHP element represents a backdoor way of approving the project without complying to the will of the voter. Not all of the residents in Santee can just pick up and move to avoid the decades long impacts of this project, yet we will feel the pain and contend with our tax dollars going to support this huge project.
The community has pushed back on this project for many decades; it's time that the council listen to its constituents.
I thank you for your time!
Michele
On Wed, Apr 9, 2025 at 9:26 PM michele perchez wrote:
Dear Director Sawa and Santee City Council,
Please respect, as public servants, the court's decision and the Santee voters' right to control zoning of Fanita Ranch. Recall that the voters of Santee decisively approved Measure N and as this very large project will have an inordinate impact to our daily lives, voters have earned the right to voice our approval/disapproval for the project.This is the fair thing to do- -let the people speak.
It is my understanding that 445 units will be earmarked as Senior Housing for this project, a project that will be placed right in the middle of an extreme fire hazard severity zone.
Common sense would dictate this site would not even be a consideration given the risk and given the real threat that Santee is sure to experience fires on the scale we have seen with the recent Los Angeles area fires. Knowing that the vast majority of fatalities in those fires were senior citizens, I don't understand why the city planners and council would even contemplate continuing to push forth with this project. Please choose another site for development.
Project approval shows obvious disregard for the will of voters and an ignoring of the court's legal opinion. Contrary to the Mayor's recent comments in East County Magazine, the judge has followed the law and made the right decisions and these should be abided by.
Thank you for taking the time to read my email.
Michele Perchez
From: Tim Deesen
To: Sandi Sawa; CityClerk; [email protected] Subject: Public Comment – Opposition to Fanita Ranch Housing Expansion Project -Fanita Ranch FINAL 2nd Recirculated Sections FREIR (SCH# 200506118) “FEIR” (Response To Comments, RTC) Date: Wednesday, June 11, 2025 6:19:41 PM
Dear Honorable Mayor and Members of the Santee City Council, I am writing to express my strong opposition to the Fanita Ranch Housing Expansion project. As a resident of Santee for over 15 years, I have witnessed firsthand how each new housing development has worsened our traffic congestion. The Fanita Ranch project, which proposes 3,000 new homes, would bring an estimated 10,000 additional residents, exacerbating an already strained infrastructure.
This project has been rejected multiple times by the community, and yet it continues to resurface. The recent court ruling in August 2024 reaffirmed that the City Council failed to follow its own rules by bypassing a public vote, as required by Measure N. The residents of Santee deserve the right to vote on such a transformative project.
I urge you to respect the will of the people and reject this project once and for all.
Thank you for your consideration and for your service to the community.
Sincerely,
Tim Deesen (Santee resident since 2009)
From: Save Fanita
To: Sandi Sawa
Cc: James Jeffries
Subject: Fanita Ranch FRREIR - Item 6
Date: Wednesday, June 11, 2025 4:50:38 PM
Attachments: PWS Response to Fanita Response FB 06112025.cleaned.pdf ATT00001.txt
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Dear Director Sawa & City Council,
Please consider Preserve Wild Santee comments opposing the Fanita Ranch project attached.
Thank you,
Van Collinsworth
PRESERVEWILDSANTEE.ORG
PRESERVE WILD SANTEE
June 11, 2025
Sandi Sawa, AICP, Director of Planning & Building
Santee City Council
By Email: [email protected]
RE: Fanita Ranch FINAL 2nd Recirculated Sections FREIR
(SCH# 200506118) “FEIR” (Response To Comments, RTC)
Dear Director Sawa and City Council,
The following statements respond to the Responses to Comments (RTC) for the Fanita Ranch project, specifically addressing wildfire risks, evacuation feasibility, senior housing vulnerabilities, and inconsistencies with the Santee General Plan, including requirement for a public vote. These issues pose significant public safety and environmental impacts that warrant further mitigation / project rejection or a public vote.
Please respect the democratic process and allow the citizens of Santee to make a final vote on the project. It is residents who should determine Santee’s future - not the speculation and campaign contributions of “HomeFed” / Jeffries Financial Group of NY.
