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10 (277)Some people who received this message don't often get email from taluzzi@msn.com. Learn why this is important Date:3/3/2026 9:56:27 AM From:"Tina Aluzzi - Lounsbury" taluzzi@msn.com To:"Public Comment" publiccomment@anaheim.net, "City Clerk" cityclerk@anaheim.net, "Ashleigh Aitke n" AAitken@anaheim.net Subject:[EXTERNAL] Comprehensive Public Health, Safety, and Legal Objection – Development Application No. 2023-00043 / FEIR No. 358 – March 3, 2026, Hearing 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. Date: March 3, 2026 City of Anaheim Mayor and Members of the City Council 200 S. Anaheim Boulevard Anaheim, CA 92805 Via email address: publiccomment@anaheim.net; cityclerk@anaheim.net; aaitken@anaheim.net Subject: Comprehensive Public Health, Safety, and Legal Objection – Development Application No. 2023-00043 / FEIR No. 358 – March 3, 2026, Hearing Mayor Aitken and Members of the City Council, I submit this correspondence for inclusion in the administrative record regarding Development Application No. 2023-00043, including certification of Final Environmental Impact Report (FEIR) No. 358, adoption of the Statement of Overriding Considerations, approval of Specific Plan Amendment No. 6 (Specific Plan No. 90-1), the associated General Plan Ame ndme nt, and Development Agreement No. 2025-00001. I previously submitted written opposition on February 3, 2026, and appreciate acknowledgment of that communication – although it took 4 weeks for a response and was the same response exact generic response sent to other. After reviewing the full administrative record, the CEQA findings, and the City’s Safety Element obligations, I remain in strong opposition based on public health, emergency medical system capacity, wildfire evacuation risk, and long-term cumulative hazard exposure. I. Professional Qualifications and Public Health Context I am a licensed Registered Nurse (RN) and Public Health Nurse (PHN) in the State of California, a former Emergency Department nurse, and a Clinical Consultant with direct experience in emergency care operations, hospital throughput, surge planning, and system-level healthcare coordination. From both a clinical and population-health perspective, the proposed 447-unit high-density residential development in a Ve ry High Fire Hazard Severity Zone presents foreseeable and preventable risk amplification. Wildfire risk in hillside communities is not theoretical. It is predictable, recurring, and historically documented in Anaheim Hills. II. Anaheim Hills Wildfire History and Public Lessons Anaheim Hills has experienced multiple significant wildfire events, including: 1982 Gypsum Canyon Fire Destroyed dozens of homes and demonstrated rapid fire spread in canyon topography. 1993 Eastern Anaheim Hills Fire Significant structural loss and mass evacuations. 2008 Freeway Complex Fire Forced large-scale evacuations and demonstrated regional evacuation strain. 2017 Canyon Fire 2 Destroyed 25+ homes and forced evacuation of thousands of residents. Residents reported severe congestion on Santa Ana Canyon Road and surrounding arterials. Publicly documented lessons from Canyon Fire 2 include: • Limited egress capacity • Freeway cut-through congestion • Communication delays • Evacuation bottlenecks • Simultaneous ingress of emergency vehicles These are not isolated anomalies. They are recurring structural vulnerabilities in a hillside evacuation environment. III. CEQA – Wildfire Evacuation Adequacy Under CEQA (Pub. Res. Code §21000 et seq.) and CEQA Guidelines §§15126.2 and 15126.4, the EIR must contain substantial evidence supporting conclusions regarding environmental impacts. The FEIR acknowledges: • Increased evacuation times • Significant Unavoidable VMT impacts • Adoption of a Statement of Overriding Considerations under §15093 In a Very High Fire Hazard Severity Zone, evacuation modeling must reflect: • Simultaneous multi-neighborhood departure • Panic behavior under threat • Disabled vehicles blocking lanes • Smoke-reduced visibility • Power outages affecting signals • Nighttime evacuations • EMS ingress while residents egress • Mobility-limited residents requiring assistance Modeling orderly traffic flow does not replicate wildfire evacuation reality. Evacuation thresholds are nonlinear. Once roadway capacity is exceeded, congestion accelerates exponentially, not incrementally. IV. Medical and Emergency System Implications Residential density materially alters risk conditions compared to intermittent