ROPER Consulting 806 Canada St. Ojai, CA 93023 Phone: (805) 377-0493 E-Mail: [email protected] Subject: Esperanza Hills Housing Project Date: August 31, 2018 To: Board of Supervisors and Planning Commissioner (Via Email: [email protected]/ [email protected]) Dear Supervisors and Commissioners: I have been asked by Protect Our Homes and Hills to evaluate the need for a second, daily public access for the Esperanza Hills housing project. I have reviewed aerial photography of the site and surrounding areas on Google Maps and reviewed the proposed site plan for 340 residential units. This letter is in addition to my prior letter dated May 8, 2017 citing initial points to be addressed. In summary, it is my recommendation that there be two, full-time daily access points for this project. Ingress/egress issues were documented in the Orange County Fire Authority’s 2008 Freeway Complex Fire After-Action Report. Adding the proposed 340 units with associated vehicle traffic will compound the prior evacuation issues and create unacceptable risks to the public and first responders. I have been in the fire service for 40-years serving as the Ventura County Fire Chief, from 1998 to 2012, and as the Nevada State Forester, from 2015 to 2016. I was part of the team that developed California’s response to major emergencies, which included policy development at the local, State and Federal level. I also helped create the National Wildland Fire Cohesive Strategy. While serving in “all-hazard” emergency response role, I focused on the wildland fire topic. The purpose of the Environmental Impact Review (EIR) process is to present proposed projects and identify areas of concern. These areas of concern may be different interpretations of development statues, codes, ordinances and general areas of concerns identified from past projects or recent situations. We must also recognize that planning conditions may not always match the reality in the field. The proposed Esperanza Hills Housing project is located in an area that has a repetitive fire occurrence history as evidenced by the adopted Very High Fire Hazard Severity Zone maps (2012). It is not a matter of if a fire will start, it’s a matter of when. Fire history indicates a 5-10 year repetitive cycle that is primarily fueled by flashy vegetation and very strong Santa Ana winds. The site shares several borders with Chino Hills State Park, which will always be considered a 2 contiguous wildland fuel bed to the project location. The combination of fuels, winds, constrained access and population density create public safety concerns for first responders, public officials and residents. When a wildland fire occurs, the rate of spread can be extreme (Freeway Complex Fire – 2008, Canyon 2 Fire - 2017), thus causing public anxiety, property losses and safety concerns. The Freeway Complex, Canyon 1 and 2 fires clearly demonstrated a recurring situation where Santa Ana wind driven wildland fires have caused property loss and endangered both public and first responders’ safety. Because this recurring situation has demonstrated a strong proclivity to present itself in the future, public officials have the responsibility to address development impacts that are dangerous to the public and first responders. Philosophers often cite that we should learn from history and not repeat it. Let’s look at the Orange County Fire Authority’s (OCFA) 2008 Freeway Complex fire’s “After Action Review (AAR)”: www.ocfa.gov/Uploads/Transparency/OCFA-AAR-Freeway%20Complex%20Fire.pdf The Freeway Complex Fire is a great predictor of the future as it created a burn scar over the proposed Esperanza Hills project area. This OCFA report provides a succinct review of the project’s site wildland fire problem then and now. “The recommendations contained in this report were intended to help the OCFA better prepare for this type of disastrous wildland fire in the future, improve the planning/development process from lessons learned and improve local capability/surge capacity where possible.” Recently, Southern California Edison (SCE) distributed a “Wildfire Safety Program” flyer to customers who live within wildland fire areas (attached). SCE has recognized the increase in wildfire activity and is becoming a key partner for public agencies. A core question here is to have SCE identify if the Esperanza Hills project will be subject to the “Public Safety Power Shutoff” provisions? This is a program where SCE may temporary shut off the electrical grid to target areas before/during wildfire activity. Here is a listing of past wildland fire issues (AAR), sections from the submitted Environmental Impact Report and questions relative to the SCE “Wildfire Safety Program” flyer. We should ask ourselves if we allow further growth, have