From: Dave Mcneil <[email protected]> Sent
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From: Dave McNeil <[email protected]> Sent: Friday, July 10, 2020 12:21 PM To: Chris Jacobs Subject: Submittal of comments on Fanita Draft Revised EIR Attachments: Fanita RDEIR David McNeil FB 07132020.pdf Mr. Jacobs: Attached are my comments on the above referenced document. Respectfully, David McNeil 1 POB 513 Gardnerville, NV 89410 July 13, 2020 Mr. Chris Jacobs, Principal Planner Department of Development Services Santee City Hall, Building 4 10601 Magnolia Avenue Santee, CA 92071 Email: [email protected] Subject: Fanita Ranch Revised Draft Environmental Impact Report “RDEIR” Dear Mr. Jacobs, These comments focus upon fire safety associated with the Fanita Ranch Revised DEIR and supplement my comments dated June 15, 2009 on the 2007 Fire Protection Plan (FPP 2007). Comments are limited to my areas of expertise in fire and land use development permitting review. All points in my 2009 letter remain relevant to the current project proposal. As disclosed by the RDEIR, the project site is located within a Very High Fire Hazard Severity Zone and is subject to severe wildland fire behavior. Fuels include FM4 chaparral, which would surround the island of development on the northeast portion of the property and its ingress/egress routes. FM4 chaparral burns at high intensity even under moderate weather conditions. These conditions would place the public and firefighters at high risk. While all of Fanita is subject to high intensity burns, the northern portion of the site has the greatest alignment with regional open space and the Santa Ana wind-driven fire corridor. Therefore, alternatives to the project that eliminate, relocate, or consolidate development to the existing wildland urban interface should be a high priority to avoid significant adverse safety impacts. Public Safety Power Shutoff (PSPS) programs have been implemented by California electric utilities in recent years as extreme fire conditions and power line failures have resulted in increasingly devastating wildfires across California.1 In 2019, PSPS actions occurred across the state, including affected areas of Poway and Ramona.2 If an ignition occurs during a PSPS that affects the project site, any portions of the site that require pumping for adequate water pressure would be adversely impacted. This is a significant impact that could disrupt the ability to fight a wildfire. The RDEIR has not disclosed and adequately considered the impacts of fires impacting the site during PSPS events authorized by the California Public Utilities Code Sections 451 and 399.2(a). 1 https://www.cpuc.ca.gov/deenergization/ 2 https://www.cpuc.ca.gov/uploadedFiles/CPUCWebsite/Content/News_Room/New sUpdates/2019/Nov.%2015%202019%20SDGE%20ESRB- 8%20Report%20for%20Oct.%2020-Nov.%201%202019.pdf The RDEIR indicates that 21 lots in a portion of the northeast “Vineyard Village” are subject to inadequate pressure without private pumps, but has not considered the issue in the context of fire during a PSPS. Will there be back-up power sources for any and all of the pumps required to serve the project? If so what are their sources of power? (RDEIR, Table 7, p. 3-60) Some of the Fuel Management Zones are extreme in relation to the 100 feet of defensible space standard. Expansive FMZs will be counterproductive when wind-driven embers or other sparks meet invasive fuels with lower ignition points than more ignition resistant shrubs. Invasive annual grasses that create a more flammable landscape increase the potential for erosion and impacts to wildlife. The shear size of the FMZs introduces a management burden that is impractical and unlikely to be kept to standard over time. And the FMZs would do little to diminish ember storms originating from adjacent vegetation and beyond. In contrast to FPP 2007, FPP 2020 chose input variables to reduce the BehavePlus modeling flame height calculations down from 95 feet to 66 feet. Considering that extremes are becoming the new normal, it would have been more appropriate to adjust the variables in the opposite direction. For instance, BehavePlus inputs for the same FM4 chaparral fuel model could be adjusted to generate flame lengths over 140 feet. Even FPP 2007 acknowledged flame heights could be generated in excess of 100 feet. Adjusting variable inputs may psychologically boost the land entitlement process, but it will not change the public safety threat represented by the actual fuel, topography and increasing frequency of hazardous fire weather conditions within the region brought about by climate change. Steep drainages with burning chaparral will funnel heat through the topographic chimneys to the homes above/windward. Homes and roads located on ridge top saddles will receive the brunt of the energy discharged as the wind is squeezed and accelerated by the topography. Locating homes in these locations is negligent. Late evacuation over a ridge top road through a saddle with fire below