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Susana Barrios From:Rick Moyer <dr.rickmoyer@gmail.com> Sent:Tuesday, July 21, 2026 6:40 AM To:Rafael Cobian; Cory Wilkerson; Rudy Emami Cc:Ashleigh Aitken; Natalie Meeks; Public Comment; Lindsey Young Subject:\[EXTERNAL\] DFES-"Contra-flow strategy" Warning: This email originated from outside the City of Anaheim. Do not click links or open attachments unless you recognize the sender and are expecting the message. Dear Rafael and Cory, I am writing to raise concern regarding the proposed evacuation plans for Weir Canyon and Santa Ana Canyon (SAC), specifically the suggestion to implement a "contra-flow" strategy to expedite evacuations during a wildfire. According to the DFES provided by Dudek, the contra-flow plan requires maintaining first responder access to evacuation areas, and it should only be implemented if contra-flow can be sustained all the way to SR-91 or another safe area. My primary concern is regarding first responder access. Large fire trucks, such as those used during the Canyon 2 fire, require a significant turning radius - typically an inside turning radius of 20 to 28.5 feet and an outside curb-to-curb turning radius of 45 to 55 feet. For example, as one travels down SAC, the road width varies significantly and often narrows to two lanes in either direction. Implementing a contra-flow system under these conditions would reduce first responder travel to a single lane and create significant logistical challenges at each intersection. Does this configuration provide sufficient room for large fire trucks to turn at intersections and access the area? This is a matter best left to the Anaheim fire department. For example, it should be relatively straightforward to have an experienced large fire truck driver, along with the Fire Chief and Fire Marshall, do a couple of practice runs on SAC and Weir Canyon to determine if the concept of contra-flow is even feasible. If it is feasible, then plans should be made to implement contra-flow early on in an evacuation, especially given the limited number of exits and historically long evacuation times. If it is not feasible, then the idea just needs to be dismissed. Best regards, Rick. -- Dr. Rick Moyer 1 Susana Barrios From:Rick Moyer <dr.rickmoyer@gmail.com> Sent:Tuesday, July 21, 2026 2:01 PM To:Rafael Cobian Cc:Ashleigh Aitken; Natalie Meeks; Public Comment; Lindsey Young; Cory Wilkerson; Rudy Emami Subject:Re: \[EXTERNAL\] DFES-"Contra-flow strategy" Thank you Rafael. Don't you think the time to determine whether or not contra-flow is truly a viable option on SAC and Weir Canyon is before another wildfire occurs? -R. Dr. Rick Moyer On Tue, Jul 21, 2026, 1:20 PM Rafael Cobian <RCobian@anaheim.net> wrote: Good Afternoon Dr Moyer, Thank you for your comments regarding the potential use of contra-flow on Santa Ana Canyon Road and Weir Canyon Road. The draft Wildfire Evacuation Study does not recommend that contra-flow automatically be implemented during every wildfire evacuation. Rather, it identifies contra-flow as one of several traffic management strategies that may be utilized as part of the City's emergency planning efforts. Any decision to implement contra-flow during an actual incident would be made by Unified Command/EOC based on the specific fire conditions, roadway conditions, available resources, and life-safety priorities. We agree that maintaining emergency responder access is a critical consideration. As noted in the Dudek Dynamic Fire Evacuation Study (DFES), contra-flow should only be considered where emergency vehicle access can be maintained and the operation can be sustained to a safe destination. Fire apparatus maneuverability, roadway geometry, lane widths, and intersection operations are all important operational factors that would need to be evaluated before such a strategy could be implemented. The operational feasibility of any traffic management strategy, including contra-flow, would ultimately be evaluated by Anaheim Fire & Rescue, the Anaheim Police Department, and Public Works through the City's emergency planning and incident command processes, coming from the EOC. The Study recognizes these operational considerations and does not assume that contra-flow would be appropriate or feasible under all wildfire scenarios. Thanks, Rafael Cobian, T.E., LEED GA 1 City Traffic Engineer City of Anaheim Public Works Department │ Traffic and Transportation 200 South Anaheim Boulevard │ Suite 276 Anaheim, CA 92805 (714) 765-4991 rcobian@anaheim.net From: Rick Moyer <dr.rickmoyer@gmail.com> Sent: Tuesday, July 21, 2026 6:40 AM To: Rafael Cobian <RCobian@anaheim.net>; Cory Wilkerson <CWilkerson@anaheim.net>; Rudy Emami <REmami@anaheim.net> Cc: Ashleigh Aitken <AAitken@anaheim.net>; Natalie Meeks <natalieameeks@gmail.com>; Public Comment <publiccomment@anaheim.net>; Lindsey Young <LYoung@anaheim.net> Subject: \[EXTERNAL\] DFES-"Contra-flow strategy" Warning: This email originated from outside the City of Anaheim. Do not click links or open attachments unless you recognize the sender and are expecting the message. Dear Rafael and Cory, I am writing to raise concern regarding the proposed evacuation plans for Weir Canyon and Santa Ana Canyon (SAC), specifically the suggestion to implement a "contra-flow" strategy to expedite evacuations during a wildfire. According to the DFES provided by Dudek, the contra-flow plan requires maintaining first responder access to evacuation areas, and it should only be implemented if contra-flow can be sustained all the way to SR-91 or another safe area. My primary concern is regarding first responder access. Large fire trucks, such as those used during the Canyon 2 fire, require a significant turning radius - typically an inside turning radius of 20 to 28.5 feet and an outside curb-to-curb turning radius of 45 to 55 feet. For example, as one travels down SAC, the road width varies significantly and often narrows to two lanes in either direction. Implementing a contra- flow system under these conditions would reduce first responder travel to a single lane and create 2 significant logistical challenges at each intersection. Does this configuration provide sufficient room for large fire trucks to turn at intersections and access the area? This is a matter best left to the Anaheim fire department. For example, it should be relatively straightforward to have an experienced large fire truck driver, along with the Fire Chief and Fire Marshall, do a couple of practice runs on SAC and Weir Canyon to determine if the concept of contra-flow is even feasible. If it is feasible, then plans should be made to implement contra-flow early on in an evacuation, especially given the limited number of exits and historically long evacuation times. If it is not feasible, then the idea just needs to be dismissed. Best regards, Rick. -- Dr. Rick Moyer 3 Susana Barrios From:Rick Moyer <dr.rickmoyer@gmail.com> Sent:Saturday, July 18, 2026 12:23 PM To:Rafael Cobian; Cory Wilkerson; Rudy Emami Cc:Ashleigh Aitken; Natalie Meeks; Carlos A. Leon; Ryan Balius; Natalie Rubalcava; Norma C. Kurtz; Kristen Maahs; Public Comment; Lindsey Young Subject:\[EXTERNAL\] Draft Fire Evacuation Study Attachments:Draft City of Anaheim wildfire evacuation study June 2026.pdf; Egress Thresholds and Wildfire Fatalities.pdf; Landforming excerpt.pdf Warning: This email originated from outside the City of Anaheim. Do not click links or open attachments unless you recognize the sender and are expecting the message. Ladies and Gentlemen: On June 25, 2026 I attended a meeting at the East Anaheim Community Center expecting to participate in a relevant discussion about the Draft Fire Evacuation Study by Dudek. However, the study itself was not presented and we were informed it would be made available on-line sometime afterwards. As such, it was not possible to discuss the study. I was informed that "comments" could be made up until July 20, 2026. The study is a 176-page long highly technical analysis which is often redundant, filled with minutiae, and contains many proposed theoretical scenarios which may or may not apply to the wind driven ember- related fire behavior in Anaheim Hills. It appears to be designed to transfer liability for fire evacuation to new developers, forcing them to abide by new "standards". It takes hours, even days to pour through. Perhaps most importantly, the study points out that the critical element in a fire evacuation in Anaheim Hills is the "Know Your Way" plan, which presently only provides 2 exits to safety (Lakeview at the 91, and Weir Canyon at the 91) with an optional third exit at Imperial at the 91 "if conditions dictate". Please note that Santa Ana Canyon Road is not an exit to safety, it is a conduit between the Weir Canyon and Lakeview exits. On June 9, 2026, UCSB published a multi-year study entitled Egress Thresholds and Wildfire Fatalities in the Proceedings of the National Academy of Sciences, pointing out that communities the size of Anaheim Hills need six exits to safety to effectively reduce the risk of fatalities in a wildfire evacuation. Unfortunately, this study was not addressed or referenced in the Draft Fire Evacuation Study (DFES), rendering the DFES obsolete. Given the gravity of this situation and the potential for loss of lives, to serve the best interest of the community you have an obligation to confer with Dudek, community members, as well as legal counsel regarding the egress thresholds presented in the landmark UCSB study and to revise the DFES and Know Your Way plan accordingly. Once this has been done, it would serve the community's best interest if you would re-release the revised DFES with highlighted changes 7-10 days before another community meeting so that we can have a meaningful public discussion. Lives are at stake. For your convenience I have attached a copy of the DFES and a copy of the UCSB study. I have also attached a copy of an excerpt from Landforming regarding the development of Anaheim Hills to remind everyone that building density has been a concern here for over 50 years. Sincerely, -- 1 Dr. Rick Moyer 2 PNAS 2026 Vol. 123 No. 23 e2535081123 https://doi.org/10.1073/pnas.2535081123 1 of 8 RESEARCH ARTICLE | ENVIRONMENTAL SCIENCES SUSTAINABILITY SCIENCE Egress thresholds and wildfire fatalities Caitlin R. Fonga,1 , Carlo W. Brodericka, Max A. Moritzb,c , and Benjamin S. Halperna,b Edited by Tom Cova, The University of Utah, Salt Lake City, UT; received December 8, 2025; accepted April 21, 2026 by Editorial Board Member Kathleen Segerson Avoiding human fatalities during wildfires is a key public policy objective. Outward road access, or the number of egress routes, is widely assumed to influence wildfire fatalities, yet few studies have quantified if or when this factor becomes critical. To address this gap, we assembled a dataset on community- level wildfire fatality counts and combined it with nationally consistent community egress for the United States, finding that cumulative fatalities are sharply concentrated in communities with very few exits, declining steeply to roughly six nonresidential roads, beyond which additional routes confer minimal further risk reduction. Extending this analysis nationally, we mapped all small communities (<50,000 residents) to identify geographic confluence of limited egress and high wildfire hazard, highlighting regions where road constraints could directly amplify fatalities. Across the United States, 17.7 million people live in communities below this critical egress threshold, including 2.5 million in high wildfire hazard areas. Although most high- risk communities are in the western United States, unexpected hotspots appear in Oklahoma, Florida, and Hawai’i. As wildfire hazard continues to expand with climate change, fuel accumulation, and development in the wildland–urban interface, even more communities may be at risk. Targeted investment in road infrastructure, improved evacuation communication and preparedness, and development of preplanned refuge options together offer complementary and actionable pathways to reduce wildfire fatalities and build nationwide resilience. infrastructure resilience | evacuation vulnerability | disaster resilience | spatial hazard assessment Wildfires have increased in pace, scale, cost, and destructiveness in recent decades (1–4), and extreme events have become more frequent (5), elevating wildfire resilience as a critical public and policy priority. Indeed, the loss of lives, destruction of property, insurance losses, and cost of suppression have increased as human populations have grown and expanded into more heavily vegetated and remote areas (1–3, 6). These escalating impacts on both social and ecological systems have intensified global concern and accelerated efforts to build and maintain wildfire-resilient communities (5, 7–10). A key element of these concerns is the increasing number of fatalities during extreme wildfire conditions (6, 11–15). Due to a scarcity of data, there are very few studies of fatality events or their drivers (16). While a growing body of literature has quantified indirect wildfire fatalities, particularly those from smoke exposure (17–20), research on direct fatalities remains rare and is typically limited to compiling counts rather than analyzing causal mechanisms (6, 12, 21). Existing research often relies on regional case studies or postevent reports rather than systematic, comparable datasets. This data scarcity has constrained the development of broader understanding about where, how, and why fatalities occur during extreme wildfire events. Road infrastructure and outward egress are widely assumed to influence wildfire-related fatalities. Limited or poorly connected road networks create structural vulnerability, restricting both firefighter access and civilian movement during wildfires (22), potentially increasing mortality risk. Delays or bottlenecks in egress can turn otherwise survivable fires into fatal events, making road connectivity a measurable and actionable component of community vulnerability. Despite long-standing assumptions about the importance of road infrastructure, few studies have systematically analyzed how network constraints contribute to wildfire fatalities. Instead, most prior work has emphasized behavioral factors through event- or regional-scale evacuation modeling, including GIS-based trigger-point analysis that links hazard spread with evacuation timing, and local-scale traffic simulations (23–25). These approaches are implemented in several established tools, such as k-PERIL, WUIVAC, WUI-NITY, and UrbanExodus, which allow detailed, scenario-based modeling that incorporates population behavior, road network constraints, and fire progression (reviewed in ref. 26). Our approach provides a complementary perspective by offering a nationally scalable, data-driven heuristic that identifies communities at elevated evacuation risk without relying on scenario-specific simulation. Indeed, systematic reviews underline Significance Preventing deaths during wildfires is a central public safety goal. Communities are often assumed to be safer when they have more ways to evacuate, yet few studies have measured when limited road access becomes deadly. We compile national data on wildfire fatalities and road networks to test this relationship. Fatalities were highly concentrated in communities with very few exits and declined sharply up to about six outward roads, beyond which additional routes provided little added safety. Mapping these patterns across the United States revealed 17.7 million residents living below this critical threshold, including 2.5 million in high wildfire hazard areas. Targeted investments in evacuation routes, communication systems, and refuge planning could substantially reduce wildfire deaths nationwide. Author affiliations: aNational Center for Ecological Analysis and Synthesis, University of California Santa Barbara, Santa Barbara, CA 93106; bBren School of Environmental Science, University of California Santa Barbara, Santa Barbara, CA 93106; and cUniversity of California Cooperative Extension, Oakland, CA 94612 Author contributions: C.R.F., C.W.B., M.A.M., and B.S.H. designed research; performed research; analyzed data; and wrote the paper. The authors declare no competing interest. This article is a PNAS Direct Submission. T.C. is a guest editor invited by the Editorial Board. Copyright © 2026 the Author(s). Published by PNAS. This open access article is distributed under Creative Commons Attribution- NonCommercial- NoDerivatives License 4.0 (CC BY- NC- ND). 1To whom correspondence may be addressed. Email: fong@nceas.ucsb.edu. This article contains supporting information online at https://www.pnas.org/lookup/suppl/doi:10.1073/pnas. 2535081123/- /DCSupplemental. Published June 1, 2026. OPEN ACCESS Downloaded from https://www.pnas.org by 70.185.140.219 on July 2, 2026 from IP address 70.185.140.219. 2 of 8 https://doi.org/10.1073/pnas.2535081123 pnas.org persistent gaps, noting that transportation infrastructure and net- work topology remain understudied relative to behavioral and hazard modeling (27). To fill this gap, we combined a finely resolved geospatial dataset of wildfire fatalities with a nationally consistent assessment of road network structure, enabling systematic analysis of how limited or constrained egress routes create heightened community-level vul- nerability. This approach produces a parsimonious, national-scale risk-prioritization metric that identifies places where vulnerable road networks coincide with elevated wildfire hazard and exposed populations. The framework is a critical prioritization layer to guide where more detailed modeling, community engagement, and infrastructure investment are needed to reduce fire-related fatalities. Results Wildfire Fatalities Are Concentrated in Communities with Few Exits. After assembling the most extensive georeferenced wildfire fatality dataset to date, we found that cumulative fatalities across all communities were sharply concentrated in those with very few exits (n = 39 communities). For each community, we calculated per- capita fatalities and found that cumulative wildfire fatalities declined steeply as exit numbers increased (slope = −4.00, SE = 0.16, P < 0.001), before dropping to near zero beyond approximately six exits (breakpoint 6.36, SE = 0.24; R2 = 0.9749, adjusted R2 = 0.9728; Fig. 1), revealing a strong threshold effect. The threshold near six exits is remarkably consistent across com- munities of varying population size (less than 100 to more than 40,000), suggesting that it reflects a structural rather than demo- graphic constraint. Communities with more residents tend to have more exits (linear regression, P < 0.001, R2 = 0.42), but the sharp decline in fatalities below this threshold suggests that road network redundancy, rather than population size per se, mitigates fatalities. With fewer than six outward routes, communities are unlikely to have multiple independent pathways, making them vulnerable to congestion, blockage, or simultaneous exposure to fire fronts. Above this threshold, additional exits confer little extra protection because redundancy and total egress capacity are no longer limit- ing. This pattern underscores that community egress design, spe- cifically ensuring several spatially independent exits, is critical to reducing wildfire fatalities, particularly in smaller, more isolated, or topographically constrained communities. Additional analyses exploring the relationships between exits, population, and per-capita fatalities are provided in SI Appendix, Figs. S2–S5, which support our choice of per-capita fatality as the primary metric. Case studies highlight how these structural constraints manifest in real events. In the 2018 Camp Fire, 66 of 86 total fatalities occurred in Paradise, California, a town with six outward roads clustered along similar corridors, offering limited functional redundancy during evacuation (Fig. 2A). The 2023 West Maui Fires in Lahaina, Hawai’i, killed 102 people. The town’s four out- ward routes—two northbound and two southbound—provided few independent escape options (Fig. 2B), and contemporaneous reporting described residents sheltering in the ocean when evac- uation routes became impassable. The 2020 North Complex Fires claimed 13 lives in Berry Creek, California, a small community with only two exits, both oriented northeast, providing minimal functional redundancy. Wildfire Fatality Risk Hotspots. Given the very strong relationship between egress and fatalities, we expanded our analysis to assess risk at the national scale. For each small community (<50,000 residents), we combined spatial wildfire hazard, road- network egress (number of outward exits), and population exposure (number of people) to produce a composite risk score. High wildfire hazard was concentrated in the western United States (California, Arizona, New Mexico, Colorado, Washington, Oregon, Idaho), parts of the South (Texas, Oklahoma, Florida), and Appalachia (Kentucky, West Virginia) (Fig. 3A). Road egress (Fig. 3B) and population exposure (Fig. 3C) were more broadly distributed across the country than wildfire hazard. Notably, 528 communities lacked any major road exits, distributed across all but nine states, but mostly located in Alaska, highlighting potential evacuation challenges in these areas. Combined into a wildfire fatality risk score, the distribution was strongly skewed: most communities faced relatively low risk, while a smaller subset in the West, South, and Southwest United States experienced substantially elevated risk where hazard, infrastructure constraints, and population exposure coincided (Fig. 3D). Although population exposure contributes to overall risk, our fatality analysis indicates that road egress is likely a key driver of wildfire fatalities. These hotspots of concern merit infrastructure improvements, evacuation planning, and shelter- in- place strategies. Although risk is conventionally expressed as a function of haz- ard, exposure, and vulnerability, our fatality analysis revealed that egress constraints strongly influence on outcomes. We therefore mapped wildfire hazard against egress for all small towns to isolate the interplay between these two risk factors, enabling us to dis- tinguish communities where elevated risk arises primarily from fire potential, from those where limited egress amplifies risk. Small communities with limited egress occur in every United States state, and those combining limited exit roads with high hazard exist in most states (N = 35), highlighting widespread potential for evac- uation challenges. More than 2.5 million people live in commu- nities with both high hazard and highly vulnerable road networks (Fig. 4, dark red). Another 8.5 million reside in high-hazard areas with more robust road access (Fig. 4, red), while 7.6 million expe- rience moderate hazard but limited egress (Fig. 4, purple). These high-risk small towns are geographically dispersed, with substantial hotspots not only in the West but also in the South and Southeast. Hotspots in the West are expected, given the region’s historical wildfire activity and recent destructive fires. By contrast, hotspots in the South and Southeast are less acknowl- edged. However, wildfires have been increasing in these regions (28), where dense populations combined with sprawling networks Fig. 1. Relationship between number community egress points and cumulative wildfire fatality rate (2008–2024). Each point represents a community. Communities are ordered by the number of outward exits, and per- capita fatalities are summed across all wildfire events affecting communities with that number of exits or fewer. The red line shows a segmented (“broken- stick”) linear regression fit. The vertical dashed line indicates the estimated breakpoint near six ( ≈6.36 ), beyond which additional exits are associated with very minimal reductions in cumulative fatalities.Downloaded from https://www.pnas.org by 70.185.140.219 on July 2, 2026 from IP address 70.185.140.219. PNAS 2026 Vol. 123 No. 23 e2535081123 https://doi.org/10.1073/pnas.2535081123 3 of 8 of small communities amplify the overlap of limited road egress and wildfire hazard. The scale and geographic breadth of these hotspots underscore the substantial challenges communities face and the urgent need to address structural road limitations across this country, and likely others impacted by growing wildfires and limited egress. Discussion Despite advances in wildfire prediction and emergency manage- ment, fatalities remain concentrated in communities where egress is constrained. Our findings quantify this risk, showing that lim- ited egress is a key determinant of catastrophic outcomes, high- lighting a critical but addressable component of community vulnerability. The threshold of six exits likely reflects the point at which road network redundancy becomes sufficient to absorb evacuation traffic and provide alternative escape routes. Below this threshold, communities are at elevated risk, with each reduction in the number of egress routes significantly and linearly increasing likely fatalities. As such, every additional egress point that can be created for communities below this threshold should have demon- strable benefit, providing a first-order guideline for infrastructure planning and emergency preparedness, as well as a tangible lever for retrofitting and redesigning communities to be more resilient to future fire events. Although some fatalities occur in burning homes, evacuation challenges are a common thread in most of the worst events. In the Camp Fire in 2018 in northern California, the rapid and widespread impact of fire on Paradise complicated evacuation efforts as traffic volumes quickly overwhelmed limited routes, while fire- and debris-related closures further restricted escape (29). Accounts from the event describe near-total gridlock within an hour of the first evacuation order, leaving some residents trapped as advancing flames cut off remaining routes (29, 30). Postincident analysis by the National Institute of Standards and Technology (NIST) concluded that heavy traffic combined with rapidly deteriorating fire conditions led to widespread gridlock, with normal travel times extending to hours and some residents becoming trapped when remaining egress routes were compro- mised (22, 29). These findings emphasize that constrained road-network connectivity and limited redundancy can amplify congestion under extreme conditions, leaving little margin for error once primary corridors fail (22, 29). A similar dynamic emerged in Lahaina, Hawai’i in 2023, where blocked roads and inconsistent communication compounded the chaos, with utility crews diverting drivers back toward town to avoid downed power lines (31). With 17.7 million people across the country residing in com- munities with critically limited egress, the urgency of targeted infrastructure improvements is great. And, as wildfire risk inten- sifies and spreads into areas that historically have not experienced much wildfire, the concern has become national. The western States still contain the majority of high-risk communities, which makes sense since the region is a hotbed for wildfires (5, 32), but additional hotspots exist in Oklahoma, Texas, Florida, and Hawai’i, revealing gaps in current national wildfire policy and public perception of risk. Indeed, neither Oklahoma nor Texas falls within the priority landscapes of the United States Wildfire Crisis Strategy, highlighting gaps in national prioritization (33). Oklahoma’s elevated risk stems from a convergence of factors: widespread small communities, vulnerable road systems, and high burn probabilities. Hazard in this region is a function of landscape characteristics such as flash fuels in the east and fire-prone pines in the west. Seasonal wind patterns, characteristic of “Tornado Alley,” further compound fire behavior and spread. Proactively addressing limited road egress is essential for future wildfire resilience, as many communities currently considered low-risk may soon face heightened danger due to evolving hazards. The wildfire hazard landscape in the United States is evolving rapidly due to anthropogenic drivers (34), making it critical to Fig. 2. Three examples of communities with fatalities in this study, Paradise, California (A), Lahaina, Hawaii (B), and Berry Creek, California (C). The blue shaded area represents the area of the community defined by the United States Census Designated Place (CDP). The black outline indicates the buffer we constructed to capture road networks (Materials and Methods). The black bar is a 5 km or approximately 3 mile scale (unique to each map) and all communities are oriented so up is north. Red circles indicate the approximate location of the fire’s origin, while the arrow indicates the direction of wildfire spread, for at least some point of the event. Notably, fires are dynamic and can result from multiple ignitions or rapidly changing conditions, as exemplified by Berry Creek during the North Complex Fire of 2020, where numerous lightning- ignited fires merged, including the Bear/Claremont Fire that ultimately impacted the community. Roads are colored based on their designation in Open Street Maps (OSM). Maps and metrics for every community in the United States under 50 k are available in the SI Appendix.Downloaded from https://www.pnas.org by 70.185.140.219 on July 2, 2026 from IP address 70.185.140.219. 4 of 8 https://doi.org/10.1073/pnas.2535081123 pnas.org identify communities that may appear low-risk today but that are highly vulnerable. An estimated 32% of the United States popu- lation now lives in areas with elevated burn probabilities (35), and fire suppression has contributed to a build-up of fuels, creating a so-called wildfire debt that is now coming due (36, 37). Human- driven ignitions are responsible for roughly half of the burned area nationwide and have significantly lengthened the wildfire season (7, 38). Meanwhile, climate change is already altering fire regimes, and projections indicate that it will further intensify fire weather, increase temperatures, and extend the fire season, particularly in areas not previously considered high-risk, exposing even histori- cally low-risk areas to future wildfire events (36, 39–42). Our finding that 4,202 communities inhabited by over two million people are served by only one or no nonresidential road under- scores the scale of this challenge. These communities may face heightened wildfire risk in the near future, not because their loca- tion is currently hazardous, but because their vulnerability makes them ill-equipped to handle even moderate fire events. Evidence from disaster risk reduction research indicates that proactive mit- igation investments generally yield net economic benefits (43). As such, proactive investments to future-proof these communities by improving infrastructure are essential components of long-term wildfire resilience planning. Looking ahead, continued growth of the wildland–urban inter- face (WUI) will create opportunities to proactively build more resilient communities. The WUI has expanded significantly over the past several decades and is expected to continue growing (44). Nearly all wildfire-related destruction occurs in the WUI, and there is increasing recognition that new developments must be designed with resilience in mind. However, regulations governing fire-resilient development remain inconsistent across jurisdic- tions, are often only recently created or weakly enforced, and rarely if ever address egress constraints (45–47), creating a major challenge for ensuring that new communities incorporate suffi- cient evacuation routes and other design features to minimize wildfire fatalities. Expanding road networks to facilitate evacuation is an intuitive response to rising wildfire risk, but it is neither universally feasible nor without cost. Roads themselves can increase ignition potential, though both the effect and mechanism are hotly debated, with drivers ranging from human presence to increased invasive species (38, 48–50). In many fire-prone regions, steep topography and land-use constraints further limit the practicality of constructing additional egress routes. Moreover, expanding road networks could induce population growth or development in high-risk areas, potentially offsetting some of the intended safety benefits. Consequently, road expansion alone cannot fully resolve the risk of entrapment that drives wildfire fatalities, and should be con- sidered alongside complementary interventions. One such complementary approach is to reduce the likelihood of entrapment by encouraging earlier and more efficient evacuation. Early and well-targeted warnings represent a critical lever for reduc- ing fatalities, particularly in communities with limited egress where even brief delays can prove deadly. The 2025 Eaton Fire in Altadena, California, underscores the stakes: all 17 deaths occurred in a neigh- borhood that received evacuation alerts only after the fire had already passed through (51). Yet even with timely warnings, evac- uation behavior is shaped by complex social, psychological, and cultural factors. Some residents leave only when danger feels immi- nent or escape routes appear limited (52, 53), while others, believ- ing themselves prepared or wishing to defend property, choose to stay (52). Age, gender, risk perception, and the cultural or economic costs of evacuation further influence decisions (52, 54–56). Additionally, the costs and cultural implications of evacuation may weigh more heavily on Indigenous communities, further compli- cating decision-making (55). Thus, behavioral interventions must Fig. 3. Maps of wildfire hazard, egress, exposure, and wildfire fatality risk for all small United States communities. All mapped communities have fewer than 50,000 people. Categories (bins) for each variable were set on percentile distributions of the data. Wildfire hazard (A) was categorized as high, middle, or low to reflect the top 90%, 50 to 90%, and bottom 50% of values. Road egress (B) was binned as high or low with cut points reflecting fatality analysis at 0 to 6 and >6. Population exposure (C) was binned by quantiles. Risk (D) was calculated as hazard × egress × exposure and mapped with an arcsine square root transformation to make spatial patterns more visible. Alaska is displayed at 50% scale of the continental United States. White regions are unoccupied by small towns (either unpopulated, or contain larger population centers).Downloaded from https://www.pnas.org by 70.185.140.219 on July 2, 2026 from IP address 70.185.140.219. PNAS 2026 Vol. 123 No. 23 e2535081123 https://doi.org/10.1073/pnas.2535081123 5 of 8 pair improved warning systems with community engagement strat- egies that reflect local realities and trust networks. While the present study provides a scalable, empirically grounded heuristic for identifying wildfire evacuation vulnerabilities, several limitations should be considered. First, this analysis identifies statis- tical associations between the number of egress roads and fatality rates, but direct causal inference is not possible. Other unmeasured factors such as road capacity, traffic management, or evacuation tim- ing undoubtedly influence outcomes, as in the Camp fire where road closures and congestion produced widespread gridlock, trapping residents (22, 29). Second, the metric assumes that evacuation occurs primarily via roads and personal vehicles. Cases of evacuation by sea, air, or other means are not captured, and the approach may not apply to communities that adopt defend-in-place strategies rather than evacuation. Third, this study does not incorporate dynamic fire spread, temporal evacuation behavior, or community preparedness. Factors such as fire progression, spotting, or behavioral response may influence actual outcomes, and the heuristic is intended to identify general patterns rather than predict specific events. Fourth, road networks are represented using exit counts rather than full network flow or connectivity metrics, primarily due to the limitations of OpenStreetMap. The exit-count metric is robust to unconnected or missing minor roads, but detailed network-based or simulation mod- eling approaches, such as WUI-NITY, UrbanExodus, or K-PERIL, could complement this heuristic for local-scale analyses (reviewed by ref. 26). Fifth, population data are static and based on Census counts, which do not capture transient populations such as tourists in high-season periods, which significantly complicates evacuation deci- sions (57). Finally, this analysis does not account for dimensions of socioeconomic vulnerability that may independently influence risk. Despite these limitations, the proposed metric provides a straight- forward, nationally scalable tool to identify communities with ele- vated evacuation risk, complementing more detailed, scenario-specific modeling approaches. Conclusions Limited road access increases the risk of wildfire fatalities, and addressing this vulnerability offers one of the most direct ways to save lives. Although our results are derived from United States communities, the underlying dynamics of limited egress routes, growing WUIs, and escalating fire hazards pose a global threat, underscoring the relevance of these interventions internationally. Communities with few exits face sharply elevated risk, and stra- tegically increasing egress capacity could substantially reduce mor- tality during extreme fires. Mitigation efforts—such as risk-informed evacuation planning, traffic management, and community out- reach—can complement these infrastructure improve ments, while adaptation strategies, including the expansion and redundancy of road networks, enhance long-term escape capacity. The appropri- ate scale of action varies: local governments can directly address neighborhood-level vulnerabilities, whereas state and federal agen- cies provide essential support through funding, coordination, and cross-jurisdictional planning. Aligning efforts across these levels ensures that interventions are targeted, equitable, and scalable, giving people living in at-risk communities the best chance of survival as wildfire hazards intensify and spread. We point to three, nonexclusive pathways for intervention. First, communities can expand or diversify road networks to increase egress redundancy, though such solutions may be limited by terrain, cost, or ecological considerations. Second, proactive efforts to modify human behav- ior—through earlier warnings, improved risk communication, and community evacuation training—can reduce delays that transform congestion into tragedy. Third, investment in Temporary Refuge Areas (TRAs) and other preplanned shelter-in-place options can enhance survival when evacuation fails, as they were likely critical in recent fires such as the Camp Fire (29). These strategies outline a comprehensive approach to mitigating wildfire fatalities: expand- ing physical escape capacity where feasible, enabling faster and more adaptive evacuation behavior, and ensuring viable last-resort refuge when neither is possible. Our results provide clear guidance for targeted mitigation and adaptation investments, emphasizing the urgent need to align infrastructure planning with wildfire resilience strategies. Materials and Methods Fatality Data Compilation and Validation. We compiled a dataset of wildfire- related fatalities from two primary sources: the California Department of Forestry and Fire Protection (CalFire) annual “Redbooks” and the Western Fire Chiefs Fig. 4. Combined wildfire hazard and limited egress in small United States communities. Bivariate map showing limited egress and wildfire hazard for small United States communities (population < 50,000). Communities are classified into six combinations based on quantile bins of hazard and egress: low, moderate, and high for burn hazard and low and high for road egress.Downloaded from https://www.pnas.org by 70.185.140.219 on July 2, 2026 from IP address 70.185.140.219. 6 of 8 https://doi.org/10.1073/pnas.2535081123 pnas.org Association (WFCA) incident records. These sources provided the set of fatal fires and their associated incident characteristics. However, Redbooks are only availa- ble from 2008 onward and both sources only record the total number of civilian fatalities without reporting specific locations. To geolocate individual fatalities, we supplemented official reports with systematic web searches (news media, coroner’s reports, and agency releases), which allowed us to confirm names and locations for reported wildfire fatalities in the United States between 2008 and 2024 (see SI Appendix, Table S1 for full documentation). For this study, a “wildfire- related civilian fatality” was defined as a nonfire- fighting individual who died directly and immediately as a result of wildfire conditions during the event itself. This includes individuals whose bodies were recovered in vehicles, on foot, or within structures overtaken by fire. Fatalities were included only when the cause of death was directly attributable to fire exposure or entrapment during evacuation. We excluded deaths occurring after rescue (e.g., individuals who later died in hospital), longer- term smoke- related mortality, and deaths not directly caused by wildfire conditions. We also excluded one individual who died in the vehicle collision that ignited a fire and one civilian water tender engaged in firefighting operations (see notes in SI Appendix, Data and associated links for details of individual fatalities). For each fire, we recorded the total number of identified fatalities and linked them to the corresponding community and its estimated number of road exits. Notably, the 2025 Redbooks have not been released, which would likely include both the Eaton and Palisades fires from early 2025. Thus, we supplemented this dataset with media- reported information for these two fires. Of the 342 wildfire- related fatalities identified across 35 events, we identified Census Places (CPs) (which neighborhood they live in) for 315 individuals. All of the remaining 27 cases were excluded from analyses, for different reasons, Seventeen occurred in urban areas with populations greater than 50,000 (11 in Santa Rosa and six in Pacific Palisades, a neighborhood within the City of Los Angeles). These were excluded from our analyses because cities with >50,000 people have extensive road networks. One individual died in a vehicle collision that initiated the fire, and one was a civilian water tender who perished while working. Four deaths occurred in rural locations outside the boundaries of a Census Place, while one individual died later in a hospital without a reported place of residence. For three cases, no informa- tion could be located. Some of these unresolved classifications likely reflect privacy protections or reporting restrictions rather than true uncertainty in fatality counts. To test if road network characteristics influence wildfire fatality risk, we calcu- lated a per- capita fatality rate for each community by dividing identified fatali- ties by population. Communities were then ordered by number of exits, and we computed cumulative per- capita fatalities across this ordered list, so each point reflects the total fatalities for communities with that number of exits or fewer. Cumulative and concentration curves are common in epidemiology, environmen- tal risk assessment, and economics for revealing how outcomes concentrate across populations or places and for prioritizing interventions (36, 58–60). This approach highlights how fatalities are concentrated in communities with limited egress. We then applied a segmented (broken- stick) linear regression to fit two linear trends separated by an estimated breakpoint, representing a threshold number of exits at which additional egress no longer substantially reduces cumulative fatalities. Separate linear models were fitted on either side of the breakpoint. This approach follows established methods for identifying critical thresholds in ecological and hazard- related data (61, 62) and allows clear visualization of both the magnitude and location of potential safety thresholds. As a sensitivity analysis, we repeated this approach using percentile- ranked exit values to account for the uneven distribution of exits across communities [sensu (63, 64)], which yielded similar results (SI Appendix, Fig. S1). We note that the estimated breakpoint should be interpreted as a heuristic rather than a strict threshold: communities near the breakpoint experience the most dynamic changes in cumulative fatalities, and while additional exits beyond the breakpoint confer diminishing marginal bene- fits, they do not guarantee safety, nor does falling below it guarantee catastrophe. Additionally, as more data on communities and wildfire events are added, the estimated breakpoint may become more precise, refining our understanding of where cumulative fatalities respond most strongly to egress. This breakpoint thus provides a practical guideline for prioritizing interventions rather than a strict rule. Risk Mapping. To evaluate risk to communities, we first defined communities as CPs, which are geographic units designated by the U.S. Census Bureau to represent both incorporated and unincorporated communities. Incorporated CPs have legal boundaries and local governments; unincorporated CPs are defined solely for statistical purposes. These shapefiles were sourced from the United States Census Bureau’s TIGER/Line repository using a custom Python pipeline (retrieved February 13, 2025). We simultaneously obtained demographic data from the American Community Survey via the Census API to support population- based exposure estimates. This approach contrasts with other work that has used heuristic models to delineate communities based on their road networks (24). We focused on small communities, defined as those with fewer than 50,000 residents, following the United States Census Bureau’s threshold for small towns. These communities are less likely to be served by robust transportation networks, and therefore more likely to face egress challenges during wildfire events. We estimated risk by multiplying three components, following standard risk assessment methodologies (65): Risk = Hazard × Vulnerability × Exposure. To cre- ate comparable and interpretable inputs across the three variables with different units and scales, we first normalized all continuous inputs using a scaled percentile approach. Specifically, we rescaled each variable to a range between 0 and 1 based on the 1st to 99th percentile values. This approach minimizes the influence of extreme outliers while preserving meaningful relative differences. Values below the 1st per- centile are set to 0, and values above the 99th percentile are set to 1, such that: Hazard. We quantify wildfire hazard using the annual burn probability raster from the Wildfire Risk to Communities v2 (2024) release, which is derived from the latest national run of the Fire Simulation Model (FSim). FSim is a probabilistic fire- behavior modeling system that simulates tens of thousands of wildfire sea- sons under observed weather, fuels, topography, and ignition patterns to estimate the long- term, climatological probability that a given location burns in any given year. Inputs include LANDFIRE fuels and vegetation, topography, and spatially explicit ignition densities derived from the Fire Program Analysis Fire Occurrence Database, along with historical fire- season weather from Remote Automated Weather Stations. For each simulation, FSim samples thousands of plausible fire seasons based on the historical climatology (approximately 1992–2020) and sim- ulates ignition, spread, and containment across the continental United States. The resulting annual burn probability represents the long- term average likelihood that a given pixel burns in any year, rather than a forecast for a particular season. Thus, the hazard values represent an average annual likelihood of burning over many simulated seasons rather than a single- year forecast. The simulations are based on landscape and climate conditions through 2020, so they do not capture subsequent increases in fuel aridity or extreme fire weather observed in recent years—likely leading to an underestimation of current hazard. The burn probability map uses the native 270 m FSim grid downscaled to 30 m to match LANDFIRE 2.2.0 fuels and to extend burn probability estimates into developed (nonburnable) cells adjacent to wildland fuels, ensuring a continuous hazard surface for community- level analysis; thus our analysis works at 30- m resolution. For each CP, we created a 0.5 km buffer around the boundary and calculated the mean and maximum burn probability of all intersecting 30- m cells within this buffered perimeter. This distance was chosen to represent the imme- diate surroundings where firebrands (embers) can typically ignite structures—a primary mechanism of wildfire spread into communities (35, 66–69). Empirical and modeling studies show that ember transport distances of several hundred meters are common, while transport of up to 1 to 2 km can occur under extreme wind and fire conditions (69–71). To test the sensitivity of our results to this buffer size, we compared outcomes using a 2 km buffer, representing more extreme ember transport scenarios. A paired t test showed a statistically significant but numerically small difference between the mean burn probability of the full CP area and the 0.5 km buffer (t = −41.995, df = 30,264, P < 2.2e–16), with the buffer yielding slightly higher values (mean difference = –0.000166). The 2 km buffer produced marginally higher mean (mean difference = 9.26e–05, P < 0.001) and maximum burn probabilities (mean difference = 0.00047, P < 0.001), but these differences were minimal. We therefore retained the 0.5 km buffer as it captures the typical near- community ember exposure without overrepresenting rare, long- distance spotting events. For visualization, we divided burn probability into three hazard bins—low, medium, and high—using the 50th and 90th percentiles of the combined nor- malized mean and maximum burn probability within community perimeters. These percentile breaks were chosen to account for the strongly right- skewed [1]x_scaled =(x −P1)∕(P99 −P1).Downloaded from https://www.pnas.org by 70.185.140.219 on July 2, 2026 from IP address 70.185.140.219. PNAS 2026 Vol. 123 No. 23 e2535081123 https://doi.org/10.1073/pnas.2535081123 7 of 8 distribution of burn probabilities, in which most communities experience rela- tively low hazard. The 50th percentile separates the lower half of communities from the higher- risk half, while the 90th percentile highlights the subset of com- munities exposed to the most extreme hazard, allowing clearer visualization of both typical and extreme risk areas. Vulnerability. We quantify vulnerability as the number of access routes into and out of a community, providing a simple measure of potential egress constraints. Because detailed evacuation and traffic models require high- resolution local data and careful calibration (72), they are not scalable for national prioritization. Operational products and state studies (e.g., refs. 73–75) remain essential com- plements for local planning but lack consistency across jurisdictions. Instead, we focus on a parsimonious road- access metric that identifies areas with limited egress. We used OSM to identify roads that intersect with the boundary of a CP. OSM is a collaborative, user- driven mapping platform that provides freely available, editable geographic data, including roads. We only consider the higher- order types of roads (motorway, primary, secondary and tertiary roads), excluding small residential and unclassified roads (e.g., dirt, cycling routes) as we reason these are unlikely to be used for evacuation. While OSM data can contain errors or outdated information, we mitigate this limitation by using a simple, robust metric, counting the number of exits, rather than performing full network analyses, which are highly sensitive to missing or unconnected roads. At the highest level, OSM classifies motorways as roads designed for fast, long- distance travel with controlled access and no intersections. Next are trunk roads, which are major routes that connect cities and regions but have either intersec- tions or lower capacity than motorways. Primary roads are routes between towns and cities, while secondary and tertiary roads form regional and local connections, often linking smaller communities. OSM data were accessed December 13, 2024. To assess access for each community, we first buffered each CP by 6 km to capture major roads that may serve communities from the outskirts. We used this expanded boundary to query OSM and download candidate higher- order roads (motorway, trunk, primary, secondary, and tertiary). We then clipped these roads to a 0.5 km buffer around the original CP boundary, which we used to measure egress. Within this 0.5 km band, we tallied all intersecting roads and summed their tagged lane counts. This distance was chosen to represent roads that are realistically accessible to residents for evacuation or emergency response. Because two- lane roads are counted in both directions but functionally represent a single access point, we divided the total road count by two to estimate the number of true exits. For visualization, road vulnerability was binned as high (>6) or low (0 to 6), with the break point based on the results from our fatality analysis. Exposure. We quantified exposure as the normalized total population of each community. Population data came from the United States Census. For visualiza- tion purposes, we grouped exposure into four bins using quartiles, resulting in the categories: low, middle, high, and very high. Risk. We estimated a composite risk score for each community by multiplying the three components: Risk = Hazard × Vulnerability × Exposure. Although we calculated raw risk as the product of hazard, vulnerability, and exposure, the resulting distribution was right- skewed due to the multiplicative nature of the index and the influence of highly populated and/or low- risk communities. To improve interpretability and visual contrast in mapping and figures, we applied a variance- stabilizing transformation using the arcsine square root function. Software. We used R (RStudio) R version 4.4.0 and Python (VS Code) version 3.10.12. R analyses relied on the following packages: tidyverse, sf, rnaturalearth, rnaturalearthdata, RColorBrewer, scales, tidycensus, ggpubr, biscale, dplyr, ggplot2, and minpack.lm. Python analyses relied on the following packages: geopandas, pandas, osmnx, networkx, numpy, matplotlib, rasterio, rasterstats, shapely, tqdm, tenacity, requests, concurrent.futures, multiprocessing, zipfile, io, logging, glob, json, csv, ast, signal, functools, and mpl_toolkits. Excel file, data, codes and scripts data have been deposited in GitHub (https://github.com/ wwri/roads- pnas) (76). Data, Materials, and Software Availability. For full documentation, including complete code required to reproduce analyses and figures, see the ReadMe. All code required to perform analyses and generate figures is available at https:// github.com/WRI- Science/roads- pnas (76). Excel file, data, codes and scripts data have been deposited in GithHub (https://github.com/wwri/roads-pnas) (76). 