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General (04) Susana Barrios From:Andrew Winger <arwinger@gmail.com> Sent:Thursday, July 23, 2026 11:38 AM To:Rudy Emami; Rafael Cobian; Cory Wilkerson; Public Comment Subject:\[EXTERNAL\] Dudek Wildfire Evacuation Study Comments Attachments:Dudek Wildfire Draft Andrew Winger Comments.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. Hi, I am attaching my full comments following my review of the Draft Dudek Wildfire Evacuation Study. East Anaheim urgently needs a champion within City Hall who will insist that the community is safe before additional development is approved. Unfortunately, as currently written, this study does not accomplish that. In many ways, it confirms the serious evacuation challenges residents have been raising for years, but it does not go far enough to ensure those challenges are corrected before more evacuation demand is added. It does not have to remain that way. With meaningful revisions, this study could become a public-safety framework that both protects East Anaheim residents and allows responsible development to move forward only when evacuation safety has been demonstrated. I would also ask that Public Works engage directly and constructively with residents regarding the concerns raised about the Know Your Way plan. Residents are not raising theoretical objections. There are real operational concerns with the plan, and they should be acknowledged, tested, and addressed rather than dismissed. Thanks, Andrew Winger 1 Page 1 of 21 Comments on the DraŌ City of Anaheim / Dudek Wildfire EvacuaƟon Study SubmiƩed by: Andrew Winger 7/23/26 The primary issue in East Anaheim is that there have been no significant infrastructure improvements made to the community since the devastaƟng 2017 wildfires, when residents experienced evacuaƟon Ɵmes exceeding 2.5 hours. Despite this, large housing projects conƟnue to be approved. Instead of first determining whether the community is already safe before approving addiƟonal development, the DraŌ Dudek Wildfire EvacuaƟon Study appears to focus primarily on limiƟng how much worse each new project may make evacuaƟon condiƟons. In other words, the community is already drowning and treading water to stay afloat. Instead of providing a life preserver, the Dudek study appears to limit the quanƟty of addiƟonal weight that can be Ɵed to the community’s ankles each Ɵme a new project is added. My comments are divided into two secƟons. First, I propose a methodology adjustment that would help ensure the study is used to make the community safer, not merely to measure incremental worsening. Second, I provide comments and requested revisions to the draŌ study as currently wriƩen. SecƟon 1: Recommended Methodology Adjustment Add a life-safety margin requirement. The final study should require a “life-safety margin” test. If fire, smoke, embers, or route loss can arrive before residents can evacuate safely, that condiƟon should be considered potenƟally significant. New development should not be approved unless that safety margin is corrected first. The Dudek methodology already requires fire modeling and evacuaƟon modeling. Therefore, the City should be able to compare evacuaƟon clearance Ɵme against modeled fire-arrival Ɵme, route exposure, smoke exposure, ember exposure, and available safe egress Ɵme. The standard should be simple: EvacuaƟon Ɵme should be less than the Ɵme available before evacuaƟon routes or affected zones become unsafe. Page 2 of 21 This would ensure that the City is not only measuring whether a project adds more delay than a confidence interval, but also whether residents can actually escape before condi Ɵons become life-threatening. This standard would be legally and pracƟcally sound because it is:  ObjecƟve  Measurable  Based on modeled fire and evacuaƟon Ɵming  Connected directly to public safety  Not an automaƟc ban  Capable of being addressed through miƟgaƟon The life-safety margin test should not be applied to unrealisƟc zero-noƟce igniƟons immediately adjacent to homes. It should be applied to reasonably foreseeable wildfire scenarios, such as a SR-241 igniƟon, Canyon Fire II-type condiƟons, Freeway Complex Fire-type condiƟons, or other historically grounded wildfire scenarios affecƟng East Anaheim. Add a funcƟonal-egress redundancy requirement. The final study should also evaluate funcƟonal egress redundancy, not merely modeled evacuaƟon Ɵme. A recent peer-reviewed study published in Proceedings of the NaƟonal Academy of Sciences, “Egress Thresholds and Wildfire FataliƟes,” found that wildfire fataliƟes are sharply concentrated in communiƟes with very few exits, and that fatality risk declines steeply unƟl roughly six outward roads are available. The study explains that communiƟes with fewer than six outward routes are more vulnerable because they lack mulƟple independent pathways and are more suscepƟble to congesƟon, blockage, or simultaneous exposure to fire fronts. This is directly relevant to East Anaheim. Under Anaheim’s Know Your Way evacuaƟon framework, many East Anaheim evacuaƟon movements are effecƟvely directed toward a very small number of funcƟonal outbound corridors. For much of East Anaheim, the pracƟcal evacuaƟon choices are reduced to Nohl Ranch Road toward the SR-55 freeway or Santa Ana Canyon Road toward the SR-91 freeway at Lakeview. When a fire is not approaching from the east, Weir Canyon Road and the SR-91 entrances may provide a third funcƟonal opƟon. However, for the historical east-origin fire paƩern affecƟng Anaheim Hills, the community’s Page 3 of 21 effecƟve egress redundancy may be much lower than the road network appears to show on a map. The final Dudek study should therefore idenƟfy not merely how many roads exist, but how many independent, usable, direcƟonally appropriate evacuaƟon corridors are available under each wildfire scenario. A road should not be counted as a meaningful evacu aƟon exit if it sends residents toward the fire, depends on a freeway segment likely to be blocked, merges immediately into the same boƩleneck as another route, or is