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December 12, 2015 Mr. Michael
Coyne City of Santee 10601
Magnolia Avenue Santee, CA 92071
[email protected] RE: Cheyenne
Project Recirculated Draft EIR
(RDEIR), SCH #2005071037 Dear
Mr. Coyne, We encourage
selection of the No Project
Alternative. Should the city council
approve a project alternative, the
Jurisdictional Drainage Avoidance
Alternative is significantly superior
to the project. We encourage
the city staff report to adopt
this No Project position for
the following reasons. Significant
Adverse Impacts The Cheyenne
Project RDEIR underestimates significant
impacts, does not disclose, avoid
or adequately mitigate for
significant adverse impacts of the
project. Aesthetic impacts,
biological impacts, public safety
impacts and water supply impacts
are significant. The project’s
GHG emissions are significant and
there are not conditions attached
to the project to avoid or
mitigate the impacts. How much
energy will the project consume?
How much GHGs will be emitted
and why isn’t the installation
of solar panels and Level 2
electrical vehicle chargers, which
must be considered feasible in
2015, a condition of project
approval? Our July 22, 2005
scope letter emphasized the
importance of including solar
systems. Why aren’t rainwater
capture and grey-‐water systems
conditions of project approval?
Without fully offsetting the
project’s energy consumption with
solar power, the GHG emissions
are a cumulatively significant
adverse impact to climate.
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All GHG impacts, aesthetic impacts,
water supply impacts, biological
impacts and public safety impacts
should be disclosed and avoided
when feasible and fully mitigated
when not feasible.
Significant Adverse Biological Impacts
The project would impact 34.4
acres (RDEIR 4-‐65) of occupied
Diegan coastal sage scrub (CSS).
CSS is required to be avoided
because Santee has exceeded its
5% “4d interim take allowance”
of CSS when it approved the
Sky Ranch Project in 2006. No
additional CSS can be impacted
until Santee completes its MSCP
Subarea Plan. Santee first
promised to finish its MSCP
Subarea Plan in the 1990s and
then again promised to complete
it consistent with the approval
of the General Plan Update in
2003 and did not. There has
not been any meaningful progress
– the “process” has been long
stalled for years without the
draft plan ever going through
the CEQA process. Meanwhile
projects impacting natural sites are
repeatedly approved that foreclose
conservation options under the guise
of consistency with a non-‐existent
plan in permanent draft form.
Our July 22, 2005 scope letter
stressed the importance of
consistency with a “FINAL MSCP
subarea Plan.” Under the present
circumstance, all impacts to species
and species natural habitats are
significant and require analysis,
disclosure, avoidance when feasible
and adequate mitigation otherwise.
Again, no additional take of
CSS can be authorized under the
present circumstances. The proposed
project inappropriately impacts endangered
species habitat and forecloses the
habitats’ potential conservation within
the Santee MSCP Subarea Plan
preserve system. Although the project
alleges consistency with a draft
plan, it is not consistent with
prior draft plans that planned
100% and 90% conservation of
the site. The prior plans for
the site are those that can
reasonably be expected to pass
scrutiny of the CEQA process.
The present draft has significantly
eroded original conservation targets
and dodged vetting by the CEQA
process. The project would
impact two of the three Coastal
California Gnatcatcher (CAGN) sites.
It is feasible to avoid CAGN
as demonstrated by the Jurisdictional
Drainage Avoidance Alternative, thus
avoidance is required. Edge effects
have substantially reduced the on
site population already. Further
disruption is likely to eliminate
CAGN from the site.
Significant impacts to suitable
habitat for San Diego thornmint,
San Diego barrel cactus, Quino
checkerspot butterfly, and Hermes
copper butterfly should all be
avoided.
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Significant Adverse Aesthetic Impacts
The RDEIR acknowledges General Plan
Policies intended to protect
significant natural views on the
site, but errantly concludes that
the extreme amount of cut and
fill and blasting proposed does
not significantly impact aesthetics.
The views of the site are
prominent throughout most of the
city and beyond as part of
a regionally significant block of
intact landscape that creates value
and a sense of place. These
views establish the scenic northern
boundary of the city. Furthermore
the views are prominent from
two scenic highway eligible freeways,
SR-‐125 and SR-‐52. The photos
and photo-‐simulations in the RDEIR
are not representative and misleading
with regard to the significance
of the visual impacts. The
landscape simulation intended to
camouflage the project that is
depicted in Figures 4.93-‐495 is
at a density that is not
realistic. Landscaping at the density
simulated would violate the
specifications of the Fire Protection
Plan and likely guarantee loss
of structures during a Santa
Ana wind driven firestorm. Thus,
the RDEIR is not disclosing the
true impacts in either aesthetics
or wildland fire risk, or both.
Furthermore, the plants depicted may
include invasive non-‐native species
with significant adverse impacts to
adjacent biological habitat.
Significant Adverse Impacts to Public
Safety According to third
party review of the blasting
plan, “no guarantee can be
given that rock fall will not
occur.” [Padre Dam Engineering Memo
and Geocon]. This leaves residents
below blasting operations at
significant risk. The blasting
plan makes adjustments for lightning
activity, but does not include
any shutdown for Santa Ana
winds or other low humidity
conditions to reduce the risk
of igniting catastrophic wildland
fires in a Very High Fire
Hazard Severity Zone (VHFHSZ).
Operations should be halted during
Santa Ana wind conditions and
during onshore winds above 10
mph under drought conditions.
The Fire Protection Plan (FPP)
is not sufficient to reduce
hazards from wildland fire to a
level of insignificance. The project
would expose people and structures
to a significant risk of loss,
injury, or death involving wildland
fires. The project proposes to
completely embed 26 homes within
heavy wildland fuels located in
a northeast oriented canyon drainage
capable of funneling Sana Ana
winds. Another 13 homes would
be located on steep slopes
largely surrounded by wildland fuels
in the southern portion of the
site. The FPP disclaimer
acknowledges, “It must be noted
that during extreme fire conditions,
there are no guarantees that a
given structure will not burn.”
(FPP page 25)
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The northern bubble of development
does not have secondary access.
A fire carried from the
southwest up-‐canyon by an onshore
flow would move upslope toward
the development cutting off the
single evacuation route. The
“secondary/emergency access” that leads
up to the water tower is
completely impractical as an escape
or evacuation route due to
direct flame impingement, radiant and
convective heat that would be
transferred onto the road. Fuel
modification zones modeled by the
FPP generate 22 feet flames.