commercial occupancy. A vacant or intermittently used cinema does not create: • 24-hour sleeping populations • Medically fragile residents • Oxygen-dependent patients • Individuals requiring mobility devices • Pediatric evacuation logistics • Assisted evacuation requirements During wildfire emergencies: • EMS response times increase due to roadway congestion • Ambulance access becomes delayed • Emergency Departments experience surge volume • Hospitals may activate diversion status • Evacuation shelters must accommodate medically vulnerable populations As a former ER nurse, I have personally managed disaster surge events. Minutes matter. Delayed transport correlates directly with increased morbidity and mortality. In wildfire smoke conditions: • Asthma exacerbations spike • COPD patients decompensate • Cardiac events increase • Anxiety and panic attacks surge • Pediatric respiratory distress increases These are evidence-based public health consequences. Increasing residential density increases exposure burden on: • Anaheim Fire & Rescue • EMS transport capacity • Regional hospitals • Urgent care and ED throughput • Public health infrastructure V. General Plan Safety Element Consistency Government Code §65302(g) requires that the Safety Element address fire hazards and evacuation routes. Safety Element principles include: • Minimizing wildfire exposure • Ensuring adequate evacuation capacity • Maintaining emergency responder access • Avoiding intensification in high-risk zones without infrastructure capacity A legislative amendment intensifying residential density must remain internally consistent with these adopted policies (Gov. Code §65300.5). Compliance with fire code setbacks and hydrant spacing does not equate to evacuation sufficiency. Evacuation capacity is a system-level issue — not a parcel-level building code issue. I respectfully request that Council explicitly articulate findings demonstrating how adding 447 units in this location remains consistent with Safety Element wildfire and evacuation policies. VI. Cumulative Risk & Infrastructure Timing Referenced infrastructure improvements extending to 2029 cannot justify risk today. Risk exposure occurs immediately upon occupancy. Cumulative development must be analyzed not only for traffic but for wildfire evacuation system saturation. Risk accumulation is incremental until a tipping point is reached. Anaheim Hills is approaching threshold vulnerability. VII. Statement of Overriding Considerations CEQA Guidelines §15093 allows approval of projects with significant unavoidable impacts only when benefits outweigh risks. In this case, Council must override: • Significant Unavoidable VMT impacts • Increased evacuation time impacts Overriding life-safety impacts in a Very High Fire Hazard Severity Zone requires compelling evidence. Conclusive statements without robust record support risk judicial scrutiny. VIII. Housing Accountability Act Context Gov. Code §65589.5 permits denial where a specific, adverse health or safety impact is supported by substantial evidence and no feasible mitigation exists. Wildfire evacuation constraints in a Very High Fire Hazard Severity Zone constitute a potential specific adverse health and safety risk if supported by record evidence. IX. Ethical and Fiscal Considerations If approved: • CEQA litigation likely • Taxpayer-funded defense • Long-term infrastructure strain If evacuation failure results in injury or loss of life, moral and legal consequences extend beyond CEQA compliance. As healthcare professionals, we are trained to prevent foreseeable harm — not normalize incremental risk accumulation. X. Request I respectfully request that the Council: • Decline certification of FEIR No. 358 absent stronger evacuation adequacy findings; OR • Continue the matter for enhanced wildfire evacuation and cumulative hazard analysis; OR • Adopt explicit, evidence-supported Safety Element consistency findings addressing system-level evacuation capacity. This is not opposition to housing. It is opposition to high-density residential siting in a documented wildfire-prone, evacuation-constrained hillside environment. Public safety must remain paramount. Respectfully submitted, Tina R. Aluzzi-Lounsbury, BSN, RN, PHN Anaheim Hills Resident The preceding email message (including any attachments) may contain information that is confidential, protected, or constitute nonpublic information. It is intended to be conveyed only to the designated recipient(s). 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