unavailable under the modeled igniƟon and wind direcƟon. Require project analysis for all affected East Anaheim evacuaƟon zones. The methodology should require analysis of every East Anaheim zone that could be affected by a project’s evacuaƟon traffic, not just the project’s own zone or the zones closest to the igni Ɵon. For example, in the SR-241 fire scenario, the study reports that evacuaƟon of Zone 3 takes 4 hours and 55 minutes. Adding housing in Zone 8, FesƟval, Deer Canyon, or other areas may add traffic to shared corridors that also affect Zone 3 and the Anaheim Hills Elementary area. Under the current draŌ methodology, a Zone 8 project may not necessarily be required to evaluate its effect on Zone 3 under the SR-241 scenario because of proximity-based scoping. That is a major gap. Each project should be required to review impacts on every East Anaheim evacuaƟon zone and every major shared evacuaƟon corridor. By extension, every major wildfire scenario should be evaluated, including SR-241 igniƟon, Canyon Fire II-type condiƟons, Freeway Complex-type condiƟons, and other reasonably foreseeable fire pathways. These changes would meet the community’s core goal: not simply limiƟng how much worse evacuaƟon becomes, but ensuring that residents can actually evacuate safely. SecƟon 2: Comments and Requested Revisions to the DraŌ Study A. Transparency, Public Review, and Source Data 1. Provide the full 18-quesƟon community survey instrument and results. On page 37, the study states that the community survey ran from June to August 2025, included 18 quesƟons, and received 250 responses. It reports selected results, including that 96% of Page 4 of 21 respondents self-reported as Anaheim Hills residents; 70% idenƟfied evacuaƟon as a top wildfire concern; 44% said their neighborhood does not have adequate evacuaƟon routes; and 70% idenƟfied Anaheim Alert as an evacuaƟon informaƟon source. The final study should include the complete survey instrument as an appendix, including all 18 original quesƟons, all answer choices, skip logic, survey distribuƟon method, response totals by quesƟon, and de-idenƟfied raw or tabulated results. The exact wording maƩers because survey results may be used to support findings about public awareness, evacuaƟon behavior, and confidence in City communicaƟon systems. The study should also explain whether survey respondents were reporƟng actual past receipt of Anaheim Alert evacuaƟon messages, general awareness of Anaheim Alert, or expected future reliance on Anaheim Alert. If the City intends to rely on Anaheim Alert as a key evacuaƟon communicaƟon tool, the final study should include an issuance history for wildfire, evacuaƟon, road-closure, or emergency messages relevant to Anaheim Hills. Requested revision: Add the complete survey instrument, full response tables, distribu Ɵon method, and Anaheim Alert issuance history as appendices. 2. Make Figure 6 and the constrained-roadway analysis usable. Page 49 explains that the City idenƟfied constrained roadways and parcels as part of the Safety Element update. It states that constrained roadways have a single point of connecƟon with the rest of the roadway network, and that constrained parcels are areas where at least 30 parcels are located along a constrained roadway. The study states that 82 constrained parcel locaƟons were idenƟfied, 48 of them in eastern Anaheim, and 28 within or adjacent to a Very High Fire Hazard Severity Zone. Figure 6, on page 51, is criƟcal to public understanding of evacuaƟon constraints. However, Figure 6 is too small to evaluate meaningfully in the draŌ document. Requested revision: Replace Figure 6 with zone-by-zone enlarged maps and add a table lisƟng every constrained roadway, the evacuaƟon zones it serves, the number of parcels affected, whether the route is one-way-in/one-way-out, whether gates or private roads limit access, and whether the route is included in evacuaƟon modeling. 3. Publish project scoping assumpƟons before modeling is completed. The study’s project-level methodology will be highly sensiƟve to assumpƟons. This could allow project results to be influenced by selecƟve or unsupported assumpƟons. These include fire Page 5 of 21 scenario selecƟon, zones included or excluded, vehicle counts, rou Ɵng, evacuaƟon phasing, shadow evacuaƟon, school assumpƟons, signal assumpƟons, and miƟgaƟon assumpƟons. If these assumpƟons are negoƟated privately between the City, applicant, and consultant, the public will not be able to meaningfully evaluate the result. Requested revision: Require publicaƟon of project scoping assumpƟons before evacuaƟon modeling is completed. The scoping package should include the fire scenario, zones included or excluded, vehicle counts, route assumpƟons, phasing assumpƟons, shadow evacuaƟon assumpƟons, school-day assumpƟons, and miƟgaƟon assumpƟons. 4. Add a plain-language explanaƟon of the confidence interval and require full disclosure in project reports. Page 77 defines the confidence interval as the normal variability in evacuaƟon Ɵme when the model is re-run. Table 6 lists example confidence intervals by zone for Scenario 1, including 6:51 for Zone 1, 7:03 for Zone 3, 6:37 for Zone 5, 6:23 for Zone 8, and 16:49 for Zone 15. This is important, but the concept is easy to misunderstand. A project that adds less Ɵme than the confidence interval may sƟll be adding people or vehicles to an evacuaƟon system that is already unsafe. The confidence interval should not be treated as proof of safety. Requested revision: Add a plain-language secƟon explaining that the confidence interval measures project-related worsening against model variability, but does not prove the total evacuaƟon condiƟon is safe. Future project reports should disclose both the project-caused increase and the total resulƟng evacuaƟon Ɵme for every affected zone and corridor. B. Fire Scenario SelecƟon, Wind AssumpƟons, and Model Severity 5. Explain why the fire modeling used the 97th-percenƟle wind rather than stronger foreseeable Santa Ana wind condiƟons. Page 54 idenƟfies the wildfire behavior modeling inputs and states