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Effinger, “Traffic modeling of potential emergency wildfire evacuation routes,” Master’s Thesis, California Polytechnic State University, San Luis Obispo, CA (2011). 75. C. Zimmerman, R. Brodesky, J. Karp, “Using highways for no- notice evacuations: Routes to effective evacuation planning primer series” (Tech. Rep. FHWA- HOP- 08- 003, Federal Highway Administration, Washington, DC, 2007), https://rosap.ntl.bts.gov. 76. WRI Science, Data from “Roads, development, and environmental impacts in the global road network.” GitHub. https://github.com/WRI-Science/roads-pnas. Deposited 12 May 2026.Downloaded from https://www.pnas.org by 70.185.140.219 on July 2, 2026 from IP address 70.185.140.219. DRAFT Wildfire Evacuation Study City of Anaheim JUNE 2026 Prepared for: C ITY OF ANAHEIM 200 S. Anaheim Boulevard Anaheim, California 92805 Contact: David Kennedy Prepared by: 27271 Las Ramblas, Suite 340 Mission Viejo, California 92691 Contact: Austin Ott DRAFT DRAFT 17507 i JUNE 2026 Table of Contents SECTION PAGE NO. Acronyms and Abbreviations ............................................................................................................................................. v Executive Summary ......................................................................................................................................................... vii 1 Introduction .......................................................................................................................................................... 1 1.1 History of Wildfire and Evacuation ........................................................................................................ 1 1.2 Anaheim Hills Study Area ....................................................................................................................... 1 1.2.1 Climate ...................................................................................................................................... 2 1.2.2 Topography ................................................................................................................................ 2 1.2.3 Vegetation ................................................................................................................................. 2 1.2.4 Fire History ................................................................................................................................ 3 2 Regulatory Context ............................................................................................................................................ 15 2.1 Federal ................................................................................................................................................. 15 2.1.1 National Cohesive Wildland Fire Management Strategy ..................................................... 15 2.1.2 Federal Wildland Fire Management Policy ........................................................................... 15 2.1.3 National Fire Plan .................................................................................................................. 15 2.1.4 National Fire Protection Association Codes, Standards, Practices, and Guides ............... 16 2.1.5 Federal Energy Regulatory Commission ............................................................................... 16 2.1.6 Federal Emergency Management Agency ............................................................................ 16 2.1.7 Disaster Mitigation Act of 2000 ............................................................................................ 17 2.2 State ..................................................................................................................................................... 17 2.2.1 Senate Bill 99 ........................................................................................................................ 17 2.2.2 Assembly Bill 747 .................................................................................................................. 17 2.2.3 Assembly Bill 1409 ................................................................................................................ 17 2.2.4 Attorney General Guidance ................................................................................................... 17 2.2.5 CEQA ....................................................................................................................................... 18 2.2.6 CEQA Case Law ...................................................................................................................... 18 2.2.7 CAL FIRE ................................................................................................................................. 21 2.2.8 California Governor’s Office of Emergency Services ........................................................... 21 2.2.9 California Fire Code ............................................................................................................... 21 2.2.10 California Wildland–Urban Interface Code ........................................................................... 21 2.2.11 California Public Resources Code ......................................................................................... 21 2.2.12 California Government Code ................................................................................................. 22 2.2.13 2024 CAL FIRE Strategic Plan............................................................................................... 22 2.2.14 California Mutual Aid Agreement .......................................................................................... 22 2.2.15 Local Responsibility Area Fire Hazard Severity Zone Maps ................................................ 23 DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 ii JUNE 2026 2.3 City of Anaheim .................................................................................................................................... 23 2.3.1 General Plan ........................................................................................................................... 23 2.3.2 City of Anaheim Fire Code ..................................................................................................... 28 2.3.3 City of Anaheim Wildland–Urban Interface Code ................................................................. 29 2.3.4 City of Anaheim Weed Abatement ........................................................................................ 29 3 Emergency Response Plans and Preparedness Resources ........................................................................... 31 3.1 City of Anaheim .................................................................................................................................... 31 3.1.1 City of Anaheim Emergency Operations Plan ....................................................................... 31 3.1.2 City of Anaheim Local Hazard Mitigation Plan ..................................................................... 31 3.1.3 City of Anaheim Know Your Way in an Emergency .............................................................. 31 3.1.4 Preparing for Wildfire Website .............................................................................................. 32 3.1.5 City of Anaheim Public Utilities Wildfire Mitigation Plan ...................................................... 32 3.1.6 Community Emergency Response Team .............................................................................. 32 3.2 Other Relevant Plans ........................................................................................................................... 33 3.2.1 Orange County Transportation Authority Hazard Mitigation Plan ....................................... 33 3.2.2 County of Orange Community Wildfire Protection Plan ....................................................... 33 3.2.3 Orange Unified School District Safe School Plans ............................................................... 33 4 Public Outreach and Engagement ................................................................................................................... 35 4.1 Community Workshops ....................................................................................................................... 35 4.1.1 Self-Directed Activity .............................................................................................................. 35 4.1.2 Evacuation Role Play ............................................................................................................. 36 4.1.3 Community Discussions ........................................................................................................ 36 4.2 Community Survey ............................................................................................................................... 36 4.2.1 Greatest Wildfire Concerns ................................................................................................... 37 4.2.2 Biggest Obstacles to Evacuation .......................................................................................... 37 4.2.3 Behavior Under an Evacuation Alert vs. Evacuation Order ................................................. 37 4.2.4 Evacuation Information Sources ........................................................................................... 37 4.2.5 Desired City Actions ............................................................................................................... 37 4.3 Summary .............................................................................................................................................. 37 5 Existing Infrastructure ....................................................................................................................................... 39 5.1 Emergency Alert Systems .................................................................................................................... 48 6 Constrained Roadways and Parcels ................................................................................................................ 49 7 Fire Progression Modeling ................................................................................................................................ 53 8 Evacuation Modeling ........................................................................................................................................ 63 8.1 Evacuation Modeling Methodology, Assumptions, and Scenarios ................................................... 63 8.1.1 Methodology ........................................................................................................................... 63 8.1.2 Assumptions ........................................................................................................................... 64 8.1.3 Evacuation Scenarios ............................................................................................................ 65 DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 iii JUNE 2026 8.1.4 Evacuation Modeling Results and Analysis .......................................................................... 73 8.1.5 Method for Analyzing Effectiveness of City Improvements or Project Mitigation Measures .............................................................................................................. 76 8.1.6 Confidence Interval as a Threshold for Project Impact Determination .............................. 76 9 City Recommendations ..................................................................................................................................... 81 9.1 Infrastructure Recommendations ...................................................................................................... 81 9.2 Wildfire Preparedness Recommendations ........................................................................................ 82 9.3 Evacuation Readiness Recommendations ........................................................................................ 84 9.4 Recommendation Effectiveness ......................................................................................................... 85 9.5 Other Recommendations .................................................................................................................... 86 10 Analysis of Proposed Projects .......................................................................................................................... 87 10.1 CEQA Threshold of Significance for Wildfire Evacuation ................................................................... 87 10.1.1 Existing CEQA Evacuation and Wildfire Analysis .................................................................. 87 10.1.2 City of Anaheim Wildfire Evacuation Analysis Under CEQA ................................................. 88 10.2 Standard Technical Report Format and Methodology to Support Determinations ......................... 91 10.2.1 Determine Project Impact ..................................................................................................... 93 10.2.2 Mitigation Measures .............................................................................................................. 98 10.2.3 Identify and Select Appropriate Mitigation Measures ....................................................... 103 10.2.4 Demonstrate Mitigation Effectiveness ............................................................................... 105 10.3 Integrated Findings ........................................................................................................................... 107 11 Conclusion ....................................................................................................................................................... 109 11.1 Content Review .................................................................................................................................. 109 11.2 Looking Forward ................................................................................................................................ 111 12 References ...................................................................................................................................................... 113 TABLES 1 Historical Wildfires in Anaheim ........................................................................................................................... 4 2 Summary of CEQA Case Law ............................................................................................................................ 19 3 Roadway Classifications ................................................................................................................................... 46 4 Wildfire Behavior Modeling Inputs ................................................................................................................... 54 5 Summary of Evacuation Time by Scenario and Zone1 .................................................................................... 75 6 Evacuation Time Confidence Interval* by Zone .............................................................................................. 77 7 Evacuation Clearance Times for Scenarios 3 Through 6 with Active Signal Control Strategies .................. 79 8 Methods for Determining Impacts ................................................................................................................... 94 9 Potential Mitigation Measures ......................................................................................................................... 99 10 Mitigation Measure by Impact ........................................................................................................................ 104 DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 iv JUNE 2026 FIGURES 1 Study Area ............................................................................................................................................................ 5 2 City of Anaheim LRA FHSZ Map .......................................................................................................................... 7 3 Vegetation............................................................................................................................................................. 9 4a City of Anaheim Major Wildfire Map ................................................................................................................. 11 4b City of Anaheim Wildfire History ....................................................................................................................... 13 5 Safety Infrastructure Map ................................................................................................................................. 41 6 Constrained Roadways and Parcels ................................................................................................................ 51 7 Highway 241 Ignition: 33 mph NE Winds ........................................................................................................ 57 8 East Nohl Ranch Road Ignition: 33 mph NE Winds ........................................................................................ 59 9 Deer Canyon Road Ignition: 33 mph NE Winds ............................................................................................... 61 10 Wildfire Scenario 1: SR-241 ............................................................................................................................. 67 11 Wildfire Scenario 2: E. Nohl Ranch Road ........................................................................................................ 69 12 Wildfire Scenario 3: Deer Canyon Park ............................................................................................................ 71 APPENDICES A Community Engagement Summary B Anaheim Hills Fire Evacuation Analysis DRAFT 17507 v JUNE 2026 Acronyms and Abbreviations Acronym/Abbreviation Definition AB Assembly Bill AFR Anaheim Fire & Rescue APD Anaheim Police Department APU Anaheim Public Utilities CCR California Code of Regulations CCTV Closed-Circuit Television CEQA California Environmental Quality Act City City of Anaheim CMS Changeable Message Signage CWPP Community Wildfire Protection Plan CWUIC California Wildland–Urban Interface Code DAFN Disabilities and Access and Functional Needs EIR Environmental Impact Report EOP Emergency Operations Plan EVP Emergency Vehicle Preemption FARSITE Fire Area Simulator FEMA Federal Emergency Management Agency FHSZ Fire Hazard Severity Zone FPP Fire Protection Plan IBHS Insurance Institute for Business & Home Safety I Interstate IC Incident Command LRA Local Responsibility Area LANDFIRE Landscape Fire and Resource Management Planning Tools LHMP Local Hazard Mitigation Plan MMP Mitigation Monitoring Program MTT Minimum Travel Time OCTA Orange County Transportation Authority PRC California Public Resources Code SCE Southern California Edison SRA State Responsibility Area SR State Route VHFHSZ Very High Fire Hazard Severity Zone WES or Study Wildfire Evacuation Study WUI Wildland–Urban Interface DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 vi JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT 17507 vii JUNE 2026 Executive Summary The eastern portion of the City of Anaheim (City), commonly known as Anaheim Hills, faces exposure to wildfire due to its location in the Wildland–Urban Interface, hillside topography, adjacency to flammable vegetation, and the prevalence of extreme Santa Ana wind events. This Wildfire Evacuation Study provides the City with a comprehensive, data‑driven analysis of wildfire hazard, evacuation performance, community risk, and feasible improvements that enhance safety for residents and emergency responders. This Study fulfills the intent of Senate Bill 99 and Assembly Bill 747, aligns with the City’s General Plan Safety Element, and provides a defensible methodology for project‑level California Environmental Quality Act (CEQA) review. This Study establishes various thresholds through a standardized, modeling-based CEQA framework that evaluates project-specific effects on evacuation clearance times using various thresholds including a quantitative threshold derived from the Study’s determination of zone-by-zone confidence intervals. The confidence interval is the normal variability in evacuation time during an event caused by small variations with congestion and driving behavior which is captured by the evacuation modeling. Projects that increase modeled clearance times beyond this confidence interval, i.e., the normal variability in evacuation times, are considered to have a potentially significant evacuation impact unless mitigated. Mitigation effectiveness is demonstrated through modeling or substantial evidence consistent with the methods used in this Study. Anaheim Hills contains a mixture of Moderate, High, and Very High Fire Hazard Severity Zones shaped by steep slopes, continuous fuel beds, and strong downslope winds. The Study documents the area’s long history of destructive fires—including the Freeway Complex Fire and Canyon II Fire—and outlines how the City’s Know Your Way evacuation program, fire‑adapted building codes, and community preparedness efforts form the current operational foundation. This hazard context is further informed by extensive public outreach, including surveys, workshops, and community discussions. Residents identified limited evacuation routes, confusion regarding alerts vs. orders, and roadside vegetation conditions as core concerns. These insights directly inform the Study’s recommendations for readiness and communication. Wildfire progression was simulated using FlamMap’s Minimum Travel Time model, applying severe but plausible Santa Ana wind conditions across ignition points along State Route 241, East Nohl Ranch Road, and Deer Canyon. These scenarios illustrate how quickly fire can reach the Wildland–Urban Interface—sometimes within 15 minutes— and underscore the need for fire prevention, early situational awareness, rapid decision‑making, and phased evacuation strategies. While the modeling is intentionally conservative, it provides a critical basis for identifying vulnerable areas, validating fuel modification needs, and prioritizing evacuation sequencing. To evaluate the community’s ability to evacuate under realistic conditions, the Study employed microsimulation with Dynamic Traffic Assignment using PTV Vissim. Vissim is an industry-leading microscopic traffic simulation platform that directly models individual vehicle interactions, car-following and lane-changing behavior, signal control logic, and Dynamic Traffic Assignment under constrained and non-recurring conditions—making it the most technically robust and defensible tool available for evaluating evacuation clearance times and network performance during large-scale wildfire events. Six evacuation scenarios were tested, including two catastrophic “all‑zones‑at‑once” events and four area‑specific wildfire scenarios reflecting operationally sound phased evacuations. Four of the scenarios were then remodeled to demonstrate the effectiveness of certain corridor- wide enhancements. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 viii JUNE 2026 It is important to note that emergency personnel actions such as fire suppression or field direction of evacuating vehicles are not captured in the modeling, despite being a very real facet of evacuation. Evacuation modeling is not capable of directly capturing potential field interventions due to the immense variability of such actions across incidents, locations, and operational conditions. When interpreting the results of this Study, it is of paramount importance to understand that these findings represent intentionally conservative, worst-case conditions that would very likely be improved through the timely and coordinated field actions of various City staff such as Anaheim Fire & Rescue and the Anaheim Police Department. This Study supports CEQA-level project review, which is required to disclose reasonably foreseeable worst-case conditions using defensible assumptions, rather than rely on speculative or event-specific emergency response actions. Accordingly, the results are intended to provide a conservative planning baseline that ensures transparency, consistency, and defensibility in evaluating wildfire evacuation performance and potential project-related impacts. Key Findings ▪ Catastrophic all‑zone evacuations generate the longest clearance times and do not reflect modern operational practice. ▪ Phased evacuations, informed by fire spread direction and zone proximity, significantly improve evacuation efficiency and reduce congestion. This approach reinforces the value of the Know Your Way program as an effective tool that helps residents understand the phased evacuation strategy by knowing their zone and routes that can be used during an emergency. ▪ Under certain wildfire scenarios, specific zones (e.g., Zones 4, 8, and 13) exhibit the longest clearance times, identifying where improvements will have the greatest impact. ▪ A comparison of existing vs. cumulative land use shows variable impacts by zone, emphasizing the need for project‑level modeling as development occurs. ▪ A flush strategy enabled through signal interconnectivity and closed-circuit television (CCTV) significantly improves evacuation times, especially those zones nearest the wildland and farthest from State Route 91. These results reveal that timing, sequencing, and system operations matter as much as physical roadway capacity in determining actual evacuation performance. The Study provides transportation, wildfire preparedness, and evacuation readiness recommendations aimed at reducing system strain, strengthening defensibility, and creating earlier more predictable movement. Transportation recommendations are intended to increase traffic flow and include the following: ▪ Implement signal interconnectivity, CCTV monitoring, and a corridor‑specific flush strategy to prioritize outbound flow for at‑risk zones. ▪ Develop contra‑flow plans, where feasible, on key arterials. Although emergency personnel actions are not represented in the evacuation time or fire progression modeling, these actions would be expected to reduce evacuation times and slow fire progression. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 ix JUNE 2026 ▪ Add strategic lane/shoulder enhancements and evaluate possible new or emergency‑only connections. ▪ Coordinate with Caltrans to ensure freeway interchange operations support evacuation surges. Wildfire Preparedness Recommendations can be completed prior to an evacuation order and work to create more time for evacuees to escape by interrupting the spread of fire. Such measures include the following: ▪ Validate roadside vegetation clearance widths using fire behavior modeling and adjust where needed. ▪ Enhance perimeter fuel breaks and defensible space programs. ▪ Expand education regarding home hardening, Zone 0, and Firewise standards. ▪ Install additional ALERT California cameras for early detection and situational awareness. A successful evacuation requires effective communication and cooperation between public safety officials and those impacted by evacuation notices as the incident unfolds. Evacuation Readiness Recommendations include the following: ▪ Deploy area‑wide digital evacuation signage and strengthen cellular reliability through backup power requirements. ▪ Enhance public education on alerts vs. orders, expected pre‑movement times, and the rationale for phased evacuations. ▪ Address Disabilities and Access and Functional Needs, large‑animal evacuation coordination, and school‑day evacuation scenarios. In addition to evaluating existing conditions, the Study establishes a repeatable CEQA methodology for evaluating wildfire evacuation impacts of new development through a comprehensive, data driven framework for evaluating wildfire evacuation impacts under CEQA. Historically, CEQA wildfire analysis relied on qualitative judgments, generalized statements about roadway capacity, and limited or inconsistent evaluation of how development may affect evacuation performance. This Study provides the City with a defensible, standardized, and repeatable methodology that directly responds to evolving regulatory expectations, recent CEQA case law, and the California Attorney General’s wildfire impact guidance. A central contribution of the Study is the development of a quantitative evacuation performance threshold based on modeled zone level clearance time variability. Through extensive microsimulation—20 simulation runs for each evacuation scenario—the Study establishes a confidence interval for each zone, representing normal statistical variation in evacuation performance under identical conditions. The confidence interval captures the variations in the evacuation traffic dynamics including the way congestion forms and defines the range where evacuation times normally fall even when conditions are the same. Changes within that range are considered normal fluctuation, not a meaningful worsening of evacuation conditions. Under this framework, if a proposed project increases modeled evacuation times in any affected zone by more than the established confidence interval, the project is considered to have a potentially significant evacuation impact unless mitigated. This provides the City with the objective metric CEQA has increasingly required for evaluating “increased congestion,” “impairment of evacuation,” and “exacerbation of existing hazards.” Any increase beyond normal variation in modeled scenario specific evacuation time is a potentially significant impact DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 x JUNE 2026 In addition to quantitative thresholds, the Study offers a structured set of qualitative impact criteria aligned with Appendix G of the CEQA Guidelines, Assembly Bill 747, Senate Bill 99, and industry standard fire protection practices. These criteria support evaluation of emergency access, fire behavior exposure, defensible space feasibility, ignition potential, and roadway constraints—improving consistency, transparency, and defensibility in impact determinations. The Study also defines when projects must prepare a Fire Protection Plan and a Wildfire Evacuation Study, ensuring that analysis is appropriately tailored to the City’s Local Responsibility Area High and Very High Fire Hazard Severity Zones. By integrating wildfire behavior modeling, transportation microsimulation, infrastructure assessment, emergency operations context, and community conditions, this Study allows Anaheim to evaluate project-specific impacts within a scientifically grounded and locally calibrated framework. Importantly, it also provides a mitigation evaluation method, wherein project applicants can remodel evacuation performance with recommended improvements to demonstrate effectiveness. This aligns CEQA wildfire analysis with best practices and reduces litigation risk. The Wildfire Evacuation Study provides the City of Anaheim with a scientifically grounded, operationally realistic, and CEQA‑ready roadmap for improving wildfire safety and evacuation performance in Anaheim Hills. By integrating fire behavior modeling, microsimulation, infrastructure assessment, resident feedback, and regulatory requirements, the Study offers a clear blueprint for near‑term actions, long‑term investments, and consistent project‑level review. Implementing the Study’s recommendations will enhance public safety, support emergency response, reduce wildfire risk, and strengthen the City’s ability to navigate future development within fire‑prone landscapes. DRAFT 17507 1 JUNE 2026 1 Introduction This assessment has been completed to provide the City of Anaheim (City) with information related to the need for evacuation as a result of natural and human-caused hazard related events and is consistent with requirements outlined in Assembly Bill (AB) 747 and Senate Bill (SB) 99 from the 2019 legislative session, specifically requiring agencies to evaluate the capacity of their evacuation routes and identify key routes with only one point of access. 1.1 History of Wildfire and Evacuation As described in the City’s Local Hazard Mitigation Plan (LHMP), wildfires are a regular feature of ecosystems throughout California and burn in largely undeveloped and natural areas. As it became common practice in the twentieth century to suppress naturally occurring fires in wildland areas leading to a buildup of fuels and dry plant matter, simultaneously the Wildland–Urban Interface (WUI) became a highly desirable place to live, bringing more people into wildfire prone areas. The WUI is the zone of transition between the wilderness and human-developed lands. Historically, lightning has caused some of the state’s largest fires; however, in recent years, human activity (e.g., downed powerlines or electrical sources associated with development, roadside ignitions, etc.) has been the cause of many of the state’s most destructive fires. The number and severity of wildfires across California have dramatically increased with 15 of the most destructive fires occurring since 2015 (CAL FIRE 2025a). In 2018, California saw its deadliest and most destructive fire season on record (CAL FIRE 2018). In 2020, California had its largest fire season on record, with 4% of the state’s total land burning in a single year (CAL FIRE 2020). Moreover, fire season in California has grown to include late spring and early winter months, although wildfires can and do occur throughout the year. Wildfires can have tragic consequences for impacted populations, such as the communities of Pacific Palisades and Altadena after the Palisades Fire and Eaton Fire, respectively. These fires resulted in the death of 27 individuals and more than 18,000 structures damaged or destroyed. Moreover, post fire, burned areas can be more susceptible to flooding and landslides, as wildfire destroys the vegetation that helps slow down water runoff and hold slopes together (FEMA 2025). The ground may repel water rather than absorb it when faced with ash deposits. Due to the change in landscape structure after a fire, repelled water can carry debris into water reservoirs. Smoke and other particulate matter from wildfire pose a health risk, even to those not near the blaze. These large and destructive wildfires also result in mass evacuations, which often take hours and can put evacuees at risk, such as during the 2018 Camp Fire, 2024 Mountain Fire, 2025 Palisades Fire, and 2025 Eaton Fire. These recent wildfires also demonstrate the importance and necessity of preparing communities through the development of local evacuation plans and community preparedness programs, such as the City’s Know Your Way program, to increase awareness and preparedness of all Californians living in the WUI. 1.2 Anaheim Hills Study Area Due to the Santa Ana Mountains' foothill topography, eastern Anaheim, specifically the community of Anaheim Hills, is susceptible to wildfires. As shown in Figure 1, Study Area, the community of Anaheim Hills is developed within the Santa Ana Mountain foothills in the WUI. Risk of wildfire for development located in or near the WUI is greater than for dense urban development, such as the western portions of the City. Figure 2, City of Anaheim LRA FHSZ DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 2 JUNE 2026 Map, identifies Moderate, High, and Very High fire hazard areas within both State Responsibility Areas (SRAs) and Local Responsibility Areas (LRA). The fire hazard severity zones (FHSZs) designated within the City’s jurisdictional boundary in the LRA are served by Anaheim Fire & Rescue (AFR), and areas identified in the SRA, which are primarily within unincorporated Orange County, are under the authority of the California Department of Forestry and Fire Protection (CAL FIRE). LRA and SRA determine which agency will be the lead agency responsible for managing a wildfire event. For the purposes of this evacuation study, the study area includes areas designated as LRA Moderate FHSZ, High FHSZ, and Very High Fire Hazard Severity Zone (VHFHSZ), as well as SRA VHFHSZ. The community of Anaheim Hills is designated primarily as LRA VHFHSZ. Fire risk for communities designated as LRA VHFHSZ is higher due to the proximity of wildland fuels, regional climate, and surrounding topography that supports extreme fire behavior. The following sections describe the climate, topography, vegetation, and fire history that contribute to the community’s FHSZ rating and include the regulations that apply to each of the three FHSZ classifications. 1.2.1 Climate Climate has a large influence on fire risk. Southern California, including Anaheim Hills, largely reflects a Mediterranean climate, with warm, dry summers and cold, wet winters. Temperatures average (annual) around 64°F and reach up to an average high of 85°F in August. Annual precipitation has been averaging less than 12 inches and typically occurs between December and March. The prevailing wind is an onshore flow between 5 mph and 8 mph from the Pacific Ocean (Weather Spark 2026). While the prevailing wind pattern is from the west (onshore), the presence of the Pacific Ocean causes a diurnal wind pattern known as the land/sea breeze system. During the day, winds are from the west–southwest (sea), and at night winds are from the northeast (land). The highest wind velocities are associated with downslope, canyon, and Santa Ana winds. Santa Ana winds are an extreme wind event caused by cool, dry high-pressure systems in the deserts to the east (Great Basin area of the United States) that can result in wind speeds up to 75 mph or higher. Their seasonality can often coincide with the end of the seasonal Southern California drought resulting in extreme fire hazards in the fall. 1.2.2 Topography Topography influences fire risk by affecting fire spread rates. Typically, steep terrain results in faster fire spread up- slope and reduced spread rates when moving downslope in the absence of wind. Terrain that forms a funneling effect, such as chimneys, chutes, or saddles on the landscape, can result in especially intense fire behavior. Conversely, flat terrain tends to have little effect on fire spread, resulting in fires that are driven by vegetation and wind. Anaheim Hills is set in the foothills of the Santa Anna Mountains and has various topographical features that could exacerbate fire spread and behavior. 1.2.3 Vegetation Extensive vegetation type mapping is useful for fire planning because it enables each vegetation community to be assigned a fuel model, which is used to assist with fire behavior modeling and fire progression modeling. Dominant vegetation communities and land cover types occurring in Eastern Anaheim and Anaheim Hills include grasslands, shrub and scrublands, woodlands and developed land uses (see Figure 3, Vegetation). The dominant vegetation types in the Anaheim Hills Study Area are a combination of; Mediterranean California Foothill and Lower Montane Riparian Woodland, California Ruderal Grassland and Meadow, Californian Ruderal Forest, California Central Valley and Southern Coastal Grassland, Southern California Oak Woodland and Savanna, Southern California Dry-Mesic Chaparral, and Western Warm Temperate Urban Herbaceous/Shrubland/Mixed Forest (LANDFIRE 2025) DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 3 JUNE 2026 1.2.4 Fire History Fire history data provides valuable information regarding fire spread, fire frequency, most vulnerable areas, and significant ignition sources, amongst others. In turn, this understanding of why fires occur in an area and how they typically spread can then be used for pre -planning for both wildfire and evacuation and designing defensible communities. Fire history represented below uses the Fire and Resource Assessment Program database. The Fire and Resource Assessment Program summarizes fire perimeter data dating to the early 1900s but is incomplete due to the fact that it mostly includes fires over 10 acres in size and has incomplete perimeter data, especially before the mid - twentieth century (Syphard and Keeley 2016). However, the data does provide a summary of recorded fires and can be used to show whether large fires have occurred in the project study area, which indicates whether they may be possible in the future. According to available data from the CAL FIRE in the Fire and Resource Assessment Program database, there have been 21 fires that have burned in the City of Anaheim since the beginning of the historical fire data record , which was approximately 1900, the majority of which have burned in the open space in the eastern portion of the City of Anaheim, as seen in Figure 4a, City of Anaheim Major Wildfire Map; and Figure 4b, City of Anaheim Wildfire History; and discussed in Table 1 below. Recorded wildfires within the City boundary range from approximately 1.7 acres to approximately 53,080 acres (1948 Green River Fire). In 2008, the Freeway Complex Fire, comprising the Freeway and Landfill Fires, burned 30,305 acres, destroyed 314 homes, and injured 14 firefighters (City of Anaheim LHMP). The most recent fire over 10 acres was the 2017 Canyon II Fire, which burned 9,198 acres. Due to the recency of the Canyon II fire, many residents were observed through public outreach efforts to immediately recall the Canyon II fire when the topic of evacuation is discussed. The Canyon II fire resulted in simultaneous evacuation of many zones, similar to the worst-case evacuation scenarios modeled through this study and prompted exploration of increased evacuation planning to phase evacuation in order to hasten future evacuations, an approach recognized and supported through this study. The Know Your Way program in Anaheim Hills was initiated primarily in response to the evacuation challenges experienced during the 2017 Canyon II Fire, a rapidly spreading wind-driven wildfire that prompted large-scale simultaneous evacuations of thousands of residents with little advanced notice. The event revealed confusion among residents over evacuation routes, road closures, and the expansion of evacuation zones under evacuation orders. In response to the event, City officials identified that residents needed clear guidance on evacuation zones, the designated routes to take, and overall enhanced community-wide emergency preparedness. The Know Your Way program was created to reduce congestion and improve public safety during future evacuation events. As further described below, the program established 15 evacuation zones with identified routes specified for each zone, and the City installed evacuation route signage along main evacuation corridors in east Anaheim. The following table describes past wildland fire events that have occurred since the development of Anaheim Hills began in 19821. 1 https://www.anaheim.net/DocumentCenter/View/48820/Anaheim-LHMP-Plan-2022 DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 4 JUNE 2026 Table 1. Historical Wildfires in Anaheim Fire Name Year Acres Burned Un-named 1914 18,754.99 Un-named 1929 1,084.66 Green River Fire 1948 53,080.39 Nohl Fire 1951 175.63 Un-named 1962 138.86 Paseo Grande Fire 1967 51,076.48 Owl Fire 1980 18,332.29 Gypsum Fire1 1982 20,142.33 Coal Canyon Fire 1984 449.60 Un-named 1985 539.69 Green River Fire 1985 134.65 Stagecoach Fire 1993 581.47 Highway 91 Fire 1995 176.56 Green Fire 2002 2,234.36 Green Fire 2004 16.06 Sierra Peak Fire 2006 10,591.98 241 Incident Fire2 2007 1,618.08 Freeway Complex Fire3 2008 30,305.23 Canyon I Fire 2017 2,661.42 Canyon II Fire4 2017 9,198.03 Windy Ridge Fire 2020 1.74 Source: Cal FIRE Incident Data 2024 Notes: 1 14 homes were damaged or destroyed in the Gypsum Fire. 2 2 outbuildings were destroyed, 2 homes were damaged, and 2 injuries occurred during the 241 Incident Fire. 3 314 homes were destroyed and 14 firefighters suffered non-fatal injuries during the Freeway Complex Fires. 