we truly corrected past issues and mitigated the cumulative effect of new growth? Fire Prevention: • Brush Clearance (AAR - p. 17) • Are the 170-foot clearance provision/offsets viable? • Maintenance of Defensible Space (AAR - p.18) • How do/will property owners and the Homeowner’s Association (HOA) maintain irrigated landscape (common areas) when drought conditions limit water use? 3 • Ignition Resistant Constructions (AAR - p. 19) • Are there provisions to ensure maintenance of ignition resistance construction? • Access and Water for Firefighting (AAR - p.20) • Is the current/future water system able to meet water supply demand during a wildfire? • Does the current/future water system have backup electrical power supply at each pump station? • In light of the new SCE “Public Safety Power Shutoff” program, will the water system’s backup electrical power generators have a fuel supply to run the duration of the SCE shutdown? EIR Appendix J, p.77 recognizes loss of electrical power during Freeway Fire 2008 and resulting Yorba Linda Water District water supply interruption. The Esperanza Hills Project cites that two project reservoirs will provide gravity flow in case electrical power is lost. On p.78, it cites the addition of two pump stations to refill the reservoirs. What’s unknown is at what water level will the reservoirs be maintained at? And, how quickly the reservoirs can be filled while at the same time adjusting as the demand may increase (due to exterior sprinklers, garden hoses, and hydrant use) during a wildland fire event. Loss of the water supply can affect firefighters accessing fire hydrant water, homeowners’ ability to self protect their homes and water supply for built-in interior residential fire sprinklers (required by OCFA). EIR Appendix S, Section 1.13 & 1.34 recognizes the need for backup electrical power and cites specific backup electrical power locations. A review of the project site and existing system should verify compliance or retrofit of backup electrical power. • Access (ingress & egress – public & FD dedicated access) We must recognize that evacuation-planning models are tied to fire behavior models. In the planning process, these models are static in nature and cannot recognize the dynamic nature of an actual wind driven fire. This is because wind driven fires contain numerous factors that models cannot mimic today, thus planning may not mirror reality. With the many fires seen this summer season, comments from firefighters indicate the modeling didn’t work and they have never seen fires behave this way before. Modeling can only go so far. Failure to recognize this fact can underestimate fire behavior and may compromise life safety issues. The project’s traffic study must account for residents leaving during duress and first responders gaining entry. Access roads should have preventive fuel treatments conducted/maintained on both sides to minimize fire/smoke impacts on traffic flow. Consideration should also be given to egress roads that dump onto existing public streets and whether these access points cause a “choke point.” This situation was noted during the Freeway Complex AAR, p.61. Since the roads will not be widened on Stonehaven/Via Del Agua for the development, the new residents will exacerbate the existing chokepoints in that 4 neighborhood. We also need to recognize that an electrical power grid loss (SCE Safety Shutdown or mechanical failure) may negatively affect traffic signals during evacuation efforts. Further, the referenced “emergency access easement” through the neighboring Cielo Vista project is not, to my understanding, a confirmed property right of the Esperanza Hills Developer. If legally used in an emergency, it only leads to the same choke point on Stonehaven that jammed evacuation efforts in 2008. Standard planning conditions dictate two public access points designed specifically for evacuation flows on a project of this type/size. Some fire agencies allow Fire Department (FD) restricted access points, but these restricted access points may have design flaws. The primary concern is that they require an OCFA employee to hand manipulate the access controls (gate). The drawback is that these access points may become a second thought during initial attack of a wildland fire and require special knowledge to operate, thus limiting law enforcement, medical personnel and the public access. There are work arounds (KNOX keys for police and “OPTICOM” strobe activation) to access these controls, but they must be addressed during design. There is a January 30, 2014 letter from OCFA Division Chief Kris Conception to OC Planning Kevin Canning that uses a January 31, 2014 internal memo from OCSD Lt. R. Wren addressing evacuation issues. At the conclusion of the