Natural fuels were modeled at
45 feet flame lengths. A factor
of 4x flame length (Butler
& Cohen) is needed to
provide a safe distance from
radiant heat, but is not enough
distance to assure safety from
convective heat transfers. Street
widths are 24 to 36 feet
in the north and as narrow
as 16 feet in the south
plus “10 feet of clearance on
either side of each fire
apparatus access road and driveways.”
Cedar Fire victim perished in
area of wide clearance.
In the onshore wind fire
scenario, a cluster-‐burn of
structures originating at a
“non-‐conforming” lot has the
potential to result in lives
and property lost at all 26
homes. The FPP fails to analyze
and disclose this risk. Nor
does the FPP discuss emergency
preparedness for residents or provide
any guidance as to whether
residents would be expected to
“shelter-‐in-‐place.” The FPP fails
to provide guidance to residents
in the absence of direction
from emergency responders that may
be unavailable due to multiple
simultaneous incidents. The installation
of sprinklers in all 26
structures and attic sprinklers in
2 structures with “non-‐conforming”
lots is important, but is not
enough to reduce risk to a
level of insignificance. 1
1 Lots 17 and 26 have
only 65 feet fuel modification
zones instead of the 100 feet
zones at other lots. Since 100
feet is “not achievable,” why
aren’t these two lots just
eliminated from the project to
avoid the significant risk they
add to the entire island bubble
of 26 structures? Why aren’t
attic sprinklers included in the
24 “conforming” lots? Other FPPs
acknowledge the weakness of attics
without
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An evacuation executed during a
Santa Ana wind driven firestorm
would have to be carefully
timed without error because the
single access route to Princess
Joann Road would still be
exposed to lethal levels of
radiant heat during the passage
of the fire front. The
significant fire risk at the
northern development bubble in heavy
fuels can be avoided by
selecting the Jurisdictional Drainage
Avoidance Alternative.
Radiant and Convective Heat Can
Rapidly Sever Exit Routes -
2007 Wildfire The FPP does
not analyze or disclose the
cumulatively significant amount of
wild-‐land-‐interface that the project
adds to the city’s total
burden. Santee had 13 miles of
WUI with development generally
consolidated lower in the San
Diego River Valley that allowed
most of the homes to survive
largely without fire response during
the
sprinklers. “Interior
sprinklers may also protect a
structure if a wildland fire
enters the structure through a
window or door. They will not
protect against a fire in the
attic unless attic sprinklers are
installed as part of the system
design.” [Otay Ranch FPP, page
45, bold emphasis added]
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2003 Cedar Fire. The Rattlesnake
Mountain/Sky Ranch development added
5 miles of WUI to that
total. How much WUI would be
added by Cheyenne? How much WUI
does the city fire department
consider it can defend without
adding additional brush engines and
other wildland suppression resources?
The addition of WUI by the
Cheyenne project is a significant
adverse impact. The FPP dos
not consider or disclose the
significant adverse impact to
wildland fire suppression tactics
created by locating an island
bubble of development northeast of
an existing WUI suppression anchor
point. The island makes it
infeasible to backfire from the
existing anchor point to defend
the homes at the existing WUI
from a Santa Ana wind driven
firestorm. It would violate
backfiring safety guidelines to
ignite a backfire that would
burn over the only evacuation
route and the island of
development itself and merge with
the Santa Ana wind driven flame
front. The southern 13-‐unit
development peninsula creates a
similar adverse impact for the
existing WUI at the western
base of the mountain because
the slope and ridge development
would also be in the path
of the backfire. Introduction
of the 13-‐unit peninsula of
development on a steep slope
and ridge in a VHFHSZ is
a significant adverse impact.
The FPP underestimates fire intensity
for worst-‐case scenario fires. Fuel
models useful for determining fire
intensity and flame length in
fuel modification zones under
moderate conditions can underestimate
fire intensity and flame lengths
during extended drought and extreme
weather conditions. The FPP
acknowledges that the Scott and
Burgun 2005 fuel models used
attempt to improve accuracy “outside
of severe fire season conditions”
(FPP D-‐2). The FPP should also
run the original fuel models to
gain better insight into how
natural fuels (especially outside of
the fuel modification zone) will
burn under severe fire season
conditions when fuels tend to
behave more homogenously. The
original 13 fire behavior fuel
models are “for the severe
period of the fire season when
wildfires pose greater control
problems” (Anderson 1982).2 For
example, a duplication of the
“97th percentile” inputs (FPP D-‐2)
with substitution of Fuel Model
4 Brush (consistent with habitat
at Cheyenne north) and no slope
would produce 65 feet flame
lengths (BehavePlus 5.0.5). That is
flame lengths 20 feet greater
than expected with SCAL 18, and
equal to the length of the
entire fuel modification zone for
the “non-‐conforming” lots. Utilizing
the same FM 4
2 USDA Forest Service Gen.
Tech. Rep. RMRS-‐GTR-‐153.2005. Joe
H. Scott & Robert E.
Burgan.
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inputs and doubling the midflame
wind speed to 36 mph produces
a flame length of 101.9 feet.3
Wind speeds can make a dramatic
difference in fire intensity.
Cluster burn on Grass Valley
Fire, 2007. Photo by Don
Kelsen, LA Times Significant
Risk of Cluster Burns is a
Significant Adverse Impact to those
that Cannot Evacuate “This
significant reduction in fire
intensity does not mitigate the
effect of flying embers, which
may travel a mile or more
during wind driven fires.” [
Otay Ranch FPP, page 18]
FPP acknowledges that control efforts
at the fire head are probably
ineffective for fires with flame
lengths ranging from 8-‐11 feet
and that for flame lengths over
11 feet “control efforts at the
head of the fire are
ineffective.” (FPP Table 2, D-‐6)
The EIR further acknowledges that
flame lengths for both Summer
and Fall fires are expected to
exceed eleven feet. Therefore, fires
that ignite under extreme weather
conditions are likely to spread
rapidly and consume all continuous
fuels in the path of the
fire head. Under firestorm
conditions, it is probable that
people and
3 Rate of
spread would increase to 2133.7
ch/h (26.67 mph) from 3.43 mph.
1 chain per hour = .0125
mph. 1 chain = 66 feet. 1
mile = 80 chains or 5,280
feet.