that the study used Chino Hills Remote Automated Weather StaƟon data from August 1 to December 1, 2007–2025. Table 4 uses a 97th-percenƟle Santa Ana wind speed of 33 mph, wind direcƟon of 48 degrees, and very dry fuel moisture assumpƟons. A 97th-percenƟle wind may be defensible as a high-wind planning input, but the study is being used to evaluate evacuaƟon safety during catastrophic wildfire condiƟons. Page 2 acknowledges that Santa Ana winds can reach 75 mph or higher. The final study should therefore explain why Page 6 of 21 the 97th percenƟle was selected instead of the 99th percenƟle, 99.5th percenƟle, maximum observed sustained wind, or a gust-adjusted sensiƟvity scenario. The final study should disclose the 97th, 99th, 99.5th, and maximum observed sustained wind and gust values for each weather staƟon considered. The study should also add sensiƟvity modeling using stronger but foreseeable Santa Ana condiƟons to show whether evacuaƟon conclusions remain valid. Requested revision: Add higher-wind sensiƟvity scenarios, including 99th-percenƟle, maximum observed sustained, and gust-adjusted Santa Ana wind scenarios. 6. Explain why Chino Hills RAWS was selected instead of Fremont Canyon or other potenƟally more adverse local wind staƟons. Page 54 states that Chino Hills RAWS was used as the nearest Remote Automated Weather StaƟon. The final report should provide the staƟon-selecƟon analysis supporƟng that choice. Fremont Canyon appears to be an important Santa Ana wind staƟon for Orange County. An AQMD excepƟonal-event report for the October 13, 2008 Santa Ana wind event idenƟfied Fremont Canyon RAWS as one of the windiest staƟons in the event, with a peak gust of 87 mph and peak sustained wind of 48 mph. By comparison, the same report listed Chino Airport at 51 mph gust and 29 mph sustained. Although Chino Airport is not Chino Hills RAWS, this comparison strongly suggests that Fremont Canyon may beƩer capture severe Orange County Santa Ana wind extremes. The final study should compare Chino Hills, Fremont Canyon, Windy Ridge/Wind Ridge, Corona, SanƟago Canyon if available, and any other relevant staƟons. For each staƟon, the study should list coordinates, elevaƟon, period of record, data completeness, sensor type, Santa Ana wind frequency, 97th/99th/maximum sustained winds, and 97th/99th/maximum gusts. Requested revision: Add a weather-staƟon selecƟon appendix explaining why Chino Hills was selected and whether Fremont Canyon or other staƟons show more adverse Santa Ana wind behavior relevant to Anaheim Hills. 7. Add a scenario-selecƟon appendix. Page 54 states that three igniƟon locaƟons were selected: Highway 241, Deer Canyon, and East Nohl Ranch Road. The study says these were chosen based on higher igniƟon likelihood and potenƟal to generate fire spread toward community areas and trigger evacuaƟons. Page 7 of 21 The final study should show its work. The public needs to know why these three scenarios were selected, which historical fires they represent, which plausible fire pathways were excluded, and whether a Canyon II-style or Corona/91 corridor fire progression was evaluated. Because Canyon II is specifically discussed in the report as a recent fire that caused large-scale simultaneous evacuaƟon and resident confusion, it should be used as a historical calibraƟon scenario or the study should explain why the modeled scenarios are more severe. Requested revision: Add a scenario-selecƟon appendix and at least one historical-calibraƟon scenario based on Canyon II or another documented regional fire pathway. 8. Clarify how FlamMap/MTT handled ember transport, spotting, and spot-fire ignition. The final study should clearly explain whether ember transport, spotting, and spot-fire ignition were modeled, excluded, simplified, or treated only qualitatively. Page 56 acknowledges that structures may be exposed to wind-transported embers, ember intrusion, and short-range spotting. The same discussion also states that real-world fire behavior may differ from the modeling because of factors not captured by the modeling framework, including unpredictable ember generation and transport. This is important because evacuation safety may be compromised before the modeled main fire front reaches a zone, roadway, or evacuation corridor. Wind-driven embers and spot fires can ignite receptive fuels ahead of the main fire, create smoke and visibility hazards, compromise evacuation routes, and cause residents outside the modeled fire perimeter to evacuate early. FlamMap/MTT includes spotting-related settings and outputs, but the draft study does not clearly disclose whether those features were enabled, disabled, simplified, or relied upon. If spotting was disabled, set to zero, excluded, or not relied upon, the study should explain why. If spotting was enabled, the study should disclose the assumptions and settings used, including spot probability, spotting delay, maximum spotting distance, ember landing outputs, and how spot-fire ignition was incorporated into evacuation trigger timing and route exposure analysis. Requested revision: The final study should clarify whether FlamMap/MTT spotting functionality was enabled or disabled. If spotting was enabled, the study should disclose the settings, assumptions, outputs, and how those outputs were incorporated into evacuation timing. If spotting was excluded or not relied upon, the study should explain why and add conservative sensitivity analysis or buffers for ember-driven spot fires, route compromise, smoke exposure, and earlier-than-modeled evacuation triggers. 