4 25 structures were destroyed, and 55 structures were damaged during the Canyon II Fire. DRAFT Ä90 Ä241 Ä241 Ä91 Ä91 Ä91 Ä91 Ä91 Ä91 Ä55 East Canyon R imRoadImperialHighwayLa P a lm a A v e nue SouthSerranoAvenueO a k C a nyon Dri v e E a s t NohlRanch R o a d S e rr a n o AvenueSanta A n a C anyonR o ad South WeirCany o n RoadCity of Anaheim Boundary Study Area Date: 8/15/2025 User: nreid Path: Z:\Projects\j1750701\MAPDOC\Wildfire Evacuation Study\Wildfire Evacuation Study.aprx Map: Study Area Layout: Figure 1 Study Area0 3,0001,500 Feetn SOURCE: ESRI Imagery 2025; OpenStreetMaps 2019 City of Anaheim Wildfire Evacuation Study Study Area FIGURE 1DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 6 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT N Tustin StE Santi a g o C a ny o n R d E Katella Ave We ir Ca n y o n RdRose Dr Yorba Linda Blvd Villa P a r k Rd N T ust inAv eEsperanzaRdOrangethorpe Ave NCannonStImperialHwyTu stin A v e S Weir Ca n y onRdKelloggDrF a irmont B l vdVia E s c olaNSa ntia g o B lv d LaPal m a A v e SLakeviewAveE Canyon Rim R dE N ohlRanc h R d V illag e CenterDrLakeviewAveR iv e r d a leA ve Serran o A v e GypsumCanyon RdELincoln Ave E Taft Ave Santa Ana C anyonRd Ä90 Ä55 Ä241 Ä241 Ä91 Ä91 L a P a lm a A v e nue SouthSerranoAvenueO a k C a nyon Dri v e S err anoA v e n ue E a s t NohlRanch R o a d South W eirCany o n RoadImperial HighwayEast CanyonRimRoad S a n t a Ana C a n y o n R o a d City of Anaheim Boundary Study Area State Responsibility Area High Very High Local Responsibility Area Moderate High Very High 0 0.550.275 MilesnDate: 8/15/2025 User: nreid Path: Z:\Projects\j1750701\MAPDOC\Wildfire Evacuation Study\Wildfire Evacuation Study.aprx Map: FHSZ Layout: Figure 2 City of Anaheim LRA FHSZ MapSOURCE: Bing Imagery 2024; OpenStreetMaps 2019; CalFire accessed 2025 City of Anaheim Wildfire Evacuation Study City of Anaheim LRA FHSZ Map FIGURE 2DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 8 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT N Tustin StImperialHwyE Santi ag o C a n y o n R d We ir Ca n y o n Rd E Katella Ave Tu s t i n A v eVilla P a r k Rd Yorba Linda Blvd N T ust inAv eEsperanza RdOrangethorpe Ave NCannonStS Weir C anyon R d E CanyonRim RdKelloggDrF a irmont B l vdVia E s c olaNSa ntia g o B lv d Serran o A v e LaPal m a A v e SLakeviewAveSSerranoAveOa k C anyon D r ENohl R a nch R d V illag e C enterDrLakeviewAveR iv e r d a leA ve ELincoln Ave E Taft Ave Santa Ana C anyonRd Ä90 Ä241 Ä91 Ä55 City of Anaheim Boundary Study Area Barren Brush Chaparral Closed Timber Litter Hardwood Litter Timber with Heavy Litter Timber, Grass & Understory Urban Water Date: 8/12/2025 User: nreid Path: Z:\Projects\j1750701\MAPDOC\Wildfire Evacuation Study\Wildfire Evacuation Study.aprx Map: Vegetation Layout: Figure 3 Vegetation Map0 3,0001,500 Feetn SOURCE: ESRI Imagery 2025; OpenStreetMaps 2019; Landfire 2023 City of Anaheim Wildfire Evacuation Study Vegetation FIGURE 3DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 10 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT E Santi a g o C a ny o n R dN TustinStE Katella Ave We ir Ca n y o n RdRose Dr Villa P a r k Rd Yorba Linda Blvd N T ust inAv eEsperanza RdNCannonStOrangethorpe Ave S a n taAna C a n y o n Rd Tusti n A v e S WeirCanyon Rd ImperialHwyÄ90 Ä241 Ä91 Ä55 CANYON II FREEWAY SIERRA GYPSUM East C a n yonR im Road SouthSerranoAvenueOak C an y o n Drive EastN ohl R a nch R oad S errano A ven u e Sant a An a C anyon R o ad L a Pal m a Avenu e Sout h Wei r Can y o n R o a dI mperialHi ghwayCity of Anaheim Boundary Study Area Fire Name Canyon II (2017) Freeway (2008) Gypsum Canyon (1982) Sierra Peak (2008) 0 0.550.275 MilesnDate: 8/15/2025 User: nreid Path: Z:\Projects\j1750701\MAPDOC\Wildfire Evacuation Study\Wildfire Evacuation Study.aprx Map: Figure 4a Major Fires Map Layout: Figure 4a Major Fires MapSOURCE: Bing Imagery 2024; OpenStreetMaps 2019; CalFire accessed 2025 Anaheim Wildfire Evacuation Study City of Anaheim Major Wildfire Map FIGURE 4aDRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 12 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT E Sant iago Ca n yon R dN TustinStE Katella Ave Weir Ca n y o n RdRose Dr Villa P a r k Rd Yorba Linda Blvd N T ust inAv eEsperanzaRdNCannonStOrangethorpe Ave S a n taAna C a n y o n Rd Tusti n A v e SWeir Ca n y o n Rd ImperialHwyÄ90 Ä241 Ä91 Ä55 BLUE RIDGE WINDY RIDGE B2 - YORBA COSTCO CANYON II CANYON I CROSS CREEK FREEWAY 241 INCIDENT SIERRA IRVINE GREEN GREEN EVENING HWY 91 STAGECOACH GREEN RIVER COAL CYN. GYPSUM OWL PASEO GRANDE SANTIAGO NOHL GREEN RIVER E a st Canyon R im Road SouthSerranoAvenueOak C an y o n Drive Eas tNohlRa nch R oadImperialHighwaySe rranoA venu e Sant a An a C anyon R o ad L a Pal m a Avenu e South Wei r Cany o n R o a d City of Anaheim Boundary California Fire Perimeters Study Area 0 0.550.275 MilesnDate: 8/15/2025 User: nreid Path: Z:\Projects\j1750701\MAPDOC\Wildfire Evacuation Study\Wildfire Evacuation Study.aprx Map: Fire History Layout: Figure 4b City of Anaheim Wildfire HistorySOURCE: Bing Imagery 2024; OpenStreetMaps 2019; CalFire accessed 2025 Anaheim Wildfire Evacuation Study City of Anaheim Wildfire History FIGURE 4bDRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 14 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT 17507 15 JUNE 2026 2 Regulatory Context Regulatory context establishes the legal, procedural, and operational foundation that guides how wildfire risk, emergency response, and evacuation planning must be evaluated and implemented. At the federal level, frameworks such as the National Cohesive Wildland Fire Management Strategy and related federal policies provide nationwide direction for wildfire resilience, emergency response, and community preparedness. State regulations—including SB 99, AB 747, AB 1409, Attorney General guidance, California Environmental Quality Act (CEQA) requirements, and statewide fire codes—create mandates for assessing evacuation route capacity, ensuring safe development, and evaluating wildfire impacts during land use decision making. Local regulations, such as the City of Anaheim’s General Plan Safety Element, Know Your Way, Fire Code, WUI Code, and Weed Abatement Ordinance, operationalize these federal and state requirements and tailor them to community specific hazards, infrastructure, and response capabilities. Together, these aligned federal, state, and local regulations form a cohesive framework that ensures wildfire evacuation planning is consistent, evidence-based, enforceable, and responsive to real-world risks. 2.1 Federal 2.1.1 National Cohesive Wildland Fire Management Strategy The U.S. Forest Service, in coordination with other federal, tribal, state, and local partners/agencies developed the National Cohesive Wildland Fire Management Strategy (The National Strategy), which has three key components: Resilient Landscapes, Fire Adapted Communities, and Safe and Effective Wildfire Response. Resilient Landscapes addresses the need for sustainable and resistant landscapes, specific to a local region’s environment, to aid in recovery from wildfires. In the National Cohesive Wildland Fire Management Strategy (April 2014), Landscape Classes are identified to help inform potential management options and/or policies to maintain fire-prone landscaped areas that are specific to a particular region. Fire Adapted Communities account for a community’s ability to prepare for, respond to, and recover from a wildfire. Safe and Effective Wildfire Response addresses enhancing wildfire response preparedness, while emphasizing structural protection and wildfire prevention. The National Strategy provides various actions and activities that can be implemented at the national, regional, and local levels to achieve reduced wildfire threats to landscapes, communities, the public, and emergency responders. 2.1.2 Federal Wildland Fire Management Policy The Federal Wildland Fire Management Policy was developed in 1995 and updated in 2009 by the National Wildfire Coordinating Group, a federal multi-agency group that establishes consistent and coordinated fire management policy across multiple federal jurisdictions. The Federal Wildland Fire Management Policy provides policy direction to state and local agencies for the safety of emergency responders and the public during wildfire events, activities for the purposes of fire management (i.e., vegetation maintenance) and ecosystem sustainability, responding to wildfires, protection of life and community infrastructure, and measures to prevent wildfire events. 2.1.3 National Fire Plan The National Fire Plan was a Presidential directive in 2000 as a response to severe wildland fires throughout the United States. The National Fire Plan focuses on reducing fire impacts on rural communities and ensuring sufficient DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 16 JUNE 2026 firefighting capacity in the future. The plan addresses five key points: Firefighting, Rehabilitation, Hazardous Fuels Reduction, Community Assistance, and Accountability. The plan provides technical, financial, and resource guidance and support for wildland fire management across the United States. The U.S. Forest Service and the Department of the Interior work to implement the key points outlined in the plan. These five key points would address and focus on needs, such as preparing for wildfires and the capacity to take prompt action when responding to wildfires; restoration, rehabilitation, and protection of communities after a wildfire occurs; potential programs that would help with reducing the risk of wildfires, including continued management from of wildfire fuel sources, potential hazard mitigation, and restoration of ecosystems; working directly with communities for adequate planning and action to increase protections for people and property; and providing for continued accessible information regarding the goals of the National Fire Plan. 2.1.4 National Fire Protection Association Codes, Standards, Practices, and Guides The National Fire Protection Association (NFPA) develops codes, standards, recommended practices, and guides through a consensus standards development process approved by the American National Standards Institute. The consensus standards development process brings together various professionals to achieve consensus on fire and other safety issues. NFPA standards are recommended guidelines and nationally accepted best practices in fire protection but are not law or codes, unless adopted or referenced as such by the California Fire Code or Local Fire Agency. Typical standards include Standard for Portable Fire Extinguishers, Standards for Installation of Sprinkler Systems, National Electrical Code, National Fire Alarm and Signaling Code, Standards for Fire Doors and Other Opening Protectives, Life Safety Code, as well as a number of other standards and codes specific to a building’s use and/or occupancy. 2.1.5 Federal Energy Regulatory Commission The Federal Energy Regulatory Commission requires that sufficient brush clearance be maintained between trees/vegetation and electric transmission lines. The Federal Energy Regulatory Commission does not have a direct role in electric utility plans for tree trimming and vegetation clearance but does approve reliability standards that apply to electric transmission facilities to ensure service reliability and safety. Lower voltage distribution facilities, generally lines below 200 kilovolts, are regulated by the utility regulatory commissions in each state, which set vegetation management standards for distribution lines. California requirements are described below, under the subheading for state regulations. 2.1.6 Federal Emergency Management Agency The Federal Emergency Management Agency (FEMA) is a government organization that aims to help people before, during and after disasters. FEMA promotes emergency preparedness, and funds grant programs to help communities become resilient to emergencies and disasters. During an emergency, FEMA will assist individuals and the public through various assistance programs, funding for disaster response, and implementing disaster recovery centers. After disasters, FEMA works to support recovery efforts and mitigate future emergencies. (FEMA 2025). DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 17 JUNE 2026 2.1.7 Disaster Mitigation Act of 2000 The Disaster Mitigation Act of 2000 requires that a state mitigation plan, as a condition of disaster assistance, add incentives for increased coordination and integration of mitigation activities at the state level through the establishment of requirements for two different levels of state plans: “Standard” and “Enhanced.” States that develop an approved Enhanced State Plan can increase the amount of funding available through the Hazard Mitigation Grant Program. The Disaster Mitigation Act also established a new requirement for local mitigation plans. 2.2 State 2.2.1 Senate Bill 99 Senate Bill 99 (SB 99) requires a review and update of the City’s Safety Element to identify residential developments in hazard areas that do not have at least two emergency evacuation routes. SB 99 mandates that evacuation planning is incorporated into general plan housing element updates, so communities in FHSZs have access to multiple evacuation routes. SB 99 is supported by AB 747 and AB 1409, discussed below, to enhance community safety and disaster preparedness. The Anaheim City Council approved Resolution No. 2023-005 on January 10, 2023, amending the Safety Element of the General Plan to address this topic. 2.2.2 Assembly Bill 747 AB 747 requires cities and counties to identify evacuation routes in their general plans, and ensure new developments consider safe and viable evacuation routes. AB 747 also requires local governments to assess evacuation capacity under different emergency scenarios. 2.2.3 Assembly Bill 1409 AB 1409 is an expansion of AB 747. AB 1409 requires LHMPs to include evacuation route viability and mandates that jurisdictions evaluate evacuation locations and route safety. 2.2.4 Attorney General Guidance The California Office of the Attorney General issued (October 2022) guidance (Guidance) outlining the Attorney General’s recommendations for “best practices” for analyzing and mitigating wildfire impacts of development projects under CEQA. The Guidance is intended to help local governments’ evaluation and approval considerations for development projects in fire-prone areas, and to help project design in a way that minimizes wildfire ignition and incorporates emergency access and evacuation measures. Importantly, the Guidance does not impose additional legal requirements on local governments, nor does it alter any applicable laws or regulations. The Guidance states that evacuation modeling and planning should be considered for certain projects located in High FHSZs/VHFHSZs as projects in these areas have the potential to present an increased risk of ignition and/or evacuation impacts. The Guidance encourages evacuation modeling and planning prior to project approval to provide greater flexibility regarding design modifications if the evaluation demonstrates such changes are required. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 18 JUNE 2026 The Guidance provides that evacuation modeling and analysis should include the following: ▪ Evaluation of the capacity of roadways to accommodate project and community evacuation and simultaneous emergency access. ▪ Assessment of the timing for evacuation. ▪ Identification of alternative plans for evacuation depending upon the location and dynamics of the emergency. ▪ Evaluation of the Project’s impacts on existing evacuation plans. ▪ Consideration of the adequacy of emergency access, including the Project’s proximity to existing fire services and the capacity of existing services. ▪ Traffic modeling to quantify travel times under various likely scenarios. 2.2.5 CEQA In response to the 2015 California Building Industry Association v. Bay Area Air Quality Management District, in 2018, the Office of Land Use and Climate Innovation (formerly the Office of Planning and Research) proposed and the Natural Resources Agency approved an update to the CEQA Guidelines, revising Section 15126.2 (a) to clarify that an environmental impact report (EIR) must analyze not just impacts that a project might cause, but also existing hazards that the project might make worse. Relevant to wildfire evacuation, those criteria include whether a proposed project would result in the following: ▪ Substantially impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan; or ▪ Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires 2.2.6 CEQA Case Law The following section discusses various projects that were litigated based on unsubstantial CEQA analysis, specifically the Wildfire section, and in some circumstances, the analysis relating to evacuation. Collectively, the case law demonstrates that California courts expect CEQA wildfire and evacuation analyses to be project‑specific, evidence‑based, transparent, and grounded in clear disclosure of evacuation constraints, rather than relying on assumptions or broad generalities. Courts have repeatedly required agencies to analyze how new development could exacerbate existing wildfire hazards, including increased ignition sources, impaired evacuation performance, impacts on community evacuation routes, and deficiencies in disclosure when mitigation measures are proposed without first establishing the severity of impacts. These decisions also show that CEQA analysis must meaningfully examine both on‑site and off‑site wildfire hazards, avoid unsupported assumptions about responder availability, and ensure that conclusions are backed by substantial evidence. The Anaheim Wildfire Evacuation Study (“WES” or “Study”) directly addresses these expectations by providing the City with objective evacuation modeling, standardized methodologies, and defensible evidence, enabling Anaheim to thoroughly evaluate how future projects may influence wildfire behavior, congestion, evacuation times, and community safety—thereby strengthening CEQA compliance and reducing litigation risk. Table 2 identifies key legal cases and their relevance to this WES. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 19 JUNE 2026 Table 2. Summary of CEQA Case Law Case Name Key Takeaways Bonta v. County of Lake (2024) 105 Cal.App.5th 1222 Courts require full disclosure of increased human-caused ignition risk and comparison of project conditions to existing baseline. Agencies cannot rely on design features or general statements as reason not to evaluate wildfire impacts; they must quantify or meaningfully discuss how new development changes wildfire likelihood and disclose impacts before proposing mitigation. Emphasizes the need to document ignition sources, land use changes, and wildfire exposure when reviewing new projects. Elfin Forest Harmony Grove Town Council v. County of San Diego (2021) Unpublished Demonstrates that courts will find an EIR adequately addresses fire safety and evacuation when the analysis includes comprehensive, integrated fire protection planning (FPPs, ignition-resistant construction, water supply, access, and refuge areas) supported by substantial evidence. Standardized wildfire and evacuation methodologies supported by clear and structured documentation can ensure defensible CEQA findings. Center for Biological Diversity v. County of Los Angeles (2021) 112 Cal.App.5th 317 The court found that the EIR failed to analyze wildfire risk impacts beyond the project site, including how the project could contribute to new ignition sources, and held that the wildfire discussion did not satisfy CEQA requirement for the analysis of off-site wildfire hazards. This highlights the need for a clear, evidence-based analysis. Newton Preservation Society v. County of El Dorado (2021) 65 Cal.App.5th 771 Affirms that argument, speculation, unsubstantiated opinion or narrative, or generalized concerns do not constitute substantial evidence. Evaluation of evacuation routes, rerouting options, and operational constraints establish substantial evidence showing minimal impact. This highlights the need for clear, data-supported evacuation performance evaluations to support legally defensible conclusions. Sierra Watch v. County of Placer (2021) 69 Cal.App.5th 86 (Wildfire Impacts not certified for Publication) The court found the evacuation analysis inadequate because it assumed availability of traffic control resources during wildfire, despite contradicting testimony. Evacuation times were therefore understated. CEQA requires realistic operational assumptions, including responder availability, population presence, and worst-case conditions. This study provides standardized assumptions and modeled clearance times based on defensible, repeatable methods. Maacama Watershed Alliance v. County of Sonoma (2019) 253 Cal.Rptr.3d 543 (Unpublished) Shows that a wildfire analysis—including mitigation such as vegetation management, fire suppression measures such as sprinklers, and fire protection improvements—will be upheld when supported by substantial evidence if opponents fail to provide contrary technical evidence. Reinforces the importance of documenting technical basis, modeling inputs, baseline hazards, and roadway conditions. Clews Land & Livestock v. City of San Diego (2017) 227 Cal.Rptr.3d 431 Reinforces that CEQA challenges must be based on specific, evidence-supported claims, not generalized concerns. This Study provides transparent, robust wildfire/evacuation evidence to withstand scrutiny and reduce exposure to litigation. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 20 JUNE 2026 Table 2. Summary of CEQA Case Law Case Name Key Takeaways California Clean Energy Committee v. County of Placer (2015) (Unpublished) The EIR failed because it did not adequately analyze evacuation routes or capacity under project conditions. Courts require project-specific, evidence-based evaluation of evacuation dynamics, especially where development increases population in constrained areas. This supports citywide evacuation modeling as a tool to ensure project reviews do not omit required analyses. Cal. Building Industry Assn. v. BAAQMD (2015) 62 Cal.4th 369 Reaffirms CEQA’s focus on project-caused environmental impacts but clarifies agencies must analyze whether a project exacerbates existing hazards—including wildfire, flooding, or erosion—by introducing people or structures into risky areas. Supports this Study’s effort to evaluate how new development may increase ignition risk, evacuation pressure, or exposure, and ensures that environmental review includes whether a project worsens existing wildfire vulnerabilities. Notes: EIR = environmental impact report; FPP = Fire Protection Plan; CEQA = California Environmental Quality Act. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 21 JUNE 2026 2.2.7 CAL FIRE CAL FIRE serves and safeguards the people and protects the property and resources of California (CAL FIRE 2025c). CAL FIRE provides emergency responses to all emergencies and disasters and provides the initial attack to wildfires started on SRAs. CAL FIRE also mitigates wildfire risks through various fire prevention strategies, including controlled burns and other forms of vegetation management, as well as assisting with community preparedness initiatives and performing defensible space inspections. 2.2.8 California Governor’s Office of Emergency Services The California Governor’s Office of Emergency Services is responsible for the coordination of overall state agency response to disasters. Assuring the state's readiness to respond to, recover from all hazards and assisting local governments in their emergency preparedness, response, recovery, and mitigation. 2.2.9 California Fire Code The 2025 California Fire Code (California Code of Regulations [CCR] Title 24, Part 9) establishes regulations to safeguard against the hazards of fire, explosion, or dangerous conditions in new and existing buildings, structures, and premises. The Fire Code also establishes requirements intended to provide safety for and assistance to firefighters and emergency responders during emergency operations. The provisions of the Fire Code apply to the construction, alteration, movement, enlargement, replacement, repair, equipment, use and occupancy, location, maintenance, removal, and demolition of every building or structure throughout California. The Fire Code includes regulations regarding fire-resistance-rated construction, fire protection systems such as alarm and sprinkler systems, fire services features such as fire apparatus access roads, means of egress, and fire safety during construction and demolition. The City of Anaheim has adopted the 2025 California Fire Code as Title 16, as amended, including appendices addressing fire flow requirements for buildings. 2.2.10 California Wildland–Urban Interface Code With the adoption of the 2025 codes on January 1, 2026, all wildfire protection and safety-related requirements previously found in the California Building Code, California Fire Code (CFC), and California Residential Code have been consolidated into the California Wildland–Urban Interface Code (CWUIC). The 2025 CWUIC, which is codified as Part 7 of the California Building Standards Code, consolidates all wildfire-related laws, codes, and regulations into a single wildfire-specific code. This includes the former Chapter 7A in the California Building Code, the former Chapter 49 in the CFC, and provisions of CCR Title 14, Government Code Section 51182, and Public Resources Code (PRC) Sections 4290 and 4291. The CWUIC includes special building construction regulations for development in designated FHSZs. The special construction materials and methods include design and fire-rating standards for exterior walls, doors, and windows. The CWUIC also establishes the standards for defensible space and vegetation fuel modification. The CWUIC works as a companion to the California Building Code and CFC to ensure ignition-resistant construction, fire apparatus access, and adequate fire flow in designated FHSZs. 2.2.11 California Public Resources Code The California PRC Division 4, Forests, Forestry and Range and Forage Lands, Part 2, Protection of Forest, Range and Forage Lands, Chapter 6, Prohibited Activities, Article 2, Prohibited Activities establishes fire safety regulations DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 22 JUNE 2026 designed to reduce the risk of wildfire ignition during construction activities in high fire risk areas. Pertinent sections include 4427, 4428, 4431, and 4442. These sections describe the restriction of certain tools and equipment that could produce sparks during times of increased fire danger, and the requirement of burning permits. The California PRC Division, Part 2, Chapter 1, Prevention and Control of Forest Fires, Article 9, Fire Hazard Severity Zones, discusses the requirement of the state Fire Marshal to designate their wildlands as a fire hazard severity zone, and classify the areas by hazard rating including Moderate, High and Very High. 2.2.12 California Government Code The California Government Code Sections 51175-89 discuss the requirement of the classification of lands within a FHSZ, and the regulations that apply to lands within a Moderate, High, or Very High FHSZ to reduce fire risk, ignition, and spread. These sections discuss the defensible space requirements of land in the FHSZs. 2.2.13 2024 CAL FIRE Strategic Plan The CAL FIRE Strategic Plan for 2024 outlines the efforts to identify operational opportunities, key issues, and future strategies to improve the department. Several goals are identified within the plan including: ▪ Goal 1: Attract, hire, and retain quality employees. ▪ Goal 2: Ensure all employees understand how the departments various programs and job duties contribute towards efficiently achieving the CAL FIRE mission. ▪ Goal 3: Promote a culture that values equitable access, embraces diverse backgrounds and experiences, and actively removes barriers to cultivate a more inclusive environment. ▪ Goal 4: Leverage technology to modernize internal human resources processes and create efficient and effective innovative solutions to promote, support, and enhance the employee experience. ▪ Goal 5: Strengthen the Department’s physical and digital infrastructure and streamline equitable access to information across core services. ▪ Goal 6: Identify core capabilities and strengthen operational capacity. 2.2.14 California Mutual Aid Agreement The California Fire Service and Rescue Emergency Mutual Aid Plan is an agreement between the state and local agencies and jurisdictions for responding to large-scale disasters. The agreement includes fire and police services, transportation services, equipment, and more. The California Master Mutual Aid Agreement ensures all departments and agencies get the services necessary to prevent or lessen the effect of a disaster, including wildfires. Members of the agreement work together in accordance with adopted mutual aid operational plans, which further detail the method that resources, facilities, and services are made available. The agreement facilitates cooperation between agencies to ensure effective mobilization and support when necessary. Local jurisdictions may request assistance when their local capacities and resources are overwhelmed. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 23 JUNE 2026 2.2.15 Local Responsibility Area Fire Hazard Severity Zone Maps The California State Fire Marshal is required by the PRC Sections 4201-4204, CCR Title 14, Section 1280, and California Government Code 51175-89 to classify lands within the SRA and LRA into FHSZs of Moderate, High, or Very High. LRAs are within incorporated cities, urban regions, agricultural lands, and portions of the desert where the local government is responsible for wildfire protection. This is typically provided by city fire departments, fire protection districts, counties, and by CAL FIRE under contract. CAL FIRE uses an extension of th e SRA Fire Hazard Severity Zone model as the basis for evaluating fire hazard within LRAs. Fire hazard designations are based on topography, vegetation, and weather, among other factors with more hazardous sites, including steep terrain, unmaintained fuels and vegetation, and WUI locations. The LRAs hazard rating reflects flame and ember intrusion from adjacent wildlands and from flammable vegetation in the urban area.2 The California Board of Forestry and Fire Protection (CAL FIRE) re-analyzed and reclassified the State of California’s existing FHSZs for the SRA in 2024 and the LRA in 2025. The reclassification included a shift of some lands from SRA to LRA, and now also classifies Moderate FHSZ and High FHSZ within the LRA, when previously only classified lands within the LRA as VHFHSZ. Title 14 of the CCR, Section 1280 requires local jurisdictions to adopt and codify the newly classified LRA FHSZ or intensify designations as the jurisdiction deems appropriate. For the purposes of the study, the FHSZ considered herein are the 2025 LRA FHSZ maps, as adopted by the AFR as Ordinance 6329. 2.3 City of Anaheim 2.3.1 General Plan The City of Anaheim General Plan is a comprehensive land use planning document that details goals and policies to support growth and development within its jurisdictional boundaries. The following sections detail the goals and policies of the City of Anaheim General Plan relevant to wildfire and evacuation planning. 2.3.1.1 Land Use Element The City of Anaheim Land Use Element (2025) designates the location of land uses such as residential, retail, industrial, open space, recreation, and public uses. The Land Use Element also determines the permitted density of various land use designations and provides and describes the Land Use Map for the City. The 2025 Land Use Element was edited for internal consistency across the City of Anaheim General Plan elements such as the Housing Element, and updated planning priorities. Additionally, the Circulation Element established policies to accommodate the vehicular trips generated by the population and associated land uses permitted by the Land Use Element. The Land Use Element is essential to understanding approximately how many people may be evacuating different parts of the City during an emergency evacuation event. This assists with understanding the type and amount of emergency services that may need to be provided during an evacuation, and how impacted emergency resources, services, and roadways may be during an emergency. 2 https://34c031f8-c9fd-4018-8c5a-4159cdff6b0d-cdn-endpoint.azureedge.net/-/media/osfm-website/what-we-do/ community-wildfire-preparedness-and-mitigation/fire-hazard-severity-zones/2024-fhsz-faqs_english.pdf?rev= 538374a27bb44bbab4c2786ff2eafb39&hash=AD4DB7857E3EF6F0BEC0B56429A1C262 DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 24 JUNE 2026 2.3.1.2 Safety Element The City of Anaheim Safety Element (2023) identifies potential natural risks within the City that pose a threat to the safety of the community. The Safety Element promotes relevant and responsive goals and policies to assist with community needs and protection. The City’s Safety Element determines wildfire poses a significant threat to people and property, specifically those who reside in the WUI. Eastern Anaheim and Anaheim Hills are particularly susceptible to wildfires due to their location in the WUI and a FHSZ, and proximity to the Santa Ana Mountains. The Safety Element’s Goal 2.1, A Community Protected and Prepared for Urban and Wildland Fires, and associated policies provide the framework for protecting the lives and property of Anaheim residents and community members. Goal 2.1: A Community Protected and Prepared for Urban and Wildland Fires Policy 1: Protect the lives and properties of residents, businesses owners, and visitors from urban and wildland fire hazards Policy 2: Effectively enforce City and State regulations within the VHFHSZ and incorporate new techniques and best practices as they become available to reduce future risks to existing and new developments. Policy 3: Develop a post-wildfire recovery framework that assists City staff, residents, and business owners in planning and recovery efforts Policy 4: Minimize urban and wildland fire exposure for residents, business owners, and visitors by incorporating Fire Safe Design into existing and new developments Policy 5: Continually assess the need for additional greenbelts, fuel breaks, fuel reduction and buffer zones around existing communities and roadways. This assessment should include long term maintenance of existing efforts and funding sources to sustain these projects. Policy 6: Maintain a weed abatement program to ensure clearing of dry brush areas. Policy 7: Expand vegetation management activities in areas adjacent to wildland fire prone areas. Policy 8: Refine procedures and processes to minimize the risk of fire hazards in the Special Protection Area including requiring new development to: ▪ Utilize fire-resistant building materials; ▪ Incorporate fire sprinklers as appropriate; ▪ Incorporate defensible space requirements; ▪ Comply with Anaheim Fire Department Fuel Modification Guidelines; ▪ Provide Fire Protection Plans; and, ▪ Implement a Vegetation Management Plan, which results in proper vegetation modification on an ongoing basis within the Special Protection Area. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 25 JUNE 2026 ▪ Develop fuel modification in naturalized canyons and hills to protect life and property from wildland fires, yet leave as much of the surrounding natural vegetation as appropriate. ▪ Require development to use plant materials that are compatible in color and character with surrounding natural vegetation. ▪ Provide wet or irrigated zones when required. Policy 9: Use selective trimming and obtain permits when necessary in designated areas to preserve environmentally sensitive native plants. Policy 10: Site new essential public facilities outside of the VHFHSZ, where feasible. Policy 11: Evaluate feasibility of relocating essential public facilities located within the VHFHSZ to areas outside of this hazard zone. If relocation isn’t possible, prioritize retrofitting and hardening of structures. Policy 12: Continue to classify areas of varying fire hazard severity based upon the proximity to open wildland slope, grades, accessibility, water supply and building construction features. Policy 13: All development projects within the VHFHSZ must prepare a Fire Protection Plan (FPP) to reduce or eliminate fire threats. FPPs shall be consistent with the following guidance: ▪ A Fire Protection Plan (FPP) may be required by the fire code official for new development within the Very High Fire Hazard Severity Zones (VHFHSZ). FPPs are required to include mitigation strategies that consider location, topography, geology, flammable vegetation, sensitive habitats/species, and climate of the proposed site. FPPs must address water supply, access, building ignition, and fire resistance, fire protection systems and equipment, proper street signage, visible home addressing, defensible space, vegetation management, and long-term maintenance. All required FPPs must be consistent with the requirements of the California Building and Residential Codes, the California Fire Code as adopted by the City of Anaheim, and the City of Anaheim Municipal Code. The City’s Safety Element also maintains an emergency preparedness section to assist with the anticipation and mitigation of natural and human-caused hazards. Within this section, constrained roadways and parcels are identified, and emergency evacuation routes are discussed. Constrained Roadways are segments of the roadway network that have a single point of connection with the rest of the roadway network, including cul-de-sacs or roadways with secondary connections that are not publicly accessible due to a gate or other constraint. Constrained Parcels are areas of the City where at least 30 parcels are located along a constrained roadway. These parcel locations are accessible by one means of ingress/egress, which is consistent with CAL FIRE guidance regarding PRC Section 4290.5. Under this guidance, CAL FIRE is concerned with subdivisions within the state that have 30 or more dwellings accessing a single roadway (City of Anaheim 2023). The analysis identified 82 locations of at least 30 parcels meet the constrained parcel threshold. These areas are of concern in an evacuation because constrained roadways or parcels may inhibit safe and efficient evacuations. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 26 JUNE 2026 The City’s Safety Element Goal 6.1, A City That Prioritizes Emergency Preparedness and Public Awareness of Community Risks, and Goal 7.1, A City That Can Effectively Respond and Evacuate During Hazard Events, have multiple supporting policies that relate to safe evacuations. Some of these policies include the following: Goal 6.1: A City That Prioritizes Emergency Preparedness and Public Awareness of Community Risks Policy 1: Ensure the availability of both the Safety Element and Emergency Operations Plan to employers and residents of Anaheim. Policy 2: Coordinate disaster preparedness and recovery with neighboring jurisdictions and other governmental agencies, such as Orange County, Water Districts, and Utility Providers. Policy 3: Assess emergency and evacuation capabilities for potential disruptions from existing and future hazards affecting the community. Policy 4: Ensure mapping of the City’s emergency facilities, evacuation routes and hazardous areas are periodically updated to reflect additions or modifications. Policy 5: Ensure access routes to and from hazard areas relative to the degree of development or use (e.g., road width, road type, length of dead-end roads, etc.) are adequately designed and sized to accommodate anticipated needs. Policy 6: Ensure disruption of evacuation routes from landslide movement, fault ruptures, and failures caused by earthquakes are minimized to the greatest extent feasible. Policy 7: Appropriately locate and coordinate emergency services including fire, police, and ambulance services to provide responsive services across the entire community. Policy 8: Conduct hazards-oriented public outreach to prepare the community for the following hazards: ▪ Seismic and Geologic Hazards ▪ Wildfire Hazards ▪ Flooding and Dam Inundation ▪ Hazardous Materials Release ▪ Climate Change ▪ Evacuation Policy 9: Conduct training and exercises with City staff to better prepare them for future hazards and incidents. Policy 10: Train multi-lingual personnel to assist in emergency preparedness and response activities to meet the community’s need. Policy 11: Incorporate the latest information and best practices from the Department of Homeland Security to prepare the City to respond to terrorist attacks. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 27 JUNE 2026 Policy 12: Periodically update the Emergency Operations Plan to ensure consistency with the Safety Element and Local Hazard Mitigation Plan. Policy 13: Periodically conduct and evaluate Emergency Operations Center (EOC) exercises. Goal 7.1: A City That Can Effectively Respond and Evacuate During Hazard Events Policy 1: Coordinate with neighboring jurisdictions and Caltrans regarding transportation network constraints and improvements. Policy 2: Coordinate with neighboring jurisdictions and County agencies to prioritize roadway and storm drain infrastructure retrofitting and enhancement projects along primary evacuation routes. Policy 3: Ensure all new development and redevelopment projects provide adequate ingress/egress for emergency access and evacuation. Policy 4: Identify and construct additional evacuation routes in areas of high hazard concern or limited circulation, where feasible. Policy 5: Ensure the City’s transportation network allows for effective emergency response and evacuation activities. Policy 6: Develop evacuation standards and metrics for constrained neighborhoods and alternative evacuation plans, where necessary. Policy 7: Monitor changes to hazard conditions and vulnerabilities to ensure the accessibility or viability of evacuation routes in the future. Policy 8: Expand the “Know Your Way” program to identify and enhance evacuation resources that includes areas of the City with limited ingress/egress, limited circulation capacity, and/or critical infrastructure that could impact evacuation efforts. Policy 9: Enhance the City’s existing education and outreach program, “Know Your Way,” with potential evacuation scenarios and the activities that residents and businesses can do to protect their properties and prepare for potential events. 2.3.1.3 Housing Element The City of Anaheim’s Housing Element (2025) is a required component of the City’s General Plan that addresses adequate housing opportunities for present and future Anaheim residents through 2029. The Housing Element provides the primary policy guidance for local decision making related to housing and provides a threshold for how much development and growth is expected for future conditions. Fire hazard is considered a constraint that impacts future developments within the City. This is essential to accurately planning for future evacuation scenarios. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 28 JUNE 2026 2.3.1.4 Circulation Element The City of Anaheim’s Circulation Element (updated 2024) provides goals and policies that relate to safe and efficient transportation within the City. The City’s priority goal for their circulation network is providing an efficient and accessible system to improve the quality of life for people in the City. The Circulation Element includes Goal 6, Support Efforts to Enhance Transportation Safety (City of Anaheim 2025c). Goal 6: Support Efforts to Enhance Transportation Safety ▪ Improve citywide awareness of safety for all roadway users. ▪ Continue to plan for and implement emergency vehicle and fire truck access and preemption requirements. ▪ Plan for and consider development of key evacuation routes. ▪ Support Local Roadway Safety Plan implementation efforts and Neighborhood Traffic Management Program Implementation efforts. 2.3.1.5 Environmental Justice Element The City of Anaheim adopted an Environmental Justice Element in April, 2025. The Environmental Justice Element identifies goals and policies necessary to comply with SB 1000, the Planning for Healthy Communities Act adopted in 2016. The majority of the existing Environmental Justice Communities in Anaheim exist in the western and central parts of Anaheim, away from the WUI and FHSZs. Because the identified Environmental Justice Communities are not primarily in eastern Anaheim or Anaheim Hills, they are less likely to have wildfire be a direct threat to their lives and properties than residents in eastern Anaheim. Despite their proximity to the WUI or FHSZ, in the event of a wildfire, smoke and other airborne pollutants as a result of fire, may have an effect on air quality for vulnerable communities within the nearby areas. Although these communities are not in areas identified as WUI or FHSZ, some of these communities have constrained parcels and constrained roadways, which may affect the rate and efficiency of evacuation in the event of an emergency. 2.3.2 City of Anaheim Fire Code The 2025 CFC (CCR Title 24, Part 9) establishes regulations to safeguard against the hazards of fire, explosion, or dangerous conditions in new and existing buildings, structures, and premises. The Fire Code also establishes requirements intended to provide safety for and assistance to firefighters and emergency responders during emergency operations. The provisions of the Fire Code apply to the construction, alteration, movement, enlargement, replacement, repair, equipment, use and occupancy, location, maintenance, removal, and demolition of every building or structure throughout California. The Fire Code includes regulations regarding fire-resistance- rated construction, fire protection systems such as alarm and sprinkler systems, fire services features such as fire apparatus access roads, means of egress, fire safety during construction and demolition, and WUI areas. The City of Anaheim has adopted the 2025 CFC as Title 16, as amended, including appendices addressing fire flow requirements for buildings (City of Anaheim 2025b). DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 29 JUNE 2026 2.3.3 City of Anaheim Wildland–Urban Interface Code The City of Anaheim’s WUI Code establishes requirements that reduce the risk of wildfire for developments in areas where urban development areas intersect with wildland fuels, particularly in areas that are designated as within FHSZs. The City has adopted the 2025 CWUIC, as described above in Section 2.2.10, as amended by Section 15.03.140 of the City of Anaheim Municipal Code. The WUI code requires ignition-resistant building materials, defensible space, adequate water supply for fire protection, and enhanced access requirements for the fire department. Implementation of the Code is enforced by AFR. 2.3.4 City of Anaheim Weed Abatement The City of Anaheim Municipal Code Title 6, Chapter 6.16, Weed Abatement, requires vegetation or noxious growth to be maintained to a maximum of 6 inches above the grade, and the removal of all refuse and noxious growth on any lot of private premises. This code determines alternative abatement procedures of vegetation that is considered an extreme fire hazard on properties located within the WUI are a, VHFHSZ, or high hazard fire areas (City of Anaheim 2025a). Further, AFR currently enforces the Brush Clearance and Vegetative Growth Guideline, made enforceable by adoption into Anaheim Municipal Code via Section 16.08.020, which adopts and amends the CFC. The guideline establishes fire‑prevention requirements within Anaheim’s WUI Fire Area, mandating fuel modification plan approval for new construction, restricting access during fire‑closure periods, and prohibiting activities that could ignite fires. Property owners must maintain defensible space by clearing combustible vegetation within 100 feet of structures (or more if required), pruning trees for vertical and horizontal clearance, removing deadwood, keeping roofs free of debris, and ensuring safe storage of firewood and combustibles. The document also requires 10‑foot vegetation clearance along roadways, prescribes minimum clearance distances around electrical transmission lines, prohibits tampering with fire‑area infrastructure, and regulates disposal of ashes and debris. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 30 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT 17507 31 JUNE 2026 3 Emergency Response Plans and Preparedness Resources The City of Anaheim (City) and County of Orange (County) currently have some existing emergency response plans that aid in the planning and preparation for an emergency evacuation. These plans offer valuable information for preparing the public for an emergency through the construction of an emergency evacuation study. 3.1 City of Anaheim 3.1.1 City of Anaheim Emergency Operations Plan The 2017 City of Anaheim Emergency Operations Plan (EOP) describes a comprehensive emergency management system that provides for a planned response to disaster situations associated with natural disasters, technological incidents, terrorism, and nuclear-related incidents. It delineates operational concepts relating to various emergency situations, identifies components of the Emergency Management Organization, and describes the overall responsibilities for protecting life and property and providing for the overall well-being of the population. The plan also identifies the sources of outside support that might be provided (through mutual aid and specific statutory authorities) by other jurisdictions, state and federal agencies, and the private sector. Chapter 4 of the EOP: Concept of Operations, of the EOP provides an overview of evacuation functions, agency roles and responsibilities, and overall guidelines for the evacuation of people and animals from hazardous areas to areas of safety in incidents with and without warning. It describes the coordination of participating organizations and chain of command, and how the Orange County Operational Area will manage the evacuation process before, during, and after the emergency, and may be used as a template for development of other jurisdictional evacuation plans. 3.1.2 City of Anaheim Local Hazard Mitigation Plan The City’s 2022 LHMP provides a comprehensive assessment of the City’s threats from natural and human-caused hazards and a coordinated strategy to reduce these threats. It identifies resources and information to help community members, City staff, and local officials understand local threats and make informed decisions. The LHMP can also support increased coordination and collaboration between the City, other public agencies, local employers, service providers, community members, and other key stakeholders. Wildland and urban fires have been identified by the City as the highest priority hazard threat (City of Anaheim 2022). Threats to the City of Anaheim, as identified by the LHMP, include Wildland/Urban Fire, Earthquake, Severe Weather, Dam Failure, Landslide, Disease and Pests, Flood/Storm, Human- Caused Hazards, and Climate Change. 3.1.3 City of Anaheim Know Your Way in an Emergency The City of Anaheim has created a reference website to assist in preparing occupants of east Anaheim for an evacuation. Know Your Way provides evacuation zone maps, evacuation routes, and general guidance on how to prepare to evacuate in the event of an emergency. Know Your Way provides maps showing major streets and secondary roads occupants can use to navigate to the primary evacuation route (State Route [SR] 91) to head west. This WES affirms the Know Your Way routes as the most likely evacuation routes for most emergency types; DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 32 JUNE 2026 however, as rightly acknowledged in the Know Your Way program, evacuation routes are subject to change as an incident progresses. While the evacuation routes documented are generally the quickest way to SR 91, evolving conditions may mandate redirection to maintain safety. A high level of resident awareness, including knowing one’s evacuation zone, understanding the difference between evacuation alerts and orders, and being familiar with routes to take, can significantly reduce or avoid operational challenges during an evacuation and ultimately improve the speed and overall effectiveness of the evacuation. The “Know Your Way” program is referenced throughout this Study to show the City’s operational baseline and to demonstrate how lessons learned from previous wildfire events continue to inform and strengthen evacuation practices. 