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10 (298)You don't often get email from shelly.n.robbins@gmail.com. Learn why this is important Date:3/3/2026 12:26:39 PM From:"S R" shelly.n.robbins@gmail.com To:"Public Comment" publiccomment@anaheim.net Subject:[EXTERNAL] Public Comment – CEQA Wildfire, Evacuation, and Transportation Analysis (Festival Proposal DEV2023- 00043 ) 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. 3-3-26 12:27pm Dear Mayor and Council Members, I respectfully submit the following comments regarding the Festival Proposal and the adequacy of i ts envi ronmental review under the California Environmental Quality Act (CEQA). Given the unresolved evacuation and wildfire analysis issues, I respectfully urge you to vote NO on the Festival Shopping Center Proposal DEV2023-00043. The project site is located within a designated Very High Fire Hazard Severity Zone and lies i n close proximi ty to the burn area of the 2017 Canyon Fire 2, as well as multiple wildfire events originating east of Weir C anyon. Followi ng Canyon Fi re 2, the C ity developed the “Know Your Way” evacuation initiative in recognition of documented evacuation challenges i n thi s region. Given the site’s hazard designation, wildfire history, and constrained roadway network, C EQA requires a particularly rigorous analysis of wildfire exposure and emergency evacuation performance. Based on my revi ew of the EIR, several cri ti cal analyti cal gaps appear to remain. 1. Evacuation Clearance and Roadway Capacity For several evacuation zones in this area, the primary egress route funnels down Weir C anyon Road toward the 91 West freeway interchange. This corridor already experiences significant commuter bypass traffic associated with regi onal growth in Riverside County, Corona, and the Inland Empire, frequently resulting in congested operati ng conditions. The Festival Proposal introduces substantial new residential population and mixed-use acti vity i nto this constrai ned evacuati on network. However, the EIR does not appear to include: Quantitative evacuation clearance time modeling; Analysis incorporating current baseline traffic volumes; Scenario-based modeling of wildfire events originating east of Weir Canyon with westbound evacuation demand toward the 91 freeway; Evaluation of roadway throughput, interchange bottlenecks, and queue formation duri ng emergency condi ti ons; Transparent assumptions regarding evacuation performance under red flag or peak occupancy scenari os. Although California does not prescribe a statewide evacuation performance threshold, CEQA nevertheless requires substantial evidence demonstrating that a project would not impair safe emergency access. In a Very Hi gh Fire Hazard Severi ty Zone that relies heavily on a limited roadway funnel, the absence of evacuation clearance modeli ng raises concern that emergency egress feasibility has not been fully evaluated. 2. Relationship to the City’s “Know Your Way” Initiative Following Canyon Fire 2, the City acknowledged evacuation vulnerabilities and implemented the “Know Your Way” i ni ti ative. The EIR does not appear to reconcile: The evacuation challenges identified after Canyon Fire 2; With the increased density and vehicle load proposed under the Festival Proposal; On evacuation routes that remain constrained and heavily utilized. CEQA requires agencies to address inconsistencies between a project and adopted safety planning efforts. Where a ci ty has previously recognized evacuation limitations, the addition of substantial new populati on warrants careful, evi dence-based analysis. 3. Transportation Demand, VMT, and Infrastructure Constraints The EIR evaluates transportation impacts using Vehicle Miles Traveled (VMT), as requi red under current CEQA gui delines. However, even if VMT thresholds are met, that metric does not evaluate roadway capacity, i nterchange bottlenecks, or emergency evacuation performance. Regional growth over the past decade has significantly increased commuter traffic along Weir C anyon Road and the 91 corridor, without corresponding expansion of evacuation infrastructure. While VMT may address regional travel patterns, it does not substitute for analysis of: Emergency roadway throughput, Evacuation clearance times, Bottleneck performance at freeway interchanges, The interaction between project-generated trips and an already constrained evacuation network. Where evacuation performance has not been quantitatively evaluated, reliance on VMT compliance alone may not consti tute substantial evidence that emergency access impacts are less than significant. 4. Cumulative Wildfire Exposure and Population Risk The EIR must evaluate cumulative impacts when the Festival Proposal is considered alongsi de exi sti ng development and reasonably foreseeable growth. Increasing mixed-use density within a Very High Fire Hazard Severi ty Zone may: Increase the number of residents exposed during extreme fire events; Compound evacuation congestion; Increase demand on fire protection resources during simultaneous emergencies. It is not evident that cumulative wildfire exposure and evacuation performance have been fully evaluated with substantial evidence. 5. Fire Protection Capacity and Mitigation Effectiveness The EIR should demonstrate, with project-specific evidence, that: Fire response times remain adequate during extreme wind events; Water supply and hydrant flow are sufficient under peak wildfire demand; Emergency services can accommodate increased density during concurrent incidents. General statements of compliance with fire code requirements do not substitute for a robust, scenario-based wi ldfi re i mpact analysis under CEQA. If wildfire impacts are deemed less than significant with miti gati on, the record should clearly demonstrate that mitigation measures are enforceable, supported by evidence, and effective in reducing i mpacts to a legally suffi ci ent level. Given the site’s Very High Fire Hazard Severity Zone designation, proximity to multiple wildfire events near Weir C anyon, reliance on a constrained evacuation corridor toward the 91 West freeway, and the apparent absence of evacuation clearance modeling, I respectfully urge the Council to ensure that wildfire and emergency access impacts have been fully analyzed and supported by substantial evidence before making CEQA findings. Thank you for your careful consideration. Sincerely, Shelly Robbins Shelly.n.robbins@gmail.com 8141 E. Kennedy Rd, Anaheim, CA 92808 714-793-7447 Sincerely, Shelly Robbins shelly.n.robbins@gmail.com 7 1 4-7 93-7 447 You don't often get email from shelly.n.robbins@gmail.com. Learn why this is important Date:3/3/2026 12:42:18 PM From:"S R" shelly.n.robbins@gmail.com To:"Ashleigh Aitken" AAitken@anaheim.net Cc:"Public Comment" publiccomment@anaheim.net Subject:[EXTERNAL] District 6 Resident – Request to Vote NO (Festival Shopping Ce nter Proposal DEV2023-00043) & CEQA CONCERNS 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: 3-3-26 Time: 1 2:43pm Dear Mayor Ashleigh Aitken, As a District 6 resident, this proposal directly affects my family’s evacuation safety. I want to be clear that I am not opposed to housing or new development. However, growth must be accompanied by infrastructure that ensures safe evacuation i n a Very High Fire Hazard Severity Zone. In this case, that analysis and infrastructure do not appear to be i n place. I li ve i n Zone 4 of the Know Your Way Evacuation plan and have witnessed first hand fire on the hillside di rectly across the street from me (Basil & Kennedy Rd) during the Canyon Fire 2 of 2017 and have went through the challenges of attempting to evacuate only to be met with hours of gridlock. If it weren’t for the direction of the fire changing at the last minute heading toward the Bryant Ranch area of Yorba Linda, our family would have been unable to evacuate. While I appreciate efforts to fix the Know Your Way Plan, it does not account for human behavior and has not been tested. For that