Response to Responses in the Second Recirculated Sections of the Final EIR May 2025
Appendix U Wildfire Safety Memorandum
Response To Comment (RTC) Letter - Michael Huff, Dudek May 27, 2025:
Theoretical fire modeling utilizes variable inputs and its results are limited by those inputs. Chapter 7A, Ignition Resistant Construction has limitations. “Resistant” acknowledges a potential for ignition remains. Resistance has limitations.
Page of 1 8
9222 LAKE CANYON ROAD, SANTEE CA [email protected]
Dudek places its faith (and the lives of thousands) upon unproven theory a “masterplanned” subdivision is a magic bullet to allow continued building in severely hazardous topography, regardless of dynamic fuel loads, increasingly severe fire weather with fast moving incidents or post-fire mudslides. Firefighters with long careers are now speaking frequently about the increased severity of fire behavior experienced. Dudek alleges its theory was tested by the Silverado Fire in 2020.
The Silverado Fire burned in an area previously burned by the 2007 Santiago Fire, so the fuel intensity of the Silverado fire is not a worst case scenario test for projects built with higher standard building code. Furthermore, the Silverado Fire burned only 1 12,466-acres. Comparisons with mega-fires burning hundreds of thousands of acres and destroying thousands of structures in California are limited. Still, CAL FIRE records indicate 5 structures were destroyed and another 11 were damaged by the Silverado Fire.2
The Silverado incident required the evacuation of approximately 90,000 people. 3 Evacuations were required despite higher building standards. The City response does not acknowledge or address the inadequate and reduced feasibility of evacuating existing or future Fanita Ranch residents relative to evacuation routes available for the Silverado Fire. Furthermore, two firefighters were critically burned reflecting the strain placed upon emergency personnel when at risk development requires firefighter response.
Dudek fails to address a critical weakness in the proposed Fanita Ranch subdivision design: the close clustering of homes combined with reliance on fire-resistant rather than fireproof construction. If a single home ignites—whether due to design limitations, weather impacts, or human error—nearby structures are highly susceptible to ignition, especially under extreme, low-humidity wind conditions. This domino effect significantly increases the risk of widespread fire throughout the downwind subdivision.
As seen in events like the Silverado Fire, such vulnerabilities often necessitate mass evacuations. However, Santee’s current circulation system is inadequate to support a timely evacuation of this scale.
My comments, along with those of others, do not dismiss the value of fire-resistant construction; rather, they appropriately highlight critical weaknesses that significantly impact public safety. Dudek claims that the remaining risk is at “acceptable levels.” However, this substantial residual risk can be avoided by building off-site and/or Gabbert, Bill. Orange County’s Silverado Fire similar to 2007 Santiago Fire. Wildfire Today, 1 10/29/2020. https://wildfiretoday.com/orange-countys-silverado-fire-similar-to-2007-santiagofire/#:~:text=Silverado and Santiago Fires,29, 2020) vs.
CAL FIRE. Silverado Fire https://www.fire.ca.gov/incidents/2020/10/26/silverado-fire/ 2 Fausto, Alma. Silverado fire forces 90,000 to evacuate: 2 firefighters critically burned. Orange 3 County Register, October 27, 2020. https://www.ocregister.com/2020/10/26/vegetation-fireerupts-in-canyon-hills-of-silverado-in-east-orange-county/ Page of 2 8
mitigated by increasing the distance between structures, consistent with “Essential Element”/“Guiding Principle” 3 of the Santee General Plan. Adhering to the General Plan guidelines ensures that structures are separated sufficiently to lie outside each other’s Home Ignition Zones. Failure to provide this separation leaves residents vulnerable to structure-to-structure “urban conflagration” or “cluster burns.” The statement by former CAL FIRE Director Ruben Grijalva cited by Dudek does not say there has not been or will not be any losses. The caveat of his statement, is that there has not yet been “extensive losses.” Data referenced by Director Grijalva documents at least 239 homes built after 2010 have been lost in eight different California wildfires.4
Former CAL FIRE Director Ken Pimlott, provided alternate guidance calling for new development “to make sure we’re not putting people in harm’s way”. Director Pimlott also stated, “There just may be areas in drainage or that are critical fire corridors that intensify winds that it will make it impossible to protect a structure,…We have to learn from past fires and continue to take a hard look at determining where houses can be built in the future.”5 6 7
Furthermore, contrary to Fanita Ranch design, the Orchard Hill subdivision touted by Dudek has 200-foot fuel modification zones with perimeter roads in consideration of Santa Ana wind direction, orchards, fire walls and much superior ingress and egress.