9. Do not dismiss all-zone evacuaƟon scenarios. Page 8 of 21 Page viii states that catastrophic all-zone evacuaƟons generate the longest clearance Ɵmes and do not reflect modern operaƟonal pracƟce. However, Canyon II demonstrated that real residents may not evacuate in clean, orderly phases. Smoke, sirens, social media, family separaƟon, school pickup, pets, and fear can all cause people outside the immediate evacuaƟon area to leave early. The catastrophic scenarios are important stress tests. They should not be dismissed merely because phased evacuaƟon is the preferred operaƟonal goal. Requested revision: The final study should preserve catastrophic all-zone scenarios as required stress tests and should state that phased evacuaƟon assumpƟons must be validated and supplemented with shadow-evacuaƟon sensiƟvity analysis. C. Know Your Way, Behavior, and Real-World EvacuaƟon CondiƟons 10. State clearly that Know Your Way is not validated by this study. The study repeatedly relies on phased evacuaƟon concepts associated with the Know Your Way program. Page vii states that phased evacuaƟons were modeled, and page viii states that phased evacuaƟons significantly improve efficiency and reduce congesƟon. Page 3 explains that Know Your Way was created aŌer the evacuaƟon challenges of the 2017 Canyon II Fire, when residents experienced confusion over evacuaƟon routes, road closures, and expanding evacuaƟon zones. However, a computer model of phased evacuaƟon is not the same as a validated evacuaƟon system. The report does not appear to provide evidence of a full-scale exercise, field drill, aŌer- acƟon validaƟon, or real-world proof that residents will follow phased evacuaƟon orders under wildfire stress. Requested revision: The final study should state that Know Your Way is an operaƟonal assumpƟon that must be validated through drills, exercises, communicaƟon tests, public educaƟon, and aŌer-acƟon evaluaƟon before it is relied upon as proof that future development impacts are acceptable. 11. Include failure and parƟal-compliance scenarios. The study should not assume that evacuaƟon will occur under ideal condiƟons. Page 77 acknowledges that evacuaƟon acceptability depends on fire behavior, warning Ɵme, roadway constraints, and operaƟonal response. The final study should test foreseeable failures and Page 9 of 21 parƟal-compliance condiƟons, including a crash blocking a lane, a fire compromising an evacuaƟon route, panic or early self-evacuaƟon, residents not following assigned routes, and emergency vehicles needing access against outbound traffic. Requested revision: Add sensiƟvity scenarios for crash blockage, route compromise, parƟal Know Your Way compliance, shadow evacuaƟon, noncompliance with assigned routes, and panic/self-evacuaƟon behavior. 12. Add behavioral and operaƟonal sensiƟvity scenarios. The draŌ acknowledges several real-world issues but does not appear to fully stress-test them. Page 77 notes that households outside an evacuaƟon area may leave early due to smoke while also aƩempƟng to retrieve children from schools. Page ix recommends addressing Disabili Ɵes and Access and FuncƟonal Needs, large-animal evacuaƟon coordinaƟon, and school-day evacuaƟon scenarios. These should not be leŌ as general concerns. They should be modeled or evaluated. The final study should also include realisƟc school-day and family-retrieval scenarios. For example, during a wildfire evacuaƟon, a parent may aƩempt to reach Anaheim Hills Elementary while evacuaƟon traffic is moving outbound. If traffic into Orange is blocked at Serrano Avenue and Nohl Ranch Road, that parent may encounter a closed route, stopped traffic, or conflicƟng instrucƟons. In a panic, the parent could abandon the vehicle in the roadway and proceed on foot toward the school. Even one abandoned vehicle could block or narrow an egress lane, slowing evacuaƟon traffic for residents aƩempƟng to leave. This is not an extreme or speculaƟve scenario. It reflects foreseeable human behavior during a family emergency. Parents, adult children, caregivers, and relaƟves may aƩempt to reach children, elderly residents, disabled residents, medically vulnerable family members, pets, or medicaƟon. The model should not assume that inbound traffic can simply be stopped without secondary consequences. Requested revision: Add sensiƟvity scenarios for parƟal Know Your Way compliance, shadow evacuaƟon from adjacent zones, parents retrieving children, residents aƩempƟng to return home, disabled/DAFN evacuaƟon, school-day condiƟons, cell-service failure, power failure, blocked lanes, abandoned vehicles, cross-jurisdicƟon route closures, crash condiƟons, large- animal evacuaƟon, and noncompliance with assigned routes. 13. Add a reduced-response-capacity and mutual-aid-availability scenario. Page 10 of 21 The final study should evaluate reduced local emergency response capacity as a foreseeable operaƟonal condiƟon. SecƟon 2.2.14 discusses the California Mutual Aid Agreement as a mechanism for bringing in outside resources when local capacity is overwhelmed. The exisƟng infrastructure discussion also idenƟfies mutual aid relaƟonships with nearby jurisdicƟons and states that nearby staƟons may be able to provide assistance. However, the study does not appear to evaluate the potenƟal negaƟve side of mutual aid: local Anaheim Fire & Rescue resources may already be deployed outside Anaheim when a wildfire ignites in Anaheim Hills. This was a concern raised aŌer the Canyon II Fire, where local resources were not necessarily at full availability when the fire began. The study should not assume that emergency response resources will always be fully available at the moment of igniƟon. If Anaheim fire resources are already commiƩed to another incident or mutual-aid assignment, iniƟal aƩack may be delayed, evacuaƟon decisions may occur later, traffic-control support may be reduced, and the fire may have more Ɵme to reach evacuaƟon corridors before residents can clear the area. This issue is especially important because the study acknowledges that emergency personnel acƟons are not captured in the modeling, while also staƟng that such acƟons would be expected to reduce evacuaƟon Ɵmes and slow fire progression. The final study should not assume only the beneficial side of emergency response. It should also test reduced-response- capacity condiƟons. Requested revision: Add sensiƟvity scenarios for reduced local emergency response capacity, including condiƟons where Anaheim Fire & Rescue resources are already commi Ʃed to mutual aid or another incident at the Ɵme of igniƟon. The study should evaluate how delayed iniƟal