24 (08)You don't often get email from anitayacoub@gmail.com. Learn why this is important
Date:3/23/2026 7:29:54 PM
From:"Anita Yacoub" anitayacoub@gmail.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] Request for Reconsideration of Festival Project
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.
City of Anaheim
Mayor and Members of the City Council
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:
Reiterate and incorporate all prior objections and concerns submitted in my February 3, March 3, and March 5, 2026 letters
Address the lack of substantive response to those communications
Introduce new, material information regarding the City’s incomplete wildfire evacuation study
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 transparent 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.
Thank you for your consideration,
Anita Yacoub, DVM
Anaheim Hills resident