3.1.4 Preparing for Wildfire Website AFR hosts a webpage to assist Anaheim residents in preparing themselves, their communities, and their homes for wildfire. The webpage showcases the City’s Know Your Way Plan, Cal FIRE ‘Ready, Set, Go!’ evacuation preparedness guidelines, wildfire preparedness plans for diverse needs such as Access and Functional Needs and special populations, children and seniors, and an equine or livestock evacuation registration form, to assist with planning for large animal evacuations. The webpage also provides resources to help residents prepare their homes for wildfire. Resources include guides for home hardening, defensible space, and fire-resistant plants, as determined by AFR. 3.1.5 City of Anaheim Public Utilities Wildfire Mitigation Plan The City of Anaheim Public Utilities (APU) Wildfire Mitigation Plan establishes methods and procedures to operate APU’s electrical utility lines and equipment while minimizing the risk of utility caused wildfire. As detailed in the Wildfire Mitigation Plan, APU received FEMA grant funding of $1.16 million for an underground conversion project of 2.63 miles of overhead power lines, as well as additional new underground equipment including 31 transformers, 2 capacitors, and 11 switches (City of Anaheim 2024). Two additional wildfire cameras were installed in 2023, providing Anaheim with a total of 14 cameras within and adjacent to APU service territory (City of Anaheim 2024). APU also collaborates on Vegetation Management with AFR, the Department of Public Works, and Orange County Fire Authority (OCFA). APU customers are not impacted by Southern California Edison (SCE) Public Safety Power Shutoffs; however, the City of Anaheim depends on regional transmission service via SCE. In the event SCE powerlines are de-energized during a Public Safety Power Shutoff, power is rerouted through SCE redundant transmission paths that do not traverse through an APU designated fire threat zone (FTZ), and therefore APU is determined to have a very low risk of losing transmission service in Anaheim during a Public Safety Power Shutoff. APU elects to de-energize Tier 3 FTZ overhead lines during Santa Ana Wildfire Threat Index Extreme rating, but not during a Red Flag Warning. 3.1.6 Community Emergency Response Team AFR supports a Community Emergency Response Team Program. The Community Emergency Response Team Program educates City residents about disaster preparedness and trains them in basic disaster response skills such as fire safety and medical operations. The Community Emergency Response Team training course is approved by FEMA and provides residents with critical skills in emergency preparedness and response. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 33 JUNE 2026 3.2 Other Relevant Plans 3.2.1 Orange County Transportation Authority Hazard Mitigation Plan The 2021 Orange County Transportation Authority (OCTA) Hazard Mitigation Plan was designed to support current OCTA emergency management plans by mitigating potential impacts of natural hazards on the OCTA service area. Based on a ranking considering severity, magnitude, frequency, onset and duration, Wildfire was ranked as the top worst-case scenario hazard and the top most likely scenario hazard. Wildfire was followed by earthquake, epidemic/ pandemic, severe weather, flooding, mass earth movement, and tsunami. The OCTA Hazard Mitigation Plan determined that ridership in the WUI reached over a half-million boardings in 2019. Wildfire has the potential to expose riders to wildfire hazards such as smoke and air pollution, as well as secondary hazards such as increased flooding or mass earth movement risks. Additionally, it was determined that OCTA infrastructure such as bus routes, the SR-91 Freeway, the Interstate (I) 405 Freeway, the Metrolink Rail, and other freeways were exposed to risk of wildland fire hazards and in the wildland–urban influence, interface, or intermix Fire Hazard Zone (OCTA 2021). In east Anaheim, SR-91, SR-241, and nearby Metrolink Rail are within the wildland–urban influence, interface, and intermix Zones3. Mitigation Strategies aimed at addressing wildfire hazards as proposed in the OCTA Hazard Mitigation Plan include the following: ▪ (ID 14) performing fuel modifications on OCTA properties and plant fire-adapted native plants. ▪ (ID 24) prepare and implement fire management plans, invasive species control, public education and awareness, and enhanced security measures to mitigate the potential for wildfire, and consider closure of conservation properties during times of high fire risk. ▪ (ID 25) monitor and address adverse effects from properties adjacent to conservation properties. 3.2.2 County of Orange Community Wildfire Protection Plan The County of Orange Community Wildfire Protection Plan (CWPP) addresses pre-fire improvements, vegetation management, ignition prevention, community education and outreach, firefighting initiatives and mitigations. The CWPP provides stakeholders and residents of the CWPP area with an overview of the wildland fire risks and hazards, and recommended course of action for hazardous fuel reduction areas and ways to reduce the potential ignitions and impacts of wildfire in the CWPP area (Orange County 2017). 3.2.3 Orange Unified School District Safe School Plans It is important to note that the Orange Unified School District is a separate entity from the City; therefore, the City does not have jurisdiction over the school district. However, during an emergency, the two entities, along with various other emergency response entities, coordinate efforts through the National Incident Management System as effectuated in the Anaheim EOP to work towards a safe evacuation of students and residents. Each of the district’s schools develops and adopts a Comprehensive Safe School Plan. Each site is required annually, by March 3 https://www.octa.net/pdf/OCTA_2021_HMP.pdf. Figure 11-5 – OCTA Wildland–Urban Interface Zones DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 34 JUNE 2026 1, to have reviewed, and if necessary, updated their Safe School Plan. Each school then forwards the Safe School Plan to the district through the office of Student and Community Services. The office of Student and Community Services provides plan development assistance when necessary and maintains a file of individual school plans, which are available for inspection by the public. Additionally, all schools in the district are linked through an emergency radio contact system, in case of a disaster where different schools need to coordinate their efforts. Radio drills are held periodically by the district to be prepared for an emergency and practice the school’s policies and procedures. During the 2017 Canyon II Fire, the Orange Unified School District implemented a coordinated evacuation in response to rapidly expanding wildfire evacuation orders in Anaheim Hills and Orange. On October 9, AFR recommended evacuations east of Weir Canyon Road and Serrano Avenue, prompting Orange Unified School District to evacuate Running Springs Elementary, Anaheim Hills Elementary, and Canyon Rim Elementary utilizing available school busses to Canyon High School, where students were safely staged, and reunited with families through controlled procedures the same day (Orange Unified School District 2017). As evacuation areas expanded, El Modena High School was activated as a Red Cross evacuation center. The following day, nine Orange Unified School District schools were closed, and all athletic and after‑school activities were canceled while closely monitoring air quality and coordinating with fire, police, and emergency agencies. Schools reopened in phases as conditions improved, with all campuses fully reopening by October 12, 2017, following safety inspections, air‑quality reviews, and the lifting of evacuation orders, demonstrating that pre‑identified relocation sites, bus‑based evacuations for students, and interagency coordination can effectively protect students during fast‑moving wildfires (Orange Unified School District 2017). DRAFT 17507 35 JUNE 2026 4 Public Outreach and Engagement Public outreach and engagement serve as a major component in the development of this Wildfire Evacuation Plan. To engage as many individuals as possible within the Anaheim Hills community, 8,000 doorhangers and 8,000 postcards were distributed to 16,000 residential units within Know Your Way Zones 1 through 15 with information about the Know You Way website, online community survey, and upcoming in-person and virtual community workshops. This information was also shared on relevant City social media platforms and the community’s Anaheim Hills Buzz Facebook page. Community members were invited to provide input through participation in an 18-question online survey and/or attend one of four community workshops, two of which were offered virtually. Overall, there were 250 responses to the online survey, 80 attendees at the in-person workshops, and 20 attendees at the virtual workshops. The community input collected through these outreach efforts directly informs the WES and provides valuable insights for refining future public education and outreach initiatives. These findings also help identify gaps between public officials’ assumptions and the lived experiences and perceptions of the community. This section summarizes the public outreach and engagement efforts; the full discussion of results and supporting data may be found in Appendix A, Community Engagement Summary. 4.1 Community Workshops Four community workshops were held in July 2025 for the Anaheim Hills WES, two virtual and two in person. The virtual workshops were held on July 8 and July 30 via Zoom. The in-person workshops were held on July 16, at the Anaheim Hills Golf Club, and July 21, at the East Anaheim Community Center. The four workshops had a total of 100 attendees, including 80 in person and 20 attending virtually. Attendees represented a variety of participants including homeowners, local agency representatives, environmental groups, homeowners’ associations, and community groups. These workshops included a brief overview of the project followed by self-directed and active engagement activities aimed at garnering discussion and gaining input from community members. 4.1.1 Self-Directed Activity Both in-person and virtual attendees were provided with a self-directed activity in order to identify the perceived evacuation issues in the community. When asked in the self-directed activity what the biggest obstacles were preventing participants from evacuating, lack of adequate evacuation routes, not having a family evacuation plan in place, and not having alternative housing once they evacuate were identified as the largest barriers. Additionally, when asked what risk reduction methods should be a priority in their community: workshop participants identified improving evacuation routes, roadside vegetation clearance, and invasive plant removal as top risk reduction methods in Anaheim Hills. In order to establish the validity of the need for increased fuels reduction on Public Lands, it would be advisable to prepare a Wildfire Risk Assessment that evaluates both private and public lands for their contribution to fire progression using geographic information system modeling such as FlamMap or IFTDSS. Fire modeling can aid in evaluating the effectiveness of specific fuel breaks in order to prioritize finite city resources in a timely and cost-effective way. Implementation of the existing CWPP would be effective for securing grant funding to implement such a Wildfire Risk Assessment and/or fuels reduction on publicly owned properties. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 36 JUNE 2026 4.1.2 Evacuation Role Play An evacuation role play activity was conducted in order to better understand behavioral aspects of evacuation. When asked how long it would take people to evacuate before and after going through the activity, the majority of the participants reported that it would take them between 20 and 30 minutes from receiving the order to leave. After gathering initial results, attendees were guided through the various steps that would need to be taken to actually prepare for and initiate evacuation. After developing a shared understanding of the various necessary tasks, the attendees were asked to answer the same question again. Although the average stayed the same before and after the activity, there was an increase in time reported to get ready for evacuation after conducting the activity with more respondents selecting between 30 minutes and 40 minutes, 40 minutes and 50 minutes, between 50 minutes and 60 minutes, or over 60 minutes after. There were only a few participants whose answers indicated a decrease in time needed to prepare for an evacuation. 4.1.3 Community Discussions Two community discussions occurred around two central components: Evacuation / Community Response and Wildfire Planning. Each discussion was focused on defining challenges and opportunities relevant to that topic. A summary of those discussions is below: 4.1.3.1 Evacuation/Community Response Residents reported challenges such as not knowing when to leave, mobility limitations, difficulties evacuating pets, inconsistent Police or Fire instructions, and roadway capacity constraints during evacuations. Opportunities identified include expanding Anaheim Alert and Know Your Way outreach, issuing earlier evacuation notifications, adding alternative evacuation routes such as the Mohler loop, and improving coordinated public messaging between Fire and Police Departments. 4.1.3.2 Wildfire/Hazard Planning Key challenges included overgrown vegetation, concerns about fire‑hydrant capacity following recent regional fires, and the strain new developments place on already limited road networks. Opportunities include stronger vegetation enforcement, targeted outreach to homeowners associations, more community training opportunities, regular hydrant maintenance, and limiting development in High FHSZ areas. 4.2 Community Survey The community survey ran from June to August 2025 and included 18 questions that covered the following topics: ▪ Participants’ past experiences with evacuations and evacuation priorities ▪ How participants get their evacuation information ▪ Challenges and opportunities to help improve participants’ experience with general emergency preparedness and future evacuations DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 37 JUNE 2026 The survey had 250 responses, with the vast majority of participants self-reporting as living in Anaheim Hills (96%). Survey respondents represented all evacuation zones within Anaheim Hills with the most responses coming from Deer Canyon (Zone 4), Oak Canyon (Zone 5), and Ronald Reagan Park (Zone 2). Further, participants were queried the following questions: ▪ What is your greatest concern regarding a wildfire? ▪ What is the biggest obstacle that you foresee to evacuation? ▪ What are the most used information sources during an evacuation? ▪ What actions do you desire the city to take? 4.2.1 Greatest Wildfire Concerns When asked what their greatest wildfire concerns were, the top concerns were: Loss of home or other structure (89% of respondents), Evacuation (70% of respondents), and Injury or death (58% of respondents). 4.2.2 Biggest Obstacles to Evacuation When asked what their greatest barriers to evacuation were, the top concerns were: Family members in different places when needing to evacuate (45% of respondents), My neighborhood does not have adequate evacuation routes (44% of respondents), and Pets (42% of respondents). 4.2.3 Behavior Under an Evacuation Alert vs. Evacuation Order When asked how they would respond if given an evacuation alert versus an evacuation order, 89% of respondents indicated that they would immediately evacuate after receiving an alert while only 80% responded that they would leave immediately after receiving an order, potentially indicating a lack of understanding about alerts vs orders. 4.2.4 Evacuation Information Sources When asked what information sources residents most used regarding evacuation information, the top sources identified were Anaheim Alert (70% of respondents), social media (64% of respondents), and ReadyOC (45% of respondents). 4.2.5 Desired City Actions When asked what actions the respondents want the City to take to help community members become better prepared for a disaster, as shown in Figure 7, Highway 241 Ignition: 33 mph NE Winds, respondents would like the City to provide effective emergency notifications and communication (72% of respondents), and provide community outreach regarding emergency preparedness (52% of respondents). 4.3 Summary The Anaheim Hills WES Community Engagement Summary outlines feedback gathered from four community workshops and a summer‑long survey of all project area occupants focused on wildfire preparedness and evacuation challenges in Anaheim Hills. Across workshops, residents identified inadequate evacuation routes, lack DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 38 JUNE 2026 of personal evacuation plans, and limited post‑evacuation housing as key barriers, while also emphasizing the need for improved vegetation management and enhanced public outreach. Role‑play exercises revealed that many residents underestimate the true time required to evacuate, and discussion sessions highlighted perceived issues such as inconsistent emergency messaging, mobility limitations, pet evacuation difficulties, and concerns over development in high‑risk areas. Survey results echoed these themes, identifying loss of homes, evacuation difficulty, and injury as top wildfire concerns, while residents reported relying heavily on Anaheim Alert and social media for evacuation information and requested stronger communication, preparedness outreach, and infrastructure improvements from the City. As a result of these findings, the City has an opportunity to respond through increased education/outreach, preparedness, enforcement, and potentially evacuation corridor enhancement. Educational topics such as continuing to inform residents of their evacuation routes, the importance of having an evacuation plan, how schools have prepared for evacuation, and the amount of time it takes to prepare to evacuate would be well-received by the public. The City has an opportunity to increase preparedness through designating potential emergency shelters and providing those ahead of time, with the caveat that the specifics of an incident may result in different shelters being more appropriate, the same consideration that is applied to evacuation routes. Some of the topics may warrant further study such as claims that vegetation clearance along roadways and in public lands was inadequate; while these claims would warrant specific inspection to determine validity, the results are nonetheless informative of the public’s perception, which is their reality. DRAFT 17507 39 JUNE 2026 5 Existing Infrastructure Responding Fire Stations Eastern Anaheim is serviced by AFR. AFR provides fire prevention and suppression, emergency medical, and rescue services from 11 stations. AFR serves nearly 350,000 residents throughout the City. AFR Stations 8, 9, and 10 are located in eastern Anaheim. AFR Station No. 8 is located at 4555 E Riverdale Ave, Anaheim, California. AFR Station 8 is equipped with a Type I engine, a ladder truck, two cross-staffed Type VI brush patrols, and a cross-staffed water tender; the engine and ladder crews include at least two paramedics. AFR Station 9 is located at 6300 Nohl Ranch Road, Anaheim, California and is equipped with a Type I engine, and a cross-staffed Type III brush engine; the engine crew includes at least two paramedics. AFR Station No. 10 is located at 8270 E Monte Vista Road, Anaheim, California. AFR Station 10 is equipped with a Type I engine, a ladder truck, and a cross-staffed Type III brush engine; the engine and ladder crews include at least two paramedics. Figure 5, Safety Infrastructure Map, shows the safety infrastructure, including fire and police stations that may respond in the event of an emergency, within the City boundary. In addition to the above stated City resources, Memorandum’s of Understanding exist with surrounding jurisdictions, such as Yorba Linda, Placentia, CAL FIRE, OCFA, and other agencies. As described further in Section 2, the California Fire Service and Rescue Emergency Mutual Aid Plan allows for nearby agencies and jurisdictions to assist when local agencies’ capabilities and resources are overwhelmed. Nearby and available fire stations in the general vicinity may send additional resources during a fire include but are not limited to OCFA Station 32 in Yorba Linda, and Stations 2, 8, and 23 in the City of Orange. These nearby crews and stations may quickly offer assistance when necessary to the City of Anaheim and the Anaheim Hills community. The California Fire Service and Rescue Emergency Mutual Aid Plan provides an orderly operation of mutual aid on a voluntary basis between cities, cities and counties, fire districts, special districts, county fire departments, and applicable state agencies. Furthermore, the Plan provides systematic mobilization, organization, and operation of necessary fire and rescue resources of the state and its political subdivisions in mitigating the effect of disasters. The Plan provides a comprehensive plan, as well as a fire and rescue inventory of personnel, apparatus, and equipment. Normal fire department operating procedures are utilized, including day-to-day mutual aid agreements, and plans that have been developed by local fire and rescue officials. Evacuation Routes The City of Anaheim created ‘Know Your Way’, an evacuation awareness program, to assist residents in evacuation preparedness efforts. Know Your Way divides (eastern) Anaheim into zones and assigns each zone a numerical value from 1 through 15. Know Your Way maps provide each zone with a general overview of possible routes to reach a major roadway, such as SR-91, in the event of an emergency. A list of the Know Your Way Zones and suggested evacuation routes can be found at the Know Your Way website: anaheim.net/KnowYourWay. There are many possible evacuation routes available within Anaheim during an emergency. Primary evacuation routes within the City of Anaheim may include I-5, SR-55, SR-57, SR-91, SR-90, and SR-241. Additional roadways throughout the City may be utilized to get to these roadways, or as an evacuation route during an emergency. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 40 JUNE 2026 Evacuation Centers The City of Anaheim will open evacuation shelters in the event of an emergency. In order to maintain flexibility during a wildfire incident, the locations of open evacuation centers will be released to the public as they become available to evacuees. The locations of evacuation centers are not pre-designated, as wildfires and evacuations are dynamic in nature and the availability of evacuation centers are dependent on a number of factors, such as where the fire ignited, the rate of spread, and how impacted City resources are. The Orange County Sheriff’s Department developed and updates the Orange County Public Information Map with essential information to assist with emergency evacuation. Dynamic layers on the map include road closures, emergency and animal shelter locations, and evacuation area zones including evacuation orders, evacuation warnings, and shelter in place. The Public Information Map can be found at the following link: https://www.ocsheriff.gov/resources-during-disaster Further, during an emergency, the Red Cross may activate emergency mass care shelters, if assistance is initiated and requested by the City. A map of Red Cross emergency shelters is available at https://www.redcross.org/get- help/disaster-relief-and-recovery-services/find-an-open-shelter.html. The Anaheim Know Your Way Plan does not determine evacuation centers, though it determines that in an emergency, students in the Anaheim Hills area are tentatively set to be evacuated to Orange High School, to avoid creating congestion in east Anaheim, and horses and livestock will evacuate to the Orange County Fairgrounds4. Existing Road Network People driving within or through Anaheim are served by a network of arterial, collector, and local residential roads, providing connectivity to destinations, and to nearby highways and freeways. Brief descriptions of each type of roadway classification applicable to City streets in the study area are provided below (City of Anaheim 2025c). Scenic Expressway: Divided roadways that have restricted access, serve intercity traffic, and provide scenic vistas. This four-to six-lane divided facility has a right-of-way that varies from a width of 106 feet to 148 feet. Weir Canyon and portions of Santa Ana Canyon Road are both scenic expressways. In 1966, the City Council adopted the Santa Ana Canyon Roads Access Points Map, limiting access on Santa Ana Canyon Road from Cerro Vista Road east to Weir Canyon Road. Principal Arterial: Roadways that carry a large volume of regional through traffic. Principal arterials are typically eight-lane divided facilities. The typical right-of-way of a principal arterial is 144 feet. Major Arterial: Roadways that connect to freeways and typically have six lanes, a landscaped median, left turn pockets, and a right-of-way width of 120 feet. Primary Arterial: Roadways that provide for circulation within the City and to its adjacent communities. Primary arterials are typically six-lane divided facilities or four-lane divided facilities with left turn pockets. Primary arterials can have bike lanes. The typical right-of-way width of a primary arterial is up to 120 feet. 4 https://www.anaheim.net/5204/Know-Your-Way DRAFT DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 42 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 43 JUNE 2026 Hillside Primary Arterial: Roadways that provide for circulation within the City and to its adjacent communities through areas that are constrained by terrain. Primary arterials are typically six-lane divided facilities or four-lane divided facilities with left turn pockets. Hillside primary arterials can have bike lanes. The typical right-of-way width of a hillside primary arterial is up to 112 feet. Secondary Arterial: Roadways that provide for circulation within the City. Secondary arterial facilities are four-lane roadways, with two parking lanes, that are undivided. Secondary arterials can have bike lanes or parking lanes, with some instances where both are provided. These facilities have a typical right-of-way width of 90 feet. Hillside Secondary Arterial: Roadways that provide for circulation within the City through areas that are constrained by terrain. Hillside secondary arterial facilities are four-lane roadways, that are undivided. These facilities have a typical right-of-way width of up to 78 feet. Collector Street: Roadways that distribute residential traffic from its point of origin to higher capacity facilities. They are typically two-lane undivided roadways with a 64-foot right-of-way width. Hillside Collector Street: Roadways that distribute residential traffic from its point of origin to higher capacity facilities through areas that are constrained by terrain. They are typically two-lane undivided roadways with up to a 70-foot right-of-way width. Hillside collector streets can include parking lanes. Complete Streets Collector: Roadways that distribute local traffic from its point of origin to higher capacity facilities. They include enhanced multimodal features to ensure the efficient and safe movement of all forms of travel including automobile, truck, transit, bicycle, and pedestrian. The typical right-of-way width of a complete streets collector is 90 feet. In addition to local arterial roads, Anaheim is served by three freeways that transverse the City: I-5, SR-57, and SR-91. In addition, SR-55 connects to SR-91 in Anaheim near Tustin Avenue and Santa Ana Canyon Road. These freeways and highways are described below: I-5 provides regional access to Los Angeles County to the north and San Diego County to the south. Within the City, I-5 has interchanges at Magnolia Avenue/Orangethorpe Avenue, Brookhurst Street/La Palma Avenue, Euclid Street, Lincoln Avenue, Disneyland Drive, Ball Road, Harbor Boulevard, Anaheim Boulevard, Katella Avenue, Orangewood Avenue, and State College Boulevard. There are also High Occupancy Vehicle ramps at Gene Autry Way, Disneyland Drive, and Disney Way. SR-57 provides access to northern Orange County and eastern Los Angeles County and terminates just south of the Anaheim City limit. Within the City, there are ramps at Lincoln Avenue, Ball Road, and Katella Avenue. SR-91 provides regional access westerly to South Bay cities of Los Angeles County and terminates to the east of SR-60, providing access to Riverside County and San Bernardino County. Within the City, there are ramps at Brookhurst Street, Euclid Street, Harbor Boulevard, Lemon Street, East Street, State College Boulevard, Glassell Street/Kraemer Boulevard, Tustin Avenue, Lakeview Avenue, Imperial Highway, Weir Canyon Road, and Gypsum Canyon Road. SR-55 provides access to the central coastal communities of Orange County, connecting between SR- 91 and Newport Beach. SR-55 can be accessed via SR-91 and ramps at Lincoln Avenue/Nohl Ranch Road, just outside of the City limits. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 44 JUNE 2026 High Occupancy Vehicle lanes have been constructed on several of these freeways that pass through or near the City, including sections of I-5, SR-57, SR-91, and SR-55. In addition, two toll facilities travel through the City limits. The 91 Express Lanes are an automated four-lane facility in the median of SR-91 that provides a variable congestion pricing facility between the SR-55 interchange and the I-15 interchange in Riverside. OCTA purchased and now operates the portion of these lanes in Orange County. The Riverside County Transportation Commission operates the portion of these lanes, which are in Riverside County. In addition, the Transportation Corridor Agencies operates toll facilities across Orange County, including SR-241, which connects to SR-91 in eastern Anaheim. A portion of SR-91 is part of the California Scenic Highway Program. Scenic highways are transportation corridors where visual intrusions would impact views of natural beauty from the highway. The portion of SR- 91 between SR- 55 and post mile 13.4 is officially designated as a Scenic Highway. In addition, the portion of SR-91 between east of post mile 13.4 is designated as an eligible Scenic Highway. The boundary between the Scenic Highway and eligible Scenic Highway is just west of the truck scales. Santa Ana Canyon Road functions primarily as a Scenic Expressway, transitioning to a Primary Arterial and Hillside Secondary Arterial along its length. The roadway generally provides two to three lanes per direction, with raised medians along most segments and striped medians present in certain locations. Posted speed limits range from 40 mph to 50 mph, and curb-to-curb widths vary from approximately 68 feet to over 124 feet. Sidewalks and trails are intermittently provided, with some gaps, and bicycle facilities consist primarily of Class II bike lanes. Nohl Ranch Road is classified as a Hillside Secondary Arterial and provides two lanes in each direction with a striped median. The roadway has a posted speed limit of 40 mph and curb-to-curb widths ranging from approximately 52 feet to 60 feet. Sidewalks are provided on some segments, but no bicycle facilities are currently present. Canyon Rim Road is a Hillside Secondary Arterial that generally provides two lanes per direction with either a two-way left-turn lane or raised median. The posted speed limit is 35 mph, and the curb -to-curb width is approximately 63 feet. Sidewalks are provided along the corridor, and Class II bike lanes are striped along both sides of the roadway. Anaheim Hills Road is a Hillside Secondary Arterial that generally provides two lanes per direction with a raised median. The posted speed limit is 35 mph, and the curb-to-curb width ranges between 70 feet and 115 feet. Sidewalks are provided along the corridor, and Class II bike lanes are striped along both sides of the roadway. Serrano Avenue is a Hillside Secondary Arterial with two lanes per direction and a combination of raised, striped, and two-way left-turn lane medians. The posted speed limit ranges from 35 mph to 45 mph, with curb-to-curb widths ranging from approximately 60 feet to 100 feet. Sidewalks are present throughout the corridor. Class II bike lanes are provided west of Canyon Rim Road. Imperial Highway functions as both a Major and Primary Arterial. The roadway provides between one and three lanes per direction, separated by a raised median. Posted speed limits range from 35 mph to 50 mph, and curb-to- curb widths range from approximately 84 feet to 115 feet. Sidewalks are provided along both sides of the roadway. Bicycle facilities consist of Class II bike lanes south of Nohl Ranch Road. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 45 JUNE 2026 Fairmount Boulevard is classified as a Hillside Secondary Arterial and provides one lane per direction separated by a raised median. The roadway has a posted speed limit of 35 mph, with curb-to-curb widths varying between approximately 38 feet and 77 feet. Sidewalks are intermittently provided, and no bicycle facilities are present. Weir Canyon Road functions as both a Major Arterial and a Scenic Expressway. The roadway provides three lanes per direction, separated by a raised median. The posted speed limit is 40 mph, with curb-to-curb widths ranging from approximately 118 feet to 139 feet. Sidewalks are provided along both sides of the corridor, and Class II bike lanes are striped south of Santa Ana Canyon Road. Further information on the local roadway network is below in Table 3, Roadway Classifications. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 46 JUNE 2026 Table 3. Roadway Classifications Roadway Segment Functional Classification Lanes per Direction Presence of Median Posted Speed Limit (mph)1 Curb to Curb (feet) Sidewalk Bicycle Facility Anaheim Hills Road Santa Ana Canyon Road to Nohl Ranch Road Hillside Secondary Arterial 2 SB / 2 NB Raised 35 70’ - 114’ Yes Class II Santa Ana Canyon Road Lakeview Avenue to Royal Oak Road Scenic Expressway 2 WB / 2 EB Raised 45 85’ - 124’ None Class II Santa Ana Canyon Road Royal Oak Road to Old Santa Ana Canyon Road Scenic Expressway 3 WB / 3 EB Raised 45 118’ Intermittently Class II Santa Ana Canyon Road Old Santa Ana Canyon Road to Imperial Hwy Scenic Expressway 3 WB / 2 EB Raised 45 123’ Yes Class II EB Only Santa Ana Canyon Road Imperial Hwy to Solomon Drive Primary Arterial 3 WB / 2 EB Raised 40 105’ Intermittently Class II EB Only Santa Ana Canyon Road Solomon Drive to Deer Canyon Road Primary Arterial 2 WB / 2 EB Raised 40 100’ Intermittently Class II Santa Ana Canyon Road Deer Canyon Road to Festival Drive Primary Arterial 2 WB / 2 EB Striped 40 68’ None Class II Santa Ana Canyon Road Festival Drive to Woodcreek Road Scenic Expressway 3 WB / 3 EB Raised 50 122’ Yes Class II Santa Ana Canyon Road Woodcreek Road to Gypsum Canyon Road Hillside Secondary Arterial 1 WB / 1 EB Striped 50 30’ – 35’ No None Nohl Ranch Road Meats Avenue to Serrano Avenue Hillside Secondary Arterial 2 WB / 2 EB Striped * 40 52’ – 60’ Yes None Canyon Rim Road Nohl Ranch Road to Paseo Ganado Hillside Secondary Arterial 2 WB / 2 EB TWLTL 35 63’ Yes Class II Canyon Rim Road Paseo Ganado to Serrano Avenue Hillside Secondary Arterial 2 SB / 2 NB Raised 35 63’ Yes Class II DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 47 JUNE 2026 Table 3. Roadway Classifications Roadway Segment Functional Classification Lanes per Direction Presence of Median Posted Speed Limit (mph)1 Curb to Curb (feet) Sidewalk Bicycle Facility Serrano Avenue Nohl Ranch Road to Livingston Way Hillside Secondary Arterial 2 WB / 2 EB TWLTL 45 60’ – 64’ Yes Class II Serrano Avenue Livingston Way to Canyon Rim Road Hillside Secondary Arterial 2 WB / 2 EB Striped 45 63’ Yes Class II WB Only Serrano Avenue Canyon Rim Road to Highcrest Drive Hillside Secondary Arterial 2 WB / 2 EB Raised 40 63’ Yes None Serrano Avenue Highcrest Drive to Weir Canyon Road Hillside Secondary Arterial 2 WB / 2 EB Striped 35 70’ – 100’ Yes None Imperial Highway SR-91 On-/Off-Ramp to Santa Ana Canyon Road Principal Arterial 4 SB / 4 NB Raised 35 115’ Yes None Imperial Highway Santa Ana Canyon Road to Nohl Ranch Road Primary Arterial 3 SB / 2 NB Raised 35 90’ Yes None Imperial Highway Nohl Ranch Road to Hudson Bay Drive Primary Arterial 2 SB / 2 NB Raised 40 90’ Yes Class II Imperial Highway Hudson Bay Drive to City Limit Primary Arterial 2 SB / 1 NB Raised 40 84’ – 88’ Yes Class II Fairmount Boulevard Santa Ana Canyon Road to Canyon Rim Road Hillside Secondary Arterial 1 SB / 1 NB Raised 35 38’ – 77’ Intermittently None Weir Canyon Road SR-91 Off-Ramp to Santa Ana Canyon Road Major Arterial 3 SB / 3 NB Raised 40 139’ Yes None Weir Canyon Road Santa Ana Canyon Road to Oak Canyon Drive Scenic Expressway 3 SB / 3 NB Raised 40 118’ – 124’ Yes Class II CRA 2025 Notes: TWLTL = Two‑Way Left‑Turn Lane. 1 The City of Anaheim does not have different speed limits in different directions. Speed Limits are uniform for both directions on any segment. * Median changes to TWLTL or Raised for very small portions of the segment DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 48 JUNE 2026 5.1 Emergency Alert Systems The City of Anaheim (City) utilizes Anaheim Alert for its emergency notification system. Anaheim Alert is a mass communications hub platform that allows the City to provide secure, reliable, and relevant information about the current emergency to citizens in real time. Emergency information specifically for the City of Anaheim is also distributed through the My Anaheim app. Residents can also register to receive alerts from AlertOC, which is the mass notification system that informs citizens of emergencies via voice messages and text messages within Orange County (County). In the event of a wildfire within the City limits, the Incident Command, AFR, or other City departments will coordinate with Anaheim Police Department (APD) and the Orange County Sheriff’s Department to release emergency communications to affected populations. The APD and Orange County Sheriff’s Department have the responsibility to release emergency notifications to affected population(s) via the Anaheim Alert and AlertOC. Anaheim Alert and AlertOC accounts can be created at the following links: Anaheim Alert: (https://member.everbridge.net/index/892807736725456#/signup) AlertOC: (https://member.everbridge.net/453003085613900/login) Real-time emergency and evacuation notifications may be obtained through different media outlets such as television and radio. In addition, the Wireless Emergency Alerts System and Emergency Alert System are county- wide and broadcasts emergency information via KWVE 107.9 FM and 640 AM. Municipal Cable Channel 3 is the local government channel that will be used to provide the public with alerts and notification of various disaster situations in and around Anaheim. Social media has proven to be a powerful tool in information dissemination. In the event of an emergency or disaster, the City of Anaheim together with AFR and APD will utilize their respective social media platforms to engage the public and provide situational awareness. Integrating critical information being received from verified accounts into the emergency organization can help to increase situational awareness and gain a better common operating picture for both public safety responders as well as the general public (City of Anaheim 2017). The following are the verified social media accounts for the City of Anaheim: City of Anaheim ▪ https://x.com/City_of_Anaheim/ ▪ https://www.facebook.com/cityofanaheim/ Anaheim Police Department ▪ https://x.com/anaheimpd/ ▪ https://www.facebook.com/AnaheimPD/ Anaheim Fire & Rescue ▪ https://x.com/AnaheimFire ▪ https://www.facebook.com/AnaheimFireAndRescue/ DRAFT 17507 49 JUNE 2026 6 Constrained Roadways and Parcels Constrained Areas As part of the Safety Element update process in 2022/2023 and as required by SB99, the City of Anaheim identified areas of the City that have single ingress and egress conditions, through an analysis of constrained roadways and parcels, as described herein in Section 2.3.1.2. As explained in the relevant section of the Safety Element, Constrained Roadways are segments of the roadway network that have a single point of connection with the rest of the roadway network. These could be cul-de-sacs or roadways with secondary connections that are not publicly accessible due to a gate or other constraint. Constrained Parcels are areas of the City where at least 30 parcels are located along a constrained roadway. These parcel locations are accessible by one means of ingress/egress, which is consistent with Cal FIRE guidance regarding PRC Section 4290.5. The City’s Safety Element identified 82 constrained parcel locations, with 48 of the 82 locations located in eastern Anaheim, primarily in Anaheim Hills. 28 of the constrained areas are within or adjacent to a VHFHSZ (City of Anaheim 2023). Figure 6, Constrained Roadways and Parcels, shows areas of concern for safe and efficient evacuations. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 50 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT 0 460230FeetnDate: 4/29/2025 User: nreid Path: Z:\Projects\j1750701\MAPDOC\Wildfire Evacuation Study\Wildfire Evacuation Study.aprx Map: [empty] Layout: Figure 3 Constrained Roadways and ParcelsSOURCE: Safety Element accessed 2025 City of Anaheim Wildfire Evacuation Study Constrained Roadways and Parcels FIGURE 6DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 52 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT 17507 53 JUNE 2026 7 Fire Progression Modeling Fire progression modeling is a method used to simulate and predict how wildfire may spread across a landscape over time based on key environmental and fire behavior variables. This approach supports fire planners, land managers, and emergency responders by providing insights into potential fire growth, intensity, and timing under various conditions. The modeling process relies on several spatial data inputs, including a landscape file, which includes topography and fuels spatial datasets such as vegetation type and fuel loading. In addition, ignition points must be defined to represent the likely origin of a fire. Weather conditions, including fuel moisture, wind speed, and wind direction, are also critical inputs, as they significantly influence the rate and direction of fire spread. The resulting fire progression outputs help identify high-risk areas, estimate fire arrival times, and support strategic evacuation and emergency response planning. The wildfire progression assessment involved a desktop analysis utilizing the FlamMap fire behavior modeling software and subsequent geographic information system analysis. FlamMap is a wildfire behavior modeling software developed by the U.S. Forest Service that simulates potential fire characteristics across a landscape and allows for tracking fire growth over time. FlamMap’s Minimum Travel Time (MTT) tool was used in order to evaluate the fire spread towards the Anaheim Hills community from a Santa Ana wind event. The MTT tool in the FlamMap software package is a two-dimensional fire growth model, which calculates fire growth based on calculated fire spread rates from an ignition source (point, line, or polygon). The MTT tool uses fire spread rates to find minimum travel paths between data cells in the geographic information system landscape, with an output data file representing the number of minutes for a wildfire to reach a particular location from the ignition source. In addition, the MTT tool provides line file outputs identifying major paths of wildfire spread. As FlamMap provides a static representation of fire behavior, modeling using the MTT tool holds wind and weather inputs constant over the modeling period. Model Inputs FlamMap and FARSITE software requires a minimum of five separate input files that represent field conditions in the analysis area, including elevation, slope, aspect, fuel model, and canopy cover. Each of these data files was obtained from the Landscape Fire and Resource Management Planning Tools (LANDFIRE) data distribution site. LANDFIRE is shared program between the wildland fire management programs of the U.S. Department of Agriculture Forest Service and U.S. Department of the Interior. The Landscape Base file was created at a scale of 30 meters and consisted of eight distinct data layers representing terrain (elevation, slope, and aspect) and vegetation/fuels (fuel model designation). Weather inputs for fire progression modeling utilized data from local Remote Automated Weather Stations to determine wind and fuel moisture values representative of Santa Ana weather conditions. Data from the Chino Hills Remote Automated Weather Station, which is the nearest Remote Automated Weather Station, was assessed from August 1 to December 1 from 2007 to 2025. Weather inputs utilized in this analysis are provided below in Table 4. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 54 JUNE 2026 Table 4. Wildfire Behavior Modeling Inputs Model Input 97th Percentile (Santa Ana Wind) Wind Speed 33 mph Wind Direction 48° Wind Type Gridded 1-Hour Fuel Moisture 2% 10-Hour Fuel Moisture 3% 100-Hour Fuel Moisture 5% Herbaceous Fuel Moisture 30% Live Woody Fuel Moisture 60% Crown Fire Calculation Method Scott/Reinhardt Source: Chino Hills Remote Automated Weather Station To simulate fire spread impacting the Anaheim Hills community during Santa Ana conditions, three ignition locations were selected. These include ignitions along Highway 241, Deer Canyon, and East Nohl Ranch Road. These ignition locations were chosen based on their higher ignition likelihood and potential to generate fire spread toward community areas and trigger wildfire evacuations. The ignition locations were mapped in line format to represent many possible ignition origins along the roadways. Fire spread for all three scenarios was mapped over an 8-hour (480-minute) time period. Likewise, evacuation was modeled to demonstrate an evacuation responding to each fire scenario. Model Outputs The output files generated for the fire progression runs included one grid and one line file representing fire progression over time and major spread paths, considering modeling inputs and ignition location. The files include data presenting time (in minutes) for the modeled fire to reach a specific location. An additional analysis was performed to evaluate the timing of wildfire exposure to structures located adjacent to the modeled fire perimeters. Building footprints were first mapped using FEMA’s USA Structures dataset (FEMA, 2023). Each structure was then buffered by 500 feet, and the minimum fire arrival time within each buffer was extracted to estimate when wildfire would most likely impact the structure. Highway 241 Ignition As shown in Figure 7, this scenario represents a wildfire igniting along the west side of Highway 241 and rapidly spreading southwest under strong wind conditions. This corresponds to Evacuation Scenario 3. Among the three scenarios analyzed, it presents the highest overall hazard, driven by both the fire’s large projected size and the Although emergency personnel actions are not represented in the evacuation time or fire progression modeling, these actions would be expected to reduce evacuation times and slow fire progression. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 55 JUNE 2026 extensive open space that allows for sustained, high-intensity fire growth. The broad expanse of continuous grass– shrub fuel beds provide minimal resistance to fire progression, enabling fast-moving flames to advance toward structures along the southeast edge of the Plan Area. Due to the ignition’s close proximity to developed areas, initial structure exposure is anticipated within approximately 15 minutes of ignition. As the wildfire continues its southwest progression through largely unmanaged vegetation, the combination of intense heat release, strong winds, and persistent forward spread places structures along the southeast edge of the Anaheim Hills community at ongoing risk of direct flame contact, radiant heat, and spot fire activity. In addition to the potential for direct flame contact, structures throughout the affected areas may also be exposed to ignition pathways associated with radiant heat transfer and ember cast. East Nohl Ranch Road Ignition As shown in Figure 8, E Nohl Ranch Road Ignition: 33 mph NE Winds, the modeled wildfire ignites along the south side of Nohl Ranch Road, just east of its intersection with Stage Coach Road, and spreads southwest under strong Santa Ana wind conditions originating from the northeast. This corresponds to Evacuation Scenario 4. The presence of continuous grass and shrub fuels in this area, combined with terrain that is aligned with prevailing wind direction, promotes rapid initial fire growth and efficient fire spread. Under these conditions,, initial structure exposure is anticipated within approximately 15 minutes of ignition. During the early stages of progression, the fire’s northern flank advances toward development along Serrano Avenue. Flanking fire behavior generally exhibits slower rates of spread and lower flame lengths compared to the head of the fire; therefore, initial fire intensity along this portion of the perimeter is somewhat reduced relative to areas directly downwind. Nonetheless, the community surrounding Camino Grande lies directly in the path of the advancing head fire and is projected to experience the most severe fire behavior in this scenario, including high fireline intensity, longer flame lengths, and rapid spread rates driven by wind and slope alignment. As the incident evolves, the southern flank continues to expand across mixed topography, burning through open space areas that interface with residential neighborhoods surrounding Camino Grande and Ridgeview Road. Structures along this portion of the perim eter are projected to experience potential direct fire impacts approximately 60 minutes after ignition. Meanwhile, the head of the fire continues its southwest progression, ultimately crossing Camino Grande due to the combined influence of steep terrain, a ligned winds, and receptive fuels. Communities surrounding Serrano Park are projected to experience direct fire impacts approximately 45 minutes following ignition. In addition to the potential for direct flame contact, structures throughout the affected areas may also be exposed to ignition pathways associated with radiant heat transfer and ember cast. Deer Canyon Ignition As presented in Figure 9, Deer Canyon Ignition: 33 mph NE Winds, the modeled wildfire ignition occurs along East Santa Ana Canyon Road and progresses southwest through the Deer Canyon open space. This corresponds to Evacuation Scenarios 5 and 6. The combination of aligned topography, continuous vegetative fuels, and wind influence within this corridor creates conditions favorable for rapid fire spread during the early stages of the incident. As a result, structures located along both the western and eastern margins of the open space may be exposed to wildfire within approximately 15 minutes of ignition. