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From: De Wayne Fi l ppi <
Se nt: Tue sday, De ce mbe r 30, 2025 12:29 PM
To: Natal i e Me e ks <N Me e ks@anahe i m.ne t>
Subje ct: [EXTERN AL] Shae Properties Festi val Redeve l opme nt Project
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Ms Meeks,
The proposed redevelopment of the Anaheim Hills Festival Center by Shea Properties would advers ely impac t the s afety of loc al
residents by exacerbating an already untenable wildfire evacuation crisis. W hile the developer proposes replacing a mostly vac ant
cinema with 447 multi-family units, they are essentially replacing a "transient" commercial population with a permanent res idential
population of approximately 1,664 people and their associated vehicles, all located within a Very High Fire Hazard Severity Zone
(VHFHSZ).
The FEIR explicitly admits the "elephant in the room": that our neighborhood already fac es evacuation times exceeding three hours. It
further admits that this project will add nearly 1,700 new residents and their vehicles, extending that gridlock by another 24 minutes (a
dubious claim for many hundreds of cars thrown into gridlock). In a fast-moving fire—like the 2017 Canyon Fire 2—a 24-minute delay is
the difference between life and death.
The City’s apparent current reasoning—that a 24-minute increase is "less than significant" because the situation is already critic al—is a
moral and legal fallacy. Adding more people to a failed system does not mitigate the problem; it c ompounds it. By approving this density,
the City is normalizing a life-safety deficiency. This is not "incremental growth"; it is the intentional expans ion of a known hazard zone.
The developer suggests that mitigations such as improved internal circulation and adherenc e to wildfire res ilience building c odes (MM
HAZ-4, HAZ-5, and HAZ-9) render this impact acceptable. However, no amount of internal "circulation" or fire-resis tant roofing s olves the
physics of a "bottleneck" at the primary exit points of the Hills. The project residents, no doubt grateful for the wildfire resilienc e of the
building, would soon find themselves in the 3 hour escape queue with the rest of us. Under CEQA, when a bas eline c ondition is already
at a level of critical failure, any additional impact is inherently 'significant.'
I urge the Council to consider the recent legal precedent in People v. County of Lake (2024), where the c ourt held that "bare
conclusions" are insufficient to dismiss evacuation risks. Furthermore, under SB 1241, the City is mandated to avoid "unreasonable
wildfire risks." Choosing to add residents to a "trap" area while residents are already fac ing three-hour delays is the definition of an
unreasonable risk and an odd form of compassion. Also, any proposed infrastructure improvements must be shown effective for
current residents before adding more victims to the pyre. I urge you to prioritize the lives of c urrent (and new) res idents and
disapprove the General Plan and Specific Plan amendments for this project.
DeW ayne Filppi