9222 Lake Canyon Road Santee, CA 92071 March 9, 2015 Orange County Board of Supervisors Todd Spitzer, Chairman Lisa A. Bartlett, Vice Chair Andrew Do Shawn Nelson Michelle Steel 333 W. Santa Ana Blvd, Room 465 P.O. Box 687 Santa Ana, CA 92702-0687 Via email [email protected] RE: Esperanza Hills Project (PA120037) / FEIR No. 661 Significant Adverse Impacts to Public Safety Dear Board of Supervisors, Please review these expert comments submitted on behalf of Protect Our Homes & Hills. The location and site design of the Esperanza Hills Project significantly impacts fire safety by introducing and exposing the public and firefighters to known hazards. Firefighters with adequate safety zones can defend structures threatened by wildlfire under certain conditions, however both the availability of firefighting resources and the location of adequate safety zones are in question for Esperanza Hills during major incidents in Southern California. The hazards are amplified by the high probability that the project cannot be evacuated prior to Santa Ana wind driven fire fronts that reach the site. Furthermore, attempts to evacuate the project will significantly impact the ability of older existing structures in the vicinity to be evacuated. The National Wildfire Coordinating Group “Incident Response Pocket Guide” (IRPG)1 is the standard for fighting wildland and wildland-urban-interface fires. Dispatching firefighters to fight wildland fires on and adjacent to the Esperanza Hills Project will place firefighters in situations where they will be required to either ignore the standards of the IRPG or abandon suppression tactics on site. 1 National Wildfire Coordinating Group “Incident Response Pocket Guide”, PMS 461, NFES 001077, January 2014, p.13. Safety Zones2 Esperanza Hills has not built adequate evacuation routes and safety zones into the project. A safety zone is an area where a firefighter can survive the threat of radiant and/or convective heat without a fire shelter. Separation between flames and the firefighter should be a minimum of four times flame height assuming there is no wind or slope that requires increased distance. For example, a 50 ft.3 flame height requires 200 ft. of separation on all sides, 3 acres for a 3-person engine crew. Hills and other topography, such as that at Esperanza have potential to channel convective heat that increases distances required to avoid injury. The IRPG states: “Structure protection is inherently dangerous because it involves indirect firefighting. Do not commit to stay and protect a structure unless a safety zone for firefighters and equipment has been identified at the structure during size-up and triage. Move to the nearest safety zone, let the fire front pass, and return as soon as conditions allow.4 Standard Operating Procedures for the Novato Fire Protection District confirm the IRPG: “Structure Protection Plans must be based on: … The ability of the crew and engine to safely survive the passage of the flame front without taking refuge in the engine, structure or deploying a fire shelter… Engines, structures and bodies of water should be considered last resort survival options not Safety Zones.”5 Esperanza Hills has not built adequate safety zones into site design of the Esperanza Hills project. Nowhere in the Esperanza Hills FPEP are there safety zones identified that match potential radiant and convective heat exposures. Exasperating this failure are circulation routes that are vulnerable to deadly radiant heat exposure and a certainty for producing gridlock during 2 Ibid., IRPG, p. 8. Note also that fires exceeding four feet flames are too intense for direct attack with hand tools. Control efforts at the head of fires are probably ineffective for fires with flame length exceeding eight feet. Control efforts are ineffective at the head of fires with flame lengths exceeding 11 feet. p. 69. 3 The Esperanza Hills Fire Protection And Emergency Evacuation Plan estimates flame lengths of approximately 41 feet for heavier fuels presently on site during Fall conditions. RTC acknowledges that at heavier fuel loads flame lengths “may exceed 50 feet”. Prior to the next fire, those fuel loads can be expected to grow over time potentially increasing the actual flame lengths generated. See Figures 7, 8 & 9 FlameMap, p. 45-49 and p. 40, Esperanza Hills FPP (Appendix J). 4 IRPG, p. 12. 5 Novato Fire Protection District Wildland Structure Protection Standard Operating Procedure, page 74-76. 