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structures in the vicinity of the
wildland interface will face a
significant threat of loss, injury
or death (especially at the
fire head). It is also
important to recognize that
standardized fuel modification zones
generally sufficient to prevent
structure ignition from direct flame
impingement does not assure survival
of the associated structures.4 Even
though 189 structures were destroyed
(with another 129 damaged) in
the Freeway Complex Fire, the
Orange County Fire Authority (OCFA)
considered “…brush clearance to be
adequate” based upon its inspections
of fuel management zones prior
to the fire.5 Wind driven
embers are capable of penetrating
the smallest of openings6 on
structures and can ignite spot
fires adjacent to structures in
ignitable materials that can then
damage or
4 "Fire
officials believe that embers driven
by raging winds through small
openings or against exposed wood
were responsible for igniting a
majority of the 1,125 homes
leveled by the Witch fire, the
most destructive in California this
year…An analysis of the Witch
fire's pattern of destruction points
to deficiencies in long-‐-‐-‐held
beliefs about building in
fire-‐-‐-‐prone areas. Fire-‐-‐-‐resistant
walls and roofs are helpful,
and brush clearance is essential.
But alone they are insufficient
in the face of millions of
burning embers flying horizontally
more than a mile ahead of
the flames. Of 497 structures
that burned in unincorporated areas
of San Diego County during the
Witch fire, more than half had
fire-‐-‐-‐ resistant walls and roofs,
a Times analysis of government
data showed. Information on
construction materials has not been
compiled for neighborhoods inside
the cities of San Diego and
Poway, but senior fire officials
estimate that well over 75% of
the destroyed homes had
fire-‐-‐-‐resistant exteriors.” “Lessons
From the Fire” Joe Mozingo, Ted
Rohrlich and Rong-‐-‐-‐gong Lin li,
Los Angeles Times, December 23,
2007. 5 “In 2008, staff
inspected 587 WUI parcels and
found only 16 out of compliance
with minimum requirements for
defensible space. By July 22,
all properties were in compliance.
In addition, staff inspected
approximately 790 of some 950
fuel modification parcels to ensure
that they were in “substantial
compliance” with provisions of the
requirements and found 322 in
need of some type of corrective
action. As of the date of
the fire, all but 25 had
met minimum requirements. A
preliminary assessment of homes
destroyed or damaged in the
freeway fire indicates that they
were victim to ember intrusion
rather than direct flame impingement
indicating brush clearance was
adequate.” Freeway Complex Preliminary
Report to City of Yorba Linda,
Orange County Fire Authority (OCFA),
December 2, 2008, page 6. 6
Research data has been gathered
regarding the ineffectiveness of
current ventilation standards for
preventing ember penetration. BFRL/NIST
researchers tested ¼-‐-‐-‐inch or 6
mm (the recently adopted California
WUI standard) 3 mm and 1.5
mm screens. “For all screen
sizes tested, the firebrands were
observed to penetrate the screen
and produce a self-‐-‐-‐sustaining
smoldering ignition inside the paper
beds inside the structure.” Samuel
L. Manzello, John R Shields,
and Jiann C.
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ignite structures.7 Severe convective
heat transfers through fire
whirls/tornadoes can also bypass
standard brush management zones.
“Extreme Wildfires can produce firebrand
spot---ignitions at distances of a
mile or more; however intense
firebrand exposures within one--half to
one-quarter mile often ignite
numerous surface fires within a
residential area that spread to
contact and ignite homes and/or
firebrands directly ignite homes.”
US Forest Service Fire Scientist
Jack Cohen, 4/23/2009
Homes with standard brush
management zones still have the
following significant vulnerabilities:
Homes with standard brush management
zones still have the following
significant vulnerabilities: -‐
Vulnerability of structures to
embers/firebrands due to extreme
events, human error, or inadequate
maintenance (i.e., fire tornados or
fire whirls,8 broken windows
Yang, On the Use of
a Firebrand Generator to Investigate
the Ignition of Structures in
Wildland-‐-‐-‐Urban Interface (WUI) Fires,
Building and Fire Research
Laboratory (BFRL), National Institute
of Standards and Technology (NIST),
2007, p. 11. 7 The Fanita
Ranch Fire Protection Plan
acknowledged, “The Santa Ana winds
with wind gusts of up to
60 mph blowing from the
northeast/east pose significant threat
from wind-‐-‐-‐blown embers to all
structures within this project.” Page
14. 8 “Observed fire whirl
behavior was both unexpected and
extreme in these fires, catching
many firefighters by surprise and
significantly contributing to spotting
up to 3/4 mile. 180-‐-‐-‐degree
wind shifts proceeded fire whirls
by 45 seconds to a minute.”
[Firefighter] “Respondents reported unusual
numbers of fire whirls that
ranged from several yards wide
up to a 1/2 mile wide.
Destructive fire whirls, those
causing structural damage unrelated
to fire, also were reported. In
addition to appearing suddenly, large
fire whirls, characterized by a
jet engine noise, took in
debris such as large tumbleweeds
and bushes from the bottom and
ejected flaming debris from top—
raining embers and violently
showering sparks as much as 3/4
of a mile beyond the head
of the fire. In one reported
case, a fire whirl entered an
area that had already burned
clean down to three-‐-‐-‐inch stubble
and whirled across several hundred
feet of burned area into
unburned fuel, carrying fire the
whole way and igniting the
unburned fuel. Another fire
whirl crossed an eight-‐-‐-‐lane
freeway. Small fire whirls merged
into larger ones. Some reported
fire whirls moving downhill.” “What
we were expecting to see were
fire whirls (4' to 6' tall),
what we actually saw were true
fire tornadoes. The fire researchers
kept telling us what we were
seeing was impossible and never
seen before. After three days
of discussion, the fire researchers
started to understand that what
they were expecting and what
was happening was not jiving.
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from flying debris, drapes left
over windows, open windows, open
doors and garage doors, settlement
cracks of structures built in
landslide areas, wood piles, gas
barbeques and motor-‐-‐-‐homes and
other flammables stored too close
to structures, delinquent or
inadequate fuel treatments).
Wind-blown embers
-‐ Vulnerability of adjacent homes
and the entire development from
flame impingement and radiant heat
once one or more homes are
ignited from embers/extreme events or
human error. There remains
significant fire risk of structures
within 30-‐feet of each other
to cluster burn (especially those
with north to east wildland
interfaces).9
“”Division Supervisor” Southern
California Firestorm 2003 Report for the Wildland Fire
Lessons Learned Center, Mission Centered
Solutions, December 8, 2003, page
6. 9 “As a type of
fuel, involved structures emanated
intense radiant heat. Heat levels
in the street were unusually
high.” Southern California Firestorm 2003 Report for
the Wildland Fire Lessons Learned Center, Mission
Centered Solutions, December 8, 2003,
page 7.
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Attic vents are vulnerable to
embers within a fire tornado.
Cluster burn example from
2003 Cedar fire. Photo by John
Gibbins, SDUT.