reason, I respectfully urge you to vote NO on the Festival Shopping Center Proposal DEV2023-00043 in its current form. The project site is located within a designated Very High Fire Hazard Severity Zone and lies near the burn area of the 2017 Canyon Fire 2, as well as multiple wildfire events originating east of Weir Canyon. Followi ng Canyon Fi re 2, the C i ty implemented the “Know Your Way” initiative in recognition of evacuation challenges i n thi s region. Given this documented fire history and hazard designation, CEQA requires careful analysi s of wi ldfi re exposure and emergency evacuation feasibility. Based on my review of the EIR, significant analytical concerns remai n unresolved. Evacuation Performance and Constrained Egress For several evacuation zones in this area, primary egress funnels down Weir Canyon Road toward the 91 West freeway interchange — a corridor that already experiences substantial commuter bypass traffi c due to regi onal growth in Ri verside County, Corona, and the Inland Empire. The EIR does not appear to include: Quantitative evacuation clearance time modeling; Analysis reflecting current baseline traffic conditions; Scenario-based modeling of wildfire events originating east of Weir Canyon; Evaluation of bottlenecks at the 91 interchange during emergency demand. Although California does not prescribe a statewide evacuation time standard, CEQA nevertheless requires substantial evidence demonstrating that a project would not impair safe emergency access. In a Very High Fi re Hazard Severity Zone dependent on a constrained evacuation funnel, the absence of evacuation clearance modeling raises seri ous concern. VMT Does Not Resolve Evacuation Feasibility While the EIR evaluates transportation impacts using Vehicle Miles Traveled (VMT), that metri c does not measure roadway capacity, interchange throughput, or evacuation performance. Regional growth has increased baseline congestion along Weir Canyon and the 91 corridor without corresponding expansi on of evacuation infrastructure. Compliance with VMT thresholds does not address whether emergency egress can functi on safely during wildfire conditions. Consistency with Prior Safety Planning After Canyon Fire 2, the City acknowledged evacuation limitations through the “Know Your Way” i ni ti ative. The EIR does not appear to reconcile those recognized constraints with the additional population and vehi cle load i ntroduced by this project. Cumulative Wildfire Exposure Increasing mixed-use density within a Very High Fire Hazard Severity Zone increases populati on exposure and evacuation demand during extreme fire events. It is not evident that cumulative wildfire and evacuati on impacts have been fully evaluated with substantial evidence. I support thoughtful growth in Anaheim. But adding density in a constrained wildfire evacuation corridor without fi rst ensuring adequate infrastructure and emergency modeling is not responsible planning. Given these unresolved concerns, I respectfully urge you to vote NO on the Festival Shoppi ng Center Proposal. Thank you for your service to District 6 and for carefully considering the safety of the famili es you represent. Sincerely, Shelly Robbins Shelly.n.robbins@gmail.com 8141 E. Kennedy Rd, Anaheim, CA 92808 714-793-7447 Sincerely, Shelly Robbins shelly.n.robbins@gmail.com 7 1 4-7 93-7 447 Date:3/3/2026 12:54:23 PM From:"S R" shelly.n.robbins@gmail.com To:"Carlos A. Leon" CLeon@anaheim.net Cc:"Public Comment" publiccomment@anaheim.net Subject:[EXTERNAL] Fwd: District 6 Resident – Request to Vote NO (Festival Shopping Ce nter Proposal DEV2023-00043) & CEQA CONCERNS 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. Dat e: 3-3-26 Time: 1 2:5 5 pm Dear Council Member Leon, As a District 6 resident, this proposal directly affects my family’s evacuation safety. I want to be clear that I am not opposed to housing or new development. However, growth must be accompanied by infrastructure that ensures safe evacuation i n a Very High Fire Hazard Severity Zone. In this case, that analysis and infrastructure do not appear to be i n place. I li ve i n Zone 4 of the Know Your Way Evacuation plan and have witnessed first hand fire on the hillside di rectly across the street from me (Basil & Kennedy Rd) during the Canyon Fire 2 of 2017 and have went through the challenges of attempting to evacuate only to be met with hours of gridlock. If it weren’t for the direction of the fire changing at the last minute heading toward the Bryant Ranch area of Yorba Linda, our family would have been unable to evacuate. While I appreciate efforts to fix the Know Your Way Plan, it does not account for human behavior and has not been tested. For that reason, I respectfully urge you to vote NO on the Festival Shopping Center Proposal DEV2023-00043 in its current form. The project site is located within a designated Very High Fire Hazard Severity Zone and lies near the burn area of the 2017 Canyon Fire 2, as well as multiple wildfire events originating east of Weir Canyon. Followi ng Canyon Fi re 2, the C i ty implemented the “Know Your Way” initiative in recognition of evacuation challenges i n thi s region. Given this documented fire history and hazard designation, CEQA requires careful analysi s of wi ldfi re exposure and emergency evacuation feasibility. Based on my review of the EIR, significant analytical concerns remai n unresolved. Evacuation Performance and Constrained Egress For several evacuation zones in this area, primary egress funnels down Weir Canyon Road toward the 91 West freeway interchange — a corridor that already experiences substantial commuter bypass traffi c due to regi onal growth in Ri verside County, Corona, and the Inland Empire. The EIR does not appear to include: Quantitative evacuation clearance time modeling; Analysis reflecting current baseline traffic conditions; Scenario-based modeling of wildfire events originating east of Weir Canyon; Evaluation of bottlenecks at the 91 interchange during emergency demand. Although California does not prescribe a statewide evacuation time standard, CEQA nevertheless requires substantial evidence demonstrating that a project would not impair safe emergency access. In a Very High Fi re Hazard Severity Zone dependent on a constrained evacuation funnel, the absence of evacuation clearance modeling raises seri ous concern. VMT Does Not Resolve Evacuation Feasibility While the EIR evaluates transportation impacts using Vehicle Miles Traveled (VMT), that metri c does not measure roadway capacity, interchange throughput, or evacuation performance. Regional growth has increased baseline congestion along Weir Canyon and the 91 corridor without corresponding expansi on of evacuation infrastructure. Compliance with VMT thresholds does not address whether emergency egress can functi on safely during wildfire conditions. Consistency with Prior Safety Planning After Canyon Fire 2, the City acknowledged evacuation limitations through the “Know Your Way” i ni ti ative. The EIR does not appear to reconcile those recognized constraints with the additional population and vehi cle load i ntroduced by this project. Cumulative Wildfire Exposure Increasing mixed-use density within a Very High Fire Hazard Severity Zone increases populati on exposure and evacuation demand during extreme fire events. It is not evident that cumulative wildfire and evacuati on impacts have been fully evaluated with substantial evidence. I support thoughtful growth in Anaheim. But adding density in a constrained wildfire evacuation corridor without fi rst ensuring adequate infrastructure and emergency modeling is not responsible planning. Given these unresolved concerns, I respectfully urge you to vote NO on the Festival Shoppi ng Center Proposal. Thank you for your service to District 6 and for carefully considering the safety of the famili es you represent. Sincerely, Shelly Robbins Shelly.n.robbins@gmail.com 8141 E. Kennedy Rd, Anaheim, CA 92808 714-793-7447 Date:3/3/2026 12:56:33 PM