2 evacuation exercises in those exposure areas.6 Evacuation of just the Esperanza Project was estimated to take 90 minutes to 2.5 hours.7 In these conditions, the Esperanza Hills Project would utilize the structure that firefighting SOPs designate as a last resort survival option – not a safety-zone, and make it the primary (if not the only) survival option. This is reckless public policy in an area designated as a Very High Fire Hazard Severity Zone. Note also, that the IRPG identifies property owners who remain on-site as a hazard and technical challenge for defending structures. And “no structure in the path of a wildfire is completely without need of protection.”8 Structures burn at a higher intensity than wildland fuels. If just a single structure ignites, it has a significant potential to ignite an adjacent structure (especially for structures sited within thirty feet) and then fuel cluster burns of the residential area. The Esperanza Hills Fire Protection And Emergency Evacuation Plan (EHFPEP) acknowledges the need for a Community Evacuation Plan, but punts that critical task into the future (“prior to occupancy”).9 “The CEP will form the backbone of hazard relocation/evacuation planning for the Esperanza Hills community.” Both “procedures for early evacuation and on-site refuge” are deferred. “CEP will include provisions for: … Wildfire Emergency Evacuation Plan Details. Onsite partial Relocation vs. Off-site Evacuation.”10 The plan (assuming that one is actually completed) is simply not capable of reversing the site design errors built into project approval. Therefore, the CEP for Esperanza needs to be prepared prior to project approval and be integrated consistent with site design. Failure to do so is a significant adverse impact upon public and firefighter safety. The Esperanza Hills FPEP is fatally flawed by an untenable assumption for the project site “that the wildfire evacuation triggers in Orange County during a wildfire are conservative in nature and would typically enable evacuation of threatened areas well before a fire encroaches.”11 There is not any substantial evidence presented to support this assumption – such as demonstrating the distance of the project site from the most likely origination points and calculating the potential 6 Esperanza Hills Fire Protection And Emergency Evacuation Plan (Appendix J) states: “Roadside fuel modification zones will be 10-20 feet wide” p. 54. While radiant heat will be reduced (not eliminated) in this area, anyone in traffic gridlock will be exposed to deadly radiant heat at combustion during Santa Ana wind driven firestorms because a minimum of 4 times flame length separation is required to avoid exposure to deadly radiant heat. Convective heat produced by topographic features further increases the distances needed from combustion. 7 Esperanza Hills Final EIR Responses to Comments, November 2014, page 31. 8 IRPG p. 13-14. 9 Esperanza Hills Fire Protection And Emergency Evacuation Plan (Appendix J), p. 79. 10 Ibid., p 80. 11 Ibid., p 81. 3 rates of spread from those points to the project site contrasted with the time it takes to evacuate the project and its affected vicinity. An analysis would reveal the opposite, that in fact, safe evacuation of the site is not feasible for Santa Ana wind driven firestorms from many likely ignition points (Amended Figure 19: Ignition Points & Distance to the Esperanza Hills Project Site with Estimated Times of Arrival). Nor is it sufficient for the EHFPEP to assume the Estimated Time of Arrival for the Freeway Complex Fire could not be significantly reduced for other fires by changed variables associated with more northeasterly points of origin.12 It is possible, in fact probable, for an evacuation order to be released to the public when it appears to be safe, but during the 90-minute to 2.5 hours estimated to evacuate the project there is acceleration in rate-of-spread and change of direction in the fire front that severely impacts evacuation routes. There are sections of Highway 71 adjacent to natural open space within Chino Hills State Park that are less than five miles from the project site. Wildfires are often started adjacent to highways. It is conceivable that a wind-driven fire originating from Highway 71 could reach the project faster than the Freeway Complex Fire advanced to the project site and vicinity in 2008. A worst ignition point at Highway 71, under worst weather conditions, could bring the fire front to the project site in just over 20- minutes.13 Under similar scenarios there would not be any time to evacuate the project and evacuation orders that appeared to be safe when issued could result in fatalities along evacuation route pinch points from radiant heat. 12 The Freeway Complex Fire had winds reported over 40 mph with gust exceeding 50 mph. The ignition point was also East Southeast of the Esperanza site, which contributed to a longer arrival time to the project site than might be expected from fires directly propelled by Santa Ana winds with continuous fuel. Santa Ana winds are becoming more energized and extreme at unusual times of the year, which has extended the fire season to nearly year round. For instance, in April 2014 Santa Ana winds were experienced Southern California with winds exceeding 100 mph in the mountains and exceeding 70 mph in the inland valleys. If these highly charged Santa Ana wind systems become more frequent or common at the project site, fire arrival times would become more rapid from likely ignition points and time for evacuation would be significantly reduced.