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-‐ Vulnerability of people outside
of structures to flame impingement,
radiant heat and smoke. (Individuals
on foot, on motorized and
un-‐-‐-‐motorized vehicles, hikers and
other individuals in natural lands,
individuals attempting to evacuate or
reach and secure their homes,
or individuals simply locked out
of vacant structures because they
reside in another neighborhood or
are children without keys;
individuals at inadequate fuel
buffers on sloped sections of
emergency access routes; firefighters
defending structures without adequate
safety zones or escape routes).
-‐ Vulnerability of elderly
and weak individuals within
structures to smoke, stress, or
loss of power.
Cluster burn - San Diego
County 2007
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The project site is susceptible
to cluster burns and the
evacuation route is subject to
lethal levels of radiant heat.
Clearly from a fire safety
prospective, introducing residential
development into this VHFHSZ is
ill advised and creates a
significant adverse impact. The
project should be abandoned or
at a minimum consolidated and
reconfigured for more effective Santa
Ana firestorm defense.
Rudy Reyes was severely burned
attempting to evacuate from the
Cedar fire in 2003.
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Significant Adverse Impacts to
Firefighter Safety Evacuation can
be treacherous even without
gridlocked streets based upon when
the order is given, visibility,
the fires direction and rate of
spread, distance from fuel loads,
etc. and the timing of the
decisions made to evacuate by
people and authorities. Lingering
residents located in topography that
has higher risk can place
firefighters in greater danger should
they get in trouble and seek
help. Fire authorities cannot force
individuals to evacuate,10 which can
put firefighters in greater jeopardy
if lingering residents find
themselves in trouble and request
emergency assistance.
“Wildland urban interface fires present
many challenges pertaining to
evacuation. The fire spread rate
is often so fast that
emergency responders can only estimate
the rate of spread and
direction of travel. In this
case, within minutes of the
fire start, spotting was reported
one mile down---wind from the
head of the fire. Driven by
winds of 40 MPH
10 Under certain circumstances
evacuation may pose the greatest
risk.
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and higher the rate of spread
went from the usual estimate of
acres per hour in a non
wind driven fire to acres per
minute.”11
“… law enforcement does not
have the legal authority to
force residents out of their
homes; however, law enforcement may
restrict the return of residents
once they leave. Determining where
and when to evacuate is often
difficult. Each decision brings with
it a new set of risks and
benefits. The greatest risk by
permitting residents to remain with
their homes is the potential
for loss of life.”12 “The
Tea Fire in Montecito resulted
in more than two dozen civilian
injuries, two of which were
critical burns received while trying
to flee their residence. In
2006, in Cabazon, the Esperanza
Fire resulted in four firefighter
fatalities that occurred during
structure protection efforts. The
Cedar Fire that occurred in San
Diego County in 2003 resulted
in the death of fourteen
civilians and a firefighter all
while trying to flee or protect
homes. Investigation into the citizen
deaths and injuries identified
one commonality: they all occurred
because people decided to stay and
protect their property or they
evacuated too late and got
caught in the fire front.”
When land use decisions can
site development away from
high-‐-‐-‐risk topography, (whether its
fire, flood or landslide zones)
what circumstances justify placing
people and firefighters at greater
risk of severe and life
threatening injuries? The geography
of the project site and
vicinity argues for avoidance. The
decision to build in multiple
bubbles of development intermixed
with wildlands maximizes edge and
the hazards to firefighters.
Firefighter fatality reports conclude
that decisions to defend vulnerable
structures located on high-‐-‐-‐risk
topography were a primary factor
in the fatalities of the
Esperanza Fire and the Cedar
Fire. The loss of a
19-‐-‐-‐person Granite Mountain crew
in Arizona occurred when they
were traveling though unburned fuel
toward threatened structures at the
town of Yarnell.13
11 Freeway Complex Preliminary
Report to City of Yorba Linda,
Orange County Fire Authority (OCFA),
December 2, 2008, page 15. 12
Freeway Complex Preliminary Report to
City of Yorba Linda, Orange
County Fire Authority (OCFA),
December 2, 2008, page 14.
13 Esperanza Fire Accident Investigation Factual Report,
USDA-‐-‐-‐Forest Service, October 26,
2006. Novato Fire Protection District Cedar Fire
Incident Recovery Report, May 26, 2004.
Yarnell Hill Incident Reports,
https://sites.google.com/site/yarnellreport/
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The Esperanza report identified “Causal”
and “Contributing” factors for the
firefighter fatalities. The root
cause of the deaths was the
decision to approve and build
the home in a location destined
to burn. While some consider
this incident an accident, it
may more readily be considered
a high-‐-‐-‐risk gamble that was
lost. The report identified these
top factors:
“Contributing Factor 1. Organizational
culture - The public (social
and political) and firefighting
communities expect and tolerate
firefighters accepting a notably
higher risk for structure
protection on wildland fires, than
when other resources/values are
threatened by wildfire.” (Bold
emphasis added)
“Causal Factor 2. The decision
by command officers and engine
supervisors to attempt structure
protection at the head of a
rapidly developing fire either
underestimated, accepted, and/or misjudged
the risk to firefighter safety.”
When faced with a Santa Ana
wind driven fire head rapidly
approaching project homes, will
firefighters be expected to defend
or decline to defend threatened
homes directly in the path of
the fire head?14 Poor Land
Use Decisions Exacerbate the Impact
of Expectations for Firefighter
Performance by Adding Unnecessary
Safety Risk Sites Considering
that “no structure in the path
of a wildfire is completely
without need of protection,”15 more
analysis needs to be provided
with a focus upon firefighter
safety. Firefighter escape routes and
safety zones,16 and their potential
decisions to defend structures for
the worst Santa Ana wind driven
fire points of origin, time
periods and worst weather conditions
require analysis. There have
been at least 327 wildland
firefighter fatalities in California
since 1926.17
14 Reference
Wildland Structure Protection Standard
Operating Procedure, Novato Fire
Protection District, Cedar Fire
Recovery Report, May 26, 2004.
15 Incident Response Pocket Guide,
National Wildfire Coordinating Group,
PMS461 NFES 1077, January 2010,
page 12. 16 Where are
the safety zones on the project
site? Butler and Cohen.
Firefighter Safety Zones: A
Theoretical Model Based Upon
Radiative Heating. Firefighter Safety
Zones: How Big Is Big Enough?
17 Wildland Fire Accidents by
State, National Interagency Fire
Center, page 2. Wildland firefighter
fatalities nationwide exceed one
thousand since 1910, page 24.
http://www.nifc.gov/safety/safety_documents/State.pdf
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Because of the social and
political climate associated with
expectations for firefighters to
defend property during wildfires, the
Project’s configuration relative to
topography should be analyzed and
the conditions that firefighters are
expected to engage, decline
deployment or retreat from specific
portions of the Project described.