From:"S R" shelly.n.robbins@gmail.com To:"Ryan Balius" RBalius@anaheim.net Cc:"Public Comment" publiccomment@anaheim.net Subject:[EXTERNAL] District 6 Resident – Request to Vote NO (Festival Shopping Ce nter Proposal DEV2023-00043) & CEQA CONCERNS 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. Dat e: 3-3-26 Time: 1 2:5 7 pm Dear Council Member Balius, As a District 6 resident, this proposal directly affects my family’s evacuation safety. I want to be clear that I am not opposed to housing or new development. However, growth must be accompanied by infrastructure that ensures safe evacuation i n a Very High Fire Hazard Severity Zone. In this case, that analysis and infrastructure do not appear to be i n place. I li ve i n Zone 4 of the Know Your Way Evacuation plan and have witnessed first hand fire on the hillside di rectly across the street from me (Basil & Kennedy Rd) during the Canyon Fire 2 of 2017 and have went through the challenges of attempting to evacuate only to be met with hours of gridlock. If it weren’t for the direction of the fire changing at the last minute heading toward the Bryant Ranch area of Yorba Linda, our family would have been unable to evacuate. While I appreciate efforts to fix the Know Your Way Plan, it does not account for human behavior and has not been tested. For that reason, I respectfully urge you to vote NO on the Festival Shopping Center Proposal DEV2023-00043 in its current form. The project site is located within a designated Very High Fire Hazard Severity Zone and lies near the burn area of the 2017 Canyon Fire 2, as well as multiple wildfire events originating east of Weir Canyon. Followi ng Canyon Fi re 2, the C i ty implemented the “Know Your Way” initiative in recognition of evacuation challenges i n thi s region. Given this documented fire history and hazard designation, CEQA requires careful analysi s of wi ldfi re exposure and emergency evacuation feasibility. Based on my review of the EIR, significant analytical concerns remai n unresolved. Evacuation Performance and Constrained Egress For several evacuation zones in this area, primary egress funnels down Weir Canyon Road toward the 91 West freeway interchange — a corridor that already experiences substantial commuter bypass traffi c due to regi onal growth in Ri verside County, Corona, and the Inland Empire. The EIR does not appear to include: Quantitative evacuation clearance time modeling; Analysis reflecting current baseline traffic conditions; Scenario-based modeling of wildfire events originating east of Weir Canyon; Evaluation of bottlenecks at the 91 interchange during emergency demand. Although California does not prescribe a statewide evacuation time standard, CEQA nevertheless requires substantial evidence demonstrating that a project would not impair safe emergency access. In a Very High Fi re Hazard Severity Zone dependent on a constrained evacuation funnel, the absence of evacuation clearance modeling raises seri ous concern. VMT Does Not Resolve Evacuation Feasibility While the EIR evaluates transportation impacts using Vehicle Miles Traveled (VMT), that metri c does not measure roadway capacity, interchange throughput, or evacuation performance. Regional growth has increased baseline congestion along Weir Canyon and the 91 corridor without corresponding expansi on of evacuation infrastructure. Compliance with VMT thresholds does not address whether emergency egress can functi on safely during wildfire conditions. Consistency with Prior Safety Planning After Canyon Fire 2, the City acknowledged evacuation limitations through the “Know Your Way” i ni ti ative. The EIR does not appear to reconcile those recognized constraints with the additional population and vehi cle load i ntroduced by this project. Cumulative Wildfire Exposure Increasing mixed-use density within a Very High Fire Hazard Severity Zone increases populati on exposure and evacuation demand during extreme fire events. It is not evident that cumulative wildfire and evacuati on impacts have been fully evaluated with substantial evidence. I support thoughtful growth in Anaheim. But adding density in a constrained wildfire evacuation corridor without fi rst ensuring adequate infrastructure and emergency modeling is not responsible planning. Given these unresolved concerns, I respectfully urge you to vote NO on the Festival Shoppi ng Center Proposal. Thank you for your service to District 6 and for carefully considering the safety of the famili es you represent. Sincerely, Shelly Robbins Shelly.n.robbins@gmail.com 8141 E. Kennedy Rd, Anaheim, CA 92808 714-793-7447 Date:3/3/2026 12:58:38 PM From:"S R" shelly.n.robbins@gmail.com To:"Natalie Rubalcava" NRubalcava@anaheim.net Cc:"Public Comment" publiccomment@anaheim.net Subject:[EXTERNAL] District 6 Resident – Request to Vote NO (Festival Shopping Ce nter Proposal DEV2023-00043) & CEQA CONCERNS 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. Dat e: 3-3-26 Time: 1 2:5 9pm Dear Council Member Rubalcava, As a District 6 resident, this proposal directly affects my family’s evacuation safety. I want to be clear that I am not opposed to housing or new development. However, growth must be accompanied by infrastructure that ensures safe evacuation i n a Very High Fire Hazard Severity Zone. In this case, that analysis and infrastructure do not appear to be i n place. I li ve i n Zone 4 of the Know Your Way Evacuation plan and have witnessed first hand fire on the hillside di rectly across the street from me (Basil & Kennedy Rd) during the Canyon Fire 2 of 2017 and have went through the challenges of attempting to evacuate only to be met with hours of gridlock. If it weren’t for the direction of the fire changing at the last minute heading toward the Bryant Ranch area of Yorba Linda, our family would have been unable to evacuate. While I appreciate efforts to fix the Know Your Way Plan, it does not account for human behavior and has not been tested. For that reason, I respectfully urge you to vote NO on the Festival Shopping Center Proposal DEV2023-00043 in its current form. The project site is located within a designated Very High Fire Hazard Severity Zone and lies near the burn area of the 2017 Canyon Fire 2, as well as multiple wildfire events originating east of Weir Canyon. Followi ng Canyon Fi re 2, the C i ty implemented the “Know Your Way” initiative in recognition of evacuation challenges i n thi s region. Given this documented fire history and hazard designation, CEQA requires careful analysi s of wi ldfi re exposure and emergency evacuation feasibility. Based on my review of the EIR, significant analytical concerns remai n unresolved. Evacuation Performance and Constrained Egress For several evacuation zones in this area, primary egress funnels down Weir Canyon Road toward the 91 West freeway interchange — a corridor that already experiences substantial commuter bypass traffi c due to regi onal growth in Ri verside County, Corona, and the Inland Empire. The EIR does not appear to include: Quantitative evacuation clearance time modeling; Analysis reflecting current baseline traffic conditions; Scenario-based modeling of wildfire events originating east of Weir Canyon; Evaluation of bottlenecks at the 91 interchange during emergency demand. Although California does not prescribe a statewide evacuation time standard, CEQA nevertheless requires substantial evidence demonstrating that a project would not impair safe emergency access. In a Very High Fi re Hazard Severity Zone dependent on a constrained evacuation funnel, the absence of evacuation clearance modeling raises seri ous concern. VMT Does Not Resolve Evacuation Feasibility While the EIR evaluates transportation impacts using Vehicle Miles Traveled (VMT), that metri c does not measure roadway capacity, interchange throughput, or evacuation performance. Regional growth has increased baseline congestion along Weir Canyon and the 91 corridor without corresponding expansi on of evacuation infrastructure. Compliance with