25 (052)You don't often get email from jfilppi@gmail.com. Learn why this is important
Date:3/21/2026 10:16:58 AM
From:"Julie Filppi" jfilppi@gmail.com
To:
"Ashleigh Aitken" AAitken@anaheim.net, "Ryan Balius" RBalius@anaheim.net, "Carlos A. Le on"
CLeon@anaheim.net, "Natalie Rubalcava" NRubalcava@anaheim.net, "Norma C. Kurtz" NKurtz@anaheim.net,
"Kristen Maahs" KMaahs@anaheim.net, "Natalie Meeks" NMeeks@anaheim.net, "Public Comme nt"
publiccomment@anaheim.net
Subject:[EXTERNAL] Festval Development CEQA Violation
Attachment:
Rudy Emami City Council Agenda Report March 25 2025.pdf;Zone 10 KnowYourWay.jpg;Zone 11
KnowYourWay.jpg;Zone 9 KnowYourWay.jpg;4.9-2_Evacuation Travel Time Analysis Figure 7 Only.pdf;Zone 8
KnowYourWay.jpg;
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.
Mayor and City Council Members,
The proposed Festival Center Development is not merely problematic—it is in clear violation of California Environmental Quality Act (CEQA).
The project fundamentally undermines the established Know Your Way Evacuation Plan that was in place at the time the Final Environmental
Impact Report (FEIR) was prepared, and there is no feasible mitigation for this impact.
When the FEIR was developed, the Know Your Way Plan was not hypothetical or “fluid”—it was publicly posted, formally distributed, and
actively relied upon by residents. It is the baseline condition CEQA requires to be analyzed. Any deviation from that baseline is not a minor
oversight; it is a failure to comply with the law.
The FEIR asserts that, in the event of a worst-case fire scenario in Deer Canyon, all traffic along Santa Ana Canyon Road would move westbound
toward Imperial Highway. This claim is flatly inconsistent with the City’s own evacuation plan. The Know Your Way Plan explicitly directs
residents in Zones 11, 10, 9, and 8 to evacuate eastbound on Santa Ana Canyon Road toward Weir Canyon Road—directly through the location
of the proposed development. Ignoring this reality does not make the conflict disappear; it renders the FEIR inaccurate and legally deficient.
City staff have attempted to justify this discrepancy by describing the evacuation plan as “fluid.” That characterization is irrelevant under CEQA.
The law does not permit agencies or developers to rely on vague, shifting assumptions to avoid analyzing real, documented conditions. CEQA
requires a good-faith, evidence-based analysis of the actual plan in effect—not a speculative alternative that minimizes impacts on paper.
Further compounding this issue, the City allocated $180,000 in public funds to develop a comprehensive wildfire evacuation study for the Anaheim
Hills area. Yet despite repeated public records requests, residents have been denied access to this information. This lack of transparency raises
serious concerns about what the analysis might reveal and why it has not been disclosed.
At a recent City Council meeting, Council Member Meeks expressed confidence in the current evacuation plan. However, Director of Public
Works, Rudy Emami, suggests a far less certain assessment. His City Council Agenda Report dated March 25, 2025 (see attached) outlines
deficiencies that directly mirror the concerns residents have consistently raised. These contradictions cannot be ignored—they underscore the need
for a clear, honest, and legally compliant analysis.
To be clear: the evacuation plan in effect in September 2025, when the FEIR was finalized, is the only plan that can legally serve as the basis for
analysis. The developer does not have the authority to revise or reinterpret that plan to make the project appear acceptable. Yet that is exactly
what appears to have occurred in the FEIR Appendix 4.9-2 (Evacuation Travel Time Analysis, Figure 7).
This is not a technicality. It is a violation of CEQA, and it demands correction.
Sincerely,
Julie Filppi – Anaheim Resident since 1972
200 S. Anaheim Blvd.
Second Floor
Anaheim, CA 92805
Tel: (714) 765-5176
Fax: (714) 765-5225
www.anaheim.net
CITY COUNCIL AGENDA REPORT
City of Anaheim
DEPARTMENT OF PUBLIC WORKS
DATE:MARCH 25, 2025
FROM:DEPARTMENT OF PUBLIC WORKS
SUBJECT:CONSULTANT SERVICES AGREEMENT WITH DUDEK FOR
THE CITY OF ANAHEIM WILDFIRE EVACUATION PLAN
ATTACHMENT (Y/N):YES ITEM # 14
GOVERNMENT CODE § 84308 APPLIES: YES
RECOMMENDATION:
1.That the City Council, by Motion, approve the professional services agreement,
in the not-to-exceed amount of $180,000, with Dudek, for consultant services for
the City of Anaheim Wildfire Evacuation Plan, and authorize and direct the
Public Works Director, or designee to execute the Agreement, and take any and
all actions as are necessary, required or advisable to implement and administer
the Agreement; and,
2.Increase the Public Works Department’s FY 2024/25 revenue and expenditure
budgets in the Restricted Transportation Grant funds by $90,000.