“Wildland firefighters today are
spending more hours fighting fires
than ever before, and they are
engaging fires of historic magnitude.
The risk environment associated with
wildland fire is being re-defined,
and firefighters too have begun
to redefine their own culture
as a professional endeavor.” 18
After a review of wildland
firefighter fatality incidents, the
RDEIR should describe the conditions
that would cause firefighters to
reject assignment or retreat.19 The
“Lesson Learned” analyses of fire
behavior and firefighter fatality
incidents are relevant and
available.20
Convective Heat / Fire Whirls
Pose Extreme Danger
18 Trends in Wildland Fire
Entrapment Fatalities…Revisited, James R.
Cook, National Wildland Firefighters
Association, February 2013. 19
Reference Freeway Complex Fire
Incident Narrative – Map 4
Corona Fire Engine 5—Near Miss
Entrapment, Freeway Complex Fire
After Action Report, OCFA, Pages
31 & 47. 20
http://www.youtube.com/user/WildlandFireLLC?feature=watch
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Significant Cumulative Adverse Climate
Change Impacts The project as
designed, would conflict with state
regulations, plans and policies
adopted to reduce GHG emissions.
Furthermore, the project’s GHG
emissions are cumulatively significant
adverse impacts to climate change.
The project misses feasible
opportunities to avoid and mitigate
significant cumulative climate impacts.
The project should be
designed with the goal of GHG
neutrality or GHG negative through
a net positive production of
clean renewable energy, yet according
to the RDEIR the project will
generate approximately 744 MTCO2E per
year (p. 7-‐5). At a minimum,
the project needs to utilize
the full productive capacity of
each roof for PV Solar or
commit to a minimum 8Kw system
on each unit (approximately 28
panels) to mitigate for its GHG
impacts with the goal of making
the project net zero energy.
Santee has not established
significance thresholds. The City of
San Diego’s 900 MTCO2 threshold
has not been supported by
substantial evidence and vetted
through the CEQA process. 900
MTCO2 was adopted by San Diego
as an interim measure with a
2010 memo. The “900 MTCO2E
screening threshold” applied is
outdated and inappropriate. Furthermore,
the margin of error for the
744 MTCO2E calculated for the
project means that the project
likely exceeds “900 MTCO2E” even
if the significance threshold was
valid. However, even if
credible evidence was provided that
a 900 MTCO2E significance threshold
is valid (which it was not),
California has recently established
new more aggressive requirements for
reducing GHGs (SB 350 and
Executive Order B-‐30-‐15). CEQA
requires this significant new
information to be disclosed and
incorporated appropriately into the
project. EO B-‐30-‐15 was
issued April 29, 2015. The
RDEIR has not considered the
impacts of that order on the
project design. Nor has it
considered the requirements of SB
350. “SB 350 codifies
goals Governor Brown laid out
in his January 2015 inaugural
address to double the rate of
energy efficiency savings in
California buildings and generate
half of the state’s electricity
from renewable resources by 2030”
consistent with EO B-‐30-‐15.21
SB 375 requires local and
regional planning agencies to be
responsible for developing a
“sustainable communities strategy”,
however, Santee has not developed
a plan to implement its “22
goals regarding GHGs and climate
change” and SANDAG’s Regional
Transportation Plan referenced by the
RDEIR (p. 63) has
21 “Governor Brown Signs
Landmark Climate Legislation,” Office
of Governor Edmund G. Brown,
10-‐7-‐2015.
https://www.gov.ca.gov/news.php?id=19153
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been ruled to be deficient by
the court. Regardless, there is
not any apparent attempt to
design the project with measures
that consider SB 375 (and now
SB 350 and EO B-‐30-‐15)
requirements. The project is yet
another auto-‐dependent subdivision without
mitigating its significant adverse
impacts. Furthermore, the project
needs to incorporate measures to
meet the 2030 and 2050 targets
specified by SB 350 and
Executive Order B-‐30-‐15 even if
it includes enough measures to
meet 2020 targets, which it
does not. There is additional
burden placed on new development
now because disastrous methane leaks
presently occurring were not
anticipated and factored into actions
required to meet state goals.22
Addressing Climate Change is
Urgent and Must be Considered
at the Level of Individual
Projects The project emits
GHGs directly and encourages the
continued burning of fossil fuels
indirectly that moves us collectively
toward an inhabitable planet. Action
to address climate change becomes
ever more urgent with each
passing day.23 Even meeting state
mandates is not enough to avoid
severe climatic impacts, which is
why individual projects should be
designed to be GHG neutral.24
Every avoidable emission increases
the severity of the problem as
we accelerate toward
22 SoCal Gas Aliso Canyon
Leak a Disaster for Climate,
11/24/2015.
http://www.kcet.org/news/redefine/rewire/commentary/porter-‐ranch-‐leak-‐a-‐disaster-‐for-‐climate.html
23 “Humanity today, collectively,
must face the uncomfortable fact
that industrial civilization itself
has become the principal driver
of global climate. If we stay
our present course, using fossil
fuels to feed a growing
appetite for energy-‐intensive life
styles, we will soon leave the
climate of the Holocene, the
world of prior human history.
The eventual response to doubling
pre-‐industrial atmospheric CO2 likely
would be a nearly ice-‐free
planet, preceded by a period of
chaotic change with continually
changing shorelines. Humanity’s task
of moderating human-‐caused global
climate change is urgent… Continued growth
of greenhouse gas emissions, for just another
decade, practically eliminates the
possibility of near-‐term return of
atmospheric composition beneath the
tipping level for catastrophic
effects…The stakes, for all life
on the planet, surpass those of
any previous crisis. The greatest
danger is continued ignorance and
denial, which could make tragic
consequences unavoidable.” Hansen, James
et al. “Target Atmospheric C02:
Where Should Humanity Aim?”
NASA/Goddard Institute for Space
Studies, 2008 24 Hansen, James
et al. “Target Atmospheric C02:
Where Should Humanity Aim?”
NASA/Goddard Institute for Space
Studies, 2008.
http://climate.nasa.gov/vital-‐signs/carbon-‐dioxide/
http://climate.nasa.gov/evidence/
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tipping points where the damage
becomes increasingly severe, irreversible
and uncontrollable. 25
In recent decades civilization has
placed its foot to the floor
of a sluggish climate accelerator.