VMT thresholds does not address whether emergency egress can functi on safely during wildfire conditions. Consistency with Prior Safety Planning After Canyon Fire 2, the City acknowledged evacuation limitations through the “Know Your Way” i ni ti ative. The EIR does not appear to reconcile those recognized constraints with the additional population and vehi cle load i ntroduced by this project. Cumulative Wildfire Exposure Increasing mixed-use density within a Very High Fire Hazard Severity Zone increases populati on exposure and evacuation demand during extreme fire events. It is not evident that cumulative wildfire and evacuati on impacts have been fully evaluated with substantial evidence. I support thoughtful growth in Anaheim. But adding density in a constrained wildfire evacuation corridor without fi rst ensuring adequate infrastructure and emergency modeling is not responsible planning. Given these unresolved concerns, I respectfully urge you to vote NO on the Festival Shoppi ng Center Proposal. Thank you for your service to District 6 and for carefully considering the safety of the famili es you represent. Sincerely, Shelly Robbins Shelly.n.robbins@gmail.com 8141 E. Kennedy Rd, Anaheim, CA 92808 714-793-7447 Date:3/3/2026 1:03:00 PM From:"S R" shelly.n.robbins@gmail.com To:"Norma C. Kurtz" NKurtz@anaheim.net Cc:"Public Comment" publiccomment@anaheim.net Subject:[EXTERNAL] District 6 Resident – Request to Vote NO (Festival Shopping Ce nter Proposal DEV2023-00043) & CEQA CONCERNS 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. Dat e: 3-3-26 Time: 1 :03pm Dear Council Member Campos-Kurtz, As a District 6 resident, this proposal directly affects my family’s evacuation safety. I want to be clear that I am not opposed to housing or new development. However, growth must be accompanied by infrastructure that ensures safe evacuation i n a Very High Fire Hazard Severity Zone. In this case, that analysis and infrastructure do not appear to be i n place. I li ve i n Zone 4 of the Know Your Way Evacuation plan and have witnessed first hand fire on the hillside di rectly across the street from me (Basil & Kennedy Rd) during the Canyon Fire 2 of 2017 and have went through the challenges of attempting to evacuate only to be met with hours of gridlock. If it weren’t for the direction of the fire changing at the last minute heading toward the Bryant Ranch area of Yorba Linda, our family would have been unable to evacuate. While I appreciate efforts to fix the Know Your Way Plan, it does not account for human behavior and has not been tested. For that reason, I respectfully urge you to vote NO on the Festival Shopping Center Proposal DEV2023-00043 in its current form. The project site is located within a designated Very High Fire Hazard Severity Zone and lies near the burn area of the 2017 Canyon Fire 2, as well as multiple wildfire events originating east of Weir Canyon. Followi ng Canyon Fi re 2, the C i ty implemented the “Know Your Way” initiative in recognition of evacuation challenges i n thi s region. Given this documented fire history and hazard designation, CEQA requires careful analysi s of wi ldfi re exposure and emergency evacuation feasibility. Based on my review of the EIR, significant analytical concerns remai n unresolved. Evacuation Performance and Constrained Egress For several evacuation zones in this area, primary egress funnels down Weir Canyon Road toward the 91 West freeway interchange — a corridor that already experiences substantial commuter bypass traffi c due to regi onal growth in Ri verside County, Corona, and the Inland Empire. The EIR does not appear to include: Quantitative evacuation clearance time modeling; Analysis reflecting current baseline traffic conditions; Scenario-based modeling of wildfire events originating east of Weir Canyon; Evaluation of bottlenecks at the 91 interchange during emergency demand. Although California does not prescribe a statewide evacuation time standard, CEQA nevertheless requires substantial evidence demonstrating that a project would not impair safe emergency access. In a Very High Fi re Hazard Severity Zone dependent on a constrained evacuation funnel, the absence of evacuation clearance modeling raises seri ous concern. VMT Does Not Resolve Evacuation Feasibility While the EIR evaluates transportation impacts using Vehicle Miles Traveled (VMT), that metri c does not measure roadway capacity, interchange throughput, or evacuation performance. Regional growth has increased baseline congestion along Weir Canyon and the 91 corridor without corresponding expansi on of evacuation infrastructure. Compliance with VMT thresholds does not address whether emergency egress can functi on safely during wildfire conditions. Consistency with Prior Safety Planning After Canyon Fire 2, the City acknowledged evacuation limitations through the “Know Your Way” i ni ti ative. The EIR does not appear to reconcile those recognized constraints with the additional population and vehi cle load i ntroduced by this project. Cumulative Wildfire Exposure Increasing mixed-use density within a Very High Fire Hazard Severity Zone increases populati on exposure and evacuation demand during extreme fire events. It is not evident that cumulative wildfire and evacuati on impacts have been fully evaluated with substantial evidence. I support thoughtful growth in Anaheim. But adding density in a constrained wildfire evacuation corridor without fi rst ensuring adequate infrastructure and emergency modeling is not responsible planning. Given these unresolved concerns, I respectfully urge you to vote NO on the Festival Shoppi ng Center Proposal. I’d like to remind you that you hold a duty to protect ALL Anaheim Residents regardless of thei r di strict. Thank you for your service to Anaheim and for carefully considering the safety of the families you represent. Sincerely, Shelly Robbins Shelly.n.robbins@gmail.com 8141 E. Kennedy Rd, Anaheim, CA 92808 714-793-7447 Date:3/3/2026 1:10:24 PM From:"S R" shelly.n.robbins@gmail.com To:"Natalie Meeks" NMeeks@anaheim.net Cc:"Public Comment" publiccomment@anaheim.net Subject:[EXTERNAL] Fwd: District 6 Resident – Request to Vote NO (Festival Shopping Ce nter Proposal DEV2023-00043) & CEQA CONCERNS 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. Dat e: 3-3-26 Time: 1 :1 1 pm Dear Council Member Meeks, As a District 6 resident, this proposal directly affects my family’s evacuation safety. I want to be clear that I am not opposed to housing or new development. However, growth must be accompanied by infrastructure that ensures safe evacuation i n a Very High Fire Hazard Severity Zone. In this case, that analysis and infrastructure do not appear to be i n place. I li ve i n Zone 4 of the Know Your Way Evacuation plan and have witnessed first hand fire on the hillside di rectly across the street from me (Basil & Kennedy Rd) during the Canyon Fire 2 of 2017 and have went through the challenges of attempting to evacuate only to be met with hours of gridlock. If it weren’t for the direction of the fire changing at the last minute heading toward the Bryant Ranch area of Yorba Linda, our family would have been unable to evacuate. While I appreciate efforts to fix the Know Your Way Plan, it does not account for human behavior and has not been tested. For that reason, I respectfully urge you to vote NO on the Festival Shopping Center Proposal DEV2023-00043 in its current form. The project site is located within a designated Very High Fire Hazard Severity Zone and lies near the burn area of the 2017 Canyon Fire 2, as well as multiple wildfire events originating east of Weir Canyon. Followi ng Canyon Fi re 2, the C i ty implemented the “Know Your Way” initiative in recognition of evacuation challenges i n thi s region. Given this documented fire history and hazard designation, CEQA requires careful analysi s of wi ldfi re exposure and emergency evacuation feasibility. Based on my review of the EIR, significant analytical concerns remai n