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 56 JUNE 2026 The relatively narrow configuration of the Deer Canyon open space functions to channel fire spread southward, effectively concentrating convective heat, flame lengths, and ember production along the edges of the corridor where residential development interfaces with wildland fuels. This funneling effect can increase localized fire intensity and enhance the likelihood of fire spread toward adjacent structures, particularly under wind-driven conditions. As the wildfire continues advancing south, structures bordering the open space remain susceptible to multiple exposure pathways, including direct flame contact along the WUI, radiant heat sufficient to ignite combustible materials, and wind-transported embers capable of igniting receptive fuels on or near structures. Vulnerability is expected to be greatest in locations where defensible space is limited, vegetation management is incomplete, or structural hardening features are absent. In these areas, even moderate fire behavior along the flanks of the incident may result in structure ignition due to ember intrusion or short-range spotting. Collectively, these factors contribute to a scenario in which adjacent neighborhoods could experience rapid onset of wildfire exposure with limited time for defensive response following ignition, reiterating the importance of defensible space and structural hardening. Results Summary Importantly, Fire Progression Modeling demonstrates a worst-case scenario fire and does not consider emergency personnel actions such as fire suppression. Modeling results are used to create recommendations associated with evacuation procedures, trigger points, and firefighter safety zones and escape routes. All modeling results will be used to develop criteria for determining lead time needed for notification and evacuation of various areas based on historical fires, modeling results, and traffic modeling results. The modeling represents potential wildfire behavior under a defined set of environmental conditions and assumptions and does not account for dynamic weather changes, suppression activities, or localized wind phenomena that may occur during an actual wildfire event. Fuel characteristics are represented using the best available spatial data available at the time of analysis; however, on-the-ground variability may influence actual fire behavior. FlamMap calculates fire growth across the landscape, assuming independence of fire behavior between neighboring cells and holds wind speed, wind direction, and fuel moisture inputs constant for the duration of each modeling run. These constant inputs were selected to represent severe Santa Ana wind conditions capable of producing rapid fire spread toward the analysis area, thereby providing a conservative basis for evaluating potential exposure and evacuation considerations. Because the model does not incorporate temporal changes in weather, terrain-influenced wind variability, or suppression actions, the results should be interpreted as reasonable estimates of potential fire progression rather than precise predictions of future wildfire events. Although the MTT approach allows for a temporal representation of fire spread, real-world fire behavior may differ due to factors not captured in the modeling framework, including variable weather patterns over time, fine-scale topographic effects, spatial variability in fuels, and unpredictable ember generation and transport. Additionally, published research indicates that FlamMap analyses may tend to over-predict fire spread rates under certain conditions (Finney 1998), further supporting the conservative nature of the results presented herein. Accordingly, the model outputs are intended to inform planning and risk evaluation and should be used as a decision-support tool rather than a deterministic forecast of wildfire behavior at any specific location. DRAFT DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 58 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 60 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 62 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT 17507 63 JUNE 2026 8 Evacuation Modeling This section provides a brief description of the evacuation modeling conducted for the Anaheim Hills Study Area. The analysis supports emergency planning and CEQA evaluation by examining evacuation performance, clearance times, and sensitivity to evacuation strategies, traffic control assumptions, and land use conditions. For a complete description of the microsimulation evacuation modeling and further details on the model assumptions, limitations, and potential mitigation measures to further improve evacuation performance and system resilience, see Appendix B, Anaheim Hills Fire Evacuation Analysis. As part of this effort, the modeling evaluated components of the City’s Know Your Way evacuation program, including the zone framework, testing how the zones performed under simulated evacuation conditions. The modeling demonstrates that phased evacuations enhance system performance by staggering demand and prioritizing movement for zones facing the greatest immediate threat. Implementing delayed evacuation orders, or evacuation warnings, for lower-risk areas reduces peak congestion, improves overall network utilization, and shortens evacuation times for critical zones, thereby reaffirming the Know Your Way program’s structure as an effective operational framework during fast-moving wildfire events. 8.1 Evacuation Modeling Methodology, Assumptions, and Scenarios The following provides a summary of the methodology, assumptions, and scenarios considered in the evacuation time analysis presented herein. To evaluate evacuation performance under a range of plausible emergency conditions, a series of evacuation scenarios were developed representing both conservative worst-case events and more realistic, area-specific wildfire evacuations. The scenarios reflect differences in land use conditions (Existing and Cumulative), evacuation type, geographic extent, and expected public response. Together, they are intended to bound potential evacuation outcomes while remaining consistent with guidance from the California Office of Planning and Research, the California Attorney General’s Wildfire Guidance, and local EOPs. Two evacuation types are evaluated. Catastrophic scenarios assume an immediate, areawide evacuation order and represent a highly conservative, low-probability, but high-consequence condition used to establish an upper bound on evacuation demand and clearance times. Area-specific wildfire scenarios reflect operationally realistic evacuation management, with evacuation orders issued in phases based on proximity to the fire perimeter, anticipated fire behavior, and roadway capacity constraints. 8.1.1 Methodology The evacuation analysis was conducted using PTV Vissim with Dynamic Traffic Assignment to reflect real‑world adaptive routing as congestion evolves, allowing vehicles to adjust paths based on changing network conditions. Each scenario was run until routing patterns converged, approximately 40 to 60 times, ensuring stable and representative results. Once convergence was achieved, each scenario underwent 20 independent simulation runs. This systematic approach provides a robust and conservative assessment of evacuation performance, with full technical methodology documentation available in Appendix B. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 64 JUNE 2026 8.1.2 Assumptions Evacuation Timing To ensure the analysis reflects conservative conditions relevant for emergency planning and CEQA evaluation, several assumptions were applied to determine evacuation demand and population behavior. The analysis assumes the realistic incorporation of phased evacuations are implemented by staggering the evacuation timing by zone. Therefore, zones determined to be in the most imminent threat are assumed to evacuate at the start of the simulation; while depending on the scenario, other adjacent zones were placed under a 10-minute or 1-hour delay to reflect the actions that emergency managers and law enforcement personnel enact to manage traffic demand, prioritize emergency access, and reduce system-wide congestion. This approach reflects current wildfire evacuation practices and avoids the unrealistic assumption of simultaneous mass evacuation. The scenarios assume evacuation during the early evening PM peak hour across the entire study area and are used to stress test the existing transportation network and provide a conservative benchmark for comparison. Evacuating Vehicles The analysis described herein assumes all residents within the study area are present at home at the time evacuation orders are issued. This represents the most conservative assumption because it generates the maximum potential evacuation demand. In reality, a portion of the population may be away from home due to work, school, or other activities; however, assuming full residential occupancy provides an upper-bound estimate of vehicle demand and allows the roadway network to be evaluated under the most demanding and stress-tested conditions. To ensure that the analysis reflects worst-case and highly conservative conditions, vehicle demand was developed using assumptions informed by observed behavior during recent and historical wildfire evacuations in Southern California and elsewhere in the state. The number of evacuating vehicles was calculated by applying the area’s average vehicle ownership rate of 3.4 vehicles per household to the total number of residential units, assuming that each household evacuates with all available vehicles, and adding non-residential uses resulting in approximately 61,000 vehicles under a full‑occupancy worst-case scenario. This assumption represents a feasible upper-bound estimate of potential evacuation demand by accounting for residents, employees, customers, and visitors across all land use types. It is intentionally conservative and exceeds the evacuation demand that would typically be expected under normal travel conditions or more moderate behavioral assumptions. Table 2, Evacuation Vehicles by Evacuation Zone in Appendix B displays the number of vehicles calculated for each of the 15 evacuation zones. Additional Assumptions Behavioral assumptions include the incorporation of shadow evacuees, representing residents who voluntarily leave before formal orders, and in select scenarios early evacuation by seniors, who constitute roughly 20% of the population and exhibit heightened sensitivity to smoke and health risks, is included. Although congregate care facilities were identified, they were not explicitly modeled as a separate evacuation population due to the lack of publicly available facility‑specific data, and internal operational protocols. These assumptions collectively define the evacuation demand that the transportation network must accommodate and establish a conservative foundation for evaluating system performance. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 65 JUNE 2026 Table 3, Evacuation Scenario Assumption Summary in Appendix B outlines the key assumptions for each evacuation scenario, including evacuation areas, phasing strategies, and population response assumptions. Because these assumptions differ by scenario, evacuation vehicle demand varies accordingly, as reflected in Table 4, Evacuation Vehicle Demand and Signal Timing Assumptions by Scenario. It is important to note that emergency personnel actions such as fire suppression or field direction of evacuating vehicles are not captured in the modeling, despite being a very real facet of evacuation. Evacuation modeling is not capable of directly capturing potential field interventions due to the immense variability of such actions across incidents, locations, and operational conditions. When interpreting the results of this Study, it is of paramount importance to understand that these findings represent intentionally conservative, worst-case conditions that would very likely be improved through the timely and coordinated field actions of AFR and the APD. This Study supports CEQA-level project review, which is required to disclose reasonably foreseeable worst-case conditions using defensible assumptions, rather than rely on speculative or event-specific emergency response actions. Accordingly, the results are intended to provide a conservative planning baseline that ensures transparency, consistency, and defensibility in evaluating wildfire evacuation performance and potential project-related impacts. 8.1.3 Evacuation Scenarios Scenario 1 – Catastrophic Evacuation (Existing Conditions) This scenario represents a highly conservative evacuation event with existing land use conditions where an immediate, areawide evacuation is assumed for all zones with no phased evacuation timing. All residents within the study area are assumed to evacuate simultaneously at the start of the simulation. No shadow evacuation or senior-only evacuation assumptions are applied because the entire study area is subject to a mandatory evacuation order. This scenario assumes that traffic signals are either inoperative or that evacuees are not adhering to signal control, resulting in stop-and-go conditions and uncontrolled yielding behavior. This scenario establishes an upper bound on evacuation demand and clearance time. Scenario 2 – Catastrophic Evacuation (Existing Conditions) This scenario is similar to Scenario 1 in that it also represents an immediate, areawide catastrophic evacuation event under existing land use conditions. All zones are assumed to evacuate simultaneously with no phasing and no differentiated behavioral assumptions. This scenario assumes that traffic signals remain operational and operate under the standard PM peak hour timing plan. This scenario is included to support sensitivity testing and comparative analysis and similarly represents a conservative bounding condition. Although emergency personnel actions are not represented in the evacuation time or fire progression modeling, these actions would be expected to reduce evacuation times and slow fire progression. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 66 JUNE 2026 Scenario 3 – Wildfire Scenario 1: SR‑241 Fire (Existing Conditions) This scenario represents an area-specific wildfire evacuation associated with a fire near the SR-241 corridor under existing land use conditions. Figure 10, Wildfire Scenario 1: SR-241, demonstrates the evacuated zones and fire progression for this scenario. Evacuation is implemented in phases to reflect operational wildfire response practices. Zones 1 and 2 are assumed to receive an immediate evacuation order due to their proximity to the fire perimeter. Zones 3 and 5 are assumed to evacuate after a 10-minute delay, while Zone 6 evacuates after a 1-hour delay. Shadow evacuees are assumed in Zones 4 and 8, with 50% of the population evacuating voluntarily in advance of a formal order. In addition, senior-only evacuation is assumed in Zones 9 and 10, with 20% of the population evacuating early to reflect the higher propensity of seniors to evacuate due to smoke-related health concerns. Scenario 4 – Wildfire Scenario 2: Nohl Ranch Fire (Existing Conditions) This scenario represents an area-specific wildfire evacuation associated with a fire along the south side of Nohl Ranch Road, just east of its intersection with Stage Coach Road, and spreads southwest under strong Santa Ana wind conditions originating from the northeast under existing land use conditions. Zone 6 is assumed to receive an immediate evacuation order, while Zone 7 is assumed to evacuate after a 10-minute delay. Figure 11, Wildfire Scenario 2: E Nohl Ranch Road, demonstrates the evacuated zones and fire boundary for this scenario. Shadow evacuees are assumed in Zones 3, 5, 10, 11, and 12, with 50% of the population in each zone evacuating voluntarily. No senior-only evacuation zones are assumed in this scenario, reflecting localized fire conditions and evacuation priorities. Scenario 5 – Wildfire Scenario 3: Deer Canyon Park Fire (Existing Conditions) This scenario represents an area-specific wildfire evacuation associated with a fire near Deer Canyon Park under existing land use conditions. Zones 8 and 9 are assumed to receive immediate evacuation orders. Zone 4 is assumed to evacuate after a 10-minute delay, while Zones 5 and 10 are assumed to evacuate after a 1-hour delay. Figure 12, Wildfire Scenario 3: Deer Canyon Park, demonstrates the evacuated zones and fire boundary for this scenario. Shadow evacuation is assumed in Zones 11 and 13, with 50% of the population evacuating voluntarily. In addition, senior-only evacuation is assumed in Zones 1, 2, 3, and 6, with 20% of the population evacuating early to reflect health-based evacuation decisions among senior residents. Scenario 6 – Wildfire Scenario 3: Deer Canyon Park Fire (Cumulative Conditions) This scenario mirrors Scenario 5 in terms of evacuation phasing, geographic extent, shadow evacuation assumptions, and senior-only evacuation assumptions but reflects cumulative land use conditions. The scenario isolates the effect of future growth on evacuation performance while maintaining consistent evacuation management assumptions. Figure 12 demonstrates the evacuated zones and fire boundary for this scenario. Immediate evacuation is assumed for Zones 8 and 9, followed by a 10-minute evacuation for Zone 4 and a 1-hour evacuation for Zones 5 and 10. Shadow evacuation is assumed in Zones 11 and 13 at 50%, and senior-only evacuation is assumed in Zones 1, 2, 3, and 6 at 20%. DRAFT Figure 10DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 68 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT Figure 11DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 70 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT Figure 12DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 72 JUNE 2026 INTENTIONALLY LEFT BLAN DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 73 JUNE 2026 8.1.4 Evacuation Modeling Results and Analysis As shown below, in Table 5, the following is a summary of the maximum evacuation time for each scenario: ▪ Scenario 1: It would take approximately 10 hours and 5 minutes to evacuate all zones with Zone 4 being the last to complete evacuation in the Catastrophic Evacuation (Existing Conditions) ▪ Scenario 2: It would take approximately 12 hours and 16 minutes to evacuate all zones with Zone 4 being the last to complete evacuation in the Catastrophic Evacuation (Existing Conditions). ▪ Scenario 3: It would take approximately 7 hours and 14 minutes to evacuate all zones with Zone 4 being the last to complete evacuation in the Wildfire Scenario 1: SR-241 Fire (Existing Conditions). Zones 7 and 11-14 do not evacuate in this scenario. ▪ Scenario 4: It would take approximately 5 hours and 38 minutes to evacuate all zones with Zone 5 being the last to complete evacuation in the Wildfire Scenario 2: E Nohl Ranch Fire (Existing Conditions). Zones 1-2, 4, 8-9, and 13-15 do not evacuate in this scenario. ▪ Scenario 5: It would take approximately 4 hours and 28 minutes to evacuate all zones with Zone 13 being the last to complete evacuation in the Wildfire Scenario 3: Deer Canyon Park Fire (Existing Conditions) Zones 4-5, 7, 10, 12, and 14-15 do not evacuate in this scenario ▪ Scenario 6: It would take approximately 6 hours and 2 minutes to evacuate all zones with Zone 8 being the last to complete evacuation in the Wildfire Scenario 3: Deer Canyon Park Fire (Cumulative Conditions). Zones 4-5, 7, 10,12, and 14-15 do not evacuate in this scenario. The catastrophic evacuation scenarios (Scenarios 1 and 2) establish an upper bound on evacuation clearance times, generate the highest levels of congestion and the longest evacuation times, reflecting low-probability but high-consequence conditions. Scenario 1 had a maximum evacuation time of 10 hours and 5 minutes (Zone 4), and Scenario 2 had a maximum evacuation time of 12 hours and 16 minutes (Zones 4 and 8). The difference between the catastrophic scenarios demonstrates the importance of traffic signal operations, as maintaining commuter-oriented signal phasing can materially degrade evacuation performance relative to more neutral or adaptive control strategies. The area-specific wildfire scenarios (Scenarios 3 through 6) demonstrate that phased evacuation materially improves system performance by staggering demand and prioritizing zones under the greatest immediate threat. Delaying evacuation orders for lower-risk areas reduces peak congestion, improves network utilization, and shortens evacuation times for critical zones. The inclusion of shadow evacuees and early evacuation by senior populations increases realism while remaining conservative, and results indicate that these behaviors can be accommodated when evacuation phasing is properly implemented. Although emergency personnel actions are not represented in the evacuation time or fire progression modeling, these actions would be expected to reduce evacuation times and slow fire progression. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 74 JUNE 2026 Comparison of existing and cumulative land use conditions within the area-specific wildfire scenarios (Scenarios 5 and 6) indicates that future growth can increase evacuation times in certain locations, particularly where added demand compounds existing bottlenecks or constrained roadway segments. However, the results also show that these increases are not uniform across the study area and are strongly influenced by evacuation management strategies. Zones 1, 11, and 13 experienced no change in evacuation time between existing and cumulative conditions in Scenarios 5 and 6, while Zones 2 and 3 increased by 2 minutes, Zone 9 increased by 3 minutes, Zone 6 increased by 8 minutes, and Zone 8 reflected the largest change in evacuation time with an increase of 2 hours and 4 minutes. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 75 JUNE 2026 Table 5. Summary of Evacuation Time by Scenario and Zone1 Scenario Scenario 1 – Existing Conditions, Catastrophic Evacuation Scenario 2 – Existing Conditions, Catastrophic Evacuation Scenario 3 – Wildfire Scenario 1: SR -241 Fire (Existing Conditions) Scenario 4 – Wildfire Scenario 2: Nohl Ranch Fire (Existing Conditions) Scenario 5 – Wildfire Scenario 3: Deer Canyon Park Fire (Existing Conditions) Scenario 6 – Wildfire Scenario 3: Deer Canyon Park Fire (Cumulative Conditions) Total Evacuating Vehicles 61,245 61,245 31,892 16,320 29,064 31,500 Zone Evacuation Time (Hour: Minute) Zone1 8:19 9:22 5:49 N/A 3:40 3:40 Zone 2 9:30 10:58 7:14 N/A 3:45 3:47 Zone 3 8:09 8:15 4:55 3:37 1:28 1:30 Zone 4 10:05 12:16 7:02 N/A N/A N/A Zone 5 8:19 9:50 6:54 4:27 N/A N/A Zone 6 7:55 8:43 7:14 5:38 1:56 2:04 Zone 7 2:06 1:56 N/A 1:48 N/A N/A Zone 8 9:23 12:16 6:22 N/A 3:58 6:02 Zone 9 6:23 6:26 1:12 N/A 3:37 3:40 Zone 10 7:46 7:42 2:00 2:28 N/A N/A Zone 11 4:35 7:29 N/A 3:28 2:24 2:24 Zone 12 3:47 4:08 N/A 2:48 N/A N/A Zone 13 9:11 10:15 N/A N/A 4:28 4:28 Zone 14 1:57 2:56 N/A N/A N/A N/A Zone 15 5:05 4:16 N/A N/A N/A N/A Note: 1 Emergency personnel actions such as fire suppression or field direction of evacuating vehicles are not captured in the modeling. Evacuation modeling is not capable of directly capturing potential field interventions due to the immense variability of such actions across incidents, locations, and operational conditions. When interpreting the results of this Study, it is of paramount importance to understand that these findings represent intentionally conservative, worst-case conditions that would very likely be improved through the timely and coordinated field actions of AFR and the APD. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 76 JUNE 2026 8.1.5 Method for Analyzing Effectiveness of City Improvements or Project Mitigation Measures To demonstrate the effectiveness of the recommendations in Section 9 of this study, and demonstrate methodology for evaluating the effectiveness of project mitigation measures, Scenarios 3 through 6 were remodeled accounting for a flush strategy enabled by traffic signal interconnectivity and CCTV. This strategy results in highly coordinated phasing that can prioritize those evacuating vehicles most at risk. The results are prese nted in Table 6 and demonstrate the change between evacuation without the flush strategy and with the strategy. This approach, modeling the existing conditions as is, then utilizing the same scenarios with mitigation measure/recommendations employed, clearly demonstrates the effectiveness of the changed variable and is a reproducible methodology for evaluating the effectiveness of mitigation measures on a project level as further demonstrated in Section 10.2. This exercise demonstrates that potential impacts could be mitigated through transportation and operational measures such as enhanced signal connectivity, integration with the traffic management center, or participation in areawide evacuation and traffic management improvements. 8.1.6 Confidence Interval as a Threshold for Project Impact Determination Determining whether wildfire evacuation conditions would result in a significant impact requires consideration of the inherent uncertainty and context sensitivity of evacuation behavior. Evacuation performance is influenced by localized factors, particularly human decision making under stress. While public outreach and survey results indicate that many residents are aware of wildfire risks and generally understand evacuation expectations, the survey represents only a subset of the population. Actual evacuation behavior may therefore differ from modeled assumptions due to delayed decision making, discretionary behavior, or noncompliance with law enforcement direction. In addition, precautionary evacuations outside designated zones can create secondary traffic effects. For example, households outside the evacuation area may choose to leave early due to smoke concerns while simultaneously attempting to retrieve children from nearby schools that are not under evacuation orders. If multiple households behave similarly, congestion may occur at intersections that also serve as primary access points for the designated evacuation area, reducing overall evacuation efficiency. Historical wildfire evacuations in California demonstrate that successful evacuations have occurred across a wide range of clearance times. Peer reviewed research indicates that evacuation durations commonly range from approximately 2 hours to 8 hours, with several evacuations at the upper end of this range completed successfully when supported by effective emergency management measures such as timely warnings, phased evacuations, and coordinated traffic control. These findings indicate that evacuation time alone is not a definitive indicator of significance; rather, its acceptability depends on context, including fire behavior, warning time, roadway constraints, and operational response. To account for uncertainty, this analysis evaluates evacuation performance using a statistical framework rather than a single deterministic clearance time meaning that the reported evacuation times are an average of the 20 independent model runs. Consistent with evacuation modeling research and FEMA evacuation planning methodology, each scenario was simulated using 20 independent microsimulation runs; additional details regarding the modeling methodology and assumptions are provided in the Evacuation Capacity Memorandum. The results were averaged to determine a representative evacuation time. Additionally, variability across runs was used DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 77 JUNE 2026 to establish a conservative threshold based on the upper bound of the 95th-percentile confidence interval. As discussed further in Section 10.2, the resulting scenario-specific confidence interval serves as the benchmark for determining whether project-related changes would result in a substantial increase in evacuation time, because the increase may be considered against the normal fluctuation in evacuation time. In other words, the confidence interval is the normal variability in the evacuation time that occurs due to the many overlapping variables in an evacuation that result in a range of evacuation times when the model is re-run. A change less than the anticipated confidence interval falls within normal model variability and does not reflect a change in how the system performs. In other words, any evacuation time change within this range is treated as no increase as compared to the existing conditions. Consistent with the California Attorney General’s October 2022 Wildfire Guidance described in Section 2.2.4, which directs agencies to disclose and evaluate any increase in evacuation time, and to base conclusions on clear community-wide thresholds of significance, the resulting confidence interval is used as the benchmark for determining whether a project would meaningfully increase evacuation congestion. Evacuation time increases exceeding this threshold may constitute a potentially significant impact under CEQA unless reduced through mitigation measures as further described below in Section 10.2.2. As an example of confidence intervals from a given scenario, Table 7 below demonstrates the confidence interval or normal variation by Zone that occurs during Scenario 1, which is the simultaneous evacuation of all zones. Table 6. Evacuation Time Confidence Interval* by Zone Zone Confidence Interval (HH:MM:SS) Zone 1 0:06:51 Zone 2 0:06:23 Zone 3 0:07:03 Zone 4 0:05:49 Zone 5 0:06:37 Zone 6 0:07:53 Zone 7 0:04:16 Zone 8 0:06:23 Zone 9 0:06:40 Zone 10 0:09:05 Zone 11 0:05:45 Zone 12 0:08:58 Zone 13 0:05:29 Zone 14 0:04:46 Zone 15 0:16:49 Note: * Confidence intervals would vary based on the evacuation scenario, these represent an example from Scenario 1 A Confidence Interval is the normal fluctuation expected when repeating a standard task, such as a commute to work that has normal variations but generally takes about the same amount of time each day. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 78 JUNE 2026 This WES presents a comprehensive set of recommendations designed to enhance evacuation effectiveness and improve safety. The proposed measures focus on opportunities to improve transportation infrastructure and evacuation corridors to ensure safe and efficient movement during emergencies. In addition, the recommendations address wildfire preparedness and mitigation strategies to strengthen community resilience and readiness. Finally, guidance is provided on establishing an appropriate CEQA threshold of significance for wildfire evacuation, ensuring that future development projects adequately account for evacuation capacity and public safety considerations. Together, these recommendations aim to create a reliable, coordinated, and resilient evacuation framework. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 79 JUNE 2026 Table 7. Evacuation Clearance Times for Scenarios 3 Through 6 with Active Signal Control Strategies1 Scenario / Zone Scenario 3 – Wildfire Scenario 1: SR -241 Fire (Existing Conditions) Scenario 3A – Wildfire Scenario 1: SR-241 Fire (Existing Conditions) with Emergency Signal Timing △ Scenario 4 Wildfire Scenario 2: E Nohl Ranch Fire (Existing Conditions) Scenario 4A – Wildfire Scenario 2: E Nohl Ranch Fire (Existing Conditions) with Emergency Signal Timing △ Scenario 5 Wildfire Scenario 3: Deer Canyon Park Fire (Existing Conditions) Scenario 5A – Wildfire Scenario 3: Deer Canyon Park Fire (Existing Conditions) with Emergency Signal Timing △ Scenario 6 – Wildfire Scenario 3: Deer Canyon Park Fire (Cumulative Conditions) Scenario 6A – Wildfire Scenario 3: Deer Canyon Park Fire (Cumulative Conditions) with Emergency Signal Timing △ Zone1 5:49 1:32 -4:16 N/A N/A N/A 3:40 2:56 -0:43 3:41 2:56 -0:45 Zone 2 7:14 4:24 -2:49 N/A N/A N/A 3:45 2:57 -0:47 3:48 2:56 -0:52 Zone 3 4:55 4:24 -0:30 3:37 4:20 0:43 1:28 1:27 -0:00 1:31 1:27 -0:04 Zone 4 7:02 4:55 -2:06 N/A N/A N/A N/A N/A N/A N/A N/A N/A Zone 5 6:54 4:58 -1:55 4:27 4:43 0:16 N/A N/A N/A N/A N/A N/A Zone 6 7:14 5:00 -2:13 5:38 4:13 -1:24 1:56 1:57 0:01 2:04 1:57 -0:07 Zone 7 N/A N/A N/A 1:48 1:08 N/A N/A N/A N/A N/A N/A N/A Zone 8 6:22 4:58 -1:23 N/A N/A N/A 3:58 2:08 -1:49 6:02 2:10 -3:52 Zone 9 1:12 1:04 -0:07 N/A N/A N/A 3:37 2:50 -0:46 3:41 2:51 -0:50 Zone 10 2:00 1:42 -0:17 2:28 3:05 0:37 N/A N/A N/A N/A N/A N/A Zone 11 N/A N/A N/A 3:28 3:06 -0:21 2:24 2:22 -0:01 2:25 2:24 -0:01 Zone 12 N/A N/A N/A 2:48 1:11 -1:36 N/A N/A N/A N/A N/A N/A Zone 13 N/A N/A N/A N/A N/A N/A 4:28 2:56 -1:31 4:29 2:56 -1:33 Zone 14 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Zone 15 N/A 1:43 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Note: 1 Outside of the active signal control methods, emergency personnel actions such as fire suppression or field direction of evacuating vehicles are not captured in the modeling. Evacuation modeling is not capable of directly capturing potential field interventions due to the immense variability of such actions across incidents, locations, and operational conditions. When interpreting the results of this Study, it is of paramount importance to understand that these findings represent intentionally conservative, worst case conditions that would very likely be improved through the timely and coordinated field actions of Anaheim Fire & RescueAFR and the Anaheim Police DepartmentAPD. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 80 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT 17507 81 JUNE 2026 9 City Recommendations This WES presents a comprehensive set of recommendations designed to enhance evacuation effectiveness and improve safety. The proposed measures focus on opportunities to improve transportation infrastructure and evacuation corridors to ensure safe and efficient movement during emergencies. In addition, the recommendations address wildfire preparedness and mitigation strategies to strengthen community resilience and readiness. Finally, guidance is provided on establishing an appropriate CEQA threshold of significance for wildfire evacuation, ensuring that future development projects adequately account for evacuation capacity and public safety considerations. Together, these recommendations aim to create a reliable, coordinated, and resilient evacuation framework. 9.1 Infrastructure Recommendations Transportation recommendations are aimed at enhancing the roadway network through active and passive measures to reduce necessary evacuation time by increasing capacity and/or flow in the impacted area, which works in tandem with wildfire preparedness and evacuation readiness described later in this section to reliably move residents to safety. Infrastructure recommendations include the following: 1. Signal Interconnectivity. Implement corridor-wide signal interconnectivity to allow coordinated timing during evacuations and enable flush strategies. This recommendation reduces evacuation time by allowing emergency officials to remotely control signals, enabling a flush strategy that prioritizes traffic from the most at-risk areas preventing conflicting movements and maximizing throughput to major corridors. The following subtasks are additional components of this task: a. CCTV. Implementation of CCTV for signals that allows the Anaheim Transportation division and emergency managers the ability to monitor evacuation traffic in real time, supplementing reports from first responders, enabling remote traffic control through signal interconnectivity and a flush strategy. b. EVP. Install Emergency Vehicle Preemption devices on all signals to automatically change lights to favor emergency responders. c. Signal Resiliency. Install a secondary power source such as generators or batteries to allow for continuity of service during power outages for the traffic signals, signal interconnection, CCTV, and EVP. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 82 JUNE 2026 2. Flush Strategy. Develop a flush strategy consistent with the Know Your Way evacuation routing that prioritizes neighborhoods closest to WUI that can be utilized in accordance with Know Your Way and responsive to progression of the incident. Phasing reduces system overload allowing select evacuees to clear the network prior to adding more vehicles, reducing congestion. 3. Contra-flow Strategy. Develop contra-flow plans for roadways that have multiple lanes such as Santa Ana Canyon Road and Weir Canyon Road. A contra-flow plan increases outbound road network capacity by changing lane directions, thereby reducing the amount of time necessary for evacuating vehicles to reach safety. The contra-flow plan must consider maintaining first responder access to the evacuation area and should only be implemented when contra-flow can be continued all the way to SR-91 or other areas considered safe. Contra-flow may be further enhanced by providing permanent changeable message signage that can be activated in case of evacuation. 4. Evacuation Signage – Changeable Message Signage (CMS). Install areawide digital evacuation signage that is discrete but can be used to guide evacuees, relaying real-time messages to evacuees along routes. Considering that wildfires are highly dynamic, this allows for a reliable alternative for communication between incident managers and actual evacuees on routes. CMS and communication relays should be provided with emergency power to allow for usage when power is lost. 5. Evacuation Considerations for Future Improvements. Any future roadway improvements in Anaheim Hills including planned improvements in the Circulation Updates such as the future Fairmont/SR-91 interchange or unanticipated improvements should consider evacuation and implement wide shoulders for use during evacuation. 6. Roadway Shoulder Widening. As identified in the Circulation Element, find opportunities to widen roadway shoulders when feasible to allow for use as an additional lane during evacuations. Wide shoulders may be utilized as an additional lane to increase roadway capacity during an evacuation, thereby aiding quicker evacuations, reducing likelihood for evacuation corridor blockages. Shoulder widening should be continued all the way to SR-91 or other areas considered safe. 7. Coordination with Caltrans. Coordinate with Caltrans before and during emergencies to get residents out of the evacuation area. 8. Roadway Interconnection. While many roadways are constrained by existing parcels, find opportunities for enhancing the roadway network through additional points of connection. 9. Additional SR91 Connection. Analyze feasibility of accessing SR-91 via Santa Ana Canyon Road to the weigh station, specifically for use during evacuations to provide additional access to SR-91. The additional point of connection provides another outlet for evacuation traffic to access the freeway, resulting in more people able to leave the region. 10. Signalize Canyon Rim Road and Fairmont Boulevard. Installation of a new traffic signal allows for the signal interconnectivity and flush strategy to utilize this key intersection. 9.2 Wildfire Preparedness Recommendations Similar to the infrastructure recommendations, wildfire preparedness recommendations can be completed prior to an evacuation order, which can work to create more time for evacuees to escape by interrupting the spread of fire. Many of these measures are supported by Policy 7 of Goal 2.1 of the Safety Element, and AFR continues to make DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 83 JUNE 2026 a concerted effort to implement many of the following measures. This study offers additional recommendations or reiterates the importance of the following: 1. Roadside Clearance. Evaluate effectiveness of 10 feet of roadside vegetation clearance and consider enhancing standards to directly correlate to brush type. Due to variations in slope, wind direction, and fuel type relative to the orientation of the roadway, 10 feet may be proven to be effective, or more clearance may need to be provided. While a simple standard that applies the same clearance requirement to all parcels may appear equitable, it may fail to accurately respond to real worst-case fire behavior given fuel and terrain variability. Roadside fuel modification that directly counters the expected fire behavior can reduce ignitions and prevent evacuation route burn-over. 2. WUI Fuel Breaks. Evaluate perimeter vegetation fuel breaks using advanced fire behavior analysis to establish and maintain effective fuel breaks that eliminate the potential transmission of fire from direct flame impingement and radiant or convective heat. While AFR enforces a Brush Clearance and Vegetative Growth Guideline per the Anaheim Municipal Code, it is a worthwhile endeavor to evaluate fire behavior at various locations to account for slope, wind alignment, and fuel type to determine if the 100-foot standard provides adequate protection. Effective perimeter fuel breaks can prevent a wildland fire from progressing into the built environment, providing additional time for evacuees to clear the roadway network. This may require multi-jurisdictional cooperation. 3. Community Outreach and Public Education. Expand community outreach and education programs that show how defensible space and home‑hardening measures work together to reduce wildfire spread, encouraging residents to actively maintain their landscaping and structural features. Recently, CAL FIRE, NFPA, and IBHS have developed videos that demonstrate the effectiveness of these efforts with live burns. Further, Zone 0 vegetation fuel modification regulations for the 5 feet adjacent to homes are being developed and are expected to be active in coming months; education should aim to help residents understand the future requirements. a. An annual community level wildfire prevention week would allow city staff to strategically focus these efforts ahead of expected extreme fall wildfire behavior. Events could include pop-ups at parks and community centers in the WUI. In-person events help residents connect the dots between published educational messages and their personal responsibility to maintain their assets while preparing for evacuation, reducing the amount of time necessary to activate during an evacuation. b. Empower neighborhoods to foster their own culture of preparedness through becoming Firewise communities through NFPA. Firewise communities are required to meet annual outreach and preparedness goals on top of the efforts made by city staff and help to make wildfire preparation more present in the minds of residents. 4. Wildfire Risk Assessment. Through implementation of the CWPP, grant funding may be acquired to define fire pathways via a comprehensive Wildfire Risk Assessment. Fire pathways are the likely paths through which fire is expected to primarily advance, typically realized by the convergence of prevailing wind, topography, and fuel type. Fire pathways can be confirmed through a detailed site analysis b y a qualified fire behavior expert and through fire pathway modeling. Fuel breaks can then be implemented along those fire pathways to disrupt the progression of fire and increase available time for evacuees. 5. Defensible Space Inspections. Defensible Space inspections allow qualified defensible space/home ignition zone inspectors such as those employed by AFR to evaluate homes and neighborhoods to determine areas of vulnerability. Despite the effectiveness of measures 1 through 4 above, embers may travel ahead of the fire and over fuel breaks to impact structures. An inspection such as the one DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 84 JUNE 2026 recommended herein addresses vegetation and structural weaknesses and offers opportunities to prevent embers from igniting residential landscapes or structures. 6. Home Hardening Grants. Micro-grant programs for home hardening can be obtained through CAL FIRE in order to provide funding for landscape maintenance or structural hardening, enabling greater community resilience, which reduces the risk of wildfire from progressing into the built environment. Grants can be managed by governmental organizations or Firewise communities. Anaheim’s first Firewise community was formed in 2025, and more are currently pursuing certification. 7. ALERT California Cameras. Install ALERT California cameras for fast detection and visibility of wildfire ignitions in case aircraft are grounded like they were during the Palisades and Eaton fires. Cameras support earlier detection resulting in more lead time for evacuations. AFR continues to work with APU on the addition of cameras to aid in early detection and real-time conditions. 8. Brush and Vegetative Growth Guideline Enhancement. Consider enhancing the Brush and Vegetative Growth Guideline to aid in accomplishing Tasks 1 and 2 of this section, as informed and substantiated by specific fire behavior modeling. 9.3 Evacuation Readiness Recommendations In addition to engineering improvements and wildfire preparation that happen before an incident, a successful evacuation requires effective communication and cooperation between public safety officials and those impacted by evacuation notices as the incident unfolds. This effective communication requires a shared understanding of terms and definitions, which should be learned prior to the incident. The existing Know Your Way program is in place to educate residents on evacuation routes and guide resident evacuation planning by providing the most likely evacuation routes. The following measures are intended to improve communication between incident managers and residents: 1. Cell Tower Emergency Power. For future and existing cell towers in the area, consider requiring as a condition of approval mandatory battery/generator backup power. Backup power enables cellular network coverage to remain available despite power outages caused by Public Safety Power Shutoffs or damage from wildfire aiding in transmission of evacuation information. 2. Evacuation Outreach/Education. Focused evacuation education should work to enhance the public’s understanding of the following: a. The reasoning and methodology behind phased evacuations, advising that certain zones and routes may be prioritized by incident managers given real-time wildfire conditions. b. Responding to the apparent confusion between evacuation alerts and orders discovered through Community Outreach, confirm that an alert is the appropriate time to prepare to leave or leave voluntarily, while an evacuation order is the immediate time to leave, regardless of completion of preparations. The community is notified of evacuation orders through multiple methods including wireless emergency alerts (WEA), Anaheim Alert, social media, and other forms of communication. Reinforce “leave early” culture. c. Provide household evacuation preparation time expectations based on the findings of the community outreach efforts included in this study to demonstrate the importance of having a plan and go-bags. Increased awareness leads to better preparation, which assists evacuees with leaving earlier. d. The community outreach conducted as part of this study discovered that parents/caregivers have uncertainty regarding how schools evacuate and protect students. To the extent feasible, educate parents and caregivers to understand how they and the school district can work together to facilitate successful evacuation. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 85 JUNE 2026 e. The importance of a family evacuation plan that accounts for midday evacuation when members are not at home; have a family meeting place outside Anaheim Hills. f. Re-entry restrictions that are likely to be in place for areas with evacuation orders. g. How re-entry may be phased and where residents can monitor re-entry authorization messaging. 3. Support for Disabilities and Access and Functional Needs. Identify and pre-plan evacuation support strategies for individuals with Disabilities and Access and Functional Needs (DAFN), including targeted outreach, transportation coordination, communication accommodations, and sheltering considerations. 4. Evacuation Exercises. Ensure that future scheduled evacuation planning exercises include scenario injects and operational objectives specific to evacuation operations. 9.4 Recommendation Effectiveness The effectiveness of the recommended transportation and operational improvements was evaluated by re-running the evacuation modeling described in Chapter 8 with the improvements applied. This approach allows the City to directly compare baseline evacuation performance to enhanced conditions using the same defensible, repeatable modeling framework. The re-modeling demonstrates—with quantifiable results—the degree to which specific recommendations reduce congestion, improve travel flow, and shorten evacuation clearance times for the zones most at risk. The reevaluation focused on the three area-specific wildfire evacuation scenarios (Scenarios 3, 4, 5, and 6), which reflect realistic fire behavior, phased evacuation strategies, and operational decision making. In each scenario, improvements such as signal interconnectivity, CCTV monitoring, and the implementation of a coordinated flush strategy were activated to allow evacuation priority movements to be favored throughout the network. Table 6 summarizes the resulting change in evacuation time for each zone. Overall, the analysis demonstrates that these improvements provide substantial and measurable performance gains, particularly for the zones closest to the advancing wildfires, where evacuation time matters most. Key findings include the following: ▪ Wildfire Scenario 1 (Evacuation Scenario 3 – SR-241 Fire) Zones 1, 2, 3, and 6—those nearest to the wildland interface—experience the largest improvements. Evacuation times are reduced by 30 minutes to 4 hours and 16 minutes, depending on the zone. These reductions reflect the benefit of giving priority movement to early evacuating areas during periods of high demand and constrained access. ▪ Wildfire Scenario 2 (Evacuation Scenario 4 – East Nohl Ranch Road Fire) Zones 6 and 12, which require the earliest and most urgent evacuation, show notable improvements. Evacuation times decrease by 1 hour and 24 minutes to 1 hour and 26 minutes with the recommended signal coordination and flush strategy. This demonstrates that even in highly localized fire scenarios, targeted interventions can meaningfully improve safety and roadway performance. ▪ Wildfire Scenario 3 (Evacuation Scenarios 5 and 6 – Deer Canyon Park Fire, Existing and Cumulative) Zones 8 and 9 experience significant time savings, reflecting the benefit of clearing downstream bottlenecks and reducing neighborhood level congestion during the initial evacuation wave. Evacuation clearance times decline by 46 minutes to 1 hour and 49 minutes, depending on conditions. Under cumulative growth conditions (Scenario 6), these improvements offset much of the added demand associated with future development. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 86 JUNE 2026 9.5 Other Recommendations The recommendations in this Study are not intended to represent a closed or exhaustive list. Wildfire science, transportation engineering, and emergency management technology are advancing rapidly, and new tools, data sources, and operational capabilities will continue to emerge. As innovations such as enhanced fire spread detection, real time traffic analytics, automated signal optimization, advanced communication systems, or AI supported situational awareness become available, the City should evaluate them using the same evidence-based methodology applied in this Study. This ensures that future solutions are assessed objectively, with measurable benefits to evacuation performance and community safety. Because wildfire risk is dynamic and technology evolves quickly, the City should view these recommendations as a foundation rather than a limit. Any additional strategies—whether infrastructure based, operational, or technology driven—should be tested through the Study’s modeling framework or comparable data driven analysis. Applying this methodology consistently will allow Anaheim to adopt new practices as they prove effective, maintain alignment with federal and state guidance, and continue improving evacuation readiness and resilience over time. DRAFT 17507 87 JUNE 2026 10 Analysis of Proposed Projects The methodology demonstrated in this WES at a regional level provides a reproducible, evidence‑based framework that can be applied to evaluate evacuation impacts of new development projects under CEQA. Consistent with the expectations identified in recent Attorney General guidance and CEQA case law, evaluating a project’s potential to impair evacuation requires a transparent analysis of evacuation demand, roadway performance, and system response under both existing and project‑adjusted conditions. This section standardizes the City of Anaheim process for reviewing development proposals for wildfire-related impacts by defining applicability, and standardizing questions, thresholds, and mitigation measures and setting forth a standard for technical reports to adhere to in order to set a benchmark for standardization of project review. 10.1 CEQA Threshold of Significance for Wildfire Evacuation In 2022, the California Attorney General’s Office issued guidance clarifying how local governments should evaluate wildfire evacuation impacts under CEQA. The guidance emphasizes for development projects in fire-prone areas, evacuation risks may be determined to be a significant environmental impact. Specifically, agencies are expected to assess the adequacy of evacuation routes, their capacity, and the time required for residents to safely evacuate. Projects that would impair evacuation efficiency, increase congestion, or limit safe routes may be considered to have a significant impact. The guidance also highlights the importance of integrating evacuation analysis into broader planning efforts, including transportation infrastructure improvements, wildfire preparedness and mitigation strategies, and compliance with statutory requirements such as SB 99 and AB 747. The Attorney General underscores the need to ensure that new development does not compromise public safety during wildfire emergencies. 10.1.1 Existing CEQA Evacuation and Wildfire Analysis Appendix G of the CEQA Guidelines provides a sample standardized Environmental Checklist to assist lead agencies in determining whether a proposed project may cause significant environmental impacts and therefore require further environmental review under CEQA. The checklist offers sample questions that should be answered to determine significance; the questions can be tailored by individual agencies. The purpose of the checklist is to ensure agencies evaluate all relevant environmental resource areas comprehensively and consistently. For each question, a determination of significance shall be made that may state the project has No Impact, Less than Significant Impact, Less than Significant Impact with Mitigation, or Significant Impact on the environment. A threshold of significance, whether qualitative or quantitative, may be established by the lead agency to facilitate significance determination. Appendix G of the CEQA Guidelines offers the following sample questions to guide wildfire analysis, none of which directly address wildfire evacuation: DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 88 JUNE 2026 IX. Hazards: Would the project: f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? The Hazard section requires all projects regardless of proximity to an identified fire hazard area to consider its impact to adopted emergency and response plans, and if the project would expose people to risk of loss, injury or death involving wildland fires. XX. Wildfire: If located in or near State Responsibility Areas or lands classified as Very High FHSZs, would the project: a) Substantially impair an adopted emergency response plan or emergency evacuation plan? b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines, or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? The Wildfire section of the Appendix G Checklist specifically considers impacts from projects located in or near an SRA regardless of FHSZ classification or VHFHSZ in LRA. 10.1.2 City of Anaheim Wildfire Evacuation Analysis Under CEQA Building upon the state’s guidelines, the following sections clarify the City of Anaheim’s approach to evaluating wildfire evacuation impacts under CEQA. The purpose of this Study is to assist City staff, project proponents, and the public in determining whether, based on substantial evidence, a project may have a significant impact on the environment and requires mitigation. This Study is not intended to be standalone policy but used in conjunction with commonly accepted professional standards, judgments, and practices. This Study should be updated when necessary, in response to changes in CEQA, case law, and refinement of recognized scientific analysis of impact thresholds. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 89 JUNE 2026 10.1.2.1 Applicability – Where Review is Required Given that the City is not responsible for reviewing projects within the SRA, it is recommended that the City consistently interpret “in or near State Responsibility Areas or lands classified as Very High FHSZs” to include any project within a LRA High FHSZ or VHFHSZ. For all projects requiring analysis of wildfire evacuation impacts, a FPP shall be prepared consistent with the requirements of Section 602 of the 2025 CWUIC, Title 24, Part 7 to demonstrate and evaluate the effectiveness of code compliance and answer the relevant wildfire questions from Appendix G of the CEQA Guidelines. A WES shall be prepared that addresses wildfire questions from Appendix G of the CEQA Guidelines inclusive of evacuation travel time modeling as necessary in order to provide substantial evidence to answer the relevant analysis questions. The FPP and WES may be two separate technical documents, or combined into one document, so long as the relevant questions are adequately analyzed. 10.1.2.2 Appendix G Thresholds The following thresholds are provided to evaluate the Appendix G checklist questions. These qualitative and/or quantitative thresholds provide a reliable and repeatable framework for evaluating wildfire impacts amongst projects. IXf/XXa) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan? A project would have a potentially significant impact on wildfire evacuation if it would result in substantial conflict with, obstruct, or physically interfere with the City’s EOP, Know Your Way, General Plan Safety Elements, LHMPs, or similar emergency plans. Examples of conditions triggering a potentially significant impact under this qualitative threshold may include the following: ▪ Removal, blockage, or alteration of evacuation or emergency access routes as designated in Know Your Way. ▪ Changes that introduce access restrictions or operational conflicts for emergency responders. ▪ Failing to maintain minimum emergency access widths, turning radii, or clearances required by the local fire authority. IXg) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? A project would have a potentially significant impact on wildfire evacuation if it would substantially increase the risk of loss, injury, or death involving wildland fire by placing people or structures in a location or condition where wildfire behavior, fire weather, fuel load, or access limitations would foreseeably impede safe evacuation or emergency response, as demonstrated by applicable Fire Code standards, fire authority requirements, or adopted wildfire hazard maps. Conditions indicating a potentially significant impact may include the following: Any increase beyond normal variation in modeled scenario specific evacuation time is a potentially significant impact DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 90 JUNE 2026 ▪ Locating new population or structures in areas designated as VHFHSZs without adequate mitigation to address the wildfire hazard in the form of regulatory compliance, code-exceeding project design features, or mitigation measures. ▪ Introducing development where the intent of fire-resistive construction, defensible space, or fuel modification requirements cannot be met. ▪ Creating single‑access road conditions where emergency ingress/egress is compromised. ▪ An increase to modeled evacuation times beyond the established scenario-specific confidence interval, consistent with the confidence interval determined through this study. XXb) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? A project would have a potentially significant impact on wildfire evacuation if it would substantially increase wildfire risk—due to slope, wind exposure, fuel loading, or site design—such that wildfire behavior, ember exposure, smoke transport, or spread potential would foreseeably expose project occupants to unhealthy pollutant concentrations or increase the likelihood of uncontrolled wildfire spread beyond existing conditions. Indicators of a potentially significant impact include the following: ▪ Locating structures where topography (slope, aspect) intensifies flame lengths or fire spread beyond levels controllable by local firefighting standards. Fuel modification zones may reduce fire behavior to levels controllable by local firefighting standards. ▪ Situating sensitive receptors (housing, schools, assisted living) in areas with prevailing winds that channel smoke directly toward occupants during wildfire events. ▪ Introducing development that cannot comply with the defensible space or fuel modification zone requirements of the WUI Code, or that is located where modeled fire behavior would overwhelm otherwise code-compliant defensible space. XXc) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? A project would have a potentially significant impact on wildfire evacuation if it would introduce, expand, or maintain infrastructure (e.g., new roads, fuel breaks, power lines, water facilities, or utility corridors) in a manner that substantially increases wildfire ignition potential, fire spread likelihood, or long‑term environmental disturbance beyond existing conditions, as evidenced by siting within FHSZs, noncompliance with Fire Code, or conflicts with agency fire‑management standards. Indicators of a potentially significant impact include the following: ▪ New power lines or utilities placed in VHFHSZ s without undergrounding or other equivalent fire prevention mitigation. ▪ New access roads that increase ignition sources (sparks, equipment use, public access) in hazardous fuel areas without implementing adequate roadside fuel modification consistent with the applicable Fuel Modification Guidelines. ▪ Fuel breaks or road cuts that cause vegetation type conversion, erosion, or habitat fragmentation that increases wildfire behavior or frequency. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 91 JUNE 2026 XXd) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? A project would have a potentially significant impact on wildfire evacuation if it would substantially increase the likelihood of downslope or downstream flooding, erosion, debris flow, or landslide hazards—whether under normal conditions or post‑fire conditions—such that people or structures would be at foreseeable risk due to project‑induced grading, drainage modifications, vegetation removal, or post‑fire slope instability. Conditions indicating a potentially significant impact include the following: ▪ Placing development in areas where post‑fire soil instability is anticipated based on site slope, soil type, and hydrology. ▪ Altering natural drainage patterns such that peak runoff increases flood depth or velocity on or off site. ▪ Siting structures on or below slopes prone to debris flows following wildfire denudation. ▪ Failing to meet the intent of applicable safety standards in General Plans, Safety Elements, or Fire Code requirements. The thresholds established in this Study operate independently. No single threshold supersedes another, and compliance with one does not offset exceedance of another. If a project exceeds the quantitative evacuation threshold (e.g., the zone‑level confidence interval) and the exceedance cannot be feasibly mitigated, the impact must be treated as significant under CEQA, even if the project satisfies all other qualitative or regulatory thresholds. Conversely, if substantial evidence supports that the exceedance does not result in a significant environmental impact under Appendix G of the CEQA Guidelines—taking into account both quantitative results and qualitative operational factors—the lead agency may determine the impact is less than significant with mitigation. However, where a threshold exceedance is found to represent a significant impact and cannot be reduced below that level, the impact must be disclosed as significant and unavoidable. 10.2 Standard Technical Report Format and Methodology to Support Determinations As identified in 10.1.2.1, a project within a High FHSZ or VHFHSZ is required to prepare a FPP and a WES in order to evaluate the proposed project for impacts relating to wildfire. The project WES should substantially follow the format and methodology of this document, accomplishing the following tasks: 1. Evaluate the wildfire environment (Section 1 of this report). 2. Identify the regulatory context (Section 2 of this report). 3. Evaluate the Emergency Response and Preparedness Resources relevant to the Project (Section 3 of this report). 4. Acknowledge the existing infrastructure and any constrained roadways/parcels created by the project (Section 5 and 6 of this report). 5. In cooperation with City of Anaheim staff, develop a wildfire progression and evacuation modeling scope that succinctly identifies the worst-case fire and resulting worst-case evacuation that may cause evacuation of the Project site and defines the resulting evacuation. As with this study, modeling should not include DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 92 JUNE 2026 emergency personnel field actions to demonstrate CEQA worst-case scenario level analysis. Scoping shall include at a minimum: a. The fire progression modeling which is most threatening to and causes evacuation of the Project (Section 7 of this report). Applicant may adopt this document’s wildfire progression or otherwise model fire progression modeling following the methodology of this report. b. With consideration of the Know Your Way program, confirm which zones would be evacuated relative to the fire scenario, including which zones would be evacuated immediately, with a 10-mnute delay, shadow evacuation, and shadow-senior evacuations. All zones that may be directly impacted by a Project shall be considered. c. Confirm the number of evacuating vehicles which may use this study’s assumptions or new assumptions with substantial evidence, so long as number of vehicles is held consistent across all evacuation scenarios. d. Demonstrate that the selected evacuation modeling tool can assign demand to modeled evacuation zones, simulate traffic behavior using Dynamic Traffic Assignment within a microsimulation environment, and produce roadway congestion, clearance times, and zone‑specific evacuation performance metrics to be used in the thresholds evaluation. e. Cumulative projects to be included in existing conditions. 6. Model wildfire evacuation using the methodology described in this document (Section 8 and Appendix B of this report) for existing conditions to determine the confidence interval, or normal variation, in evacuation of existing conditions. 7. Using the same model assumptions, add the Project inclusive of Project Design Features to the model and re-run to determine the change in evacuation time resulting from the Project. 8. Determine impacts in accordance with the adopted Thresholds including comparing the evacuation change in evacuation modeling time resulting from the Project to the confidence interval determined in the existing conditions scenario (Section 10.1.2.2 and 10.2.1 of this report). Only the zones ordered to evacuate, including those ordered to evacuate immediately or those evacuating on a delay, need be evaluated for impacts. 9. Select appropriate mitigation if necessary (Section 10.2.3 of this report). 10. Demonstrate the effectiveness of the mitigation by re-running the model with the Project and the Project Mitigation Measures (Section 10.2.4 of this report). 11. Studies shall include: a. Combined map of fire progression and evacuation zones/routes by evacuation order type (immediate, 10- mnute delay, shadow evacuation, and shadow-senior evacuations) such as Figures 10-12 of this report. b. Justification for selected fire scenario c. Table of evacuation vehicles by zone d. Diagram showing routing assumptions e. Explanation of phasing strategy This methodology is further explained in greater technical detail in Attachment A of Appendix B. The scoping criteria mentioned in step 5 above is consolidated into a practical, usable form in Attachment B of Appendix B. The following sections specifically address the process of selecting appropriate mitigation measures and demonstrating the effectiveness of those mitigation measures. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 93 JUNE 2026 10.2.1 Determine Project Impact The following matrix corresponds to the established thresholds and provides examples of how each threshold may be evaluated to determine if the project results in a potentially significant impact. It is the applicant’s responsibility to prepare the determination and provide the City as lead agency with substantial evidence to support their findings. To support a significance determination, the applicant should first attempt to quantify the impact through available modeling including fire behavior, fire progression, evacuation travel time, or other modeling types whenever possible, even if the issue is not solely quantitative. If the threshold cannot be evaluated quantitatively, or if the threshold requires both quantitative and qualitative evaluation, empirical data and peer reviewed research may then be utilized to complete the evaluation in accordance with CEQA. As previously stated, the thresholds established in this Study operate independently. No single threshold supersedes another, and compliance with one does not offset exceedance of another. If a project exceeds the quantitative evacuation threshold (e.g., the zone‑level scenario-specific confidence interval) and the exceedance cannot be feasibly mitigated, the impact must be treated as significant under CEQA, even if the project satisfies all other qualitative or regulatory thresholds. An impact determined in this step of evaluation may ultimately be mitigated in accordance with Sections 10.2.3 through 10.2.4 DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 94 JUNE 2026 Table 8. Methods for Determining Impacts Threshold Condition What Causes a Potentially Significant Impact Methodology IXf/XXa – Emergency Plans Removal, blockage, or alteration of evacuation or emergency access routes as designated in Know Your Way. Substantially conflicts with or obstructs adopted evacuation routing, degrading egress/ingress capacity or reliability defined in City emergency planning (e.g., Know Your Way/EOP), thereby impairing implementation of the plan. Evaluation of site planning documents for determination that either yes, or no, the project does or does not remove, block, or alter the evacuation or emergency access routes as designated in Know Your Way. Changes that introduce access restrictions or operational conflicts for emergency responders. Introduces design/operational barriers (e.g., gates, choke points, lane narrowing, conflicting traffic control) that impede response time, staging, or simultaneous ingress/egress, conflicting with Fire/Police operating procedures. Evaluation of site planning documents for determination that either yes, or no, the project does or does not create access restrictions or operational conflicts for emergency responders. FPP shall be reviewed by AFR for confirmation. Failing to maintain minimum emergency access widths, turning radii, or clearances required by the local fire authority. Noncompliance with Fire Code/agency standards reduces apparatus access and turn movements, creating foreseeable delays or failures in emergency response/evacuation execution. Evaluation of site planning documents for determination that either yes, or no, the project does or does not meet applicable codes. FPP shall be reviewed by AFR for confirmation. IXg – Exposure to Wildland Fire Risk Locating new population or structures in VHFHSZ without adequate mitigation (regulatory compliance, code-exceeding design, or mitigation measures). Siting in mapped High FHSZ or VHFHSZs without sufficient risk reduction increases expected exposure to flame fronts/embers/smoke, elevating the risk of loss, injury, or death. The adopted fire code should be evaluated to determine if compliance with those requirements is sufficient given the modeled fire behavior. When not the case, the project can create code-exceeding project design features that adequately protect the project, as determined through modeling or determined through approved studies. Evaluation of site planning documents for determination that either yes, or no, the project does or does not meet sufficient code or code-exceeding measures. FPP shall be reviewed by AFR for confirmation. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 95 JUNE 2026 Table 8. Methods for Determining Impacts Threshold Condition What Causes a Potentially Significant Impact Methodology Introducing development where the intent of fire- resistive construction, defensible space, or fuel modification requirements cannot be met. Inability to achieve required hardening and defensible space elevates structure ignition probability and reduces survivability during wildfire, increasing risk to people/structures. Evaluation of site planning documents for determination that either yes, or no, the project does or does not meet the intent of fire-resistive construction, defensible space, or fuel modification requirements. FPP shall be reviewed by AFR for confirmation. Creating single access road conditions where emergency ingress/egress is compromised. Single egress configurations elevate the probability of entrapment and evacuation delay, raising life safety risk during fast-moving fire or simultaneous blockages. Evaluation of site planning documents for determination that either yes, or no, the project does or does not create single access road conditions. XXb – Exacerbation of Wildfire Risk (slope, wind, etc.) Locating structures where topography (slope, aspect) intensifies flame lengths or fire spread beyond levels controllable by local firefighting standards. However, fuel modification zones reduce fire behavior to levels controllable by local firefighting standards. Without effective fuel modification/defensible space, slope/aspect driven fire behavior can exceed controllability, elevating ignition and spread risk; with compliant FMZs that reduce fire behavior to controllable levels, the impact may be reduced to less than significant. Conduct fire behavior modeling pre and post project to determine either yes, or no, the project does or does not intensify flame lengths or fire spread beyond levels controllable by local firefighting standards. FPP shall be reviewed by AFR for confirmation. Situating sensitive receptors (housing, schools, assisted living) in areas with prevailing winds that channel smoke directly toward occupants during wildfire events. Predictable smoke transport to sensitive receptors elevates exposure to unhealthy pollutant concentrations and evacuation complexities, constituting a substantial adverse effect. Evaluate site planning documents to determine if project locates sensitive receptors into an area that may experience smoke channeled by prevailing winds. Conduct smoke transport modeling pre and post project to determine if an upwind wildfire would expose project occupants to smoke during a wildfire event. FPP shall be reviewed by AFR for confirmation. Introducing development that cannot meet defensible space or fuel modification zone requirements of the Fire Code. Noncompliance removes a primary risk reduction layer (setbacks/clearance), increasing radiant heat/ember exposure and potential for uncontrolled spread. Evaluation of site planning documents for determination that either yes, or no, the project does or does not meet the intent of defensible space or fuel modification requirements. FPP shall be reviewed by AFR for confirmation. Creating conditions where fire arrival time is shorter than available evacuation or shelter in place clearance time. A negative time margin (arrival time < clearance time) indicates foreseeable life safety risk due to Through fire progression modeling and evacuation travel time modeling using the methodologies described in this report, DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 96 JUNE 2026 Table 8. Methods for Determining Impacts Threshold Condition What Causes a Potentially Significant Impact Methodology insufficient time to evacuate/shelter, signaling a substantial impact. determine if a fire may impact a site prior to evacuation clearance. Consideration must be given to defensible space and fuel modification, which may interrupt fire progression and prevent the fire from ever reaching the site. FPP and WES shall be reviewed by AFR for confirmation. An increase to modeled evacuation times beyond a zone’s established confidence interval. Modeled egress exceeding the zone performance threshold (per the study’s method/confidence interval) indicates evacuation performance degradation to a potentially significant level. Using the methodology in this study, model pre and post project evacuation to determine if the project increases evacuation time for any Zone by more than the established confidence interval. XXc – Infrastructure that May Exacerbate Fire Risk or Environmental Impacts New power lines or utilities placed in VHFHSZ without undergrounding or equivalent fire prevention mitigation. Elevated ignition probability (e.g., conductor contact, wind events) in high hazard areas without equivalent mitigation substantially increases wildfire risk. Evaluation of site planning documents for determination that either yes, or no, the project does or does not introduce aboveground power lines or utilities. If yes, evaluate if the project employs fire protection to prevent ignitions or damage to utilities through fire behavior modeling or as supported by effectiveness of code compliance. FPP shall be reviewed by AFR for confirmation. New access roads that increase ignition sources (sparks, equipment use, public access) in hazardous fuel areas without adequate roadside fuel modification. Added human/vehicle ignition vectors in flammable corridors, absent treatment, increase ignitions and spread potential beyond existing conditions. Evaluation of site planning documents for determination that either yes, or no, the project does or does not add roads to hazardous fuel areas without adequate roadside fuel modification. Evaluate the effectiveness of fuel modification through pre and post project fire behavior modeling. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 97 JUNE 2026 Table 8. Methods for Determining Impacts Threshold Condition What Causes a Potentially Significant Impact Methodology Fuel breaks or road cuts that cause vegetation type conversion, erosion, or habitat fragmentation that increases wildfire behavior or frequency. Unintended ecological change (e.g., invasive grasses) can raise fire frequency/intensity and long-term disturbance, constituting a substantial, ongoing risk elevation. Evaluation of site planning documents for determination that either yes, or no, the project does or does not cause vegetation type conversion. XXd – Post Fire Flooding/Landslides/Drainage Risks Placing development in areas where post-fire soil instability is anticipated based on site slope, soil type, and hydrology. Increases exposure of people/structures to debris flows, landslides, or erosion after wildfire denudation, elevating foreseeable life safety/property risk. Evaluation of site planning documents and liquefication maps for determination that either yes, or no, the project does or does not place development in a location with foreseeable post- fire slope instability. Altering natural drainage patterns such that peak runoff increases flood depth or velocity on or off site. Project induced hydrologic changes that raise flood hazard (depth/velocity) create substantial risk, especially under post-fire reduced infiltration. Evaluation of site planning documents for determination that either yes, or no, the project does or does not alter natural drainage patterns. If yes, evaluate if the alteration results in peak runoff increases flood depth or velocity on or off site through modeling or synthesization of relevant research. Siting structures on or below slopes prone to debris flows following wildfire denudation. Predictable post-fire mass wasting hazards threaten occupants/structures, representing a substantial adverse effect. Evaluation of site planning documents and liquification maps for determination that either yes, or no, the project does or does not situate structures on or below slopes prone to debris flows following wildfire denudation. Failing to meet the intent of applicable safety standards in General Plans, Safety Elements, or Fire Code requirements. Noncompliance with adopted safety/Fire Code standards signifies inadequate hazard controls, materially increasing risk to people and structures. Evaluation of site planning documents for determination that either yes, or no, the project does or does not meet the intent of applicable safety standards. Notes: EOP = Emergency Operations Plan; FPP = Fire Protection Plan; AFR = Anaheim Fire & Rescue; VHFHSZ = Very High Fire Hazard Severity Zone; FMZ = fuel modification zone; DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 98 JUNE 2026 10.2.2 Mitigation Measures If a Potentially Significant Impact has been identified, a project may reduce that impact to Less than Significant Impact with Mitigation by implementing mitigation measures that can be demonstrated to reduce the impact determined to exist through the study. Project-specific CEQA analysis must demonstrate how each measure is practicable and effective to offset the actual project impacts. Examples of mitigation measures are included in Table 9. The bank of mitigation measures is not exhaustive and represents those commonly known and used as of the writing of this study. These measures are not final and may evolve over time as technology and best practices continue to develop. Mitigation is appropriate if it can be proven to offset the impact identified when evaluating the CEQA thresholds through substantial evidence, including but not limited to modeling. To the extent feasible, measures should be implemented to the entire evacuation corridor impacted by the project as identified in the Know Your Way program. A Mitigation Monitoring Program (MMP) provides a structured, enforceable framework to ensure that all adopted mitigation measures are implemented effectively, at the appropriate stage of project development, and by the appropriate party by designating roles and responsibilities of all parties including a responsible oversight entity. Consistent with CEQA requirements, the MMP shall identify the City department or agency responsible for verification and specify the timing for completion to ensure each measure is implemented prior to when the corresponding impact would occur. The MMP is enforced throughout all phases of the project, including construction and operation. The responsible entity may delegate monitoring and verification tasks to other departments, qualified consultants, or contractors, as appropriate. For infrastructure-related measures, verification shall occur prior to prior to when the corresponding impact would occur which may occur concurrently with the approval of grading or right-of-way permits, during building inspections, or before issuance of certificates of occupancy. Given that each development proposal varies in scope, location, and potential effects, the specific timing and responsible parties are finalized as part of the individual project’s entitlement and permitting process. An enforceable, project-specific MMP ensures mitigation measures are tailored to individual project conditions while maintaining consistent City oversight and completion before the associated impact could occur .DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 99 JUNE 2026 Table 9. Potential Mitigation Measures MM No. Category Mitigation Measure Purpose / Impact Addressed Responsible parties MM-INF-1 Infrastructure Provide or fund signal interconnectivity along evacuation-relevant corridors identified in Know Your Way, and along roadways outside the Know Your Way network where the City and study determine that the project would contribute traffic during an evacuation event. Reduces delay, enables flush operations, and improves evacuation throughput. Applicant for when improvements are on site, City for off-site improvements though funding may be from applicant, unless otherwise noted in the MMP. Measure to be verified by APW. MM-INF-2 Infrastructure Install CCTV coverage at signalized intersections along evacuation-relevant corridors identified in Know Your Way, and at signalized intersections along roadways outside the Know Your Way network where the City and study determine that the project would contribute traffic during an evacuation event. Supports real-time monitoring and remote adjustments during evacuation. Applicant if CCTV installation is on site, City for off-site CCTV installation though funding may be from applicant, unless otherwise noted in the MMP. Verified by APW. MM-INF-3 Infrastructure Provide Emergency Vehicle Preemption (EVP) for signalized intersections along evacuation-relevant corridors identified in Know Your Way, and for signalized intersections along roadways outside the Know Your Way network where the City and study determine that the project would contribute traffic during an evacuation event. Improves emergency responder access; reduces conflicts with evacuees. Applicant if improvements are on site, City for off-site improvements though funding may be from applicant, unless otherwise noted in the MMP. Verified by APW. MM-INF-4 Infrastructure Install or fund backup power (battery or generator) for signals, CCTV, and CMS along evacuation-relevant corridors identified in Know Your Way, and along roadways outside the Know Your Way network where the City and study determine that the project would contribute traffic during an evacuation event. Maintains evacuation operations during outages or PSPS. Applicant to fund on-site installation, City for off-site improvements though funding may be from applicant, unless otherwise noted in the MMP. Verified by APW. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 100 JUNE 2026 Table 9. Potential Mitigation Measures MM No. Category Mitigation Measure Purpose / Impact Addressed Responsible parties MM-INF-5 Infrastructure Fund installation of permanent Changeable Message Signs (CMS) for dynamic routing along evacuation-relevant corridors identified in Know Your Way, and along roadways outside the Know Your Way network where the City and study determine that the project would contribute traffic during an evacuation event. Improves real-time communication and rerouting capability. Applicant if CMS are on site, City for off- site CMS though funding may be from applicant, unless otherwise noted in the MMP. Verified by APW. MM-INF-6 Infrastructure Design roadways to include shoulder widening or drivable shoulder improvements, or otherwise fund roadway improvements, along evacuation-relevant corridors identified in Know Your Way, and along roadways outside the Know Your Way network where the City and study determine that the project would contribute traffic during an evacuation event. Adds temporary evacuation lane capacity during wildfires. Applicant for on-site roadways, City for off-site roadway improvements though funding may be from applicant, unless otherwise noted in the MMP. Verified by APW. MM-INF-7 Infrastructure Provide fair-share funding for signalization of Canyon Rim Road / Fairmont Boulevard or similarly constrained intersections along evacuation-relevant corridors identified in Know Your Way, and at intersections along roadways outside the Know Your Way network where the City and study determine that the project would contribute traffic during an evacuation event. Improves controlled throughput and supports corridor flush strategy. Applicant is responsible for fair-share funding unless otherwise noted in the MMP. Verified by APW. MM-WF-1 Wildfire Preparedness Enhance or fund roadside vegetation clearance beyond the minimum 10-foot standard where fire behavior modeling supports the need, along evacuation- relevant corridors identified in Know Your Way, and along roadways outside the Know Reduces flame impingement, radiant heat, and ember exposure along evacuation routes. On-site roadway clearing responsibility and requirements shall be in CC&Rs prepared by the applicant, verified by AFR. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 101 JUNE 2026 Table 9. Potential Mitigation Measures MM No. Category Mitigation Measure Purpose / Impact Addressed Responsible parties Your Way network where the City and study determine that the project would contribute traffic during an evacuation event. MM-WF-2 Wildfire Preparedness Implement or fund enhanced WUI fuel breaks informed by fire behavior analysis for zones along evacuation-relevant corridors identified in Know Your Way, and along roadways outside the Know Your Way network where the City and study determine that the project would contribute traffic during an evacuation event. Prevents wildland fire spread toward development; increases evacuation lead time. On-site fuel breaks shall be Implemented by the applicant, off-site fuel breaks shall be funded by the applicant and conducted by City staff or the City’s contractor, verified by AFR. Responsibility and requirements shall be in CC&Rs prepared by the applicant, verified by AFR. MM-WF-3 Wildfire Preparedness Fund a community grant to encourage installation of home hardening features (ember-resistant vents, noncombustible zones, Class A roofs). Reduces structure ignition risk; aligns with CWUIC performance. Applicant is responsible for funding and administering the reimbursements for home hardening features. Program to be monitored by AFR. MM-WF-4 Wildfire Preparedness Contribute to ALERT California camera expansion at strategic ridgelines. Enhances early detection and situational awareness during wildfire spread. Applicant to fund installation and monitoring by UCSD/ALERT California. Verified by AFR. MM-EVAC-1 Evacuation Readiness Install on-site cell tower with backup power to maintain communication reliability. Maintains communication flow (alerts, orders, routing) during outages. Applicant to fund and install on-site installation. If an on-site location is not available, the applicant may fund installation by APU or their contractor. To be verified by APU. MM-EVAC-2 Evacuation Readiness Fund evacuation education for project occupants and adjacent neighborhoods along the Project’s evacuation-relevant corridors as determined in Know Your Way. Reduces premovement delay and confusion. Applicant to fund and implement on-site programs. Applicant to fund AFR or AFR’s chosen contractor to implement program to occupants beyond the project site. Verified by AFR. Responsibility and requirements shall be in CC&Rs prepared by the applicant, verified by AFR. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 102 JUNE 2026 Table 9. Potential Mitigation Measures MM No. Category Mitigation Measure Purpose / Impact Addressed Responsible parties MM-EVAC-3 Evacuation Readiness Require household evacuation plans including off-site meeting locations and mid-day evacuation contingencies. Reduces variability in pre- evacuation readiness and improves timing. Applicant to fund and implement on-site programs. Applicant to fund AFR or AFR’s chosen contractor to implement program to occupants beyond the project site. Verified by AFR. Responsibility and requirements shall be in CC&Rs prepared by the applicant, verified by AFR. MM-EVAC-4 Evacuation Readiness Fund DAFN specific evacuation planning (transport resources, communication accommodations). Improves equity and ensures vulnerable populations can evacuate reliably. Applicant to fund and implement on-site programs. Applicant to fund AFR or AFR’s chosen contractor to implement program to occupants beyond the project site. Verified by AFR. Notes: MMP = Mitigation Monitoring Program; APW = Anaheim Public Works; CCTV = closed-circuit television; EVP = Emergency Vehicle Preemption; CMS = Changeable Message Signage; PSPS = Public Safety Power Shutoff; WUI = Wildland–Urban Interface; CC&R = Covenants, Conditions, and Restrictions; CWUIC = California Wildland–Urban Interface Code; DAFN = Disabilities and Access and Functional Needs. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 103 JUNE 2026 10.2.3 Identify and Select Appropriate Mitigation Measures If the thresholds evaluation identifies one or more potentially significant impacts, the project must attempt to incorporate feasible and enforceable mitigation measures that directly reduce that impact to a less than significant impact. Appropriate mitigation is selected based on the specific cause of the impact. For example: ▪ If impacts are caused by roadway bottlenecks or demand surges, transportation‑based mitigation (signal coordination, lane enhancements, turn‑pocket modifications, or fair‑share contributions to evacuation improvements) may be appropriate. Such mitigation measures that create improvements to the evacuation network should be modeled to demonstrate effectiveness. ▪ If impacts arise from increased wildfire behavior or reduced defensibility, mitigation may include enhanced fuel modification, ignition‑resistant construction, fire pathway treatment, or defensible space requirements that exceed minimum code standards. ▪ If impacts stem from public readiness, confusion, or operational constraints, mitigation may include a project‑level Wildfire Evacuation and Awareness Plan, enhanced communication systems, or functional improvements to internal circulation. Selection of mitigation should be supported by substantial evidence showing (1) the mitigation directly addresses the modeled constraint, (2) it is feasible and enforceable, and (3) it reduces the impact to a less‑than‑significant level when implemented. This substantial evidence should include modeling to demonstrate effectiveness whenever possible. While acceptable mitigation measures inevitably vary by project, Table 10 demonstrates potential mitigation measures by threshold topic. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 104 JUNE 2026 Table 10. Mitigation Measure by Impact Threshold Description of Trigger Applicable Mitigation Measures (Table 9 IDs) Mechanism of Impact Reduction IX(f) / XX(a) Conflicts with or interference in emergency response/evacuation plans. MM INF-1, INF-2, INF-3, INF-4, INF-5, INF-6, INF-7; MM EVAC-1, EVAC-2, EVAC-3, EVAC-4 Restores corridor operability; increases throughput; reduces outage vulnerability; improves message clarity; reduces pre-movement delay. IX(g) Increased risk of loss, injury, death by placing people/structures where wildfire behavior or access constraints impede evacuation. MM WF-1, WF-2, WF-3, WF-4; MM INF-6, INF-7; MM EVAC-2, EVAC-4 Reduces fire intensity/ember exposure; increases structure survivability; improves detection; supports vulnerable populations; improves roadway reliability. XX(b) Project exacerbates wildfire behavior (slope, wind, fuels); fire arrival time < evacuation time; cannot meet defensible space. MM WF-1, WF-2, WF-3, WF-4; MM INF-6; MM EVAC-2, EVAC-3 Reduces fire spread; increases ignition resistance; improves early detection; reduces premovement time; increases corridor capacity margin. XX(c) Infrastructure increases ignition potential or long-term fire risk. MM WF-1, WF-2; MM INF-4, INF-5, INF-6 Offset increased ignition hazards via fuel treatment; maintain operational reliability; reroute evacuees dynamically. XX(d) Increased risk of post-fire flooding/debris flow exposure. MM WF-1, WF-2; MM EVAC-2, EVAC-4 Reduces burn severity and slope instability; improves re-entry safety; supports vulnerable populations. Confidence Interval Quantitative Threshold A significant impact would occur if the average modeled evacuation clearance time under the With Project condition falls outside the 95% confidence interval established for the Without Project condition, as defined by the difference between the lower and upper bounds of that interval. MM INF-1 through INF-7; MM EVAC-1 through EVAC-4 Directly reduces modeled clearance times by improving throughput, reducing delays, enhancing communications, and increasing system redundancy. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 105 JUNE 2026 10.2.4 Demonstrate Mitigation Effectiveness Following selection of mitigation measures, the applicant bears the burden of demonstrating effectiveness through analysis supported with substantial evidence to reduce impacts to Less than Significant. The evaluation should address both quantitative and qualitative impacts, using the appropriate evidence standard for each and documenting how the combined result reduces impacts to below the applicable thresholds of significance. Whenever possible the applicant should first attempt to quantify the impact through available modeling including fire behavior, fire progression, evacuation travel time modeling, or other modeling types whenever possible, even if the issue is not solely quantitative. If the threshold cannot be evaluated quantitatively, or if the threshold requires both quantitative and qualitative evaluation, empirical data and peer reviewed research may then be utilized to complete the analysis. 10.2.4.1 Effectiveness of Mitigation for Quantitative Impacts Mitigation measures that can be modeled should be modeled to demonstrate effectiveness. Various types of modeling are available to the applicant, but fire progression and evacuation travel time modeling should be in accordance with the methodologies described in this report. To evaluate quantitative effectiveness for evacuation improvements, re-run the project’s evacuation microsimulation using the same network, demand, evacuation phasing, and control assumptions as in the impact analysis, then apply the specific mitigation package and compare the results to the project without mitigation case generated under this Study’s methodology. Report zone level evacuation clearance times, compute the delta attributable solely to mitigation and test it against the Study’s quantitative threshold (i.e., whether the mitigation reduces the project-caused increase in evacuation time to within the scenario-specific zone level confidence interval identified herein, derived from the Study’s modeling framework). The evacuation time modeling prepared for this study in Appendix B is a reproducible framework that can be utilized for evaluating a project’s impacts and mitigation effectiveness, as evidenced this study’s remodeling to demonstrate the effectiveness of a flush strategy. To maintain statistical rigor consistent with Appendix B, run multiple random seeds, summarize means and confidence intervals in tables that mirror the Study’s formatting, and, where multiple measures are proposed, document both individual and combined effects so decisionmakers can see the contribution of each mitigation as well as the cumulative improvement. This is the same quantitative proof of effectiveness approach used in Appendix B, where measures like signal coordination and flush strategies were re-simulated to show measurable reductions in clearance times for prioritized zones. An example of modeling mitigation for evacuation time improvement could be similar to the following scenario: Through modeling methodology in accordance with this study, it is discovered that a project creates an impact by increasing evacuation times beyond the established scenario-specific zone level confidence interval. The applicant uses Table 10 to determine that MM-INF-1 and 2 may be implemented to reduce evacuation time along the corridor. The applicant can then re-run the scenario with a flush strategy enabled by MM-INF-1 and 2 and evaluate the results against the unmitigated modeling. For mitigation measures that interrupt fire progression, the methodology in Chapter 7 of this study should be reproduced to demonstrate pre-project, with project, and project with mitigation scenarios. Modeling variables and assumptions should be held consistent to highlight the effectiveness of the mitigation measure employed. An DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 106 JUNE 2026 example of modeling mitigation for a potentially significant impact under checklist question XXb could be similar to the following scenario: Through fire progression modeling in accordance with this study, it is discovered that the Project creates conditions where fire arrival time is shorter than available evacuation or shelter in place clearance time. The applicant uses Table 10 to determine that MM-WF-2 is appropriate to interrupt fire progression. Fire progression modeling is then re-run to account for an enhanced fuel break to determine if fire progression is adequately interrupted. 