Now that strong collective adverse
action is kicking in, but we
are applying little more than a
parking brake as government policy
appears blinded to the cliff of
unalterable climate forcing in the
pipeline.26
“Many aspects of climate change
and associated impacts will continue
for centuries, even if anthropogenic
emissions of greenhouse gases are
stopped. The risks of abrupt or
irreversible changes increase as the
magnitude of the warming
increases.”27
The National Oceanic and
Atmospheric Administration (NOAA) and
National Aeronautics and Space
Administration (NASA) confirmed that
2014 was the hottest year ever
recorded. (NASA 2015.) 2015 is
on pace to shatter the record
set in 2014. In the National
Climate Assessment released by the
U.S. Global Change Research Program,
experts make clear that “reduc[ing]
the risks of some of the
worst impacts of climate change”
will require “aggressive and
sustained greenhouse gas emission
reductions” over the course of
this century. (Melillo 2014.) Indeed,
humanity is rapidly consuming the
remaining “carbon budget” necessary
to preserve a likely chance of
holding the average global
temperature increase to only 2°C
above pre-‐industrial levels. According
to the IPCC, when non-‐CO2
forcings are taken into
25 “Effects that scientists
had predicted in the past would
result from global climate change
are now occurring: loss of sea
ice, accelerated sea level rise
and longer, more intense heat
waves” (NASA Global Climate
Change Vital Signs of the
Planet). “…the net damage
costs of climate change are
likely to be significant and to
increase over time.”-‐ Intergovernmental
Panel on Climate Change
http://climate.nasa.gov/effects/ 26 “Earth’s
response to climate forcings is
slowed by the inertia of the
global ocean and the great ice
sheets on Greenland and Antarctica,
which require centuries, millennia or
longer to approach their full
response to a climate forcing.
This long response time makes
the task of avoiding dangerous
human alteration of climate
particularly difficult, because the
human-‐made climate forcing is being
imposed rapidly, with most of
the current forcing having been
added in just the past several
decades. Thus, observed climate
changes are only a partial
response to the current climate
forcing, with further response still
‘in the pipeline’.” Hansen,
James et al. “Climate sensitivity,
sea level and atmospheric carbon
dioxide”, The Earth Institute,
Columbia University, NASA Goddard
Institute for Space Studies, 2013,
p. 2. 27 Intergovernmental Panel
on Climate Change , “Climate
Change 2014 Synthesis Report Summary
for Policymakers,” page 16.
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account, total cumulative future
anthropogenic emissions of CO2 must
remain below about 1,000 gigatonnes
(Gt) to achieve this goal.28
Leading scientists—characterizing the
effects of even a 2°C increase
in average global temperature as
“disastrous”—have prescribed a far
more stringent carbon budget for
coming decades. (Hansen 2013.)
Climate change will affect
California’s climate, resulting in
such impacts as increased
temperatures and wildfires, and a
reduction in snowpack and
precipitation levels and water
availability.
California has a mandate under AB
32 to reach 1990 levels of
greenhouse gas emissions (“GHG”) by
the year 2020, equivalent to
approximately a 30 percent reduction
from a business-‐as-‐usual projection.
Health & Saf. Code § 38550.
The state must also reduce
emission levels to 80 percent
below 1990 levels by 2050.
(Executive Order S-‐3-‐05 (2005).) In
enacting SB 375, the state has
also recognized the critical role
that land use planning plays in
achieving greenhouse gas emission
reductions in California.29
In 2015, Governor Brown issued
Executive Order B-‐30-‐15 requiring
greenhouse gas emissions to be
40% below 1990 levels by
2030.30 The most recent legislative
session passed SB 350, which
requires widespread electrification of
the transportation sector, half of
all power generated to be from
renewable sources, and a doubling
of energy efficiency in buildings.
The state Legislature has
found that failure to achieve
greenhouse gas reduction would be
“detrimental” to the state’s economy.
Health & Saf. Code §
38501(b). In his 2015 Inaugural
Address, Governor Brown reiterated
his commitment to reduce greenhouse
gas emissions with three new
goals for the next fifteen
years:
28 IPCC 2013 (“Limiting the
warming caused by anthropogenic CO2
emissions alone with a probability
of >33%, >50%, and >66%
to less than 2°C since the
period 1861–1880, will require
cumulative CO2 emissions from all
anthropogenic sources to stay between
0 and about 1570 GtC (5760
GtCO2), 0 and about 1210 GtC
(4440 GtCO2), and 0 and about
1000 GtC (3670 GtCO2) since
that period, respectively. These
upper amounts are reduced to
about 900 GtC (3300 GtCO2), 820
GtC (3010 GtCO2), and 790 GtC
(2900 GtCO2), respectively, when
accounting for non-‐CO2 forcings as
in RCP2.6. An amount of 515
[445 to 585] GtC (1890 [1630
to 2150] GtCO2), was already
emitted by 2011.”). See also
UNEP 2013 (describing emissions
“pathways” consistent with meeting
2°C and 1.5°C targets). 29 See
http://www.arb.ca.gov/cc/sb375/sb375.htm. 30
Marin County has demonstrated the
feasibility of state GHG reduction
targets. Marin achieved a 15%
below 1990 levels by 2012 –
eight years ahead of schedule
and set a new aggressive target
of 30% below 1990 levels by
2020.
http://www.marincounty.org/main/county-‐press-‐releases/press-‐releases/2015/cda-‐climateaction-‐111015
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• Increase electricity derived from
renewable sources to 50 percent;
• Reduce today’s petroleum use in
cars and trucks by 50 percent;
• Double the efficiency of existing
buildings and make heating fuels
cleaner. (Brown 2015 Address.)
Although some sources of GHG
emissions may seem insignificant,
climate change is a problem
with cumulative impacts and effects.
Ctr. for Biological Diversity v.
Nat’l Highway Traffic Safety Admin.,
(9th Cir. 2008) 538 F.3d 1172,
1217 (“the impact of greenhouse
gas emissions on climate change
is precisely the kind of
cumulative impacts analysis” that
agencies must conduct). One source
or one small project may not
appear to have a significant
effect on climate change, but
the combined impacts of many
sources can drastically damage
California’s climate as a whole.
Similarly, CEQA requires that an
EIR consider both direct and
indirect impacts of a project.
CEQA Guidelines, § 15064.
A BAU Analysis Would Improperly
Discount the Project’s GHG Emissions
To the extent the RDEIR
would utilize a “Business As
Usual” (BAU) comparison and a
900MTCO2E significance threshold, that
fall-‐back position would be
improper. An EIR should compare
the capacity of the existing
site to absorb CO2 to the
post-‐project conditions, which will
likely show that under existing
conditions, the site has net
negative GHG emissions.
According to CEQA Guidelines §
15064.4, the “existing environmental
setting” is the appropriate baseline
against which to measure the
significance of a project’s GHG
impacts. GHG emissions
from the thousands of discrete
new sources, while small in
comparison to global emissions, each
contribute to the cumulative problem.