unresolved. Evacuation Performance and Constrained Egress For several evacuation zones in this area, primary egress funnels down Weir Canyon Road toward the 91 West freeway interchange — a corridor that already experiences substantial commuter bypass traffi c due to regi onal growth in Ri verside County, Corona, and the Inland Empire. The EIR does not appear to include: Quantitative evacuation clearance time modeling; Analysis reflecting current baseline traffic conditions; Scenario-based modeling of wildfire events originating east of Weir Canyon; Evaluation of bottlenecks at the 91 interchange during emergency demand. Although California does not prescribe a statewide evacuation time standard, CEQA nevertheless requires substantial evidence demonstrating that a project would not impair safe emergency access. In a Very High Fi re Hazard Severity Zone dependent on a constrained evacuation funnel, the absence of evacuation clearance modeling raises seri ous concern. VMT Does Not Resolve Evacuation Feasibility While the EIR evaluates transportation impacts using Vehicle Miles Traveled (VMT), that metri c does not measure roadway capacity, interchange throughput, or evacuation performance. Regional growth has increased baseline congestion along Weir Canyon and the 91 corridor without corresponding expansi on of evacuation infrastructure. Compliance with VMT thresholds does not address whether emergency egress can functi on safely during wildfire conditions. Consistency with Prior Safety Planning After Canyon Fire 2, the City acknowledged evacuation limitations through the “Know Your Way” i ni ti ative. The EIR does not appear to reconcile those recognized constraints with the additional population and vehi cle load i ntroduced by this project. Cumulative Wildfire Exposure Increasing mixed-use density within a Very High Fire Hazard Severity Zone increases populati on exposure and evacuation demand during extreme fire events. It is not evident that cumulative wildfire and evacuati on impacts have been fully evaluated with substantial evidence. I support thoughtful growth in Anaheim. But adding density in a constrained wildfire evacuation corridor without fi rst ensuring adequate infrastructure and emergency modeling is not responsible planning. Given these unresolved concerns, I respectfully urge you to vote NO on the Festival Shoppi ng Center Proposal. I'd like to remind you that as a representative of District 6, you uniquely hold a much stronger requi rement to speak out agai nst this project to represent the residents that you represent. Remember you were elected to represent us, no matter how much lobbyists try to pressure you. We expect you to represent the residents of the communi ty you were elected i nto and wi ll remember this vote at the next election for District 6 this year in determining if you are the best representati ve to conti nue representing District 6. Thank you for your service to District 6 and for carefully considering the safety of the famili es you represent. Sincerely, Shelly Robbins Shelly.n.robbins@gmail.com 8141 E. Kennedy Rd, Anaheim, CA 92808 714-793-7447 Date:3/3/2026 1:12:59 PM From:"S R" shelly.n.robbins@gmail.com To:"Public Comment" publiccomment@anaheim.net Subject:[EXTERNAL] Fwd: District 6 Resident – Request to Vote NO (Festival Shopping Ce nter Proposal DEV2023-00043) & CEQA CONCERNS 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. ---------- Forwarded message --------- From: S R <shelly.n.robbins@gmail.com> Date: Tue, Mar 3, 2026 at 1:05 PM Subject: District 6 Resident – Request to Vote NO (Festival Shopping Center Proposal DEV2023-00043) & CEQA CONCERNS To: <kmaahs@anaheim.net> Cc: <publiccmment@anaheim.net> Dat e: 3-3-26 Time: 1 :05pm Dear Council Member Maahs, As a District 6 resident, this proposal directly affects my family’s evacuation safety. I want to be clear that I am not opposed to housing or new development. However, growth must be accompanied by infrastructure that ensures safe evacuation i n a Very High Fire Hazard Severity Zone. In this case, that analysis and infrastructure do not appear to be i n place. I li ve i n Zone 4 of the Know Your Way Evacuation plan and have witnessed first hand fire on the hillside di rectly across the street from me (Basil & Kennedy Rd) during the Canyon Fire 2 of 2017 and have went through the challenges of attempting to evacuate only to be met with hours of gridlock. If it weren’t for the direction of the fire changing at the last minute heading toward the Bryant Ranch area of Yorba Linda, our family would have been unable to evacuate. While I appreciate efforts to fix the Know Your Way Plan, it does not account for human behavior and has not been tested. For that reason, I respectfully urge you to vote NO on the Festival Shopping Center Proposal DEV2023-00043 in its current form. The project site is located within a designated Very High Fire Hazard Severity Zone and lies near the burn area of the 2017 Canyon Fire 2, as well as multiple wildfire events originating east of Weir Canyon. Followi ng Canyon Fi re 2, the C i ty implemented the “Know Your Way” initiative in recognition of evacuation challenges i n thi s region. Given this documented fire history and hazard designation, CEQA requires careful analysi s of wi ldfi re exposure and emergency evacuation feasibility. Based on my review of the EIR, significant analytical concerns remai n unresolved. Evacuation Performance and Constrained Egress For several evacuation zones in this area, primary egress funnels down Weir Canyon Road toward the 91 West freeway interchange — a corridor that already experiences substantial commuter bypass traffi c due to regi onal growth in Ri verside County, Corona, and the Inland Empire. The EIR does not appear to include: Quantitative evacuation clearance time modeling; Analysis reflecting current baseline traffic conditions; Scenario-based modeling of wildfire events originating east of Weir Canyon; Evaluation of bottlenecks at the 91 interchange during emergency demand. Although California does not prescribe a statewide evacuation time standard, CEQA nevertheless requires substantial evidence demonstrating that a project would not impair safe emergency access. In a Very High Fi re Hazard Severity Zone dependent on a constrained evacuation funnel, the absence of evacuation clearance modeling raises seri ous concern. VMT Does Not Resolve Evacuation Feasibility While the EIR evaluates transportation impacts using Vehicle Miles Traveled (VMT), that metri c does not measure roadway capacity, interchange throughput, or evacuation performance. Regional growth has increased baseline congestion along Weir Canyon and the 91 corridor without corresponding expansi on of evacuation infrastructure. Compliance with VMT thresholds does not address whether emergency egress can functi on safely during wildfire conditions. Consistency with Prior Safety Planning After Canyon Fire 2, the City acknowledged evacuation limitations through the “Know Your Way” i ni ti ative. The EIR does not appear to reconcile those recognized constraints with the additional population and vehi cle load i ntroduced by this project. Cumulative Wildfire Exposure Increasing mixed-use density within a Very High Fire Hazard Severity Zone increases populati on exposure and evacuation demand during extreme fire events. It is not evident that cumulative wildfire and evacuati on impacts have been fully evaluated with substantial evidence. I support thoughtful growth in Anaheim. But adding density in a constrained wildfire evacuation corridor without fi rst ensuring adequate infrastructure and emergency modeling is not responsible planning. Given these unresolved concerns, I respectfully urge you to vote NO on the Festival Shoppi ng Center Proposal. Thank you for your service to District 6 and for carefully considering the safety of the famili es you represent. Sincerely, Shelly Robbins Shelly.n.robbins@gmail.com 8141 E. Kennedy Rd, Anaheim, CA 92808 714-793-7447 Date:3/3/2026 