BACKGROUND:
The easternmost part of the City of Anaheim, commonly referred to as Anaheim Hills, is
an At-Risk community. CAL FIRE has designated a majority of this part of the City as a
Very High Fire Hazard Severity Zone within a Local Responsibility Area. The location
of Anaheim Hills in the wildland-urban interface within the Santa Ana Mountain
foothills makes wildfires a significant threat to the area.
Given the history of wildfires in the area, the future development of the region, and
changes in State legislation around evacuation preparedness, the City is looking to create
a comprehensive Wildfire Evacuation Plan for Anaheim Hills. The plan is consistent
with recently approved State legislative bills for cities to identify and evaluate evacuation
routes in very high fire hazard zones. Additionally, the plan will help the City comply
with recent updates to the California Environmental Quality Act (CEQA) when
determining the impacts of projects in wildfire prone areas.
In March 2024, the City of Anaheim applied for a grant from the California Fire Safe
Council (CSFC) USDA State Fire Capacity Grant Program to create a wildfire
evacuation plan for the City of Anaheim. The grant is funded by the US Forest Service
through the CSFC. In September 2024, the CSFC awarded a $90,000 grant for the City
to develop a wildfire evacuation plan (Plan), with a $90,000 local match.
DISCUSSION:
Consultant Services Agreement with Dudek for the City of Anaheim Wildfire Evacuation Plan
March 25, 2025
Page 2 of 3
In October 2024, after awarding of the grant, staff developed and initiated a request for proposals
(RFP) for consulting services to develop a Plan. Staff posted an RFP on PlanetBids on November
27, 2024, with a scope of work specifying the following desired objectives (see Attachment 1).
Develop a comprehensive Wildfire Evacuation Plan for Anaheim Hills
Review and update existing mapping of critical evacuation routes, evacuation centers, and
single routes of access
Defining evacuation scenarios
Modeling and analysis of these scenarios
Education and outreach campaign for the development of the plan and distribution of
evacuation preparedness information
Developing recommendations, including thresholds of significance, possible mitigation
measures, and potential impact fee program.
At the conclusion of this effort, these findings will be used to inform future policy decisions and
also support environmental scoping for future development projects.
Consultant proposals were due on December 23, 2024, and as of that date three proposals were
received. In accordance with the qualification-based selection process, pursuant to City Council
Policy No. 4.1, Public Works established a review board, reviewed proposals, and rated the
proposals. The rated proposals are listed below in rank order.
Firm Ranking:
1.Dudek
2.Fehr & Peers Associates, Inc.
3.Bureau Veritas North America, Inc.
The evaluation criteria included the ability of the consultants to perform the specific tasks
outlined in the RFP, qualifications of the specific individuals who will work on the project,
amount of time and involvement of key personnel who will be involved in respective portions of
the project, reasonableness of the fee requested to do the work, demonstrated record of success by
the consultant on work previously performed, and the specific method and techniques to be
employed by the consultant on the project.
The review board concluded that Dudek was the most qualified firm based on the evaluation
criteria and is therefore recommended to provide professional services for the Plan.
Therefore, staff recommends that City Council approve the attached professional service
agreement with Dudek in the not-to-exceed amount of $180,000, and authorize the Public Works
Director to execute the agreement and take any and all actions that are necessary, required or
advisable to implement and administer the Agreement.
Upon City Council approval of these recommendations, Public Works staff will work to
immediately initiate this study effort. Dudek’s proposed schedule calls for a nine-month project
duration.
Consultant Services Agreement with Dudek for the City of Anaheim Wildfire Evacuation Plan
March 25, 2025
Page 3 of 3
This item supports Anaheim’s Strategic Plan Goal E. – Support Public Safety, Strategy No. 5 –
Assess the City’s Emergency Preparedness capabilities, resources, and tools, and implement
changes as needed to ensure the City is properly positioned to respond to disasters.
IMPACT ON BUDGET:
This action will increase the Department of Public Works Department’s revenue and expenditure
budget in Restricted Transportation funds by $90,000 for FY 2024/25. The required match will be
supported by the General Fund.
Respectfully submitted,
Rudy Emami
Director of Public Works
Attachments:
1.Agreement with Exhibit A (Proposal)
2.City Request for Proposals
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LEGEND
Project Location
Evacuation Zone
Direction of Travel
Road Closure
Study Intersection
Cumulative Project Location
Within Evacuation Zone
Not Within Evacuation Zone
Cumulative Projects
Anaheim Hills Festival
FIGURE 7SOURCE: Esri 2023; Open Street Maps 2023Z:\Projects\j1510901\MAPDOC\DOCUMENT\Evacuation Plan
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0D[DU
S a n ta Ana Canyon RoadE s p er a n za
R o adLakeview AvenueLa Palma Avenue
Orangethorpe Avenue
Nohl R a n c h R oad
Serrano AvenueCanyon Rim
Road
0LOHV
),*85(
&XPXODWLYH3URMHFWV
$QDKHLP+LOOV)HVWLYDO
Weir
Canyon Road
LEGEND
Project Location
Evacuation Zone
Direction of Travel
Road Closure
Study Intersection
Cumulative Project Location
Within Evacuation Zone
Not Within Evacuation Zone