10.2.4.2 Effectiveness of Mitigation for Qualitative Impacts For qualitative impacts, effectiveness must be demonstrated through structured, evidence‑based documentation that aligns with the methodology and evaluation logic used throughout this Study. Because certain evacuation‑related effects—such as public readiness, clarity of alerts, vegetation management near corridors, or improvements to building defensibility—cannot be captured solely through clearance‑time modeling, the Study requires that qualitative mitigation be supported by substantial evidence showing how each measure reduces operational risk or exposure pathways. This includes describing the operational purpose of each measure, explaining the mechanism by which it improves evacuation performance or reduces the likelihood of route impairment, and providing tangible verification materials such as communication templates, defensible space inspection protocols, maintenance procedures, or vegetation treatment plans. Such explanation should be stated in the EIR section corresponding to the evaluation question. Qualitative mitigation should also connect directly to the fire‑behavior and evacuation context established earlier in this Study—for example, demonstrating how enhanced roadside clearance reduces the probability of flame impingement on critical evacuation routes, or how improved public messaging reduces pre‑departure delay by reinforcing phased evacuation expectations. Where appropriate, this Study’s methodology allows qualitative measures to be translated into limited sensitivity tests (e.g., reduced pre‑movement time or fewer random slowdowns) to show that their operational effect is directionally consistent with quantitative improvements, while making clear that these tests supplement—not replace—the substantive qualitative record. By following the same structured evaluative approach used throughout this Study, qualitative mitigation can be shown to meaningfully reduce risk, improve operational conditions, and contribute to achieving a less‑than‑significant impact under CEQA. The following examples demonstrate how the quantitative scenarios in 10.2.4.1 are enhanced by adding a qualitative component. Through modeling methodology in accordance with this study, it is discovered that a project creates an impact by increasing evacuation times beyond the established confidence interval. The applicant uses Table 10 to determine that MM-INF-1 and 2 may be implemented to reduce evacuation time along the corridor. The applicant can then re-run the scenario with a flush strategy enabled by MM-INF-1 and 2 and evaluate the results against the unmitigated modeling. If those two mitigation measures do not adequately reduce evacuation time, additional mitigation measures may be added and modeled. If a mitigation measure such as MM-INF-5 is implemented and effectiveness cannot be modeled, substantial evidence such as empirical data supporting the effectiveness of CMS may be incorporated to demonstrate qualitative enhancements that support faster, better coordinated evacuation. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 107 JUNE 2026 Through fire progression modeling it is discovered that the Project creates conditions where fire arrival time is shorter than available evacuation or shelter in place clearance time. The applicant uses Table 10 to determine that MM-WF-2 is appropriate to interrupt fire progression. Fire progression modeling is then re-run to account for an enhanced fuel break to determine if fire progression is adequately interrupted. It is determined that the single mitigation measure is not sufficient, and MM- WF-4 is provided to allow for quicker detection of fires. Substantial evidence such as empirical data supporting the effectiveness of wildfire detection cameras may be incorporated to demonstrate qualitative enhancements that support faster, better coordinated evacuation. 10.3 Integrated Findings Using the methodology established in this Study, the final step is to synthesize both the quantitative and qualitative evaluations into a single, defensible conclusion regarding impact significance. This requires integrating the re‑modeled evacuation results—produced using the same simulation approach demonstrated in Appendix B—with the qualitative evidence that addresses aspects of evacuation performance not fully captured by clearance‑time metrics. The integrated finding should clearly describe how the selected mitigation reduces the project‑caused increase in evacuation time to within the confidence interval established in this Study, while also demonstrating how qualitative measures—such as improved public communication, enhanced roadside vegetation management, defensible space treatments, or operational readiness improvements—reduce exposure, operational uncertainty, or the likelihood of evacuation route impairment. Together, these components must show, consistent with the structure of Appendix B, that mitigation has both measurably improved modeled performance and substantively addressed non‑modelled operational risks, resulting in a fully supported conclusion that the project’s wildfire evacuation impacts have been reduced to a less‑than‑significant level under CEQA. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 108 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT 17507 109 JUNE 2026 11 Conclusion This WES for the City of Anaheim (with a focus on Anaheim Hills) provides a comprehensive, evidence‑based foundation for understanding wildfire hazard, community exposure, evacuation system performance, and practical measures to strengthen public safety, operational readiness, and CEQA defensibility. It integrates wildfire science, transportation operations, community input, and regulatory guidance into a single framework that can be applied consistently—both for citywide planning and for project‑level CEQA review. 11.1 Content Review The Study synthesizes federal, state, and local guidance germane to wildfire preparedness and evacuation— including the City’s General Plan (Safety, Land Use, Circulation, Environmental Justice), adopted fire codes (including the 2025 CFC and the CWUIC), and emergency management plans (EOP, LHMP), as well as SB 99 and AB 747 requirements for evacuation route identification and evaluation. It also distills evolving expectations from CEQA case law and Attorney General guidance that call for transparent, evidence‑driven evacuation analysis and mitigation. Together, these sources establish the analytical and policy framework that this WES uses to evaluate risk and recommend actions. The Study documents the Anaheim Hills fire environment—topography, climate, vegetation/fuels, and recorded fire history including major events such as the Freeway Complex Fire and Canyon II Fire—illustrating how Santa Ana wind‑aligned terrain and continuous fuels can drive rapid fire spread toward neighborhoods in the WUI. The “Know Your Way” evacuation program context is summarized to show the City’s operational baseline and how lessons from recent fires inform evacuation. The roadway system (freeways, arterials, hillside facilities) and public safety assets (AFR stations, mutual aid) are described alongside constrained roadway and parcel analyses synthesized from the Safety Element in accordance with SB 99. This allows evacuation modeling to be grounded in the actual network geometry, operational policies, and known bottlenecks. Using FlamMap’s MTT tool, the Study evaluates representative Santa Ana wind scenarios from multiple ignition locations (e.g., SR‑241 corridor, East Nohl Ranch, Deer Canyon). While the modeling is purposefully conservative (static severe weather inputs and continuous fuels), it serves its intended role: to define plausible fire arrival timing at the WUI edge and adjacent structures and to provide a defensible basis for phasing evacuations and prioritizing corridors for protection and throughput. The Study then quantifies evacuation performance with PTV Vissim and Dynamic Traffic Assignment across a suite of scenarios—two catastrophic (upper‑bound, no phasing) and several area‑specific wildfire scenarios that reflect operational best practices (phased orders, shadow evacuation behavior, and, as applicable, early DAFN evacuation). The evacuation modeling provides a conservative planning benchmark intended to inform preparedness and investment decisions. For each scenario, the analysis reports network‑wide and zone‑level clearance times and identifies which combinations of ignition location, evacuation phasing, and demand profiles most challenge the network. The area‑specific scenarios show materially improved performance compared to catastrophic “all‑at‑once” assumptions, reinforcing the value of phasing and demand management. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 110 JUNE 2026 Key Results at a Glance. ▪ Catastrophic, unphased evacuations produce the longest clearance times and most severe congestion— useful as a stress test, but not reflective of modern wildfire operations. ▪ Phased evacuations and prioritized corridor operations shorten clearance times for the most‑at‑risk zones and better utilize available capacity across time. ▪ Under cumulative conditions, time increases are not spatially uniform; targeted operational strategies can offset much of the added demand, while highlighting a few locations (e.g., specific zones) where additional improvements provide the greatest return. Recommendations. The Study advances a coordinated suite of areawide Transportation, Wildfire Preparedness, and Evacuation Readiness measures: ▪ Transportation: Implement corridor‑wide signal interconnectivity and CCTV coverage to enable real‑time monitoring and a flush strategy that prioritizes zones nearest the fire; evaluate contra‑flow and drivable shoulders where feasible; signalize critical intersections for integration into evacuation timing plans; coordinate with Caltrans on interchange and ramp operations (e.g., SR‑91 interfaces); explore additional connections and emergency‑only links. ▪ Wildfire Preparedness: Validate and, where necessary, enhance roadside fuel modification and perimeter fuel breaks based on modeled or observed fire behavior; expand home hardening and defensible space programs; leverage Firewise efforts, targeted inspections, and micro‑grants; add ALERT camera coverage to improve early detection and situational awareness. ▪ Evacuation Readiness: Strengthen two‑way information flow through digital evacuation signage, resilient communications (backup power at towers), and public education that clarifies alerts vs. orders, supports phased operations, and sets realistic pre‑movement time expectations; expand outreach for DAFN needs and integrate evacuation‑specific objectives into exercises. CEQA Framework and Thresholds. The Study provides thresholds for evaluating wildfire impacts and standardizes a repeatable framework for project‑level CEQA evaluations that: (1) model the project’s evacuation effects under the Study’s methodology; (2) evaluate results against the City’s qualitative and quantitative thresholds (including the scenario-specific zone‑level quantitative confidence interval established here); (3) select mitigation that directly addresses the modeled constraints; and (4) re‑model with mitigation to demonstrate impact reduction. It distinguishes quantitative proof‑of‑effectiveness (replicated simulations, deltas against the confidence interval) from qualitative evidence (plans, protocols, inspection/maintenance programs, communications artifacts) and prescribes an integrated finding that synthesizes both—mirroring the approach shown in Appendix B. Although emergency personnel actions are not represented in the evacuation time or fire progression modeling, these actions would be expected to reduce evacuation times and slow fire progression. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 111 JUNE 2026 11.2 Looking Forward This WES gives the City (AFR, APD, Public Works/Traffic, Planning) a common set of data, assumptions, and tools. The traffic microsimulation with Dynamic Traffic Assignment and the fire progression analysis establish a shared baseline for operational planning, public messaging, and future design choices. The recommendations prioritize measures that deliver measurable evacuation time reductions and tangible risk reduction along likely fire pathways—while remaining pragmatic about feasibility, interagency coordination, and funding. The Study’s results and improvement deltas (e.g., time savings under a flush strategy) support near‑term operational adjustments (signal timing templates, activation protocols) and bolster the City’s justification for capital investments (signal interconnect, cameras, shoulder widening) and grant pursuits (fuel treatments, home‑hardening programs, outreach). Where larger structural changes are contemplated (e.g., interchange or connection concepts), this WES provides the technical rationale for concept development and partnership with Caltrans, OCTA, and adjacent jurisdictions. For project review, the methodology and thresholds supply a standard of practice that reduces analytic inconsistency, clarifies expectations for applicants, and strengthens the City’s findings. By requiring project‑specific modeling and re‑modeling with mitigation, and by documenting the qualitative mechanisms that reduce exposure (route reliability, defensibility, communications), the City can make well‑supported determinations of significance and mitigation effectiveness—and, when necessary, clearly identify and disclose significant and unavoidable effects with appropriate findings. The outreach summary demonstrates Anaheim Hills residents are motivated but need clarity on routes, timing, and roles—especially differences between alerts and orders, time required to get out the door, pet/large animal logistics, and how schools coordinate evacuations. The WES points to practical, high‑visibility improvements (zone‑specific signage, seasonal campaigns, drills) that make evacuation behavior more predictable and earlier, which is the single most effective “demand management” strategy available during a fast‑moving event. Wildfire is an enduring reality for Anaheim Hills; evacuation success hinges on prepared people, defensible places, and reliable corridors working in concert. This WES provides the City with a clear, defensible roadmap: it quantifies where and when strain appears, identifies which measures most effectively relieve evacuation times, and embeds those practices into a CEQA ‑ready evaluation framework. Implemented together, these strategies will reduce risk, speed clearance, and save lives —and will help Anaheim demonstrate leadership in wildfire‑resilient planning and operations. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 112 JUNE 2026 INTENTIONALLY LEFT BLANK DRAFT 17507 113 JUNE 2026 12 References California Code of Regulations, Title 24, 2022 California Fire Code. https://codes.iccsafe.org/content/ CAFC2022P1/california-code-of-regulations-title-24. Accessed August 2025. CAL FIRE (California Department of Forestry and Fire Protection). 2018. 2018 Incident Archive California Department of Forestry and Fire Protection. https://www.fire.ca.gov/incidents/2018. Accessed August 2025. CAL FIRE. 2020. 2020 Incident Archive California Department of Forestry and Fire Protection. https://www.fire.ca.gov/incidents/2020/. Accessed August 2025. CAL FIRE. 2022a. “Emergency Fund Fire Suppression Expenditures.” September 16, 2022. Accessed September 10, 2024. http://large.stanford.edu/courses/2022/ph240/chunduru1/docs/ calfire-28oct22.pdf. CAL FIRE. 2022b. California High Hazard Zones (Tier 1). June 2, 2022. https://hub-calfire-forestry.hub. arcgis.com/maps/a71a85136b0b414ea734fdfbe3d7674a/explore. CAL FIRE. 2025a. Top 20 Most Destructive California Wildfires. https://34c031f8-c9fd-4018-8c5a- 4159cdff6b0d-cdn-endpoint.azureedge.net/-/media/calfire-website/our-impact/fire-statistics/ top-20-destructive-ca-wildfires.pdf?rev=737a1073f76947b4a3bfb960b19f44c7&hash= 7CA02D30D9BF46A32D5D98BD108BA26A. Accessed August 2025 CAL FIRE. 2025b. Fire And Resource Assessment Program. https://www.fire.ca.gov/what-we-do/fire-resource- assessment-program. Accessed August 2025. CAL FIRE. 2025c. What We Do. https://www.fire.ca.gov/what-we-do. Accessed August 2025. City of Anaheim. 2017. Emergency Operations Plan. https://www.anaheim.net/DocumentCenter/ View/21657/City-of-Anaheim-EOP-2017 City of Anaheim. 2022. Local Hazard Mitigation Plan. https://www.anaheim.net/DocumentCenter/View/ 48820/Anaheim-LHMP-Plan-2022. Accessed August 2025. City of Anaheim. 2023. City General Plan; Safety Element. Accessed August 2025. City of Anaheim. 2024. Wildfire Mitigation Plan https://www.anaheim.net/DocumentCenter/View/55332/ 2024-Wildfire-Mitigation-Plan Accessed August 2025. City of Anaheim. 2025a. Anaheim Municipal Code. https://codelibrary.amlegal.com/codes/anaheim/latest/ anaheim_ca/0-0-0-86120. Accessed August 2025. City of Anaheim. 2025b. Anaheim Fire Code; Anaheim Municipal Code, Title 16, Fire. https://codelibrary.amlegal.com/ codes/anaheim/latest/anaheim_ca/0-0-0-63233. Accessed August 2025. DRAFT CITY OF ANAHEIM / WILDFIRE EVACUATION STUDY 17507 114 JUNE 2026 City of Anaheim. 2025c. City General Plan; Circulation Element. https://www.anaheim.net/DocumentCenter/ View/9520/D0-Circulation-Element?bidId=. Accessed August 2025. City of Anaheim. 2025. Community Emergency Response Team https://www.anaheim.net/887/ Community-Emergency-Response-Team-CERT Accessed August 2025. City of Anaheim. 2025 Preparing for Wildfire https://www.anaheim.net/5629/Preparing-for-Wildfire Accessed August 2025. FEMA (Federal Emergency Management Agency). 2025. How FEMA Works. https://www.fema.gov/about/ how-fema-works. Accessed August 2025. OCTA (Orange County Transportation Authority). 2021. Hazard Mitigation Plan https://www.octa.net/ pdf/OCTA_2021_HMP.pdf Accessed August 2025.State of California. 2024. Orange County. 2017. County-wide Community Wildfire Protection Plan https://occonservation.org/ wp-content/uploads/2017/05/CWPP-Draft-040617_Dont-Distribute.pdf Accessed August 2025. Orange Unified School District. 2017. Letter from the Superintendent’s Office: Update on Canyon Fire 2. Orange Unified School District. https://www.orangeusd.org/about-us/news/release-article/~board/2017/post/ letter-from-the-superintendents-office. Accessed February 2026. Weather Spark. 2026. Climate and Average Weather Year Round in Anaheim, California. https://weatherspark.com/ y/1828/Average-Weather-in-Anaheim-California-United-States-Year-Round DRAFT Appendix A Community Engagement Summary DRAFT DRAFT ANAHEIM HILLS WILDFIRE EVA CUATION STUDY COMMUNITY ENGAGEMENT SUMMARY To: David Kennedy, Corey Wilkerson From: Alison Sells, Austin Ott Subject: Anaheim Hills Wildfire Evacuation Study Community Workshop Summary Date: October 2025 Public outreach and engagement serve as a major component in the development of this Wildfire Evacuation Study by exposing the perceptions around evacuation that indicate opportunities for improvement in community outreach, education, and officials’ approach to evacuation. To engage as many individuals as possible within the Anaheim Hills community, 8,000 door hangers and 8,000 postcards were distributed to 16,000 residential units within Know Your Way Zones 1 through 15 with information about the Know You Way website, the online community survey, and upcoming in-person and virtual community workshops. This information was also shared on relevant City social media platforms and the community’s Anaheim Hills Buzz Facebook page. Community members were invited to provide input through participation in an 18-question online survey and/or attend one of four community workshops, two of which were offered virtually in order to encourage attendance. Overall, there were 250 responses to the online survey, 80 attendees at the in-person workshops, and 20 attendees at the virtual workshops. The community input collected through these outreach efforts directly informs the wildfire evacuation study and provides valuable insights for refining future public education and outreach initiatives. These findings also help identify gaps between public officials’ assumptions and the lived experiences and perceptions of the community. 1 Community Workshop Overview Four community workshops were held in July 2025 for the Anaheim Hills Wildfire Evacuation Study, two virtual and two in person. The virtual workshops were held on July 8 and July 30 via zoom. The in-person workshops were held on July 16, at the Anaheim Hills Golf Club, and July 21, at the East Anaheim Community Center. The four workshops had a total of 100 attendees, including 80 in person and 20 attending virtually. The workshops were hosted by Dudek Evacuation Planners and local agency representatives from the City of Anaheim including members from the Transportation, Fire, and Police departments. Attendees represented a variety of participants including homeowners, environmental groups, homeowner’s associations, and community groups. These workshops included a brief overview of the project followed by self-directed and active engagement activities aimed at garnering discussion and gaining input from community members. DRAFT MEMORANDUM SUBJECT: ANAHEIM HILLS WILDFIRE EVACUATION STUDY COMMUNITY WORKSHOP SUMMARY 17507 2 OCTOBER 2025 1.1 Self-Directed Activity The self-directed activity included three posters asking participants to answer the following questions: Question 1: What are the biggest potential obstacles preventing you from evacuating? Question 2: What actions have you taken to prepare for evacuation? Question 3: What risk reduction methods do you think should be a priority in your community? For the in-person workshops, participants were directed to posterboards, one for each of the questions above, and asked to identify their top answers to the above questions by placing a bead in a corresponding jar to record their answers. For the virtual workshops, participants were shown an image of the posterboard, one for each of the questions above, and asked to identify their top answers to the above questions via an in-meeting digital survey. Results Question 1: The first of the self-directed activity questions aims to understand what community members would identify as the biggest potential obstacles that would prevent them from evacuating. Options for responses included: ▪ Disability. ▪ Elderly loved ones at home. ▪ No access to transportation. ▪ Lack of adequate evacuation routes. ▪ No family evacuation plan is in place. ▪ I want to defend my home. ▪ Information needed. ▪ I do not have alternative housing. ▪ Other As shown in Exhibit 1, across all participants the three biggest obstacles identified for workshop participants included (1) lack of adequate evacuation routes, (2) not having a family evacuation plan in place, and (3) not having alternative housing once they evacuate. DRAFT MEMORANDUM SUBJECT: ANAHEIM HILLS WILDFIRE EVACUATION STUDY COMMUNITY WORKSHOP SUMMARY 17507 2 OCTOBER 2025 Exhibit 1. Responses to Evacuation Obstacles To address these obstacles, the City has multiple current and ongoing initiatives, including this Wildfire Evacuation Study that has evaluated the existing evacuation network, identified opportunities for improvement, and provides recommendations for funding and implementation to strengthen route capacity. To support households directly, the City’s Know Your Way program offers tailored resources to help families develop personal evacuation plans. Additionally, the City’s Emergency Operations Plan (EOP) outlines comprehensive strategies for mass care and sheltering, ensuring that residents have access to safe housing and essential services during an emergency. Together, these efforts aim to close the gaps identified by the community and build a more resilient, prepared population. Question 2: The second of the self-directed activity questions aims to understand what actions community members have taken to prepare for evacuation. Options for responses included: ▪ Looked up evacuation routes. ▪ Prepared a go-bag. ▪ Prepared a personal evacuation plan. ▪ Other As shown in Exhibit 2, across all participants the two most common preparedness actions included 1) looked up evacuation routes and 2) prepared a go-bag. DRAFT MEMORANDUM SUBJECT: ANAHEIM HILLS WILDFIRE EVACUATION STUDY COMMUNITY WORKSHOP SUMMARY 17507 3 OCTOBER 2025 Exhibit 2. Responses to Evacuation Preparation Activities Public safety during emergencies is a collective responsibility that requires coordinated action by both the City and its residents. The City has a fundamental duty to safeguard the community by planning, investing in infrastructure, and delivering essential services during disasters. This includes developing comprehensive emergency operations and evacuation plans, maintaining reliable transportation networks, and ensuring the availability of firefighting and law enforcement resources. These measures establish the framework for a safe and organized response when emergencies occur. At the same time, individuals play a critical role in their own preparedness and personal safety. Residents are responsible for creating household evacuation plans, assembling emergency supply kits, and staying informed about local hazards and official guidance. Programs such as the City’s Know Your Way initiative provide tools and resources to help families take these steps, reinforcing the importance of personal readiness. When individuals are prepared, the City’s emergency response can be more effective, as resources can be directed to those most in need. Question 3: The third of the self-directed activity questions aims to understand what community members would identify as priority risk reduction activity. Options for responses included: ▪ Evacuation route improvement. ▪ Public land fuels reduction. ▪ Roadside vegetation clearance. ▪ Public education. ▪ Invasive plant removal. ▪ Home hardening. ▪ Green waste disposal. ▪ Shaded fuel breaks. • Other DRAFT MEMORANDUM SUBJECT: ANAHEIM HILLS WILDFIRE EVACUATION STUDY COMMUNITY WORKSHOP SUMMARY 17507 2 OCTOBER 2025 As shown in Exhibit 3, across all participants, the three priority risk reduction activities identified were 1) improve evacuation routes, 2) roadside vegetation clearance, and 3) public lands fuel reduction. Exhibit 3. Responses to Risk Reduction Activities The improvement of evacuation routes such as widening, when possible, can increase the capacity of the roadways and logically allow the passage of more vehicles. However, constraints such as adjacent parcel ownership can often prohibit the ability to widen or add roadways. Similarly, while the City would face relatively low barriers to maintaining roadways for lands owned or controlled by the city, roadside clearance on privately owned properties can present greater challenges and would require a robust vegetation management/weed abatement program. The AFRD currently enforces 10 feet of roadside abatement via their Brush Clearance and Vegetative Growth Guideline, made enforceable by adoption into Anaheim Municipal Code via Section 16.08.020 which adopts and amends the California Fire Code. Such a program, supported through local ordinance, allows local officials to enforce and forcibly abate properties. Removing vegetative fuels from lands adjacent to roadways does harden roadways and prevent the possibility for fire progression through the community and evacuation route burn over. In order to establish the validity of the need for increased fuels reduction on Public Lands or along roadways, or otherwise evaluate effectiveness of current efforts, it would be advisable to conduct a Wildfire Risk Assessment of the various fuel types along private and public lands for their contribution to fire progression using GIS modeling such as Flammap or IFTDSS. Due to variances in slope and fuel type amongst various other contributing factors, fire modeling can aid in evaluating the effectiveness of roadside clearance and fuel break distances in order to DRAFT MEMORANDUM SUBJECT: ANAHEIM HILLS WILDFIRE EVACUATION STUDY COMMUNITY WORKSHOP SUMMARY 17507 3 OCTOBER 2025 prioritize finite city resources in a timely and cost-effective way. For example, while 10 feet of clearance from a roadway may be effective in grassy fuels, more may be necessary to separate evacuation routes from more dense fuels such as shrubs dependent upon wind and topography in that specific location. Further, 100 feet of defensible space along the community edge may be more than effective for certain fuel, topography, and wind alignment scenarios, but inadequate in other locations. Implementation of the existing CWPP would be effective for securing grant funding to implement such a Wildfire Risk Assessment and/or fuels reduction on publicly owned properties. 1.2 Evacuation Role Play To better understand behavioral aspects of evacuation in the local Anaheim Hills community, workshop attendees participated in an evacuation role-play exercise. During this role-play, participants were asked to consider a scenario in which they were home in the evening and issued an immediate evacuation order, then asked to respond to several prompts. To provide baseline, participants were asked how many minutes (e.g., 0-10 minutes, 10- 20 minutes, 20-30 minutes, etc.) it would take them to leave once they received an evacuation order. Once participants estimated how long it would take them to pack and leave after receiving an evacuation order, they were guided through potential steps one would take after receiving an evacuation order to prepare for evacuation. From a list of items, participants were asked to identify anything they would want to collect and take with them. The list included practical items, such as passports and medications to sentimental items, such as heirlooms and photographs. From the items participants identified for themselves, participants were asked to locate those items in their home, then asked to consider how long it would take them to gather and pack those items. Having now completed the role-play, participants were asked again to indicate how many minutes it would take them to leave if they received an evacuation order. Results When first asked to report how long it would take to depart after receiving an evacuation order, most participants reported it would take them between 20 and 30 minutes to depart. Although the average stayed the same before and after the activity, there was an increase in time reported to get ready for evacuation after conducting the activity with more respondents selecting between 30 and 40 minutes, between 40 and 50 minutes, between 50 and 60 minutes, or over 60 minutes. There were only a few participants whose answers indicated a decrease in time needed to prepare for an evacuation. The time that elapses between issuing an evacuation order and vehicles getting on the road is a key factor that adds meaningful context for emergency managers. Extended evacuation preparation windows underscore the importance of issuing evacuation orders, as does understanding historical evacuations. The Los Angeles fires of 2025 demonstrated that it is important to issue early evacuation alerts and orders and continue to expand those orders well ahead of the fire progression (McChrystal Group, 2025). Further, such delays further inform the discussion of evacuation times in Section 8 of this Wildfire Evacuation Study. 1.3 Community Discussions The community workshops included small group discussions, conducted in a roundtable format with small groups rotating to different discussion topics, each led by a facilitator from the Dudek Evacuation Planning Team and City of Anaheim transportation planners. The discussions were also guided by participation from representatives from Anaheim Fire and Rescue and the Anaheim Police Department. The group discussions were a key feature of the DRAFT MEMORANDUM SUBJECT: ANAHEIM HILLS WILDFIRE EVACUATION STUDY COMMUNITY WORKSHOP SUMMARY 17507 4 OCTOBER 2025 community workshops to learn more about the community members’ past experiences with evacuation and build upon the insights received from the public survey. The discussion groups were divided between two topics: Discussion Topic 1: Evacuation/Community Response Discussion Topic 2: Wildfire/Hazard Planning Each group discussed every topic with the responses from previous groups hidden at the start of each discussion section to allow for each group to think independently. These discussions were framed to have participants think about each topic in terms of challenges and opportunities that could either help or harm a community for an evacuation. Results The small group discussions revealed that residents are concerned about both the practical barriers to evacuation (mobility, pets, traffic capacity) and the systemic issues of communication and infrastructure strain. At the same time, community members expressed strong support for proactive measures, such as improved alerts, coordinated messaging, and infrastructure enhancements that can significantly improve safety and preparedness. These insights provide a critical foundation for shaping the City’s Wildfire Evacuation Plan and related emergency management strategies. Key Challenges Identified Community members highlighted several barriers that complicate effective evacuation and wildfire response: ▪ Timing and Communication: Uncertainty about when to leave and conflicting instructions between police and fire departments. ▪ Accessibility: Difficulty evacuating due to mobility limitations of self or loved ones, and challenges evacuating with pets. ▪ Access Restrictions: Concerns about being away when evacuation orders are issued and not being permitted to re-enter to retrieve pets or belongings. ▪ Infrastructure Limitations: Roads perceived as lacking capacity to handle evacuation traffic, compounded by new development pressures. ▪ Environmental Risks: Overgrown vegetation and worries about fire hydrant capacity, particularly considering past regional fires. Key Opportunities Identified Participants also identified opportunities to strengthen preparedness and community resilience: ▪ Enhanced Alerts and Outreach: Expanding Anaheim Alerts and the Know Your Way program, issuing earlier warnings, and focusing outreach through Homeowners Associations. ▪ Improved Evacuation Infrastructure: Adding alternative evacuation routes (notably the Mohler loop) and limiting new development in High Fire Hazard Severity Zones. ▪ Coordinated Messaging: Ensuring consistent communication between Fire and Police Departments to reduce confusion during evacuations. ▪ Vegetation and Infrastructure Management: Increasing vegetation enforcement, conducting regular fire hydrant maintenance, and hosting more informative community training. DRAFT MEMORANDUM SUBJECT: ANAHEIM HILLS WILDFIRE EVACUATION STUDY COMMUNITY WORKSHOP SUMMARY 17507 5 OCTOBER 2025 2 Community Survey The community survey ran from June to August 2025 and included 18 questions that covered the following topics: ▪ Participants’ past experiences with evacuations and evacuation priorities. ▪ How participants get their evacuation information. ▪ Challenges and opportunities to help improve participants’ experience with general emergency preparedness and future evacuations. The survey had 250 responses, with most of the participants self-reporting as living in Anaheim Hills (96%). Survey respondents represented all evacuation zones within Anaheim Hills with the most responses coming from Deer Canyon (Zone 4), Oak Canyon (Zone 5), and Ronald Reagan Park (Zone 2). When asked if they knew if their home was in a Very High Fire Hazard Severity Zone, 59% responded “Yes’. Additionally, when asked if they felt they had adequate insurance to cover hazards impacting their home, 48% said yes, with 23% reporting seeing higher premiums or risk of cancellation, and 13% saying their insurance would not be adequate for a disaster. Further, participants were asked the following questions: ▪ What is your greatest concern regarding a wildfire? ▪ What is the biggest obstacle that you foresee to evacuation? ▪ What are the most used information sources during an evacuation? ▪ What actions do you desire the city to take? 2.1 Greatest Wildfire Concerns When asked what their greatest wildfire concerns were, as shown in Exhibit 4, the top concerns were: Loss of home or other structure (89% of respondents), Evacuation (70% of respondents), and Injury or death (58% of respondents). This list of concerns may aid in guiding future public education and community outreach efforts. DRAFT MEMORANDUM SUBJECT: ANAHEIM HILLS WILDFIRE EVACUATION STUDY COMMUNITY WORKSHOP SUMMARY 17507 6 OCTOBER 2025 Exhibit 4. Responses to Greatest Wildfire Concerns 2.2 Greatest Barriers to Evacuation When asked what their greatest barriers to evacuation were, as shown in Exhibit 5 the top concerns were: Family members in separate places when needing to evacuate (45% of respondents), my neighborhood does not have adequate evacuation routes (44% of respondents), and Pets (42% of respondents). DRAFT MEMORANDUM SUBJECT: ANAHEIM HILLS WILDFIRE EVACUATION STUDY COMMUNITY WORKSHOP SUMMARY 17507 7 OCTOBER 2025 Exhibit 5. Responses to Greatest Barriers to Evacuation 2.3 Behavior Under an Evacuation Alert vs Evacuation Order Exhibit 6, below, demonstrates the respondent’s reported behaviors when asked how they would respond if given an evacuation alert versus an evacuation order. It is interesting to note that more respondents reported that they would immediately evacuate after receiving a warning than after receiving an order, potentially identifying a lack of understanding between the two notice types. DRAFT MEMORANDUM SUBJECT: ANAHEIM HILLS WILDFIRE EVACUATION STUDY COMMUNITY WORKSHOP SUMMARY 17507 8 OCTOBER 2025 Exhibit 6. Percent of respondents that would take each action after receiving an Evacuation Warning vs Evacuation Order 2.4 Evacuation Information Sources When asked what information sources residents most used regarding evacuation information, as shown in Exhibit 7, the top sources identified were Anaheim Alert (70% of respondents), social media (64% of respondents), and ReadyOC (45% of respondents). DRAFT MEMORANDUM SUBJECT: ANAHEIM HILLS WILDFIRE EVACUATION STUDY COMMUNITY WORKSHOP SUMMARY 17507 9 OCTOBER 2025 Exhibit 7. Responses to Evacuation Information Sources 2.5 Desired City Actions When asked what Actions the respondents want the City to take to help community members become better prepared for a disaster, as shown in Exhibit 8, Provide effective emergency notifications and communication (72% of respondents), and Provide community outreach regarding emergency preparedness (52% of respondents). DRAFT MEMORANDUM SUBJECT: ANAHEIM HILLS WILDFIRE EVACUATION STUDY COMMUNITY WORKSHOP SUMMARY 17507 10 OCTOBER 2025 Exhibit 8. Responses to Desired City Actions In response to the evacuation challenges experienced during the 2017 Canyon II Fire, the city has created the Know Your Way Program. Further, the City has requested this Wildfire Evacuation Study to better understand the nuances around evacuation in Anaheim. The results and findings of this WES aim to inform local officials and emergency managers on community needs, these expressed desires, and guide evacuation alerts and orders by providing context around potential events. 2.6 Additional Comments When asked if there was anything else people wanted to share, the following were the top answers: ▪ Police should be controlling traffic more during evacuations. ▪ Respondents feel streets are already too crowded and that the city should not allow more high- density apartments. ▪ Respondents want an analysis of road closures to promote getting Anaheim Hills traffic out (91 and 55 freeways) ▪ Respondents want more vegetation management on city owned property, especially on evacuation routes. DRAFT MEMORANDUM SUBJECT: ANAHEIM HILLS WILDFIRE EVACUATION STUDY COMMUNITY WORKSHOP SUMMARY 17507 11 OCTOBER 2025 3 Community Outreach Summary and Key Takeaways As part of the Anaheim Hills Wildfire Evacuation Study, the City and project team implemented a robust community outreach and engagement program designed to understand resident experiences, concerns, and priorities regarding wildfire evacuation. Outreach Methods included citywide notifications distributing 8,000 doorhangers and 8,000 postcards to 16,000 residential units across Know Your Way Zones 1–15 along with promoting information through City social media channels and the Anaheim Hills Buzz Facebook group. Recipients of these notices were asked to attend a virtual or in person workshop and complete an 18-question online community survey open from June to August 2025. The Project team received 250 survey responses, with 96% of responses being from Anaheim Hills residents and representing all evacuation zones. The four Community Workshops included two virtual workshops and two in-person workshops. Total workshop attendance reached 100 participants including 80 in person and 20 virtual. Workshops were facilitated by Dudek Evacuation Planners and City of Anaheim representatives, with participation from homeowners, local agencies, HOAs, environmental groups, and community organizations. Key takeaways from these efforts include concerns about preparedness including lacking a family evacuation plan and not having a clear idea where they would go or stay after evacuating, despite many participants saying they had reviewed evacuation routes and prepared a gobag. While respondents advised that they knew they could gather evacuation information via Anaheim Alert, Social Media, or ReadyOC, there were concerns about the consistency of messaging across multiple platforms and apparent confusion between the implications of evacuation alerts versus evacuation orders. Residents also believe roadway capacity is insufficient for evacuation traffic and would like to see improvement of evacuation routes in the form of increased capacity or, at the very least, roadside evacuation clearing. Finally, residents most want the City to improve emergency notifications and communication, expand education on emergency preparedness, and conduct more vegetation management, especially along evacuation corridors. The community data gathered through these outreach efforts were incorporated into this wildfire evacuation study as appropriate and can prove beneficial to city staff by informing future public education/outreach campaigns and being utilized to evaluate the effectiveness of prior campaigns. This data is also helpful in identifying dissonance between the understandings held by public officials and the perceptions of the public that they serve. While some of the issues brought forth by the public are being analyzed in this wildfire evacuation study, other concerns may implore city departments to evaluate the effectiveness of existing programs such as vegetation clearance programs that various respondents implied were lacking. DRAFT Appendix B Anaheim Hills Fire Evacuation Analysis DRAFT DRAFT 3900 5th Avenue, Suite 310 San Diego, CA 92103 619-795-6086 www.CRAmobility.com TO: David Kennedy, City of Anaheim FROM: Phuong Nguyen, CR Associates DATE: 5/12/2026 RE: Anaheim Hills Fire Evacuation Analysis ATTACHMENTS: 1 – Methodology for Developing and Evaluating Quantitative Threshold 2 – Scoping Criteria This memorandum presents the results of a wildfire evacuation analysis conducted for the Anaheim Hills study area to evaluate the ability of the existing transportation network to accommodate emergency evacuation demand under a range of conservative yet plausible wildfire scenarios. The analysis is intended to support emergency planning and CEQA impact evaluation by examining evacuation performance, clearance times, and system sensitivity to different evacuation management strategies, traffic control assumptions, and land use conditions, while holding the roadway network configuration constant. Consistent with guidance from the California Office of Planning and Research, the California Attorney General’s Wildfire Guidance, Appendix Q of the California Fire Code, and local Emergency Operations Plans, multiple scenarios were evaluated, including both highly conservative catastrophic evacuations and more operationally realistic, area-specific wildfire events that incorporate phased evacuation, shadow evacuation behavior, and early evacuation by vulnerable populations. Together, these scenarios are designed to bound potential evacuation outcomes while reflecting observed evacuation behavior and best practices from recent Southern California wildfire events. Evacuation Scenario Framework and Assumptions To evaluate evacuation performance under a range of plausible emergency conditions, a series of evacuation scenarios were developed representing both conservative worst-case events and more realistic, area-specific wildfire evacuations. The scenarios reflect differences in land use conditions (Existing and Cumulative), evacuation type, geographic extent, and expected public response. Together, they are intended to bound potential evacuation outcomes while remaining consistent with guidance from the California Office of Planning and Research, the California Attorney General’s Wildfire Guidance, and local Emergency Operations Plans. Two evacuation types are evaluated. Catastrophic scenarios assume an immediate, areawide evacuation order and represent a highly conservative, low-probability but high-consequence condition used to establish an upper bound on evacuation demand and clearanc e times. Area-specific wildfire scenarios reflect operationally realistic evacuation management, with evacuation orders issued in phases based on proximity to the fire perimeter, anticipated fire behavior, and roadway capacity constraints. Phased evacuation is implemented through staggered evacuation timing by zone. Immediate Evacuation Zones represent areas under direct and imminent threat and are assumed to evacuate at the start of the simulation. Ten-minute and one-hour evacuation zones represent areas where evacuation orders are intentionally delayed to manage traffic demand, prioritize emergency access, and reduce system-wide congestion. This approach reflects current wildfire evacuation practices and avoids the unrealistic assumption of simultaneous mass evacuation. DRAFT Anaheim Hills Evacuation Analysis Page | 2 Technical Memorandum Behavioral response assumptions were also incorporated. Shadow evacuees are included in select zones to represent households that voluntarily evacuate despite not being under an official evacuation order, a well-documented response during wildfire events. Shadow evacuation demand is applied as a percentage of the population in designated zones to conservatively capture this behavior without overstating demand. Special consideration was given to senior populations. Based on U.S. Census data, residents aged 65 and older represent approximately 20 percent of the study area population. Public outreach and survey responses from senior residents indicated a heightened likelihood of early evacuation due to health concerns, particularly the potential for wildfire smoke to exacerbate existing respiratory or cardiovascular conditions. As a result, the analysis assumes that seniors evacuate earlier in select phased evacuation scenarios, even where the broader population is not subject to an immediate evacuation order. This assumption reflects an abundance-of-caution response and ensures that vulnerable populations are appropriately represented in the evacuation analysis. Evacuation Vehicles Assumption This evacuation analysis evaluates the ability of the study area transportation network to accommodate emergency evacuation demand under worst-case conditions. Consistent with State guidance and CEQA best practices for wildfire evacuation analysis, the methodology intentionally applies conservative assumptions to ensure that results are protective of public safety and suitable for emergency planning purposes. The analysis assumes that all residents within the study area are present at home at the time evacuation orders are issued. This represents the most conservative assumption because it generates the maximum potential evacuation demand. In reality, a portion of the population may be away from home due to work, school, or other activities; however, assuming full residential occupancy provides an upper-bound estimate of vehicle demand and allows the roadway network to be evaluated under the most demanding and stress-tested conditions. Table 1 summarizes the land use inventory used to inform evacuation demand, including residential units, non-residential land uses by square footage, and the presence of congregate care facilities within each evacuation zone. While congregate care facilities are identified in the inventory, they were not explicitly modeled as a separate evacuation population in the quantitative analysis. This is due to the lack of publicly available, facility-specific information regarding resident counts, staffing levels, vehicle availability, evacuation timing, and operational protocols, all of which are necessary to accurately model congregate care evacuation behavior. Congregate care facilities are subject to State of California regulations and typically operate under facility-specific emergency and evacuation plans that differ substantially from those of the general population. Evacuations from these facilities often involve pre-arranged transportation, medical support, phased movement of residents, and coordination with local emergency responders. Because these procedures are highly individualized and not publicly disclosed, incorporating them into a generalized evacuation traffic model would introduce uncertainty and could misrepresent actual operations. Accordingly, the evacuation analysis presented herein focuses on the general residential population under worst-case occupancy conditions. It is recommended that the City separately coordinate with congregate care facility operators and relevant emergency management agencies to develop contingency plans tailored to these facilities. Such planning would complement the findings of this analysis and help ensure that the unique needs of congregate care populations are addressed through targeted, facility-specific evacuation strategies. DRAFT Anaheim Hills Fire Evacuation Analysis Page | 3 Technical Memorandum Table 1 - Evacuation Area Statistic Zone Residential (Units) Auto Commercial (SF) General Commercial (SF) Industrial (SF) Office (SF) Hotel (SF) Recreational (SF) Religious Facilities (SF) Congregate Care (Beds) 1 1,882 0 0 0 129,000 0 0 0 0 2 1,920 0 0 0 0 0 0 0 0 3 490 0 0 0 0 0 0 0 6 4 1,970 0 0 0 0 0 0 0 0 5 1,478 0 43,000 0 19,000 0 32,910 0 6 6 1,530 0 29,000 0 0 0 1,479 0 120 7 822 0 0 0 0 0 0 0 6 8 1,649 10,000 1,308,000 0 25,000 28,135 36,860 0 0 9 531 0 23,000 0 0 0 0 13,325 0 10 820 0 157,000 0 0 0 6,259 8,972 266 11 589 0 4,000 0 5,000 0 18,033 0 117 12 1,518 0 165,000 0 44,000 0 0 0 6 13 1,282 20,000 635,000 97,000 98,000 0 0 0 0 14 310 0 84,000 0 0 0 0 0 0 15 1,222 6,000 207,000 0 0 0 0 0 6 DRAFT Anaheim Hills Fire Evacuation Analysis Page | 4 Technical Memorandum Modeling Assumptions and Dynamic Traffic Assignment Evacuation scenarios were modeled using PTV Vissim with Dynamic Traffic Assignment (DTA) enabled. DTA is a routing methodology in which vehicles dynamically select routes based on prevailing and evolving traffic conditions, rather than following fixed, pre-defined paths. As congestion builds, vehicles may divert to alternate routes with lower travel times, reflecting the adaptive and often unpredictable routing behavior observed during real-world evacuation events. In an evacuation context, DTA is particularly important because traffic conditions change rapidly as large volumes of vehicles enter the network simultaneously. Roadway bottlenecks, queue spillback, and downstream congestion influence route choice in real time. By allowing vehicles to respond to these conditions, DTA provides a more realistic representation of evacuation flow compared to static or fixed-route assignment methods. When a DTA-based model is first run, route choices are initially uncalibrated and may not reflect stable or optimal evacuation patterns. Early iterations often exhibit unrealistic routing, excessive congestion on certain links, or inefficient use of available network capacity. As the model is iterated, Vissim updates perceived travel costs and redistributes traffic accordingly. Model convergence occurs when successive simulation runs produce consistent routing patterns and stable evacuation times, indicating that vehicles have settled into equilibrium routes given network constraints. In the context of evacuation modeling, convergence reflects a stabilized evacuation process in which congestion patterns, queue formation, and clearance times no longer fluctuate materially between runs. Once the model achieved convergence, each scenario was simulated across 20 independent runs to account for stochastic variability and to stabilize the evacuation time estimates. Evacuating Vehicle Demand Assumptions The number of evacuating vehicles is a critical input to the evacuation analysis, as it directly influences roadway congestion, clearance times, and overall evacuation performance. To ensure that the analysis reflects worst-case and highly conservative conditions, vehicle demand was developed using assumptions informed by observed behavior during recent and historical wildfire evacuations in Southern California and elsewhere in the state. Experience from these events indicates that evacuees in auto-oriented communities with high vehicle ownership rates often attempt to evacuate using all available household vehicles. This behavior is driven by concerns over personal safety, property protection, uncertainty regarding evacuation duration, and the desire to retain mobility once displaced. As a result, evacuation vehicle demand can substantially exceed typical daily travel assumptions and household trip generation rates. Based on local and regional data, the average vehicle ownership within the study area is approximately 3.4 vehicles per household. Applying this ownership rate to the total number of residential units and assuming that each household evacuate with all available vehicles yields an estimated evacuation demand of approximately 61,000 vehicles under a full-occupancy, worst-case scenario. This assumption represents the upper bound of potential evacuation demand and significantly exceeds what would be expected under normal travel conditions or more moderate behavioral assumptions. Table 2 displays the number of evacuating vehicles by zone. DRAFT Anaheim Hills Fire Evacuation Analysis Page | 5 Technical Memorandum Table 2 - Evacuation Vehicles by Evacuation Zone Zone Residential (Units) Evacuating Vehicles 1 1,882 6,399 2 1,920 6,528 3 490 1,666 4 1,970 6,698 5 1,478 5,025 6 1,530 5,202 7 822 2,795 8 1,649 8,0001 9 531 1,805 10 820 2,788 11 589 2,003 12 1,518 5,161 13 1,282 4,359 14 310 1,054 15 1,222 4,155 Total 18,013 61,245 Evacuation Scenarios The evacuation scenarios were deliberately developed to guide the analysis from a highly conservative, worst-case planning condition to more operationally realistic, data-driven wildfire evacuation scenarios grounded in fire science and observed emergency response practices. The scenario selection process began with catastrophic, area-wide evacuation assumptions intended to establish an upper bound on evacuation demand and clearance times under low-probability but high-consequence conditions. These scenarios assume immediate evacuation across the entire study area and are used to stress - test the existing transportation network and provide a conservative benchmark for comparison. The analysis includes six different scenarios; they are as follows: Scenario 1 – Existing Conditions, Catastrophic Evacuation Scenario 1 represents a highly conservative, catastrophic evacuation event under existing land use conditions. An immediate, areawide evacuation is assumed for all zones, with no phased evacuation timing. All residents within the study area are assumed to evacuate simultaneously at the start of the simulation. No shadow evacuation or senior-only evacuation assumptions are applied because the entire study area is subject to a mandatory evacuation order. This scenario establishes an upper bound on evacuation demand and clearance time. Scenario 2 – Existing Conditions, Catastrophic Evacuation Scenario 2 mirrors Scenario 1 and represents an immediate, areawide catastrophic evacuation under existing land use conditions. All zones are assumed to evacuate simultaneously with no phasing and no differentiated behavioral assumptions. This scenario is included to support sensitivity testing and comparative analysis and similarly represents a conservative bounding condition. 