Older Adults:
The Dudek letter uses a project euphemism “active adult community.” Dudek fails to provide evidence the 55+ residents would not have the same vulnerabilities as other 55+ residents identified by PWS April 2, 2025 comment letter. Comparisons are valid and relevant, in part, because the project has designed encroaching Home Ignition Zones between structures which are not fire proof.
4 CBIA. Office of the State Fire Marshal Property Loss Data Summary - Exhibit Attached Tandy, Katie. Cal Fire’s Retiring Chief: ‘Firefighter face the impacts of climate change every 5 day’. KQED The California Report, 12/14/2018. https://www.kqed.org/news/11712563/calfires-retiring-chief-firefighters-face-the-impacts-of-climate-change-every-day Thompson, Don. Retiring Cal Fire Director: California Must Mull Home Ban in Fire-Prone 6 Areas. Associated Press. CAPR 12/11/2018. https://www.capradio.org/articles/2018/12/11/ retiring-cal-fire-director-california-must-mull-home-ban-in-fire-prone-areas/ #:~:text=Department of Forestry and Fire Protection Director Ken Pimlott will,now routinely threaten large populations.
Peterson, Molly. One Potential Solution to Deadly Wildfires in the Wilderness: Don’t Build 7 There. KQED, 6/12/2019.
Page of 3 8
CAL FIRE - Fire Hazard Severity Zone Map Updates:
Dudek misinterprets public comments regarding changes to “Fire Hazard Severity Zone” maps in Santee. Comments do not suggest changes to the site. The map changes confirm CAL FIRE most recent data recognizes greater vulnerability than data incorporated by prior maps, in part, due to the consistent trend for greater weather extremes.
Dudek downplays the significance of the greater hazard recognition for Santee and the Fanita Ranch site by stating the Santee City Council has not yet adopted the updated map. Santee City Council is predisposed not to consider significant new information released by Cal Fire. Reference the City Council meeting recording 4/9/25.
However, when the updated map was initially presented to City Council at hearing, Santee Fire Chief Justin Matsushita recommended adoption of Chapter 7A standards for any lot split by the new CAL FIRE Map and adoption of Very High Fire Hazard Severity Zone standards for the entire city.8
Santee Fire Chief Justin Matsushita:
“I can look at this through the lens of a fire agency standpoint. And it is not popular, but I would want the entire map red because that means that I’m going to have the most fire resilient structures on the planet. Right, but that’s unfortunately not, I don’t, I’m not the king. We also have to balance the impact that will have on construction and the viability of projects. So we know that there is this kind of tug of war and so apologies if you wanted that from us. That’s my bad.”9
The risk of the hazards identified by CAL FIRE map data remain significantly elevated due to lack of adequate spacing between structures and other factors identified in public comment, which Dudek does not address. The hazard map update is new and significant information.
Santee City Council Agenda Item 10, April 9, 2025. Presenting Santee Fire Hazard Severity 8 Zone Map as Recommended by CAL FIRE… Exhibit attached.
Santee City Council 4/9/2025, Item 10 recording at https://cityofsantee.cablecast.tv/ 9 CablecastPublicSite/show/2082?site=1
Page of 4 8
Emergency Alert Failures:
Regardless of the significant potential for alert system failures, a “layered” alert system does not compensate for the inability of the project to be evacuated prior to the potential for fast moving wind driven ignitions and flame fronts to reach project structures and evacuation routes. Dudek confirms, for ‘short-notice wildfire events”, residents would be sheltered on-site and instructed to remain indoors, despite project vulnerability to structure-to-structure cluster burns. Dudek does not address data demonstrating increased vulnerability and destruction of homes with 10-20 feet of separation. And once again, the request to estimate evacuation times for specific evacuation zones or provide performance standards for evacuation has been ignored.
Evacuation routes near chaparral and coastal sage habitats remain vulnerable to radiant heat, direct flame impingement and smoke. All routes are vulnerable to loss of visibility and smoke inhalation.
Educational Outreach:
The effectiveness of educational outreach is limited. There is not pre or post testing of individual residents to assess deficiencies or retention of concepts. Nor is there compulsory participation. Individuals have a wide range of interest and ability to participate in or grasp information. I know from first hand experience performing such educational outreach among thousands of at risk households in San Diego County.
