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24 (02)Some people who received this message don't often get email from taluzzi@msn.com. Learn why this is important Date:3/23/2026 9:42:25 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, "Kristen Maahs" KMaahs@anaheim.net, "Natalie Meeks" NMe e ks@anaheim.net, "Carlos A. Leon" CLeon@anaheim.net, "Ryan Balius" RBalius@anaheim.net, "Natalie Rubalcava" NRubalcava@anaheim.net, "Jennifer Diaz" JDiaz@anaheim.net Subject:[EXTERNAL] Comprehensive Follow-Up and Request for Reconsideration – Unresolve d Public Safe ty, CEQA, and Safety Element Issues – Anaheim Hills Festival Center Project (DA 2023-00043 / FEIR No. 358) 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 23, 2026 City of Anaheim Mayor and Members of the City Council 200 S. Anaheim Boulevard Anaheim, CA 92805 Via Email: publiccomment@anaheim.net; cityclerk@anaheim.net; aaitken@anaheim.net; kmaahs@anaheim.net; nmeeks@anaheim.net; cleon@anaheim.net; rbalius@anaheim.net; nrubalcava@anaheim.net; jdiaz@anaheim.net Subject: Comprehensive Follow-Up and Request for Reconsideration – Unresolved Public Safety, CEQA, and Safe ty Element Issues – Anaheim Hills Festival Center Project (DA 2023-00043 / FEIR No. 358) Mayor Aitken and Members of the City Council, I respectfully submit this follow-up correspondence for inclusion in the administrative record regarding Development Application No. 2023-00043 and Final Environmental Impact Report (FEIR) No. 358. This letter is intended to: 1. Reiterate and incorporate all prior objections and concerns submitted in my February 3, March 3, and March 5, 2026 letters 2. Address the lack of substantive response to those communications 3. Introduce new, material information regarding the City’s incomplete wildfire evacuation study 4. Request reconsideration or delay of final actions pending full and consistent safety analysis I. Lack of Response and Incomplete Administrative Record To date, I have not received a response to any of my letters addressing the detailed public health, wildfire evacuation, emergency response, and Safety Element concerns raised in prior correspondence. Given the technical, legal, and life-safety nature of these issues, the absence of formal responses raises concern as to whether: These issues have been fully evaluated The administrative record adequately reflects them Required findings are supported by substantial evidence II. Professional and Public Health Perspective As a Registered Nurse (RN) and Public Health Nurse (PHN) with emergency department and critical care experience, my concerns are grounded in: Emergency response operations Hospital surge capacity Disaster preparedness Population-level risk assessment Wildfire evacuation is not theoretical—it is a predictable, recurring public health emergency in Anaheim Hills. III. Historical Wildfire Evidence and Known System Failures Anaheim Hills has experienced multiple significant wildfire events: 1982 Gypsum Canyon Fire 1993 Eastern Anaheim Hills Fire 2008 Freeway Complex Fire 2017 Canyon Fire 2 These events revealed consistent and documented vulnerabilities: Limited evacuation routes Congestion along Santa Ana Canyon Road Evacuation bottlenecks Delayed emergency response access Simultaneous ingress/egress conflicts These are recurring structural conditions—not hypothetical scenarios. IV. Fundamental Change in Risk Profile – Residential vs. Commercial Use The project replaces intermittent commercial use with 447 residential units, introducing: A permanent 24-hour population Sleeping residents during nighttime emergencies Children, elderly, and medically fragile individuals Mobility-limited residents requiring assistance Oxygen-dependent and chronic illness populations Unlike a theater, residential use creates: Continuous evacuation demand Increased EMS utilization Greater reliance on emergency systems This is a material and irreversible change in risk conditions. V. Emergency Medical and Healthcare System Impacts From a clinical operations perspective: During wildfire events: EMS response times increase Ambulance access is delayed Hospitals experience surge conditions Emergency departments may go on diversion Shelters must support medically vulnerable populations Wildfire smoke exposure leads to: Asthma exacerbations COPD decompensation Increased cardiac events Pediatric respiratory distress Anxiety and panic-related emergencies These are evidence-based public health impacts that scale with