25 (005)Date:3/4/2026 8:06:45 AM
From:"Hisham Sabeh" sabehsbills@gmail.com
To:
"Ashleigh Aitken" AAitken@anaheim.net, "caleon@anaheim.net" caleon@anaheim.net, "Norma C. Kurtz"
NKurtz@anaheim.net, "Kristen Maahs" KMaahs@anaheim.net, "Natalie Me e ks" NMeeks@anahe im.net, "Ryan
Balius" RBalius@anaheim.net, "Natalie Rubalcava" NRubalcava@anaheim.ne t
Cc:"Public Comment" publiccomment@anaheim.net, "City Clerk" cityclerk@anaheim.net, "Indhira Y. Gagnon"
IGagnon@anaheim.net
Subject:[EXTERNAL] Legal & Safety Opposition to Second Reading of Festival Anaheim Hills Project (EIR No. 358)
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URGENT: Legal & Safety Oppos ition to Second Reading of Fes tival Anaheim Hills Project (EIR No. 358)
To the Honorable Mayor and Council Members ,
I am writing to formally oppos e the final adoption of the 447-unit project at the Anaheim Hills Fes tival s ite. The 4-3 vote on March 3rd was bas ed on an incomplete
and legally vulnerable record. We urge the Council to revers e its decis ion based on the following:
1. Failure to Mitigate the Documented 24-Minute Evacuation Delay (not 14)
According to EIR Appendix C (Res pons es to Written Comments ), the City admits this project results in a "potential extens ion of time to evacuate by approximately 24
minutes ." In a wind-driven wildfire in a Very High Fire Hazard Severity Zone (VHFHSZ), a 24-minute delay is the difference between life and death. Per SB 99 (2020)
and Gov. Code § 65302(g)(5), the City is required to ens ure res idential developments in hazard areas have adequate evacuation routes . A $200,000 developer payment
does not create a new road; it merely funds a plan to manage a gridlock that you are knowingly creating.
2. Omis s ion of Regional "Shadow Traffic" and Bypas s Volume
The Traffic Analys is (Section 4.17) is fundamentally flawed becaus e it ignores inter-city bypas s volume. Fairmont Blvd and Weir Canyon s erve as primary
"s hortcuts " for thous ands of commuters from Yorba Linda and the Inland Empire trying to avoid the 91 Freeway. This "s hadow traffic" is not documented in local
VMT (Vehicle Miles Traveled) s tudies but is a daily reality. Adding nearly 900 cars to a corridor that is already a regional relief valve is a direct violation of the
General Plan Safety Element.
3. Economic Des tabilization of the Home Ins urance Market
The Council has failed to s tudy the project’s impact on our crumbling insurance market. With premiums in 92807/92808 already s urging by 20–30% this year, adding
high-dens ity units to a high-ris k zone s ignals to carriers that the "ris k dens ity" has exceeded safe limits . This project acts as a "tipping point" for mas s ins urance
non-renewals , potentially rendering thous ands of exis ting homes uninsurable and uns ellable.
4. CEQA Incons is tency and Lack of Overriding Cons iderations
The "Statement of Overriding Cons iderations " is invalid becaus e the City has not exhaus ted feas ible alternatives in s afer, trans it-rich areas like the Platinum Triangle.
You are prioritizing developer convenience over the phys ical and financial s urvival of your cons tituents.
Thank you to the council members who voted NO on 3/3 and for thos e that voted yes , pleas e consider the facts above and Vote NO on March 24th.
Sincerely,
F. Sabeh
952 S Endicott Ct Anaheim Hills