Furthermore, education without implementation/reinforced action has limited periods of retention. Contrary to Dudek’s claim of hardening, critical evacuation routes remain significantly exposed to chaparral and coastal sage vegetation fuels.
Increased frequency of extreme weather events and record breaking temperatures:
Dudek does not address the implications of increasing temperatures and extreme weather events. Nor does Dudek refute rising amounts energy are being trapped inside the earth’s atmosphere, all energy is conserved and the rising amounts of energy are distributed by higher velocity winds with greater duration. The implications for the project of significant new record breaking climatic data remain unconsidered.
Dudek did not address climatic factors resulting in the loss of over 7,000 structures outside of a Fire Hazard Severity Zone on the Eaton Fire.
Dudek did not address the lack of confidence demonstrated by insurance companies cancelling policies or the prospect for project homeowners to obtain and retain coverage in a Fire Hazard Severity Zone.
Dudek did not address or recognize the rising frequency of fast moving fires throughout the state and beyond.
Dudek did not address the potential for post fire mudslides on and below avoidable steep topography. Geologic studies identified numerous ancient landslides.
Page of 5 8
Thematic Response 2 - Wildfire Risk [P 1-8 - 1-11]
Senior Housing:
The RTC is inadequate. While prior Descriptions of the project evidently included some option or provision for what the RTC now describes as Senior Housing, the 2020 and 2022 documents did not reveal the extent to which a Senior Housing component would be relied upon to avoid General Plan consistency and Measure N public vote requirements. Review of Section 3.1 and Table 3.1 confirm the project description does not use the term “Senior Housing” nor does the description specifically state residents would be limited to age 55+. The specific “age-restriction” is not revealed. The project description veiled what is now identified as 55+ Senior Housing with the euphemism “Active Adult.”
In contrast, the first use of the term “…senior housing” is revealed in a “Density Bonus Law Revisions” discussion February 2025, pages 0-4, 0-5 of the Second Recirculated Sections of Final EIR.
CEQA requires full disclosure. The serious issues raised by public comments in regard to 445 units of Senior Housing must be addressed.
Recent Wildfires - RTC on wildfire comparisons:
Unless and until the applicant produces a fire proof project design where evacuation is not necessary, vulnerability comparisons of the proposed Fanita Ranch project with other wildfire losses are relevant and appropriate. There are no “acceptable levels” of destruction when occupied structures are spaced so close together that the ignition of just a single structure can ignite a chain reaction of destruction. The 150-mile separation from Santee to the LA fires is not significant. Weather, fuel and topography comparisons are relevant. California’s weather, vegetation and topography is diverse, yet mega-fire destruction stretches from north to south, a distance of approximately 770 miles border to border.
RTC cites the 2020 Silverado Fire in Irvine as evidence the Fanita Ranch project will withstand future firestorms. [P.1-9 FEIR] The argument is not convincing. Reference pages 2 and 3 of this letter.
RTC [P. 1-9] provides statements that would mislead the reader to conclude there would not be wildfire structure losses with Chapter 7A compliant construction.
In fact, new homes built with Chapter 7A, Ignition Resistant Construction have been destroyed by wildfire. State Fire Marshal data indicates, at least 239 homes built after 2010 have been lost in eight different California wildfires.10 10 CBIA. Office of the State Fire Marshal Property Loss Data Summary - Exhibit Attached Page of 6 8
Thematic Response 3 - Issue of a Public Vote
Contrary to the RTC assertion, a public vote is required for project approval. “Essential Element” / “Guiding Principle” #3 in the Land Use Element of the Santee General Plan establishes density limits (as recognized by Measure N) by establishing minimum lot sizes for developable acreage. The developer and City choose to ignore the letter and spirit of Measure N, which provides the residents of Santee veto power over project’s which increase density. The Fanita Ranch project proposes to more than double the number of units over what could be built consistent with “Essential Element” / “Guiding Principle” #3.
RTC 04-3 General Plan Inconsistency Issue:
RTC implies the purpose of “Essential Element” / “Guiding Principle” #3 did not include avoidance or mitigation of significant environmental impacts and thus the inconsistency is “less than significant.” PWS April 2, 2025 comment letter pages 23-25 specifically refutes the false assumption GP#3 was not adopted to avoid or mitigate for significant adverse environmental impacts.