1:48:36 PM From:"S R" shelly.n.robbins@gmail.com To: "Public Comment" publiccomment@anaheim.net, "Ashleigh Aitken" AAitken@anahe im.ne t, "Carlos A. Leon" CLeon@anaheim.net, "Ryan Balius" RBalius@anaheim.net, "Natalie Rubalcava" NRubalcava@anahe im.net, "Norma C. Kurtz" NKurtz@anaheim.net, "Kristen Maahs" KMaahs@anaheim.net, "Natalie Meeks" NMe e ks@anaheim.net Subject:[EXTERNAL] Supplemental Information and Clarification of Prior Public Testimony – Fe stival Shopping Center Environmental Review - Vote No 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: 3-3-26 Time: 1:49pm Dear Mayor and Members of the City Council, I previously provided verbal testimony during public meetings regarding the proposed Festival Shoppi ng Center project and its Environmental Impact Report. This letter is submitted as supplemental information to clari fy and expand upon i ssues raised during that testimony so they may be considered as part of the administrative record for the project’s envi ronmental review. My prior testimony addressed concerns regarding traffic congestion, regional commuter patterns, wildfire evacuation condi ti ons, and safety constraints affecting Anaheim Hills residents. The information below summari zes and clarifies those poi nts so that they may be clearly documented in the record. Several of the issues discussed below were previously raised during public testimony and are i ncluded here to ensure the record clearly reflects those concerns. 1. Traffic Study Timing and Peak Hour Analysis The Draft Environmental Impact Report indicates that traffic data used for the project’s analysi s was collected duri ng a weekday period between approximately 4:00 PM and 6:00 PM. During prior public testimony, it was noted: “The study was conducted on a Tuesday between 4:00 and 6:00 p.m., yet our communi ty’s actual peak traffic often begins around 6:00 p.m. and continues until at least 7:00 p.m.” Residents in Anaheim Hills regularly experience congestion extending beyond the study wi ndow identified in the D EIR. In recent years, regional commuting patterns have shifted due to hybrid and remote work schedules, resulting i n extended or shi fted peak travel periods rather than the traditional peak windows historically used in traffic studi es. Because the transportation analysis appears to rely on a limited study period, the DEIR may not fully capture actual peak congestion conditions experienced by the community. Clarification would be helpful regarding: • The basis for selecting the 4:00–6:00 PM study period • Whether traffic data was collected or analyzed beyond 6:00 PM • Whether post-pandemic commuting patterns were considered in determining the study methodology • Whether extended peak-hour conditions currently experienced by residents were evaluated 2. Limited Corridor Scope and Regional Pass-Through Traffic The DEIR appears to analyze a limited set of local intersections while omitting several major corridors that residents experi ence as part of the same congestion network. During prior public testimony, it was noted: “The study only included a narrow selection of streets and did not appear to account for commuters from Yorba Li nda or regional drivers bypassing freeway congestion by using Santa Ana Canyon Road.” Anaheim Hills functions as a regional pass-through (cut-through) corridor for dri vers traveli ng between Orange C ounty, Riverside County, Corona, Yorba Linda, and surrounding communities. Many drivers use Santa Ana Canyon Road, Imperial Highway, Weir Canyon Road, and Gypsum Canyon Road as alternative routes to bypass freeway congestion. This regional pass-through traffic significantly affects congestion conditions in Anaheim Hills but does not appear to be fully reflected in the DEIR’s transportation analysis. Because these corridors function as interconnected commuter and evacuation routes, it is important that transportation modeling incorporate these regional travel patterns when forecasting project impacts. Clarification would be helpful regarding: • Whether regional pass-through commuter traffic was incorporated into the traffic forecasts • Whether origin-destination travel patterns from surrounding counties were evaluated • Whether the study area boundaries adequately capture regional corridors affecting congestion i n Anaheim Hills • Whether corridors such as Santa Ana Canyon Road, Imperial Highway, Weir Canyon Road, and Gypsum C anyon Road were considered in the analysis 3. Consideration of Regional Transportation Modeling The transportation analysis appears to rely primarily on localized intersection analysis and tradi ti onal tri p-generation methods. While such approaches are commonly used in project-level traffic studies, they may not fully capture regi onal travel behavi or affecting Anaheim Hills roadways. The Southern California Association of Governments (SCAG) maintai ns regional travel demand models designed to analyze cross-jurisdictional commuter flows across Southern C ali forni a. These regional models incorporate broader travel patterns, including cross-county commuter flows, regi onal housi ng growth trends, origin–destination travel patterns, and extended peak travel periods. Because Anaheim Hills experiences traffic influenced by regional commuting patterns, clarificati on would be helpful regarding whether regional modeling data or SCAG forecasts were considered when preparing the DEIR transportati on analysis. 4. Regional Growth and Cumulative Traffic Effects Anaheim Hills roadways are increasingly affected by regional population growth and commuter patterns extendi ng beyond the City of Anaheim. Over the past decade, significant residential development has occurred in nearby communi ti es wi thi n Riversi de and San Bernardino Counties, including areas such as Corona and the Inland Empire. These growth patterns have increased commuter traffic traveling through Anaheim Hills as drivers seek alternative routes between counti es or bypass freeway congesti on. As a result, corridors such as Santa Ana Canyon Road, Imperial Highway, Weir Canyon Road, and Gypsum Canyon Road function not only as local streets but also as regional travel routes connecting multi ple jurisdi cti ons. Under CEQA, environmental review must consider cumulative impacts, including reasonably foreseeable growth and travel demand affecting the transportation network. Because regional population growth contri butes to the traffi c condi ti ons experienced in Anaheim Hills, it would be helpful for the environmental analysis to clari fy how regi onal growth trends and cross- jurisdictional commuter patterns were considered in evaluating transportation and evacuati on conditions. Because regional commuter traffic and population growth directly influence congesti on conditions on evacuation corridors, consideration of these cumulative effects is important for accurately evaluating both transportation and wildfire evacuation impacts. 5. Baseline Assumptions Related to the Former Edwards Theater The DEIR appears to rely in part on historical assumptions related to activity levels associated with the former Edwards Theater located at the Festival Center site. During prior testimony, it was noted: “That theater had been declining for years prior to closing. A thousand parking spaces does not equal a thousand people.” The Edwards Theater closed in September 2022 and had experienced declining attendance for several years pri or to closure. If the transportation analysis assumes traffic levels associated with full parking capacity or peak theoretical theater attendance, the baseline conditions used in the DEIR may not accurately reflect actual site activity in recent years. Clarification would be helpful regarding whether baseline conditions reflect observed traffic levels or theoreti cal maximum parking capacity. 