aƩack, delayed evacuaƟon orders, reduced field traffic control, and delayed mutual-aid arrival could affect fire progression, evacuaƟon trigger Ɵming, route exposure, and life-safety margins. D. Safety Threshold and Corridor-Wide Project Review 14. Require absolute safety comparisons, not only project deltas. The study’s proposed confidence-interval method is useful for determining whether a project increases evacuaƟon Ɵme beyond normal model variaƟon. Page 77 explains that evacuaƟon Ɵme increases exceeding the confidence interval may consƟtute a potenƟally significant impact unless miƟgated. Page 11 of 21 However, the project-delta test does not answer the most important life-safety quesƟon: can people actually get out before fire, smoke, embers, blocked roads, or route loss makes evacuaƟon unsafe? For example, Table 5 shows that under Scenario 3, the SR-241 fire scenario, Zone 3 has a modeled evacuaƟon Ɵme of 4 hours and 55 minutes. If modeled fire progression reaches the zone, its evacuaƟon route, or a criƟcal boƩleneck before that Ɵme, the concern is not merely whether a new project adds more than a few minutes. The concern is whether there is already a negaƟve life-safety margin. The life-safety margin analysis should account not only for the modeled arrival of the main fire front, but also for earlier route compromise from smoke, ember exposure, spo ƫng, and spot- fire igniƟon. Requested revision: Every project analysis should compare evacuaƟon clearance Ɵme against fire-arrival Ɵme, smoke exposure, ember exposure, route exposure, route failure, and available safe egress Ɵme. The study should include a life-safety-margin test in addiƟon to the confidence-interval project-delta test. 15. Evaluate all zones sharing the same evacuaƟon corridors, not just formally ordered zones, and require a funcƟonal-egress redundancy analysis. The project methodology should not be limited to the project’s own evacuaƟon zone or only the zones formally ordered to evacuate. A project in one zone may add traffic to shared downstream corridors, intersecƟons, signals, freeway ramps, or boƩlenecks used by other zones. This issue is especially important because wildfire evacuaƟon safety depends not only on evacuaƟon Ɵme, but also on the number of independent and usable evacuaƟon routes. A recent PNAS study, “Egress Thresholds and Wildfire FataliƟes,” found that wildfire fataliƟes are sharply concentrated in communiƟes with few exits and decline steeply unƟl roughly six outward roads are available. The study explains that below this threshold, communi Ɵes are vulnerable to congesƟon, blockage, and simultaneous exposure to fire fronts because they lack sufficient road-network redundancy. For East Anaheim, the pracƟcal number of funcƟonal evacuaƟon exits may be much lower than the number of roads shown on a map. Under the Know Your Way plan, many evacuaƟon movements are directed toward a limited number of outbound corridors: Nohl Ranch Road toward the SR-55 freeway, Santa Ana Canyon Road toward the SR-91 freeway at Lakeview, and, depending on fire direcƟon, Weir Canyon Road and the SR-91 entrances. If a fire approaches Page 12 of 21 from the east, which is the historical paƩern residents are most concerned about, some corridors may be less usable or may direct residents toward the hazard. Mul Ɵple zones may therefore be compeƟng for the same limited outbound corridors. This is why the study should not count theoreƟcal roads as meaningful evacuaƟon exits unless they are independent, usable, and direcƟonally appropriate under the fire scenario being modeled. Requested revision: Require evaluaƟon of all zones and corridors affected by project traffic, including shared evacuaƟon routes, downstream boƩlenecks, adjacent zones, and reasonably foreseeable shadow evacuaƟon. The final study should also require a funcƟonal-egress redundancy analysis showing how many independent, usable outbound evacuaƟon corridors remain available under each wildfire scenario, and whether a project adds evacuaƟon demand to a community already constrained to too few func Ɵonal exits. 16. Apply the methodology to projects outside Very High Fire Hazard Severity Zones when they affect evacuaƟon routes serving High or Very High zones. The final study should avoid creaƟng a loophole where projects outside a mapped Very High Fire Hazard Severity Zone avoid evacuaƟon analysis even though they add vehicles to the same constrained evacuaƟon corridors. EvacuaƟon impact is a network issue, not merely a parcel- boundary issue. For example, if the East Anaheim Community Center near Weir Canyon Road and Santa Ana Canyon Road were converted to a high-density housing project, that project might not be required to include wildfire risk analysis if the analysis is based only on the parcel’s mapped fire- hazard designaƟon. However, that project would directly affect the evacuaƟon of thousands of homes by adding traffic to shared evacuaƟon corridors. Page 13 of 21 (Map showing East Anaheim Community Center as outside wildfire risk zones, but within the evacuaƟon corridor) Requested revision: Add the following applicability standard: Any project located in the Wildland-Urban Interface, in a High or Very High Fire Hazard Severity Zone, near a Very High Fire Hazard Severity Zone, or using evacuaƟon corridors serving High or Very High Fire Hazard Severity Zones shall be required to evaluate wildfire evacuaƟon impacts under the City’s wildfire evacuaƟon methodology. E. MiƟgaƟon Standards, Durability, and Enforceability 17. Require miƟgaƟon to be enforceable, durable, and maintained for the life of the project. The study idenƟfies infrastructure and operaƟonal measures such as signal interconnecƟvity, CCTV monitoring, evacuaƟon-specific signal Ɵming, emergency vehicle preempƟon, backup power, and flush strategies. Page 81 idenƟfies infrastructure recommendaƟons including signal interconnecƟvity, CCTV, and signal resiliency with secondary power sources such as generators or baƩeries. These measures should not be treated as theoreƟcal future improvements when evaluaƟng project impacts. If a