General (21)You don't often get email from Learn why this is important
Date:1/21/2026 5:18:43 PM
From:"Linda"
To:"Planning" Planning@anaheim.net
Cc:"Amanda Lauffer" ALauffer@anaheim.net, "Eibet Olmedo" EOlmedo@anaheim.net, "City Cle rk"
cityclerk@anaheim.net
Subject:[EXTERNAL] Cover Letter and Attached CEQA Objection – Anaheim Hills Festival Proje ct
Attachment:CEQA_Traffic_Objections_Anaheim_Hills_Festival_Project.pdf;
Warning: This email originated from outside the City of Anaheim. Do not click links or open attachme nts unle ss you recognize the
sender and are expecting the message.
Dear Planning Commission Members,
Please include this letter and the attached CEQA objection PDF in the official record for the Anaheim Planning Commission regarding the
Anaheim Hills Festival Project
I am submitting this letter as a brief cover and summary to accompany the attached PDF, which sets forth my formal CEQA objections
regarding traffic and public safety deficiencies in the Anaheim Hills Festival Specific Plan Amendment Project.
In short, the City’s traffic analysis remains incomplete and misleading in several critical respects. The analysis does not account for reasonably
foreseeable traffic generated by a high-attraction grocery tenant such as Trader Joe’s, and it relies on the proposed Fairmont overpass as a
purported solution to congestion that is largely driven by freeway traffic funneling onto Santa Ana Canyon Road, an already constrained two-
lane corridor. The overpass does not meaningfully relieve this bottleneck.
In addition, I am requesting an explanation for the inconsistency in fire authority review. The Anaheim Fire Chief formally objected to the
SALT/Deer Canyon project based on evacuation and fire safety concerns, yet no comparable objection was raised for the Festival Project
despite similar evacuation constraints and wildfire risk conditions.
These issues are addressed in detail in the attached objection. I respectfully request that this letter and the attached document be entered into the
official record and considered prior to any further action on the project.
Thank you for your attention.
Sincerely,
Linda Hurley
Anaheim Hills
Formal CEQA Objections – Traffic and Public Safety Deficiencies
Project: Anaheim Hills Festival Specific Plan Amendment Project
FEIR No.: 358
State Clearinghouse No.: 2024010859
I submit this comment to formally object to the adequacy of the Final Environmental Impact Report
(FEIR) for the Anaheim Hills Festival Specific Plan Amendment Project with respect to traffic,
circulation, and public safety impacts. These objections are submitted to preserve all administrative
remedies and to identify specific CEQA deficiencies that remain unresolved despite preparation of the
FEIR.
I. Failure to Analyze Reasonably Foreseeable Worst-Case Traffic Conditions
The Traffic Impact Analysis relies primarily on weekday AM and PM peak-hour conditions and fails to
analyze reasonably foreseeable worst-case conditions, including weekend peaks, event-driven surges,
holiday traffic, and overlapping emergency conditions such as wildfire evacuation during congestion.
CEQA requires analysis of reasonably foreseeable conditions, not average or convenient study
periods. This omission renders the FEIR informationally deficient under CEQA Guidelines §15151.
II. Inadequate Evaluation of Traffic Safety Impacts
The FEIR relies on LOS and VMT metrics while failing to analyze traffic safety, including queue
spillback, blocked emergency access, turning conflicts, sight distance limitations, and increased
collision risk. Passing LOS does not equate to safe conditions. CEQA requires evaluation of physical
safety impacts, which is absent here.
III. Improper Segmentation of Traffic and Emergency Access Analysis
Traffic congestion analysis is improperly siloed from emergency evacuation analysis. The FEIR fails to
evaluate compound scenarios involving congestion plus emergency response or evacuation. CEQA
requires evaluation of combined foreseeable conditions; this segmentation understates risk.
IV. Inadequate Cumulative Traffic Impact Analysis
The FEIR fails to meaningfully analyze cumulative impacts from reasonably foreseeable nearby
development and commercial intensification. Statements that such impacts are outside the scope or
addressed later do not satisfy CEQA’s cumulative impact requirements, particularly given limited
egress routes in Anaheim Hills.
V. Unreasonable Reliance on Generic Trip Generation Assumptions
The Traffic Impact Analysis relies on generic ITE trip rates without adequate adjustment for local
conditions, vehicle dependency, event traffic, and emergency surges. CEQA requires reasoned
judgment, not mechanical reliance on generalized averages.
VI. Insufficient and Non-Enforceable Traffic Mitigation
Mitigation measures rely on signal timing, signage, and future design review without enforceable
performance standards or physical improvements. CEQA requires feasible, enforceable mitigation
capable of actually reducing impacts.
VII. Conclusion
For these reasons, the FEIR fails to function as an adequate informational document under CEQA with
respect to traffic and public safety. Revision and recirculation are required to address worst-case
conditions, safety impacts, cumulative effects, and enforceable mitigation. Failure to do so leaves the
FEIR legally vulnerable.
Respectfully submitted,
Linda Hurley
Interested Party / Commenter
Anaheim Hills