Numerous state and local
agencies have adopted quantitative
criteria to determine whether an
individual project’s emissions are
cumulatively significant. The State
Lands Commission, for example, has
used a zero threshold of
significance. Regardless of the
precise quantitative threshold adopted,
it is both feasible and
informative to determine significance
based on the project’s actual
net emissions in comparison to
the existing environment.
The purpose of analyzing the
significance of the project’s GHG
impacts based on the actual
environment, not in comparison to
some hypothetical version of the
project, is to disclose a
significant impact and avoid and
minimize it to the extent
feasible. This objective, the
core purpose of CEQA, is not
possible under a BAU methodology
comparison.
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Moreover, the RDEIR has not
presented any substantial evidence
that this approach is consistent
with the goals of AB 32.
The AB 32 Scoping Plan
projected a “business as usual”
scenario solely to quantify the
emissions reductions across all
sectors of the California economy
necessary to achieve AB 32’s
statewide emissions goals for the
year 2020 goals. The Scoping
Plan then identified dozens of
measures from various economic
sectors that could contribute to
the necessary reductions. But absent
some analysis of the project’s
contributions to statewide emissions
goals and inventories, which the
RDEIR fails to provide, it is
not possible to scale down the
Scoping Plan’s business as usual
assumptions to be used as
significance criteria on a project
level, nor would it be rational
to conclude that the project is
consistent with AB 32’s goals
based on a comparison with a
non-‐existent, hypothetical higher-‐emitting
version of the project.
Additional Mitigation is Needed to
Address the Project’s Significant GHG
Impacts California, (with the
exception of Texas) leads the
nation in GHG emissions.32 An
EIR should consider additional
mitigation measures during construction
and operation of the project
that would lower the project’s
overall GHG emissions and
contribution to climate change. The
California Air Pollution Control
Officers Association has identified
existing and potential mitigation
measures that could be applied
to projects during the CEQA
process to reduce a project’s
GHG emissions. (CAPCOA 2010). The
California Office of the Attorney
General also has developed a
list of reduction mechanisms to
be incorporated through the CEQA
process. (California Office of the
Attorney General 2010). These
resources provide a rich and
varied array of mitigation measures
that should be incorporated into
the revised project. Potential
mitigation measures during operation
of the project include, but are
not limited to:
• Analyzing and incorporating the
U.S. Green Building Council’s
LEED
(Leadership in Energy and Environmental
Design) or comparable standards for
energy and resource-‐efficient building
during pre-‐design, design,
construction, operations and management.
• Designing buildings for passive
heating and cooling, and natural
light, including building orientation,
proper orientation and placement of
windows, overhangs, skylights, etc.;
• Designing buildings for maximum
energy efficiency including the
maximum possible insulation, use
of compact florescent or other
low-‐energy lighting,
32 Magill, Bobby. “Texas,
California Lead Nation in Carbon
Emissions, Climate Central, October
29, 2015.
http://www.climatecentral.org/news
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use of energy efficient appliances,
etc. • Reducing the use of
pavement and impermeable surfaces; •
Requiring water reuse systems; • Installing
light emitting diodes (LEDs) for
traffic, street and other
outdoor
lighting • Limiting the hours of
operation of outdoor lighting •
Maximizing water conservation measures in
buildings and landscaping, using
drought-‐tolerant plants in lieu of
turf, planting shade trees; • Ensure
that the Project is fully
served by full recycling and
composting
services; • Ensure that the Project’s
wastewater and solid waste will
be treated in
facilities where greenhouse gas
emissions are minimized and captured.
• Installing the maximum possible
photovoltaic array on the building
roofs
and/or on the project site to
generate all of the electricity
required by the Project, and
utilizing wind energy to the
extent necessary and feasible;
• Installing solar water heating systems
to generate all of the
Project’s hot water requirements;
• Installing solar or wind powered
electric vehicle and plug-‐in hybrid
vehicle charging stations to reduce
emissions from vehicle trips.
Mitigation measures related to Project
construction could include:
• Utilize recycled, low-‐carbon, and
otherwise climate-‐friendly building
materials such as salvaged and
recycled-‐content materials for building,
hard surfaces, and non-‐plant
landscaping materials;
• Minimize, reuse, and recycle
construction-‐related waste; • Minimize
grading, earth-‐moving, and other
energy-‐intensive construction
practices; • Landscape to preserve
natural vegetation and maintain
watershed integrity; • Utilize alternative
fuels in construction equipment and
require construction
equipment to utilize the best
available technology to reduce
emissions. “Emissions Gap”
and Importance of a Net Zero
Energy Project Every GHG
emission is a cumulatively
significant impact to climate.
Certainly this project that would
generate approximately 744 MTCO2E per
year is significant. One reason
is because of the large
“Emissions Gap” between the projected
results of current GHG reduction
pledges and policies33 versus the
reductions required to hold
33 International GHG reduction
commitments are termed Intended
Nationally Determined Contributions (INDC).
These are largely unsecured pledges
that may or may not be
enacted to reduce GHG emissions.
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the increase in average global
temperature to 2 degrees Celsius
above pre-‐industrial levels. (Even a
2oC increase will have catastrophic
impacts).34 The severity of
the gap is illustrated in
Figure ES1: Historical greenhouse
(GHG) emissions and projections until
2050 and Figure ES2: The
Emission Gap (next page). The
current emission trend is illustrated
in shaded gray, which corresponds
to calamitous temperature increases.
The shaded blue represents the
substantial GHG reductions required
to meet less severe temperature
increases. The upward Current
Policy Trajectory line appears in
yellow/gold in Figure ES2: The
Emission Gap (next 2 pages).
The gap is sufficiently wide
that the Department of Defense
is preparing a “Climate Change
Adaptation Roadmap”. The foreword to
the plan states:
“Rising global temperatures, changing
precipitation patterns, climbing sea
levels, and more extreme weather
events will intensify the challenges
of global instability, hunger,
poverty, and conflict. They will
likely lead to food and water
shortages, pandemic disease, disputes
over refugees and resources, and
destruction by natural disaster in
regions across the globe. In
our defense strategy, we refer
to climate change as a ‘threat
multiplier’ because it has the
potential to exacerbate many of
the challenges we are dealing
with today – from infectious
disease to terrorism…Climate change
is a global problem. Its
impacts do not respect national
borders. No nation can deal
with it alone. We must work
together… Secretary of Defense
Chuck Hagel, Department of Defense
2014 Climate Change Adaptation
Roadmap
http://cait.wri.org/indc/ 34
“Temperature increases beyond 1.0°C
may elicit rapid, unpredictable, and
non-‐linear responses that could lead
to extensive ecosystem damage”
Stockholm Institute, “Targets and
Indicators of Climate Change” 1990.