project relies on these measures to reduce or offset evacua Ɵon impacts, they must be funded, installed, tested, operaƟonal, and maintained before the project is occupied. Page 14 of 21 The final study should also require miƟgaƟon to be durable for the life of the project. New housing or other development permanently adds people, vehicles, and evacua Ɵon demand to the community. Therefore, miƟgaƟon should not be temporary, one-Ɵme, or allowed to degrade without replacement. A mailing campaign may be forgo Ʃen within months. Public educaƟon may lose effecƟveness as residents move in and out of the area. BaƩeries for traffic signals may degrade over Ɵme. Cameras, communicaƟons systems, signs, and traffic-control equipment may become obsolete, fail, or lose funding. If these measures are used to jusƟfy a finding that a project’s evacuaƟon impact is less than significant, the City should require permanent maintenance, replacement, tesƟng, reporƟng, and funding obligaƟons. MiƟgaƟon should remain effecƟve for as long as the development remains occupied. Requested revision: The final study should require any miƟgaƟon relied upon in project modeling to be enforceable before occupancy and durable for the life of the project. This includes funding, installaƟon, tesƟng, maintenance, replacement schedules, backup-power tesƟng, staff training, public reporƟng, and a responsible party for long-term implementaƟon. Temporary outreach campaigns, one-Ɵme mailers, or equipment with finite service life should not be used as permanent miƟgaƟon unless there is an enforceable program to refresh, replace, and verify the miƟgaƟon over Ɵme. 18. DisƟnguish between baseline City obligaƟons and project-specific miƟgaƟon. Many recommended improvements appear to be communitywide safety needs, not merely project-specific miƟgaƟon. For example, page 81 recommends signal interconnecƟvity, CCTV monitoring, emergency vehicle preempƟon, and signal resiliency. Page 84 recommends educaƟon on evacuaƟon alerts and orders, expected pre-movement Ɵmes, and phased evacuaƟon raƟonale. These improvements should not be used to give developers credit for fixing condi Ɵons the City should already be addressing. A developer should not receive miƟgaƟon credit for improvements that already exist, are already funded, are already required, or are necessary to correct exisƟng evacuaƟon deficiencies. Requested revision: The final study should disƟnguish between baseline City obligaƟons and project-specific miƟgaƟon. Project miƟgaƟon credit should be limited to new, enforceable, project-related improvements that are not already funded, required, or needed to correct exisƟng deficiencies. Page 15 of 21 19. IdenƟfy whether assumed miƟgaƟon is installed, funded, tested, and operaƟonal. Any evacuaƟon modeling that assumes signal interconnecƟvity, CCTV, flush strategy, emergency vehicle preempƟon, backup power, changeable message signs, contraflow, or cell backup power should disclose whether those improvements currently exist. If they do not exist, the project should be modeled without them first. Any reliance on future improvements should be Ɵed to enforceable pre-occupancy condiƟons and long-term maintenance obligaƟons. Requested revision: Add a required “miƟgaƟon status table” for every project analysis showing whether each assumed improvement is exisƟng, funded, designed, installed, tested, operaƟonal, maintained, and enforceable. 20. Do not use acƟve signal control or flush strategies where the study shows they do not help. The study shows acƟve signal control and flush strategies improving Scenarios 3 through 6, but the acƟve-signal table is not shown for Scenarios 1 and 2, and the notes indicate that the strategy is most useful for area-specific phased evacuaƟon scenarios. If catastrophic all-zone scenarios are not improved by acƟve signal control, those measures should not be used to dismiss catastrophic-scenario impacts. Requested revision: The final study should clearly state that acƟve signal control and flush strategies may only be used as miƟgaƟon for scenarios and zones where modeling shows they reduce the specific project impact. 21. Do not allow qualitaƟve miƟgaƟon to offset quanƟtaƟve evacuaƟon-Ɵme impacts without substanƟal evidence. Some miƟgaƟon measures, such as public educaƟon campaigns or readiness outreach, may be useful. However, qualitaƟve miƟgaƟon should not be allowed to offset a quanƟtaƟve evacuaƟon-Ɵme exceedance unless there is substanƟal evidence showing that the measure changes evacuaƟon behavior enough to reduce the modeled impact. A public readiness campaign should not erase 20 minutes of added evacuaƟon delay unless there is evidence that it changes departure Ɵme, compliance, route behavior, or pre-movement behavior enough to offset that delay. Page 16 of 21 Requested revision: QualitaƟve miƟgaƟon should be allowed only where the impact is qualitaƟve or where substanƟal evidence connects the measure to a measurable evacuaƟon- performance benefit. Where modeling is possible, modeled impacts should require modeled miƟgaƟon. 22. Include project downsizing and density reducƟon as explicit miƟgaƟon opƟons. The miƟgaƟon discussion should include more than infrastructure, technology, and public outreach. The most direct way to reduce evacuaƟon impact may be to reduce the project itself. Requested revision: Add project downsizing, reduced residenƟal unit count, reduced occupancy, altered access, addiƟonal ingress/egress, relocaƟon of density away from constrained routes, and phased occupancy as explicit miƟgaƟon measures. F. Know Your Way: Specific Operational Concerns Requiring Validation 23. The final study should not rely on Know Your Way without addressing specific operational weaknesses. The earlier comments identify Know Your Way as an unvalidated operational assumption. This section explains why that issue deserves specific attention before the Dudek study is used to support future development approvals. The concern is not that phased evacuation is an improper goal. The concern is that the Dudek study appears to rely on Know Your Way