6. Evacuation Conditions, Wildfire Risk, and Evacuation Modeling Anaheim Hills residents have experienced significant evacuation challenges during past wildfire events affecti ng the area. During prior testimony, it was noted: “Seven minutes may seem negligible to the builders, but it is already over three hours for resi dents attempti ng to evacuate.” Residents have also described emergency conditions during prior wildfire events where indi viduals sought refuge i n commercial areas such as the Festival Shopping Center because evacuation routes were severely congested. Additionally, discussions with fire officials have indicated that the State of California has not established a specific evacuation time threshold that is considered “safe.” Because no statewide evacuation ti me standard exists, it is particularly important that environmental review clearly disclose the methodology used to evaluate evacuati on conditions. It is currently unclear from the DEIR what benchmark or performance standard was used to determine that evacuation condi ti ons are acceptable. Residents have also observed that wildfire events affecting Anaheim Hills have historically origi nated from multi ple di recti ons. During prior testimony, it was noted: “In the past, many fires affecting Anaheim Hills have come from the east, from Corona, not only from D eer Canyon.” Clarification would be helpful regarding: • Whether evacuation modeling incorporated historical wildfire scenarios affecting Anahei m Hi lls • Whether the analysis considered fire events originating east of Anaheim Hills under Santa Ana wi nd conditions • What methodology was used to evaluate evacuation performance in the absence of a statewide evacuation safety standard • Whether evacuation modeling incorporated realistic human behavioral factors duri ng emergency evacuati on events • Whether evacuation modeling evaluated congestion points or bottlenecks within the Anahei m Hi lls road network • Whether the analysis evaluated the time required for vehicles to clear known congestion poi nts along pri mary evacuati on routes Clear disclosure of evacuation modeling assumptions is particularly important in wildfire-prone areas where roadway capaci ty and evacuation timing directly affect public safety. 7. Consistency With Prior Safety Evaluations for Similar Projects During previous development proposals affecting nearby areas, concerns regarding wi ldfi re evacuati on capaci ty were raised by public safety officials. During prior testimony, it was noted: “A similar project in the Deer Canyon area raised evacuation concerns from publi c safety offi ci als. It is unclear what safety conditions or infrastructure improvements justify a different conclusion for the Festi val project.” If evacuation constraints influenced prior planning decisions regarding nearby developments, clari fi cation regardi ng any changes in safety conditions, infrastructure improvements, or emergency response capabili ti es would be helpful in understandi ng how safety considerations are being evaluated consistently across projects affecting the same evacuation network. Conclusion The issues described above relate to conditions experienced by Anaheim Hills resi dents and may assi st i n ensuri ng that the environmental analysis accurately reflects real-world traffic patterns, evacuation conditions, and regional travel behavior. This information is provided to assist the City in ensuring that the environmental analysi s accurately reflects the conditions experienced by residents and that the administrative record fully documents these concerns. These comments are provided to ensure that the administrative record accurately reflects the condi ti ons experi enced by Anaheim Hills residents and to assist the City in ensuring that the environmental analysi s fully evaluates transportation, evacuation, and cumulative impact considerations relevant to the project. Thank you for your time and consideration. Sincerely, Shelly Robbins Shelly.n.robbins@gmail.com 8141 E. Kennedy Rd, Anaheim, CA 92808 714-793-7447 Anaheim Hills Resident District 6 Date:3/3/2026 1:49:23 PM From:"S R" shelly.n.robbins@gmail.com To:"Public Comment" publiccomment@anaheim.net Subject:[EXTERNAL] Fwd: Supplemental Information and Clarification of Prior Public Testimony – Fe stival Shopping Center Environmental Review - Vote No 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. ---------- Forwarded message --------- From: S R <shelly.n.robbins@gmail.com> Date: Tue, Mar 3, 2026 at 1:48 PM Subject: Supplemental Information and Clarification of Prior Public Testimony – Festival Shopping Center Environmental Review - Vote No To: <publiccomment@anaheim.net>, <aaitken@anaheim.net>, <cleon@anaheim.net>, <rbalius@anaheim.net>, <nrubalcava@anaheim.net>, <nkurtz@anaheim.net>, <kmaahs@anaheim.net>, <nmeeks@anaheim.net> Date: 3-3-26 Time: 1:49pm Dear Mayor and Members of the City Council, I previously provided verbal testimony during public meetings regarding the proposed Festival Shoppi ng Center project and its Environmental Impact Report. This letter is submitted as supplemental information to clari fy and expand upon i ssues raised during that testimony so they may be considered as part of the administrative record for the project’s envi ronmental review. My prior testimony addressed concerns regarding traffic congestion, regional commuter patterns, wildfire evacuation condi ti ons, and safety constraints affecting Anaheim Hills residents. The information below summari zes and clarifies those poi nts so that they may be clearly documented in the record. Several of the issues discussed below were previously raised during public testimony and are i ncluded here to ensure the record clearly reflects those concerns. 1. Traffic Study Timing and Peak Hour Analysis The Draft Environmental Impact Report indicates that traffic data used for the project’s analysi s was collected duri ng a weekday period between approximately 4:00 PM and 6:00 PM. During prior public testimony, it was noted: “The study was conducted on a Tuesday between 4:00 and 6:00 p.m., yet our communi ty’s actual peak traffic often begins around 6:00 p.m. and continues until at least 7:00 p.m.” Residents in Anaheim Hills regularly experience congestion extending beyond the study wi ndow identified in the D EIR. In recent years, regional commuting patterns have shifted due to hybrid and remote work schedules, resulting i n extended or shi fted peak travel periods rather than the traditional peak windows historically used in traffic studi es. Because the transportation analysis appears to rely on a limited study period, the DEIR may not fully capture actual peak congestion conditions experienced by the community. Clarification would be helpful regarding: • The basis for selecting the 4:00–6:00 PM study period • Whether traffic data was collected or analyzed beyond 6:00 PM • Whether post-pandemic commuting patterns were considered in determining the study methodology • Whether extended peak-hour conditions currently experienced by residents were evaluated 2. Limited Corridor Scope and Regional Pass-Through Traffic The DEIR appears to analyze a limited set of local intersections while omitting several major corridors that residents experi ence as part of the same congestion network. During prior public testimony, it was noted: “The study only included a narrow selection of streets and did not appear to account for commuters from Yorba Li nda or regional drivers bypassing freeway congestion by using Santa Ana Canyon Road.” Anaheim Hills functions as a regional pass-through (cut-through) corridor for dri vers traveli ng between Orange C ounty, Riverside County, Corona, Yorba Linda, and surrounding communities. Many drivers use Santa Ana Canyon Road, Imperial Highway, Weir Canyon Road, and Gypsum Canyon Road as alternative routes to bypass freeway congestion. This regional pass-through traffic significantly affects congestion conditions in Anaheim Hills but does not appear to be fully reflected in the DEIR’s transportation analysis. Because these corridors function as interconnected commuter and evacuation routes, it is important that transportation modeling incorporate