10 (321)
Susana Barrios
From: Sean McEachern <sean.mceachern@sheaproperties.com>
Sent: Tuesday, March 3, 2026 4:37 PM
To: Amanda Lauffer <ALauffer@anaheim.net>; Heather R. Allen <HAllen@anaheim.net>
Cc: Fogg, Andrew K. <afogg@coxcastle.com>
Subject: \[EXTERNAL\] Festival - Letter Response
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Heather / Amanda,
Per our discussion, please see attached letter response to the recent letter received from Chatten Brown.
I will also bring a physical copy to the hearing.
Thank you,
Sean
Shea Properties
Sean McEachern
Vice President, Development | Multifamily Development & Acquisitions
O: 949-389-7078
130 Vantis Street, Suite 200 | Aliso Viejo, CA 92656
SheaProperties.com | Facebook | Linked In
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1
City Council, City of Anaheim March 3, 2026
c/o Theresa Bass, City Clerk
200 S. Anaheim Boulevard
2nd Floor, Suite 217
Anaheim, CA 92805
Dear City Council members,
This letter responds to an Anaheim Hills Festival Specific Plan Project comment letter submitted by Chatten Brown
Law (the “Chatten Brown Letter”) dated February 27th, 2026 and received earlier today. The comments focus on
the Evacuation Time Analysis and raises issues related to the fire evacuation report - specifically, whether the SALT
project is in evacuation area 8 or 9. Their basic argument is that SALT is “partially” in evacuation area 8 and, as
such, will evacuate to the east, along the same route as the Festival project, rather than to the west, as the
evacuation study assumes.
In response, the Dudek team offers:
1. The Know Your Way Plan has the Hills Preserve Project Evacuating to the east under the Deer Canyon Fire
scenario:
If a fire occurs in Deer Canyon, the evacuation study assumes that the Hills Preserve project would evacuate
to the west, away from the fire area, instead of driving towards the fire to the east. The Chatten Brown
Letter claims that if the ignition point is located further to the southwest in the canyon that the fire may not
reach east Santa Ana Canyon Road and, thus, residents from the project would still evacuate to the
east. This assertion is incorrect. As Figure 4b in the Chatten Brown Letter shows, there would be a much
lower fire risk to the Hills Preserve project under this scenario and they would most likely shelter in place
instead of evacuating. However, if such a fire reached a point where the residents of the Hills Preserve
project would need to evacuate, they would still need to evacuate to the west, away from the oncoming fire,
as at that point it would be closer to the east side of the project and Santa Ana Canyon Road. As the
comment pointed out, the Hills Preserve Fire Plan also identified this same issue, and notes that residents
would need to evacuate west, away from the fire, under these conditions. While the Hills Preserve Project
was denied due to evacuation concerns, it does not invalidate this aspect of its evacuation study, as the
comment suggests. Also, it is important to note that the Know Your Way program indicates routes may
change depending on fire progression, which is the basis for the Evacuation Analysis conclusions based on
the fire scenario considered worst-case.
2. The approach ignores the differences between commercial uses and residential uses:
The Chatten Brown Letter notes that residents will take longer to prepare for evacuation than commercial
users. While this may be the case, it would present a more desirable scenario than what was analyzed. This
scenario would result in a more staggered pattern of evacuators reaching the roadway network, creating
less of a bottle neck at critical points, such as the Wier Canyon Road / Santa Ana Canyon Road
intersection. The evacuation memo takes a more conservative approach assuming all users within the
TO: ANAHEIM CITY COUNCIL
SUBJECT: ANAHEIM HILLS FESTIVAL SPECIFIC PLAN PROJECT
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project, as well as the adjacent neighborhoods would all leave at the same time, creating a larger bottle
neck at the choke points. As noted in the Evacuation Memo, the full evacuation is anticipated to take over
3 hours to evacuate the area, this time would account for the time it would take for residents within the
area to prepare to evacuate. Additionally, the comment cites no sources, standards, or studies that confirm
their claims, nor does it cite any evidence that the behaviors of the different groups will meaningfully impact
evacuation times.
3. The comment also suggests that the Project is indicated in the wrong fire hazard severity zone. At the time
of the report’s preparation, the fire hazard severity zone was consistent with the technical memorandum.
CAL FIRE updated its mapping and later, the City adopted the new mapping, which does include the Project
site within a high and very high fire hazard severity zone. This map change does not impact the Project’s
evaluation. The project’s fire protection plan and the evacuation study considered the project directly
adjacent to very high fire hazard severity zones and required the same restrictive ignition resistant
requirements as a project directly within one of these zones. The map change does not impact any of the
critical evacuation procedures or approaches as detailed in the evacuation study. Therefore, although the
Project’s mapped FHSZ is inaccurately portrayed in the Evacuation Time Analysis, it is only a map edit that
would be needed and no other changes would be triggered. Most importantly, though, this map edit would
not change any of the analysis or conclusions detailed in the Evacuation Study.
Sincerely,
____________________________________
Michael Huff
Senior Director – Fire Protection Planning
Michael Huff