functioning as intended, even though the plan depends on several real-world assumptions that have not been demonstrated through full-scale testing, public awareness, alert-system validation, traffic-control drills, or interagency evacuation exercises. If Know Your Way does not function as modeled, then any project-level evacuation conclusions that rely on phased compliance may significantly understate real-world evacuation risk. I. Human behavior during wildfire evacuations is unlikely to follow a perfect phased plan. Know Your Way appears to rely on residents receiving instructions, understanding their assigned zone, trusting the instructions, and following the assigned route under emergency conditions. That may be an appropriate planning objective, but it should not be assumed as the default real-world outcome. Page 17 of 21 During an actual wildfire, residents may panic, leave before their zone is ordered, attempt to retrieve children, check on elderly relatives, return home for pets or medication, ignore assigned routes, or evacuate based on smoke, flames, sirens, social media, or information from neighbors. Once the first evacuation alert is issued, residents in adjacent zones may reasonably assume they are also at risk and begin evacuating. The final study should therefore model partial compliance, noncompliance, early self- evacuation, shadow evacuation, and family-retrieval behavior rather than assuming that residents will evacuate only when, where, and how the City directs them. II. Public understanding of evacuation zones appears insufficient. Know Your Way depends on residents knowing their evacuation zone before an emergency occurs. However, many residents do not appear to know their zone, and the City has not demonstrated that residents have received repeated, direct, household-level education about their evacuation zone and assigned evacuation route. If the City attempted to evacuate one zone during a fast-moving wildfire, many residents outside that zone may evacuate anyway because they do not know their zone, do not trust that they are safe, or do not understand the difference between evacuation zones. The final study should require evidence of public education and zone awareness before assuming high levels of Know Your Way compliance. This could include annual mailed notices, refrigerator magnets, direct household mailers, public drills, school-based outreach, neighborhood meetings, and measured public-awareness surveys. III. Emergency communication assumptions should be tested and disclosed. The effectiveness of Know Your Way depends on clear, timely, and geographically accurate emergency communication. The final study should disclose whether Anaheim Alert has been recently tested for wildfire evacuation messaging, how often it has been used for actual wildfire or evacuation events, and whether residents have demonstrated that they understand zone- specific evacuation instructions. A text-based alert system may also reach people outside the intended evacuation area, or may be forwarded through social media without the original context. Once public social media amplifies the first evacuation message, the practical result may be broader panic or mass evacuation from multiple zones. The final study should therefore include communication-failure and over-notification scenarios, including delayed alerts, cell-service failure, power failure, residents not enrolled in Anaheim Alert, message forwarding on social media, and alerts that cause evacuation outside the intended zone. Page 18 of 21 IV. Traffic-control and staffing assumptions should be disclosed and tested. The final study should identify the actual traffic-control plan that would be used to implement Know Your Way during a wildfire. This includes who would staff traffic-control points, how quickly they can mobilize, where they would be stationed, what routes they would block or prioritize, how they would prevent inbound traffic, and how they would avoid creating new congestion with turn-around traffic. Blocking inbound traffic may be difficult or counterproductive if vehicles attempting to enter the area must turn around in the same limited roadway network being used for evacuation. It is also unrealistic to assume that all inbound traffic can simply be stopped, because parents, adult children, caregivers, and relatives may attempt to reach children, elderly residents, disabled residents, or family members who need help evacuating. As discussed in Point 12, family-retrieval behavior should be modeled as a foreseeable evacuation condition. Know Your Way should not assume that parents, caregivers, or relatives will comply with inbound traffic restrictions when children or vulnerable family members may be in the evacuation area. For example, a parent attempting to reach Anaheim Hills Elementary could encounter a closure at Serrano Avenue and Nohl Ranch Road, abandon a vehicle in panic, and continue on foot toward the school. Even one abandoned vehicle could block or narrow an egress lane, slowing outbound evacuation traffic. The final study should not assume successful traffic control unless the City discloses the plan, identifies staffing requirements, confirms mobilization time, and demonstrates that the plan can be implemented within the evacuation window. V. Vulnerable residents require a specific evacuation plan. Know Your Way appears to rely in part on residents helping neighbors. Neighbor-to-neighbor assistance is valuable, but it cannot substitute for a formal plan for elderly residents, disabled residents, medically fragile residents, residents without vehicles, and residents who need help evacuating. Many neighbors do not have the access, keys, medical knowledge, physical ability, or legal authority to assist vulnerable residents. Family members and caregivers may attempt to enter the evacuation area to help, which could conflict with traffic-control assumptions that restrict inbound movement. The final study should require a specific vulnerable-population evacuation component, including procedures for elderly residents, disabled residents, medically