1 Including Anaheim Hills Festival Center & Movie Theater DRAFT Anaheim Hills Fire Evacuation Analysis Page | 6 Technical Memorandum Scenario 3 – Wildfire Scenario 1: SR-241 Fire (Existing Conditions) Scenario 3 represents an area-specific wildfire evacuation associated with a fire near the SR-241 corridor under existing land use conditions. Evacuation is implemented in phases to reflect operational wildfire response practices. Zones 1 and 2 are assumed to receive an immediate evacuation order due to their proximity to the fire perimeter. Zones 3 and 5 are assumed to evacuate after a 10-minute delay, while Zone 6 evacuates after a one-hour delay. Shadow evacuation is assumed in Zones 4 and 8, with 50 percent of the population evacuating voluntarily in advance of a formal order. In addition, senior-only evacuation is assumed in Zones 9 and 10, with 20 percent of the population evacuating early to reflect the higher propensity of seniors to evacuate due to smoke-related health concerns. Scenario 4 – Wildfire Scenario 2: E Nohl Ranch Fire (Existing Conditions) Scenario 4 represents an area-specific wildfire evacuation associated with a fire near the E Nohl Ranch area under existing land use conditions. Zone 6 is assumed to receive an immediate evacuation order, while Zone 7 is assumed to evacuate after a 10-minute delay. No one-hour evacuation zones are assumed for this scenario. Shadow evacuation is assumed in Zones 3, 5, 10, 11, and 12, with 50 percent of the population in each zone evacuating voluntarily. No senior-only evacuation zones are assumed in this scenario, reflecting localized fire conditions and evacuation priorities. Scenario 5 – Wildfire Scenario 3: Deer Canyon Park Fire (Existing Conditions) Scenario 5 represents an area-specific wildfire evacuation associated with a fire near Deer Canyon Park under existing land use conditions. Zones 8 and 9 are assumed to receive immediate evacuation orders. Zone 4 is assumed to evacuate after a 10-minute delay, while Zones 5 and 10 are assumed to evacuate after a one-hour delay. Shadow evacuation is assumed in Zones 11 and 13, with 50 percent of the population evacuating voluntarily. In addition, senior-only evacuation is assumed in Zones 1, 2, 3, and 6, with 20 percent of the population evacuating early to reflect health-based evacuation decisions among senior residents. Scenario 6 – Wildfire Scenario 3: Deer Canyon Park Fire (Cumulative Conditions) Scenario 6 mirrors Scenario 5 in terms of evacuation phasing, geographic extent, shadow evacuation assumptions, and senior-only evacuation assumptions but reflects cumulative land use conditions. The scenario isolates the effect of future growth on evacuation performance while maintaining consistent evacuation management assumptions. Immediate evacuation is assumed for Zones 8 and 9, followed by a 10-minute evacuation for Zone 4 and a one-hour evacuation for Zones 5 and 10. Shadow evacuation is assumed in Zones 11 and 13 at 50 percent, and senior-only evacuation is assumed in Zones 1, 2, 3, and 6 at 20 percent. For each scenario, the table identifies zones assumed to evacuate immediately, within 10 minutes, or within one hour, as well as areas where limited “shadow evacuation” is expected based on observed community behavior. In select scenarios, early evacuation by a portion of the senior population is included to account for heightened health vulnerability and precautionary response. The table also indicates whether traffic signals are assumed to operate without control or under a standard traffic plan. While the scenarios represent reasonable planning assumptions, the development and implementation of a formal emergency evacuation plan would further enhance evacuation operations; potential measures to improve performance are discussed later in this report. Table 3 summarizes the key assumptions for each evacuation scenario, and because each scenario applies different evacuation areas, phasing strategies, and population response assumptions, the resulting evacuation vehicle demand varies by scenario, as summarized in Table 4. DRAFT Anaheim Hills Fire Evacuation Analysis Page | 7 Technical Memorandum Figures 1 through Figure 3 present graphical depictions of the assumed fire perimeters and corresponding evacuation assumptions for Scenarios 3 through 6. DRAFT Anaheim Hills Fire Evacuation Analysis Page | 8 Technical Memorandum Table 3 - Evacuation Scenario Assumption Summary Scenario ID Scenario Name Land Use Assumed Evacuation Type Immediate Evacuation Evacuating Within 10 Minutes Evacuating Within 1 Hour Shadow Evacuation Areas Senior-Only Early Evacuation Traffic Control 1 Existing Conditions – No Signal Control Existing Catastrophic All Zones N/A N/A Adjacent Zones in City of Orange N/A None 2 Existing Conditions – Standard Signal Control Existing Catastrophic All Zones N/A N/A Adjacent Zones in City of Orange N/A Standard Plan 3 Wildfire Scenario 1 – SR-241 Fire Existing Area-Specific Zones 1, 2 Zones 3, 5 Zone 6 Zones 4, 8 (50% evacuate) Zones 9, 10 (20% evacuate) Standard Plan 4 Wildfire Scenario 2 – East Nohl Ranch Fire Existing Area-Specific Zone 6 Zone 7 N/A Zones 3, 5, 10, 11, 12 (50% evacuate) None Standard Plan 5 Wildfire Scenario 3 – Deer Canyon Park Fire Existing Area-Specific Zones 8, 9 Zone 4 Zones 5, 10 Zones 11, 13 (50% evacuate) Zones 1, 2, 3, 6 (20% evacuate) Standard Plan 6 Wildfire Scenario 3 – Deer Canyon Park Fire Cumulative (Future Growth) Area-Specific Zones 8, 9 Zone 4 Zones 5, 10 Zones 11, 13 (50% evacuate) Zones 1, 2, 3, 6 (20% evacuate) Standard Plan DRAFT Anaheim Hills Fire Evacuation Analysis Page | 9 Technical Memorandum Table 4 - Evacuation Vehicle Demand and Signal Timing Assumptions by Scenario Zone / Signal Plan Type Scenario 1 – Existing Conditions, Catastrophic Evacuation Scenario 2 – Existing Conditions, Catastrophic Evacuation Scenario 3 – Wildfire Scenario 1: SR-241 Fire (Existing Conditions) Scenario 4 – Wildfire Scenario 2: E Nohl Ranch Fire (Existing Conditions) Scenario 5 – Wildfire Scenario 3: Deer Canyon Park Fire (Existing Conditions) Scenario 6 – Wildfire Scenario 3: Deer Canyon Park Fire (Cumulative Conditions) Flashing Red Standard Standard Standard Standard Standard 1 6,399 6,399 6,399 0 1280 1280 2 6,528 6,528 6,528 0 1306 1306 3 1,666 1,666 1,666 833 333 333 4 6,698 6,698 3349 0 6,698 6698 5 5,025 5,025 5,025 2513 5,025 5025 6 5,202 5,202 5,202 5,202 1040 1040 7 2,795 2,795 0 2,795 0 0 8 8,000 8,000 4,000 0 8,000 8,400 9 1,805 1,805 361 0 1,805 1805 10 2,788 2,788 558 1394 2,788 2788 11 2,003 2,003 0 1002 1002 1002 12 5,161 5,161 0 2581 0 0 13 4,359 4,359 0 0 2180 2180 14 1,054 1,054 0 0 0 0 15 4,155 4,155 0 0 0 0 Total 61,245 61,245 31,892 16,320 29,064 31,500 DRAFT Anaheim Hills Fire Evacuation Analysis Page | 10 Technical Memorandum Figure 1 - Scenario 3 (Main Report Scenario 1) – Wildfire Scenario 1: SR-241 Fire (Existing Conditions) DRAFT Anaheim Hills Fire Evacuation Analysis Page | 11 Technical Memorandum Figure 2 - Scenario 4 (Main Report Scenario 2) – Wildfire Scenario 2: E Nohl Ranch Fire (Existing Conditions) DRAFT Anaheim Hills Fire Evacuation Analysis Page | 12 Technical Memorandum Figure 3 - Scenario 5 & 6 (Main Report Scenario 3) – Wildfire Scenario 3: Deer Canyon Park Fire (Existing Conditions) DRAFT Anaheim Hills Fire Evacuation Analysis Page | 13 Technical Memorandum Analysis Results Evacuation analysis results for each evaluated scenario are presented below, with each discussion identified by the corresponding scenario name in parentheses. Reported evacuation times and performance measures are based on outputs from the PTV Vissim models after each scenario achieved convergence under Dynamic Traffic Assignment. As described in the methodology, convergence indicates that routing patterns, congestion conditions, and evacuation clearance times stabilized across successive simulation runs; accordingly, the results represent consistent and reliable estimates of evacuation performance under the assumed worst-case conditions for each scenario. For scenarios that include phased evacuation, the total evacuation time reflects the elapsed time from the start of the evacuation overall, not the time at which individual zones are assumed to begin evacuating. A summary of evacuation results is provided in Table 5. The catastrophic evacuation scenarios (Scenarios 1 and 2) establish an upper bound on evacuation clearance times by assuming an immediate, areawide evacuation with no phasing. These scenarios generate the highest levels of congestion and the longest evacuation times, reflecting low-probability but high-consequence conditions. Differences between these catastrophic scenarios further illustrate the importance of traffic signal operations, as maintaining commuter-oriented signal phasing can materially degrade evacuation performance relative to more neutral or adaptive control strategies. The area-specific wildfire scenarios (Scenarios 3 through 6) demonstrate that phased evacuation materially improves system performance by staggering demand and prioritizing zones under the greatest immediate threat. Delaying evacuation orders for lower-risk areas reduces peak congestion, improves network utilization, and shortens evacuation times for critical zones. The inclusion of shadow evacuees and early evacuation by senior populations increases realism while remaining conservative, and results indicate that these behaviors can be accommodated when evacuation phasing is properly implemented. Comparison of existing and cumulative land use conditions within the area-specific wildfire scenarios (Scenarios 5 and 6) indicates that future growth can increase evacuation times in certain locations, particularly where added demand compounds existing bottlenecks or constrained roadway segments. However, the results also show that these increases are not uniform across the study area and are strongly influenced by evacuation management strategies. Potential mitigation measures to further improve evacuation performance and system resilience are discussed below and include a combination of operational, technological, and programmatic approaches that may be applied individually or cumulatively to address evacuation needs. Some potential mitigation measures are provided below. Traffic Operations and Signal Control Improvements Implement operational and technology-based improvements to enhance traffic management during evacuation events. These measures would include enhanced connectivity between traffic signals and the Traffic Management Center (TMC), supported by redundant communication pathways to ensure continuous signal control and coordination during emergencies. Improved connectivity would enable rapid activation of evacuation-specific traffic signal timing plans that prioritize outbound movements from high-risk areas, reduce conflicting movements, and improve traffic flow at critical intersections along designated evacuation routes. DRAFT Anaheim Hills Fire Evacuation Analysis Page | 14 Technical Memorandum Evacuation Capacity Improvements at Intersections and Roadways Improving evacuation performance is not solely a function of increasing overall roadway capacity, but also of enhancing the City’s ability to actively manage and prioritize traffic flow during emergency conditions. Strategic intersection and roadway improvements can provide smoother evacuation operations, reduce friction points, and allow traffic control strategies to be focused on areas facing the greatest risk. These improvements are particularly important in evacuation scenarios where downstream congestion, limited access points, or constrained neighborhood circulation can materially affect clearance times. The City should continue to identify opportunities to both increase effective evacuation capacity and strengthen operational control over the transportation network during emergency events. Emphasis should be placed on corridors and intersections that serve higher-risk neighborhoods, provide critical outbound connectivity, or function as gateways between local streets and the regional roadway system. Improvements that support reversible operations, emergency-only use, or enhanced signal control can significantly improve evacuation performance without requiring continuous full-time roadway expansion. Potential evacuation capacity and control improvements include the following: • Fairmont Boulevard between South Old Bridge Road and Via Aboles This segment currently operates as a single lane in each direction and appears to have sufficient right of way to support increased evacuation capacity. Opportunities include widening to provide two lanes in each direction or constructing buffered bicycle lanes in each direction. Under emergency conditions, buffered bicycle lanes could be temporarily repurposed as additional evacuation lanes. Given that evacuation objectives are focused on moving vehicles out of the hazard area, providing two northbound lanes, or one northbound lane supplemented by a buffered bicycle lane usable for evacuation, would be a reasonable and targeted alternative. • South Fairmont Boulevard and East Canyon Rim Road Installation of a traffic signal at this intersection would improve the City’s ability to manage evacuation traffic and regulate competing movements. Connecting the signal to the City’s Traffic Management Center would allow for real-time monitoring, coordination with adjacent signals, and implementation of evacuation-specific timing plans that prioritize outbound movements from higher-risk areas. • South Country Hill Road and South Bridge View Drive The City should evaluate the feasibility of creating an emergency evacuation roadway connection between these two streets using an existing utility easement located near the southern end of South Bridge View Drive. If feasible, this connection could provide an additional evacuation outlet for the surrounding neighborhood and reduce reliance on a limited number of access points. In conjunction with this improvement, installation of a traffic signal at South Fairmont Boulevard and South Old Bridge Road should be considered to facilitate controlled and efficient evacuation of traffic from the South Country Hill Road area. Evacuation Wayfinding and Traveler Information Systems Deploy evacuation-specific digital wayfinding and traveler information systems to improve communication with evacuees and support coordinated evacuation behavior. These systems would provide clear, real-time guidance on recommended evacuation routes, reduce unnecessary circulation and localized congestion, and decrease reliance on cellular communication networks, which may become congested or unreliable during large-scale evacuation events. Wayfinding improvements DRAFT Anaheim Hills Fire Evacuation Analysis Page | 15 Technical Memorandum would be focused on key decision points, evacuation route entrances, and areas with a high potential for discretionary or precautionary evacuation traffic. Programmatic Evacuation Mitigation Fee Framework Establish a programmatic evacuation mitigation framework, modeled after best practices used in Vehicle Miles Traveled (VMT) mitigation programs adopted by California jurisdictions, to address cumulative evacuation impacts over time. Under this framework, new development would contribute to a dedicated evacuation and emergency transportation mitigation program through proportional mitigation fees. Fees would be assessed based on dwelling units or equivalent measures of project intensity, reflecting each project’s contribution to evacuation demand and systemwide stress. Funds collected through the mitigation program would be pooled and applied to prioritized, systemwide improvements that directly enhance evacuation performance and emergency response capacity. Eligible improvements could include traffic signal timing upgrades, physical roadway or intersection improvements at identified evacuation bottlenecks, expansion of evacuation-specific wayfinding infrastructure, enhancements to TMC operations and communications redundancy, and acquisition of additional firefighting equipment and personnel to support evacuation operations. DRAFT Anaheim Hills Fire Evacuation Analysis Page | 16 Technical Memorandum Table 5 - Summary of Evacuation Time by Scenario and Zone Scenario Scenario 1 – Existing Conditions, Catastrophic Evacuation Scenario 2 – Existing Conditions, Catastrophic Evacuation Scenario 3 – Wildfire Scenario 1: SR-241 Fire (Existing Conditions) Scenario 4 – Wildfire Scenario 2: E Nohl Ranch Fire (Existing Conditions) Scenario 5 – Wildfire Scenario 3: Deer Canyon Park Fire (Existing Conditions) Scenario 6 – Wildfire Scenario 3: Deer Canyon Park Fire (Cumulative Conditions) Total Evacuating Vehicles 61,245 61,245 31,892 16,320 29,064 31,500 Zone Evacuation Time (Hour : Minute) Zone1 8:19 9:22 5:49 N/A 3:40 3:40 Zone 2 9:30 10:58 7:14 N/A 3:45 3:47 Zone 3 8:09 8:15 4:55 3:37 1:28 1:30 Zone 4 10:05 12:16 7:02 N/A N/A N/A Zone 5 8:19 9:50 6:54 4:27 N/A N/A Zone 6 7:55 8:43 7:14 5:38 1:56 2:04 Zone 7 2:06 1:56 N/A 1:48 N/A N/A Zone 8 9:23 12:16 6:22 N/A 3:58 6:02 Zone 9 6:23 6:26 1:12 N/A 3:37 3:40 Zone 10 7:46 7:42 2:00 2:28 N/A N/A Zone 11 4:35 7:29 N/A 3:28 2:24 2:24 Zone 12 3:47 4:08 N/A 2:48 N/A N/A Zone 13 9:11 10:15 N/A N/A 4:28 4:28 Zone 14 1:57 2:56 N/A N/A N/A N/A Zone 15 5:05 4:16 N/A N/A N/A N/A DRAFT Anaheim Hills Fire Evacuation Analysis Page | 17 Technical Memorandum Attachment A - Methodology for Determining and Evaluating Quantitative Threshold Determining whether a fire evacuation would result in a significant impact requires careful consideration of the inherent uncertainty and context-sensitivity of evacuation conditions. Evacuation times and performance thresholds are highly sensitive to localized factors, particularly human behavior under stress. While public outreach and survey results indicate that many respondents are aware of wildfire risks and generally understand evacuation expectations, the survey sample represents only a subset of the total population. Actual evacuation performance may therefore diverge from modeled assumptions due to factors such as noncompliance with law enforcement direction, delayed decision-making, or discretionary behavior. In addition, precautionary or health-driven evacuations can generate unintended secondary effects. For example, a household with a history of respiratory illness located outside a formal evacuation zone may choose to evacuate early due to smoke concerns and simultaneously attempt to retrieve a child from El Rancho Charter, which is not under evacuation. If multiple households behave similarly, increased traffic volumes near the school can create congestion at key intersections that also serve as access points for the designated evacuation area, thereby degrading overall evacuation efficiency despite those trips originating outside the evacuation zone. A review of historical wildfire evacuation performance in California, as documented in the peer- reviewed literature, demonstrates that successful evacuations have occurred across a wide range of clearance times. Research synthesizing evacuation outcomes from major California wildfires indicates that evacuation times commonly range from approximately two hours to as much as eight hours, with several evacuations at the upper end of this range executed successfully under appropriate emergency management conditions (e.g., timely warnings, phased evacuations, and traffic control) (eScholarship, University of California, Wildfire Evacuation Case Studies and Clearance Time Variability). These findings underscore that evacuation time alone is not a definitive indicator of significance; rather, its acceptability depends on context, including fire behavior, warning time, roadway constraints, and operational response. This inherent variability in evacuation performance is not unique to historical case studies; it is also present in resident behavior and in day-to-day traffic conditions. Community workshop survey data collected from Anaheim Hills residents illustrates the degree to which mobilization time estimates vary even within the same neighborhood: self-reported departure times spanned a 30-minute range across respondents, with a coefficient of variation of 41 percent, and individual estimates shifted by as much as 50 minutes between two polls administered within the same session. Similarly, observed weekday traffic data from PeMS station VDS 1208176 on SR-91 shows that under ordinary (non-emergency) conditions, hourly volumes fluctuate by 14 to 23 percent from day to day across the AM peak, midday, PM peak, and evening periods. These patterns confirm that variability in travel time and traffic flow is a persistent, real-world phenomenon, not an artifact of modeling. Recognizing this variability, the initial approach to determining evacuation significance for this analysis adopts a data-driven framework that explicitly accounts for uncertainty in evacuation performance. Rather than relying on a single deterministic clearance time, evacuation performance was evaluated using the distribution of modeled outcomes and the 95th-percentile Confidence Interval. Critically, because the stochastic microsimulation model is designed to mirror real-world conditions, the variability observed across simulation runs reflects the same day-to-day fluctuation documented in both the resident survey data and the empirical traffic record. The range between the lower and upper DRAFT Anaheim Hills Fire Evacuation Analysis Page | 18 Technical Memorandum bounds of the 95th-percentile Confidence Interval therefore spans both directions of this uncertainty; when applied as a threshold, the net effect across the full CI band is zero. An impact delta that falls within this range is statistically indistinguishable from natural variability and does not constitute a significant impact. Only project-induced deltas that exceed the CI threshold represent a discernible, meaningful change in evacuation performance. In particular, Total Evacuation Time for Stochastic Evacuation Models: Confidence Interval Convergence Testing (Grandison and Galea, 2017) and A Review of Uncertainty Quantification in Evacuation Modelling (Ronchi et al., 2020) show that confidence intervals applied to upper-percentile evacuation times provide a defensible means of assessing convergence, robustness, and proximity to performance thresholds in evacuation analyses where individual runs vary due to behavioral and operational uncertainty. This approach is also consistent with FEMA's hurricane evacuation planning methodology, as documented in the Hurricane Evacuation Studies Program under the FEMA National Hurricane Program, which emphasizes the use of clearance time distributions derived from multiple simulation runs to inform evacuation timelines and decision thresholds, rather than reliance on single point estimates. Framework for Conducting Evacuation Analysis for Land Development Projects Because wildfire evacuation analysis involves the interaction of numerous variables -- including fire origin, zone configuration, population loading, route availability, signal operations, and driver behavior -- formal scoping between the project applicant, the lead agency, and the local fire department is essential to ensure that all applicable assumptions are explicitly agreed upon prior to modeling, creating the transparency and comprehensiveness necessary for a defensible significance determination. To provide a consistent and replicable basis for conducting project-level analyses, the following framework establishes the recommended sequence of steps that each land development project should be required to complete. A sample scoping form for use in implementing Step 1 is provided as Attachment A. Land development projects located within or adjacent to High or Very High Fire Hazard Severity Zones that require environmental review under CEQA shall conduct a project-level wildfire evacuation analysis in accordance with the framework described below. The framework follows a nine-step sequential process that addresses project scoping, fire scenario identification, route assignment, simulation modeling, significance determination, and mitigation verification. Each step must be completed in order, and the findings of each step inform the assumptions and inputs for subsequent steps. Substituting a fixed time-based threshold for the methodology described herein, or omitting any required step, is not a defensible basis for significance determination. Step 1: Project Scoping Prior to any modeling, the project applicant shall coordinate with the lead agency and the local fire department to establish the parameters of the evacuation analysis through a formal scoping process. The scoping agreement shall document the following items at a minimum. Evacuation Zone Definition. The number, geographic boundaries, and classification of each evacuation zone shall be identified. Zone types include Immediate (direct threat requiring immediate departure), Immediate with Staged Delay (phased departure with a defined offset interval, typically DRAFT Anaheim Hills Fire Evacuation Analysis Page | 19 Technical Memorandum 10 minutes), Shadow (precautionary self-directed evacuation), Shadow with Senior (precautionary evacuation with assisted or extended mobilization), and project-specific zones such as event or festival sites. Phasing triggers and delay intervals between zones shall be specified in the scoping agreement. Population and Vehicle Loading. Zone-level populations shall be established using the most current available data, including census records, approved development entitlements, and any applicable specific plan or environmental document. Vehicle loading rates, average household size, special needs population estimates, and any event or temporary occupancy conditions (such as festival attendance or seasonal visitors) shall be documented and agreed upon prior to modeling. Fire Origin Scenario. The fire ignition location, wind direction, wind speed, and rate of spread shall be identified based on the most likely full-evacuation trigger for the study area. Where fire behavior varies significantly by direction, the lead agency and fire department may require analysis of both a worst-case project-specific fire scenario and a worst-case regional fire scenario if the two differ. The selected fire origin scenario directly determines which evacuation zones are activated, which routes are available, and the sequence of zone departures. Evacuation Route Assignment. Evacuation routes shall be assigned in accordance with the local Know Your Way evacuation program or equivalent adopted route guidance. Route assignments shall account for the selected fire origin scenario, including any routes that may be blocked or compromised by the fire perimeter or smoke. Contraflow candidates and signal preemption corridors shall be identified during scoping and carried forward into the modeling assumptions. Time of Day and Season. The analysis shall reflect peak occupancy conditions. At minimum, the weekday PM peak period shall be evaluated. Where the project generates significant weekend or event-based traffic, a weekend or event scenario shall also be evaluated. Seasonal fire risk windows, particularly periods of elevated Santa Ana wind conditions, shall be considered in establishing the modeling time of day. Model Parameters. The minimum number of stochastic simulation seeds shall be set at 20 independent runs per scenario. Additional parameters to be established during scoping include the model warm-up period, background traffic volumes, signal timing plans, emergency preemption logic, and any contraflow or special traffic control measures assumed to be in place during an evacuation event. Step 2: Fire Scenario Identification Based on the scoping agreement, the analyst shall formally document the selected fire origin scenario and confirm the resulting zone activation sequence. The applicant may either refer to the fire progression modeling scenarios from the Anaheim WES, or, if those scenarios are not accurate to the Project, the applicant team may model fire progression using FlamMap and the same methodologies disclosed in the Anaheim WES. The fire scenario shall represent the most likely condition under which a full or near-full community evacuation would be triggered. The documentation shall include the fire ignition location, assumed wind direction and speed, rate of spread, and the resulting determination of which zones are classified as Immediate, Shadow, or unaffected for the purposes of the analysis. This determination is fixed for all subsequent modeling steps and shall not be revised without reinitiating the scoping process with the lead agency and fire department. DRAFT Anaheim Hills Fire Evacuation Analysis Page | 20 Technical Memorandum Step 3: Evacuation Route Assignment and Network Coding The analyst shall code the evacuation network into the microsimulation model in accordance with the route assignments established during scoping. Each zone shall be assigned its primary and, where applicable, secondary evacuation routes consistent with the adopted Know Your Way guidance and the selected fire scenario. Routes that are assumed to be blocked or capacity- constrained due to the fire perimeter shall be removed from the available network. Any contraflow lanes, signal coordination plans, or emergency preemption logic agreed upon during scoping shall be incorporated into the baseline network prior to the baseline simulation run. Step 4: Baseline Simulation The baseline scenario shall represent existing conditions without the proposed project. The baseline simulation shall include all existing background traffic, the full zone population and vehicle loading established during scoping, and any existing signal timing or emergency preemption infrastructure. A minimum of 20 independent simulation runs using different random seeds shall be executed to capture stochastic variability in traffic flow, routing decisions, and driver behavior. The mean total evacuation time for each Immediate evacuation zone shall be computed across all 20 runs and recorded as the baseline performance measure. Step 5: Confidence Interval Threshold Calculation The 95th-percentile Confidence Interval shall be calculated from the distribution of total evacuation times produced by the 20-baseline simulation runs for each Immediate zone. The CI threshold is defined as the range between the lower and upper bounds of this interval. As established in the preceding section of this report, the variability observed across simulation runs reflects the same day-to-day fluctuation in travel time and traffic patterns documented in both resident survey data and empirical traffic records. Because this variability exists symmetrically across both the lower and upper bounds, the net effect across the full CI band is zero. The CI range therefore functions as a net-zero threshold: a project-induced change in evacuation time that falls within this band is statistically indistinguishable from natural variability and does not constitute a significant impact. The CI threshold value shall be documented separately for each Immediate evacuation zone and carried forward as the zone-specific significance criterion. Step 6: Project Scenario Simulation The project scenario shall add the proposed project's trip generation to the baseline evacuation network inclusive of Project Design Features but exclusive of any project-specific infrastructure improvements as mitigation measures. Project traffic shall be loaded in accordance with the vehicle generation rates and zone assignments established during scoping, including any event or festival attendance associated with the project. A minimum of 20 independent simulation runs shall be executed using the same random seed set as the baseline scenario to ensure comparability. The mean total evacuation time for each Immediate zone shall be computed across all 20 project runs. Step 7: Impact Determination The project impact for each Immediate evacuation zone shall be calculated as the difference (delta) between the mean project scenario evacuation time and the mean baseline evacuation time for that zone. The delta shall then be compared against the zone-specific CI threshold established in Step 5. DRAFT Anaheim Hills Fire Evacuation Analysis Page | 21 Technical Memorandum A project impact is determined to be less than significant if the delta for all Immediate zones or delayed evacuation zones falls within the CI threshold. A project impact is determined to be potentially significant if the delta for one or more Immediate zones or delayed evacuation zones exceeds the CI threshold. In accordance with the findings documented in this report and consistent with the peer-reviewed literature (Grandison and Galea, 2017; Ronchi et al., 2020), this CI-based comparison is the appropriate and defensible basis for significance determination. A fixed time- based threshold shall not be substituted for the zone-specific CI threshold without written concurrence from the lead agency and fire department. Step 8: Mitigation Measures Where the impact determination identifies one or more Immediate zones or delayed evacuation zones with a delta exceeding the CI threshold, the applicant shall identify and implement feasible mitigation measures sufficient to reduce the project impact to within the CI threshold for all affected zones. Mitigation measures shall be evaluated in coordination with the lead agency and fire department and may include, but are not limited to, the following. CCTV and Traffic Monitoring Equipment. Installation of closed-circuit television cameras at key evacuation corridor intersections to enable real-time monitoring and incident response during an evacuation event. Emergency Signal Preemption. Installation of emergency vehicle preemption equipment on evacuation route signal controllers to allow coordinated signal override by responding agencies during an evacuation. Signal Coordination and Emergency Control. Implementation of an evacuation-specific signal coordination plan for the primary evacuation corridors, including provisions for emergency manual or remote control of signal timing by traffic operations or fire department personnel. Access and Circulation Improvements. Physical improvements to project driveways, access points, or internal circulation that reduce vehicle queuing or conflict during evacuation loading, including turn channelization, driveway consolidation, or on-site queuing capacity enhancements. Phased Development or Occupancy Restrictions. Where the cumulative vehicle loading of the project is a primary driver of the exceedance, phased occupancy conditions may be established as mitigation, with subsequent phases contingent on infrastructure improvements or demonstrated capacity thresholds. All proposed mitigation measures shall be incorporated into a Mitigation Monitoring and Reporting Program (MMRP) consistent with CEQA requirements, with defined implementation triggers, responsible parties, and verification mechanisms. Step 9: Mitigation Verification Following the identification of mitigation measures, the analyst shall re-run the microsimulation model with all mitigation measures incorporated into the network. A minimum of 20 independent runs shall be executed for the mitigated scenario using the same random seed set. The mean total evacuation time for each Immediate zone shall be computed and the delta against the baseline recalculated. The mitigation scenario shall be determined to reduce the project impact to a less- than-significant level only if the delta for all Immediate evacuation zones falls within the respective DRAFT Anaheim Hills Fire Evacuation Analysis Page | 22 Technical Memorandum zone-specific CI threshold. If one or more zones remain in exceedance, additional mitigation measures shall be identified and the verification process repeated until all zones achieve compliance. The verified mitigated scenario results shall be reported in the project's environmental document alongside the unmitigated project results and the baseline performance data.DRAFT Anaheim Hills Fire Evacuation Analysis Technical Memorandum Attachment B - Sample City of Anaheim - Wildfire Evacuation Analysis Project Scoping Form DRAFT City of Anaheim Wildfire Evacuation Analysis Project Scoping Form Page | 1 Planning and Building Department C I T Y O F A N A H E I M WILDFIRE EVACUATION ANALYSIS Project Scoping Form To be completed jointly by the project applicant, the City of Anaheim Planning and Building Department, and the Anaheim Fire and Rescue Department prior to commencement of evacuation modeling. A. Project Identification Complete all fields. This section establishes the project record and identifies the parties responsible for the scoping agreement. Project Name Case Number / APN Project Address / Location Project Description (brief) Applicant / Developer Applicant Contact / Phone Traffic / Evacuation Analyst Analyst Firm City Planning Contact Anaheim Fire and Rescue Contact Scoping Meeting Date Form Completed By Date Submitted DRAFT City of Anaheim Wildfire Evacuation Analysis Project Scoping Form Page | 2 Planning and Building Department B. Fire Hazard Severity Zone Determination Confirm the project site's Fire Hazard Severity Zone (FHSZ) designation. A wildfire evacuation analysis is required for projects located in or adjacent to a High or Very High FHSZ. Site FHSZ Designation ☐ Moderate ☐ High ☐ Very High ☐ Not in FHSZ FHSZ Map Reference / Source Adjacent to FHSZ? ☐ Yes ☐ No ☐ Under Review ☐ N/A Analysis Required? ☐ Yes -- proceed to Section C ☐ No -- attach justification memo ☐ ☐ C. Evacuation Zone Definition Identify each evacuation zone to be included in the analysis. Attach a labeled zone map. Zone type, activation sequence, and delay intervals must be confirmed by Anaheim Fire and Rescue. Zone ID Zone Name / Description Zone Type Activation Sequence Delay Interval (min) Approx. Households Zone Type options: Immediate | Immediate with Staged Delay | Shadow | Shadow + Senior | Project-Specific (e.g., event / festival site) DRAFT City of Anaheim Wildfire Evacuation Analysis Project Scoping Form Page | 3 Planning and Building Department D. Population and Vehicle Loading Document the population and vehicle loading assumptions for each zone. All sources must be cited and agreed upon prior to modeling. Zone ID Total Population Avg. HH Size Total DUs Vehicles per DU Special Needs Pop. Data Source Event / Festival Occupancy? ☐ Yes (complete below) ☐ No ☐ Other Max. Event Attendance Estimated Event Vehicles Event Frequency / Season DRAFT City of Anaheim Wildfire Evacuation Analysis Project Scoping Form Page | 4 Planning and Building Department E. Fire Origin Scenario The fire origin scenario determines zone activation, route availability, and departure sequence. This determination must be confirmed by Anaheim Fire and Rescue and is fixed for all subsequent modeling steps. Fire Origin Location (Description) Fire Origin Coordinates (Lat / Long) or description (include map if needed) Wind Direction Wind Speed (mph) Rate of Spread (acres/hr or mi/hr) Scenario Type ☐ Worst-case project-specific ☐ Worst-case regional ☐ Both required ☐ Other Justification / Basis for Selection Blocked or Compromised Routes F. Evacuation Route Assignment Assign primary and secondary evacuation routes for each zone consistent with Anaheim Fire and Rescue's Know Your Way program. Note contraflow candidates and signal preemption corridors. Zone ID Primary Route(s) Secondary Route(s) Contraflow Candidate? Preemption Corridor? DRAFT City of Anaheim Wildfire Evacuation Analysis Project Scoping Form Page | 5 Planning and Building Department Zone ID Primary Route(s) Secondary Route(s) Contraflow Candidate? Preemption Corridor? Know Your Way Program Reference Additional Route Notes G. Time of Day and Season Select all time period(s) to be analyzed. At minimum, the weekday PM peak period is required. Anaheim Hills area projects must evaluate Santa Ana wind season conditions. Analysis Time Period(s) ☐ Weekday PM Peak ☐ Weekend Midday ☐ Event / Festival ☐ Other (specify) Other Time Period (if applicable) Santa Ana Wind Season? ☐ Yes -- include seasonal scenario ☐ No ☐ ☐ Seasonal Window (months) DRAFT City of Anaheim Wildfire Evacuation Analysis Project Scoping Form Page | 6 Planning and Building Department H. Model Parameters Confirm the modeling assumptions to be used in all simulation scenarios. Parameters agreed upon here are fixed for baseline, project, and mitigated runs. Intersection-level signal optimization tools such as SimTraffic are not recommended for wildfire evacuation analysis. These platforms are designed for steady-state, recurring traffic operations and assume a stable background demand; they cannot model the time-sequenced zone loading, network-wide queue propagation, or dynamic rerouting that characterize an evacuation event. Evacuation analysis requires a microsimulation platform with dynamic traffic assignment (DTA) capability, such as VISSIM or TransModeler, that can simulate the full network response to a demand surge under non- recurrent, non-equilibrium conditions. Practitioner should determine the most appropriate and best tool for evacuation analysis, based on substantial evidence, at the time of the analysis. Simulation Platform ☐ VISSIM ☐ TransModeler ☐ Other (specify) Other Platform (if applicable) Number of Random Seeds (min. 20) Model Warm-Up Period (min) Background Traffic Volume Source Traffic Count / Data Year Signal Timing Plan ☐ Existing adopted plan ☐ Evacuation- specific plan ☐ Both Emergency Preemption (Existing) ☐ Yes ☐ No ☐ Partial (note below) Preemption Notes Contraflow (Baseline) ☐ Yes ☐ No ☐ Under Evaluation Other Agreed Parameters / Notes I. Project Traffic Assumptions DRAFT City of Anaheim Wildfire Evacuation Analysis Project Scoping Form Page | 7 Planning and Building Department Document the trip generation and zone assignment for the proposed project. These values will be added to the baseline evacuation network in the project simulation scenario. Project Land Use Type(s) Total Project Units / Floor Area Trip Generation Rate Source (e.g., ITE) Total Project Vehicles (evacuation loading) Zone(s) to Which Project Traffic is Assigned Event / Festival Traffic Included? ☐ Yes ☐ No ☐ N/A Methodology Notes / Assumptions J. Significance Threshold Methodology Confirm the significance threshold approach. Per the Anaheim WES methodology, the 95th-percentile Confidence Interval derived from the baseline simulation is the required threshold. A fixed time-based threshold shall not be substituted without written concurrence from the City and Anaheim Fire and Rescue. Threshold Method ☐ 95% CI Range (required) ☐ Other (attach justification) Justification if Not 95% CI (attach) All Parties Concur on Threshold? ☐ Yes ☐ No -- pending resolution Notes / Conditions K. Potential Mitigation Measures (Pre-Identified) (Optional) If mitigation measures are known or anticipated at the time of scoping, identify them below. These will be incorporated into the mitigated simulation scenario if the project scenario exceeds the CI threshold. DRAFT City of Anaheim Wildfire Evacuation Analysis Project Scoping Form Page | 8 Planning and Building Department CCTV / Traffic Monitoring ☐ Yes -- include in modeling ☐ No ☐ Under Evaluation Emergency Signal Preemption ☐ Yes -- include in modeling ☐ No ☐ Under Evaluation Signal Coordination / Evac. Plan ☐ Yes -- include in modeling ☐ No ☐ Under Evaluation Access / Circulation Improvements ☐ Yes -- include in modeling ☐ No ☐ Under Evaluation Phased Occupancy / Development ☐ Yes -- include in modeling ☐ No ☐ Under Evaluation Description of Proposed Mitigations MMRP Trigger Conditions (if known) L. Scoping Agreement and Signatures By signing below, all parties confirm that the parameters documented in this form are agreed upon and shall serve as fixed assumptions for all evacuation modeling. Any subsequent changes to agreed parameters require an amended scoping agreement signed by all parties. City of Anaheim Anaheim Fire and Rescue Project Applicant / Analyst Name: Name: Name: Title: Title: Title: Department / Firm: Department / Firm: Department / Firm: Signature: Signature: Signature: Date: Date: Date: Required Attachments: Labeled evacuation zone map | FHSZ designation map | Know Your Way route map | Trip generation worksheets | Any referenced planning or environmental documents DRAFT DRAFT