“Essential Element” / “Guiding Principle” #3 was adopted by the Santee City Council after a 1984 Environmental Impact Report and later Ogden Environmental’s Biotechnical Report for Fanita Ranch circa 1993 were released to study large development proposals.
[Final Environmental Impact Report for Fanita Ranch Units 1-5 (City of Santee TM83-01, TM83-04, TM83-05, TM83-06, TM83-06, TM83-07, P83-01, P83-02, P83-03, R83-01, R83-03. RBR & Associates, Inc.. 1984 ( tDAR id: 312247)] Therefore, the project does cause a significant inconsistency with a plan or policy adopted for the purpose of avoiding or mitigating an environmental effect. The significant impact of inconsistence with GP#3 must be addressed.
Furthermore, RTC fails to address the inconsistence with Habitat Conservation Plans and Endangered Species Acts called out by our letter 4/2/25 on page 23.
Page of 7 8
Conclusion:
The Fanita Ranch project has significant adverse impacts to public safety and should be rejected. Wildfire vulnerabilities, evacuation challenges, senior housing concerns, General Plan and HCP inconsistencies were not adequately addressed by the public response to comments.
I urge the City to reject the project or require mitigations, including increased structure spacing, enhanced evacuation route capacity, compliance with Measure N public vote requirement and CEQA disclosure requirements. Thank you for considering these comments.
Sincerely,
/s/
Van K. Collinsworth, Director/Physical Geographer/Fire Professional Exhibits:
Orange County’s Silverado fire similar to Santiago Fire Silverado Fire - Cal Fire Incident Summary
Silverado fire forces 90,000 to evacuate: 2 firefighters critically burned Office of the State Fire Marshal Property Loss Data Summary Cal Fire’s Retiring Chief: ‘Firefighter face the impacts of climate change every day’
Retiring Cal Fire Director: California Must Mull Home Ban in Fire-Prone Areas One Potential Solution to Deadly Wildfires in the Wilderness: Don’t Build There Santee City Council Agenda Item 10, April 9, 2025. Presenting Santee Fire Hazard Severity Zone Map as Recommended by CAL FIRE…
1984 Final Environmental Impact Report for Fanita Ranch Units 1-5…Citation Page of 8 8
Office of the State Fire Marshal Property Loss Data Summary The Office of the State Fire Marshal maintains an extensive data retrieval service of fire incidents across the state, including those related to fires occurring in the Wildland-Urban Interface (WUI).
Regarding the ten worst property-loss fires dating back to 2017, CBIA requested residential data that identified:
• whether the dwelling was single-family or multifamily • damage assessment (destroyed, major damage, affected, no damage) • valuation of the structure
• year the structure was built
Among other things, we wanted to see whether the regulatory rules that applied to newer units and development were faring any better than older dwellings/development. These regulatory rules included:
• The State Fire Marshal’s “fire hardening” building standards • Defensible space mandates
• Cal Fire’s Fire Safe Development Standards
We used a demarcation point of 1/1/10 as that is when all three of these rules were being consistently implemented in new construction in the WUI areas of California.
On average, only 1% of the homes and apartments which were destroyed, damaged, or affected were new dwellings (built after 1/1/10) even though new dwellings make up roughly 7% of the states total housing stock.
For all these fires, there is evidence that significant, initial residential development took place in the period of 1945-1980, decades before these critical rules were put in place.
New, production-style development has fared extremely well compared with older neighborhoods. Of the 31,000 data points retrieved from the SFM, it was extremely rare to see more than two new homes on the same street destroyed or affected by the fires, while entire neighborhoods of older dwellings being destroyed was commonplace.
This seems to make the case that the state should place major focus on fire-hardening existing neighborhoods in ways similar to those required of all new construction.
Simply put: California’s existing rules for new construction appear to be working very well.