dependent residents, residents without transportation, and caregivers or relatives attempting to assist them. VI. The assigned route structure may send residents toward the hazard in some scenarios. Page 19 of 21 For East Anaheim, evacuation route usefulness depends heavily on fire origin, wind direction, and route availability. In the historical east-origin fire scenarios that most concern residents, some Know Your Way routing directs residents eastward toward Weir Canyon Road or toward corridors that could be closer to the hazard. A route that appears available on a static map may not be a safe or functional route under a specific ignition and wind scenario. The final study should evaluate whether assigned Know Your Way routes remain directionally appropriate under each modeled wildfire scenario. It should identify which routes become unsafe, compromised, counterintuitive, or likely to be ignored by residents who perceive they are being directed toward the fire. VII. Traffic signal timing should not be treated as a cure for gridlock. Signal timing, interconnectivity, CCTV, and flush strategies may improve evacuation performance in some scenarios. However, traffic signal timing has limited value once the network is already in gridlock or when downstream bottlenecks prevent vehicles from clearing intersections. The final study should clearly distinguish between conditions where active signal control improves evacuation and conditions where the roadway network is already saturated. Signal timing should not be used as mitigation unless modeling shows that it reduces the specific evacuation impact under the specific scenario being analyzed. VIII. Interagency route control must be addressed. East Anaheim evacuation depends in part on routes that connect to or pass through neighboring jurisdictions. During prior evacuations, residents have reported that the City of Orange blocked traffic into Orange at Serrano and Nohl Ranch Road, eliminating a critical evacuation path. Whether or not that action was legally justified during those events, the Dudek study should not assume that cross-jurisdictional routes will remain available unless the City has written interagency agreements and operational protocols. The final study should identify every evacuation route that depends on Orange, Caltrans, CHP, county agencies, or other jurisdictions. If a neighboring jurisdiction can close or restrict a route, that route should be modeled as unavailable in a sensitivity scenario unless a binding operational agreement confirms it will remain open for Anaheim evacuations. IX. Know Your Way should be validated before it is used to support future project approvals. The final study should require the City to validate Know Your Way before relying on it as a basis for less-than-significant evacuation findings. Validation should include public education, household-level zone notification, alert-system testing, tabletop exercises, traffic-control drills, interagency coordination exercises, school-day scenarios, vulnerable-population scenarios, and after-action reporting. Page 20 of 21 Requested revision: The final study should state that Know Your Way is an unvalidated operational assumption unless and until the City demonstrates that residents understand their zones, alerts can be delivered accurately and timely, traffic-control resources can be deployed within the required evacuation window, vulnerable residents can be assisted, neighboring jurisdictions will preserve agreed evacuation routes, and the plan has been tested through drills or real-world after-action evidence. Project-level evacuation analysis should include sensitivity scenarios for Know Your Way failure, partial compliance, shadow evacuation, inbound family/caregiver traffic, blocked cross-jurisdiction routes, communication failure, and directionally inappropriate routes. Conclusion The DraŌ Dudek Wildfire EvacuaƟon Study is a useful starƟng point, but it should not become a tool for approving addiƟonal development while only limiƟng how much worse each project makes evacuaƟon. The study should be revised so that the City first determines whether residents can evacuate safely under reasonably foreseeable wildfire condiƟons. The final study should require a life-safety margin, evaluate funcƟonal egress redundancy, analyze all affected zones and corridors, disclose modeling assumpƟons before project analysis is completed, preserve catastrophic and shadow-evacuaƟon scenarios, and require miƟgaƟon that is enforceable, durable, funded, tested, and maintained for the life of the project. The final study should also clearly state that Know Your Way is an operaƟonal assumpƟon, not a validated evacuaƟon outcome. Before Know Your Way is used to support future project approvals, the City should demonstrate that residents understand their zones, alerts can be delivered accurately and Ɵmely, traffic-control resources can be deployed within the required evacuaƟon window, vulnerable residents can be assisted, cross-jurisdicƟonal routes will remain available, and the plan has been tested through drills or real-world aŌer-acƟon evidence. New development creates permanent evacuaƟon demand. Therefore, miƟgaƟon must also be permanent, enforceable, maintained, and periodically verified. Temporary outreach, one-Ɵme educaƟon campaigns, or equipment that degrades over Ɵme should not be used to offset a permanent evacuaƟon impact unless the City requires ongoing funding, replacement, tesƟng, and public accountability for the life of the project. The goal should not be to determine how much addiƟonal evacuaƟon delay is acceptable. The goal should be to ensure that East Anaheim residents can survive a wildfire evacuaƟon. Page 21 of 21 References/Sources Dudek DraŌ Wildfire EvacuaƟon Study, City of Anaheim, June 2026 Fong, C. R., Broderick, C. W., Moritz, M. A., & Halpern, B. S. (2026). Egress Thresholds and Wildfire FataliƟes. Proceedings of the NaƟonal Academy of Sciences, 123(23), e2535081123. hƩps://doi.org/10.1073/pnas.2535081123 AQMD October 13, 2008 Santa Ana wind excepƟonal-event report