these regional travel patterns when forecasting project impacts. Clarification would be helpful regarding: • Whether regional pass-through commuter traffic was incorporated into the traffic forecasts • Whether origin-destination travel patterns from surrounding counties were evaluated • Whether the study area boundaries adequately capture regional corridors affecting congestion i n Anaheim Hills • Whether corridors such as Santa Ana Canyon Road, Imperial Highway, Weir Canyon Road, and Gypsum C anyon Road were considered in the analysis 3. Consideration of Regional Transportation Modeling The transportation analysis appears to rely primarily on localized intersection analysis and tradi ti onal tri p-generation methods. While such approaches are commonly used in project-level traffic studies, they may not fully capture regi onal travel behavi or affecting Anaheim Hills roadways. The Southern California Association of Governments (SCAG) maintai ns regional travel demand models designed to analyze cross-jurisdictional commuter flows across Southern C ali forni a. These regional models incorporate broader travel patterns, including cross-county commuter flows, regi onal housi ng growth trends, origin–destination travel patterns, and extended peak travel periods. Because Anaheim Hills experiences traffic influenced by regional commuting patterns, clarificati on would be helpful regarding whether regional modeling data or SCAG forecasts were considered when preparing the DEIR transportati on analysis. 4. Regional Growth and Cumulative Traffic Effects Anaheim Hills roadways are increasingly affected by regional population growth and commuter patterns extendi ng beyond the City of Anaheim. Over the past decade, significant residential development has occurred in nearby communi ti es wi thi n Riversi de and San Bernardino Counties, including areas such as Corona and the Inland Empire. These growth patterns have increased commuter traffic traveling through Anaheim Hills as drivers seek alternative routes between counti es or bypass freeway congesti on. As a result, corridors such as Santa Ana Canyon Road, Imperial Highway, Weir Canyon Road, and Gypsum Canyon Road function not only as local streets but also as regional travel routes connecting multi ple jurisdi cti ons. Under CEQA, environmental review must consider cumulative impacts, including reasonably foreseeable growth and travel demand affecting the transportation network. Because regional population growth contri butes to the traffi c condi ti ons experienced in Anaheim Hills, it would be helpful for the environmental analysis to clari fy how regi onal growth trends and cross- jurisdictional commuter patterns were considered in evaluating transportation and evacuati on conditions. Because regional commuter traffic and population growth directly influence congesti on conditions on evacuation corridors, consideration of these cumulative effects is important for accurately evaluating both transportation and wildfire evacuation impacts. 5. Baseline Assumptions Related to the Former Edwards Theater The DEIR appears to rely in part on historical assumptions related to activity levels associated with the former Edwards Theater located at the Festival Center site. During prior testimony, it was noted: “That theater had been declining for years prior to closing. A thousand parking spaces does not equal a thousand people.” The Edwards Theater closed in September 2022 and had experienced declining attendance for several years pri or to closure. If the transportation analysis assumes traffic levels associated with full parking capacity or peak theoretical theater attendance, the baseline conditions used in the DEIR may not accurately reflect actual site activity in recent years. Clarification would be helpful regarding whether baseline conditions reflect observed traffic levels or theoreti cal maximum parking capacity. 6. Evacuation Conditions, Wildfire Risk, and Evacuation Modeling Anaheim Hills residents have experienced significant evacuation challenges during past wildfire events affecti ng the area. During prior testimony, it was noted: “Seven minutes may seem negligible to the builders, but it is already over three hours for resi dents attempti ng to evacuate.” Residents have also described emergency conditions during prior wildfire events where indi viduals sought refuge i n commercial areas such as the Festival Shopping Center because evacuation routes were severely congested. Additionally, discussions with fire officials have indicated that the State of California has not established a specific evacuation time threshold that is considered “safe.” Because no statewide evacuation ti me standard exists, it is particularly important that environmental review clearly disclose the methodology used to evaluate evacuati on conditions. It is currently unclear from the DEIR what benchmark or performance standard was used to determine that evacuation condi ti ons are acceptable. Residents have also observed that wildfire events affecting Anaheim Hills have historically origi nated from multi ple di recti ons. During prior testimony, it was noted: “In the past, many fires affecting Anaheim Hills have come from the east, from Corona, not only from D eer Canyon.” Clarification would be helpful regarding: • Whether evacuation modeling incorporated historical wildfire scenarios affecting Anahei m Hi lls • Whether the analysis considered fire events originating east of Anaheim Hills under Santa Ana wi nd conditions • What methodology was used to evaluate evacuation performance in the absence of a statewide evacuation safety standard • Whether evacuation modeling incorporated realistic human behavioral factors duri ng emergency evacuati on events • Whether evacuation modeling evaluated congestion points or bottlenecks within the Anahei m Hi lls road network • Whether the analysis evaluated the time required for vehicles to clear known congestion poi nts along pri mary evacuati on routes Clear disclosure of evacuation modeling assumptions is particularly important in wildfire-prone areas where roadway capaci ty and evacuation timing directly affect public safety. 7. Consistency With Prior Safety Evaluations for Similar Projects During previous development proposals affecting nearby areas, concerns regarding wi ldfi re evacuati on capaci ty were raised by public safety officials. During prior testimony, it was noted: “A similar project in the Deer Canyon area raised evacuation concerns from publi c safety offi ci als. It is unclear what safety conditions or infrastructure improvements justify a different conclusion for the Festi val project.” If evacuation constraints influenced prior planning decisions regarding nearby developments, clari fi cation regardi ng any changes in safety conditions, infrastructure improvements, or emergency response capabili ti es would be helpful in understandi ng how safety considerations are being evaluated consistently across projects affecting the same evacuation network. Conclusion The issues described above relate to conditions experienced by Anaheim Hills resi dents and may assi st i n ensuri ng that the environmental analysis accurately reflects real-world traffic patterns, evacuation conditions, and regional travel behavior. This information is provided to assist the City in ensuring that the environmental analysi s accurately reflects the conditions experienced by residents and that the administrative record fully documents these concerns. These comments are provided to ensure that the administrative record accurately reflects the condi ti ons experi enced by Anaheim Hills residents and to assist the City in ensuring that the environmental analysi s fully evaluates transportation, evacuation, and cumulative impact considerations relevant to the project. Thank you for your time and consideration. Sincerely, Shelly Robbins Shelly.n.robbins@gmail.com 8141 E. Kennedy Rd, Anaheim, CA 92808 714-793-7447 Anaheim Hills Resident District 6