60139.00001\43656647.1
STAFF REPORT
PRESENTING THE SANTEE FIRE HAZARD SEVERITY ZONE MAP AS RECOMMENDED BY
CAL FIRE FOR PUBLIC COMMENT AND ASK CITY COUNCIL TO RECEIVE REPORT AND
PROVIDE STAFF DIRECTION
CITY COUNCIL MEETING
APRIL 9, 2025
BACKGROUND
Prompted by the devastating Oakland Hills fire of 1991, Assembly Bill 337 (Bates, 1992) called for the California Department of Forestry and Fire Protection (CAL FIRE) to evaluate fire hazard severity in local responsibility areas (LRA) and to make recommendations to local jurisdictions where Very High Fire Hazard Severity Zones (FHSZ) exist. (CA GOV 51175).
Between 2008 and 2011, CAL FIRE worked with local jurisdictions to make recommendations of the Very High FHSZ within the LRAs. CAL FIRE provided the City of Santee with their recommendations on June 11, 2009. The City adopted those recommendations into the Santee Very High FHSZ Map on October 28, 2009.
New legislation, Senate Bill 63 (Stern, 2021), now requires the adoption of all three (Moderate, High, and Very High) FHSZ classes in the LRA. Previously only Very High FHSZ were required for adoption in the LRA. These new zones are based on scientific analysis of factors such as fuel loading, topography, fire weather, and historical fire patterns. In the State Responsibility Area (generally unincorporated areas), CAL FIRE directly maps and designates FHSZ and provided each jurisdiction with a FHSZ map for their area on April 1, 2024. In 2025, CAL FIRE began to roll out customized maps to LRA jurisdictions, beginning with Northern California on February 10, 2025 and finishing with the jurisdictions located in San Diego, Riverside, Orange, Imperial, San Bernadino, Mono, Inyo, and Los Angeles on March 24, 2025.
The City of Santee received its LRA map on March 24, 2025.
DISCUSSION
What Are Fire Hazard Severity Zones?
Fire Hazard Severity Zones (FHSZ) are classified on their likelihood of experiencing wildfire and the potential severity of fire behavior. These zones help guide fire prevention efforts, building standards, defensible space requirements, and public safety planning. The three classifications are:
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• Moderate: Areas with a lower likelihood or intensity of wildfire. • High: Areas with a significant risk of wildfire occurrence. • Very High: Areas with the highest likelihood of wildfire occurrence and severe fire behavior.
CAL FIRE’s Role
The California Department of Forestry and Fire Protection (CAL FIRE) plays a critical role in the identification and mapping of FHSZ. Using science-based models that consider vegetation, climate conditions, topography, wind patterns, and fire history, CAL FIRE develops FHSZ maps statewide that are updated periodically to reflect current conditions.
CAL FIRE provides these recommendations to local jurisdictions for adoption.
Local Jurisdiction Responsibilities
State law requires local jurisdictions to take specific actions regarding the CAL FIRE recommended FHSZ:
1. The City must make the map available for public review and comment within 30 days of receiving CAL FIRE’s recommendations (April 23rd).
2. The City must adopt (designate) the LRA FHSZ map within 120 days of receiving CAL FIRE’s recommendations (July 22nd).
3. The City must transmit a copy of the ordinance to the Board of Forestry within 30 days of adoption.
4. The City must provide the adopted map to the county recorder, county assessor, and county planning agency.
5. The City may increase the geographical extent and hazard level of CAL FIRE’s recommended zones.
6. The City may not decrease recommended zones.
By adopting these zones through an ordinance, local agencies ensure compliance with state law while enhancing community safety from wildfires.
Implications of FHSZ Designations
The adoption of the new FHSZ map has several important implications for property owners and the City:
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1. Building Standards: The updated FHSZ map will be used by the Building Official to enforce wildfire-resistant construction standards for new buildings in the high and very high FHSZ starting on January 1, 2026.
2. Property Disclosure Requirements: Property owners in the Very High and High FHSZ must disclose this information during property sales as part of the Natural Hazard Disclosure Statement as soon as the map is adopted.
3. Defensible Space Requirements: Properties now within the Very High (VH) FHSZ zone must comply with defensible space clearance requirements (typically 100 feet around structures).
4. Safety Element Updates: FHSZ maps will inform updates to the Safety Element of General Plans to address wildfire risks comprehensively.
5. Fire Safe Regulations: New projects in the VHFHSZ must comply with the California Code of Regulations, Title 14 (Natural Resources) fire safe regulations for access and water supply.