Also,
http://www.carbonbrief.org/two-‐degrees-‐the-‐history-‐of-‐climate-‐changes-‐speed-‐limit
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The severity of the gap
is massive in both the size
of emissions and in its
consequences, which is why every
GHG emission is a cumulatively
significant adverse impact.
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Significant Ruling by the Supreme
Court of California considering GHGs
The Supreme Court of
California issued a ruling November
30, 2015 that offers additional
guidance for evaluation and
processing of projects with GHG
impacts. [Center for Biological
Diversity v. California Department of
Fish & Wildlife, S217763]
Consistent with this decision,
substantial evidence has been
provided that the project has
cumulatively significant adverse impacts
to climate that are feasible to
avoid or mitigate, but have not
been. CEQA requires the lead
agency to evaluate and apply
feasible mitigation measures and then
provide a statement of overriding
considerations for any significant
impacts that remain if the
project is to be approved. [p.
28] The RDEIR fails in both
regards. The RDEIR fails to
provide substantial evidence to
support the Finding of insignificance
for GHG emissions [p. 7-‐4,
7-‐5]. The RDEIR fails to
provide substantial evidence how
emissions might be reduced beyond
statewide programs and business as
usual city policies that would
apply to the project regardless
of GHG emissions. The Court
affirmed that local government
carries the burden of evaluating
projects’ climate impacts. [p. 26]
Failure to provide substantial
evidence to support a finding
of no significance (which is
the case here) deprives the
public of information needed to
determine the significance of the
project’s GHG impacts. [p. 24]
Furthermore, the Court affirmed that
GHG impacts are global and
should be considered in the
context of the global problem.
[p. 11] Meeting state goals
depends upon increased efficiency and
conservation measures applicable all
the way down to the level
of individuals. [p. 12]
Substantial evidence must support the
baseline / significance threshold.
[p. 19] The RDEIR fails to
provide supporting evidence for a
BAU comparison and Santee has
not established a significance
threshold or Climate Action Plan
supported by substantial evidence.
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__________________________________________________________________________________________
9222 Lake Canyon Road,
Santee, CA 92071
Tel/Fax (619) 258-‐7929
[email protected]
I.D.#980429
Preserve Wild Santee
29
Cumulatively Significant Adverse Impacts
of Water Use Increasing demand
and competition for water raises
water rates. This in turn
harms landscapes by causing the
death of landscaping plants,
especially trees. Tree mortality
is on the rise as residents
let lawns die or replace them
with plastic turf.35 This in
turn reduces carbon sequestration
(dead plants do not sequester
carbon) and also magnifies the
heat island effect, speeds runoff
and reduces infiltration rates
throughout the city, thereby reducing
groundwater recharge. This is a
cumulatively significant adverse impact
to climate from the project
that is not analyzed, disclosed
or mitigated. Furthermore,
the RDEIR downplays the severity
of the Level 2 drought and
water demand impact. What we
currently call drought appears to
be the new normal for water
availability. The PDMWD availability
form is based on outdated
assumptions in a water infrastructure
that is at historically low
levels. Without a minimum 20%
cut in project demand, building
the project is inconsistent with
the 20% reduction ordered for
the District. This is another
significant adverse impact.
Effective December 1, 2015, projects
that exceed 500 square feet of
landscaped area require submission of
landscape plans consistent with
emergency response to California’s
prolonged drought conditions. Why
haven’t landscape plans been
submitted to show consistency? Plans
should be provided with sufficient
time for public review.
Conclusion CEQA requires that
public agencies not approve “projects
as proposed if there are
feasible alternatives or mitigation
measures available which would
substantially lessen the significant
effects of such projects.”
We encourage selection of the
No Project Alternative. Should the
city council approve a project
alternative, the Jurisdictional Drainage
Avoidance Alternative is significantly
superior to the project. The
project should be designed with
the goal of GHG neutrality. The
project should avoid significant
adverse impacts and mitigate for
significant adverse impacts that
cannot be avoided. Thank you
for considering our comments.
35 Maureen Cavanaugh, Amita
Sharma, Neiko Will, “Drought Taking
Heavy Toll On San Diego Trees”,
KPBS, November 4, 2015.
http://www.kpbs.org/news/2015/nov/04/droughts-‐heavy-‐toll-‐san-‐diego-‐trees/
-
__________________________________________________________________________________________
9222 Lake Canyon Road,
Santee, CA 92071
Tel/Fax (619) 258-‐7929
[email protected]
I.D.#980429
Preserve Wild Santee
30
Van K. Collinsworth Geographer /
Wildland Fire Expert / Director,
Preserve Wild Santee Conservation
Coordinator / California Chaparral
Institute
Frank Landis Conservation Chair,
California Native Plant Society San
Diego
John Buse Senior Counsel,
Center for Biological Diversity
Cc: Santee City Council
Attachments: -‐ Resumes -‐ Wildland
Structure Protection Standard Operating
Procedure -‐ Climate Change 2014
Synthesis Report Summary for
Policymakers -‐ Target C02: Where
Should Humanity Aim? -‐ Climate
sensitivity, sea level and
atmospheric carbon dioxide -‐
Assessing “Dangerous Climate Change”:
Required Reduction of Carbon
Emissions to Protect Young People,
Future generations and Nature -‐
The Emissions Gap Report 2015
-‐ Executive Summary -‐ Supervisors
Approve Climate Action Plan Update
-‐ County committed to reducing
greenhouse gas emissions ahead of
state goals -‐ Department of
Defense 2014 Climate Change
Adaptation Roadmap -‐ UN on
wrong track with plans to limit
global warming to 2C, says top
scientist -‐ Climate change is
happening now – a carbon price
must follow | James E Hansen
| -‐ Global alteration of ocean
ecosystem functioning due to
increasing human CO2 emissions -‐
SoCal Gas' Aliso Canyon Leak a
Disaster For Climate | Commentary
| Rewire | KCET -‐ Huge
Gas Leak In The Valley Boosted
California's Methane Emissions By 25%
-‐ Center for Biological Diversity
v. California Department of Fish
& Wildlife, S217763
-
Novato Fire Protection District Cedar Fire Incident Recovery
Report
May 26, 2004 Page 73 of 90
Draft SO
P’sTitle: Wildland Structure Protection Standard Operating
Procedure
Overview Structure protection is a dangerous task often
performed at the most intense segments of the fire. Due to the
inherent dangers of wildland firefighting in genera