population density. VI. Evacuation Modeling Limitations The FEIR acknowledges: Increased evacuation times Significant unavoidable impacts Reliance on a Statement of Overriding Considerations However, evacuation models often fail to reflect real-world conditions: Panic behavior Disabled vehicles blocking lanes Smoke-reduced visibility Power outages Nighttime evacuations Simultaneous multi-neighborhood evacuation Evacuation failure is nonlinear—once capacity is exceeded, congestion escalates rapidly. VII. NEW MATERIAL ISSUE – Missing Wildfire Evacuation Study A critical issue now requires immediate attention: The City’s Own Wildfire Evacuation Study Has Not Been Completed Approved: March 2025 Cost: $180,000 Expected completion: ~9 months Status (March 2026): Not delivered Yet: The Festival Project was approved without it The project directly depends on evacuation safety analysis The study was intended to answer the very risks under consideration VIII. Inconsistency in Decision-Making The administrative record indicates: Evacuation conditions require further study Yet the approval implies: Sufficient information already exists These positions are internally inconsistent and materially significant. IX. Potential Conflict of Interest The City’s evacuation study contractor: Dudek The developer’s evacuation consultant: Dudek This raises legitimate concerns: Independence of analysis Objectivity of conclusions Public confidence in findings Even the appearance of conflict is problematic in a life-safety context. X. Timing and Integrity of the Study Approving the project prior to study completion: Alters baseline conditions Risks invalidating study conclusions Undermines the purpose of the study This creates a circular and compromised analytical framework. XI. General Plan Safety Element and Legal Consistency Under California law: Gov. Code §65302(g): Safety Element must address wildfire and evacuation Gov. Code §65300.5: Internal consistency required Key Safety Element principles: Minimize wildfire exposure Ensure evacuation capacity Maintain emergency access Avoid intensification without infrastructure support Parcel-level compliance ≠ system-level safety The City must demonstrate how this project remains consistent with these policies. XII. CEQA and Statement of Overriding Considerations Under CEQA: Significant impacts require substantial evidence Overriding considerations must be supported Here, the City overrides: Increased evacuation times Significant unavoidable impacts Without the City’s own evacuation study, the evidentiary basis is incomplete. XIII. Cumulative Risk and Infrastructure Timing Infrastructure improvements extend to future years (e.g., 2029) Risk begins immediately upon occupancy Cumulative development: Incrementally increases evacuation demand Pushes system toward threshold failure Anaheim Hills may be approaching that threshold. XIV. Legal, Fiscal, and Ethical Implications Potential consequences include: CEQA litigation Challenges under Housing Accountability Act Taxpayer-funded legal defense Long-term infrastructure strain If evacuation failure results in harm: Consequences extend beyond legal compliance Ethical responsibility becomes paramount XV. Request for Council Action In light of all prior and newly presented information, I respectfully request that the City Council: 1. Delay Final Approval Actions Until the Wildfire Evacuation Study is completed and released 2. Integrate Study Findings Into any final decision-making 3. Provide Formal Written Response Addressing: Evacuation capacity Safety Element consistency Role of incomplete study 4. Evaluate Rehearing / Reconsideration Based on: New material information Incomplete record Potential inconsistencies XVI. Closing This is not opposition to housing. It is a request that decisions involving life safety be made with complete, consistent, and transpare nt analysis. Approving high-density residential development in a wildfire-prone hillside community without the City’s own evacuation study is not consistent with: Public health principles Emergency preparedness standards Sound planning practice I respectfully urge the Council to take a measured, evidence-based approach before proceeding further. 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). If you are not the intended recipient of this message, please notify the sender by replying to this message, and then delete it from your system. 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