6. Subdivision Map Act: Projects in the VHFHSZ must have their tentative map reviewed by the Board of Forestry.
7. Subdivision Review (AB-2911): Developments with 30 or more homes in the VHFHSZ must be routinely reviewed by CAL FIRE when there is only one way out of the development.
8. CEQA: There are additional CEQA requirements for projects in the VHFHSZ.
Discussion Items
Item 1: Fire Hazard Severity Zones (FHSZ) and Local Jurisdiction’s Authority to Expand FHSZ While local jurisdictions cannot exempt properties from zone-specific requirements, they can expand zones within their City boundary. The intent of CAL FIRE’s recommendations is to inform local jurisdictions of the hazards present in their community. If local jurisdictions would like to enhance the safety requirements, they are encouraged to do so. For instance, some jurisdictions in forested areas have designated their entire area as High, even when CAL FIRE only recommended Moderate. In such cases, all new structures in the City would be built to California Building Code Chapter 7A standards, with increased wildfire exposure protection.
To expand the VHFHSZ, the City must demonstrate substantial evidence the expansion is needed. State law does not specify how this could be justified, but CAL FIRE has indicated that fire modeling could be considered such evidence.
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To expand the High and Moderate FHSZ, no evidence is required and may be done at the City’s discretion. A new map from the City could accomplish this.
Item 1 Discussion
Does the City of Santee want to expand any of the three zones within the City or adopt the Santee FHSZ Map that was recommended by CAL FIRE?
Item 2: Parcels that are Split Between Zones
CAL FIRE's broad recommendations have resulted in parcels being split between multiple zones, complicating compliance determination. For example, if a parcel is split between the Moderate and High zones, neither state law nor CAL FIRE provide any guidance on how to apply the differing requirements to the structure or parcel. Does part of the structure need to be complied with CBC Chapter 7A while another part doesn't? In the event of a wildfire, the entire structure will likely be exposed to embers. Current code administration practices are when there are two differing requirements, the most restrictive shall apply.
Notably, 7,800 structures that burned in the Eaton fire in Altadena were not in any FHSZ.
Other jurisdictions have drafted ordinances to clarify that the most severe zone apply to the entire parcel.
If directed, City staff could create a map that extends the most severe zone to cover the entire parcel and provide clarity about what regulations are applicable.
Item 2 Discussion
How does the City of Santee want to address requirements for parcels that span multiple zones?
Item 3: Public Comment Period
Within 30 days of receiving CAL FIRE’s recommendations, local jurisdictions must make the information available for public review and comment. The information must be presented in a format that is understandable and accessible to the general public, including but not limited maps. (CA GOV Section 51178.5) There is no time period requirement for the public comment period. Some jurisdictions are limiting this to the Council Meetings while others have created surveys on their websites.
Staff can easily and quickly create a webpage dedicated to this and allow for comments for a set period of time.
Item 3 Discussion
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How does the City of Santee want to address the public comment requirement of CA GOV Section 51178.5.
FISCAL IMPACT
The adoption of FHSZs is required by state law. Financial impacts for the City are unknown at this time. However, implementation may require additional staff time for enforcement activities such as building code reviews, new construction inspections, and defensible space inspections. These costs can generally be absorbed within existing departmental budgets or offset through permit fees.
ENVIRONMENTAL REVIEW
The adoption of FHSZs is exempt from environmental review as it is an administrative action mandated by state law.
CONCLUSION
To ensure compliance with state wildfire safety regulations and enhance community protection, staff recommends the following steps:
1. Receive the Fire Marshal's Report – Formal acceptance of CAL FIRE’s Fire Hazard Severity Zone (FHSZ) recommendations specific to Santee, including the official FHSZ map.
2. Open Public Comment Period – Allow community input on the proposed FHSZ designations per standard municipal procedures.
3. Provide Staff Direction – Council guidance for drafting an ordinance aligning with CAL FIRE’s hazard classifications (Moderate/High/Very High).
4. Schedule Ordinance Adoption – Upon Council direction, staff will return at a future date within the state’s 120-day window with an ordinance for first and second reading prior to adoption.
ATTACHMENTS
1. Previously adopted Santee VHFHSZ Map
2. New Santee FHSZ Map
3. CAL FIRE’s Fire Hazard Severity Zones Local Responsibility Area FAQ sheet with applicable state laws