would be deadly. The tendency is for the public to wait as long as possible before evacuating. Hope and denial can outweigh observable facts and lead to paralysis. Authorities recognize this problem. In the deadly Tubbs and Camp Fires, which occurred in Northern California in 2017 and 2018, respectively, authorities did not issue evacuation orders in some areas out of fear that it was too late. In the Camp Fire specifically, a perishing resident didn’t evacuate with her surviving daughter precisely because an evacuation advisory was not issued to her or received by the time the daughter felt she must make a decision. The complicating factors of human psychology and challenges of communication merged into confusion and tragedy. Exercising responsible land use at the planning stage can avoid similar scenarios. The geography of “Vineyard Village” assures that authorities and residents alike must be able to make this same calculation and reach the correct conclusions. There is a long and growing list of public and firefighter fatalities that prove theoretical paper decisions are much more difficult in practice. 2 A calculation to shelter or evacuate is complicated by variables beyond residents’ ability to resolve prior to an event. The density of the development has designed overlapping Home Ignition Zones that make a cluster burn likely if one or more homes ignite due to human error (open window) or intense convective activity (a fire whirl or tornado). Residents that stay are placing a bet that thousands of their neighbors have not made an error that will impact them or that severe weather will not breach their shelters. The applicant has carried forward this flaw from 2007 and has now doubled-down on it. FPP 2020 fails to consider how evacuation of the project significantly impacts the feasibility of evacuating the established WUI with less fire resistant older homes. Virtually all of the homes on the existing WUI are highly susceptible to embers. Many homes would need to be evacuated as occurred during the Cedar Fire. A shift in wind direction that put these homes on the head of a wind-driven fire rather than the flank would result in lost structures when embers penetrate attic vents. The lack of analysis is not surprising considering the mixed and confusing message of the FPP with regard to shelter-or-evacuate decisions. What are the time estimates for evacuating the project independently? What are the time estimates for evacuation when adding in zones of the established WUI under various scenarios? For instance, what is the scenario for an ignition from SR-67 and points east of San Vicente Reservoir? The Revised DEIR fails to consider the significant impact on the established WUI of abandoning the fuel load management prescribed in the 2007 FPP. Mitigation to harden the established WUI to ember intrusion should be required. Without fuel load management, fuel loads will grow more hazardous and the significant impact of eliminating backfiring operations at the existing WUI as a suppression tactic becomes more significant. Timing is critical for success and firefighters must know that their firing tactic will not put others at risk. It is not feasible to backfire over routes potentially in use for late evacuation or the developed areas the routes are connected to. Fuel loads will grow, but a tool to eliminate the hazard during an actual incident has been removed by the site plan. Mitigation to harden the established WUI to ember intrusion should be required for this significant impact as well. Inability to reduce embers and manage the intensity of the main fire front with a properly timed backfire puts the established WUI at higher risk of loss of life and property. The “Evacuation Plan” is simplistic and lacks detail. The document states: “The decision on whether to evacuate or shelter-in-place is carefully considered with the timing and nature of the incident (San Diego County 2014). Sheltering-in-place is the preferred method of protection for people that are not directly impacted or in the direct path of a hazard.” (p. 18) 3 However, the document does not “carefully” plan evacuations for: • Various ignition points • Multiple weather condition scenarios • Onshore versus offshore wind-driven fires • Periods when school buildings are occupied during the day or after hours by the community • AM and PM commute hours and traffic gridlock • Evacuation phases for different portions of the project • Evacuation phases for different portions of the established WUI offsite • Multiple simultaneous incidents throughout Southern California • Cluster burns of structures • Residents “in the direct path of a hazard.” • Specific safety zones and feasibility of specific escape routes to these zones • Specific “predesignated temporary refuge areas” The Evacuation Plan document is a plan in name only. It is a “plan” without a plan in that it only offers very general suggestions on how to manage home evacuations from the project site and ignores the established WUI.