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General (08) Susana Barrios From:Concerned Anaheim Residents <concernedanaheimresidents@gmail.com> Sent:Monday, July 27, 2026 10:39 AM To:Cory Wilkerson Cc:Public Comment; City Attorney; City Clerk; Robert Fabela; Mike Lyster; Rudy Emami; Rafael Cobian; Ashleigh Aitken; Eric Anderson; Patrick Russell; mcid@anaheimpa.com Subject:\[EXTERNAL\] Request for Post-Release Public Technical Meeting, Online Access, and Extension of Comment Period – Draft Wildfire Evacuation Study You don't often get email from concernedanaheimresidents@gmail.com. Learn why this is important 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 Mr. Wilkerson, City Clerk, Mayor, and City Councilmembers, Please accept this request regarding the Draft Wildfire Evacuation Study and include it in the administrative record. Concerned Anaheim Residents respectfully requests that the City hold at least one additional post- release public technical meeting or workshop on the Draft Wildfire Evacuation Study before the Study is scheduled for City Council consideration. We also request that the public comment period remain open, or be reopened and extended, until after that meeting occurs and after the City publishes written responses to the questions and concerns raised by residents. The June 25, 2026 community meeting occurred before residents had access to the Draft Study. While that meeting allowed the City to introduce the topic, it did not provide residents a meaningful opportunity to review the actual 176-page draft, evaluate the methodology, examine the confidence-interval threshold, compare the presentation to the written report, or ask informed technical follow-up questions based on the released document. A pre-release meeting is not a substitute for post-release public engagement. This is especially important because the Draft Study is not merely informational. It proposes a repeatable CEQA framework and threshold methodology that may shape how future development projects in Anaheim’s fire-hazard areas are evaluated. Residents should have a meaningful opportunity to question the data, assumptions, modeling, legal framing, and proposed thresholds before the City Council is asked to adopt or rely on the Study. Request for Online Access and Accessibility Concerned Anaheim Residents also requests that any post-release meeting be made available online for residents who cannot physically attend. At minimum, the City should provide livestream access, remote participation, captioning or transcript access, a posted recording, the meeting presentation, and all handouts or technical materials in advance. 1 Residents who are elderly, disabled, medically vulnerable, working, caregiving, without transportation, or otherwise unable to attend in person should not be excluded from meaningful participation in a life- safety study affecting evacuation planning and future development review. Need for a Complete Public Question-and-Response Matrix We are also concerned that the City may not have maintained a complete public record of the questions, comments, and concerns raised at the June 25 meeting. Residents asked that unanswered questions be tracked and publicly answered. If the City did not create a complete question log, meeting transcript, recording, staff notes, or other record sufficient to reconstruct those questions and responses, that absence should be disclosed. The City should not rely on a pre-release meeting as evidence of meaningful public engagement if the questions, comments, and concerns raised at that meeting were not fully preserved, publicly posted, and answered. At minimum, the City should now prepare a public Question-and-Response Matrix using all available sources, including staff notes, presentation materials, emails, public comments, any City recordings, and resident-provided transcripts, recordings, or question lists. The Question-and-Response Matrix should include a complete, unabridged, and not selectively summarized list of substantive resident questions and comments raised at the June 25 meeting and during the public comment period, subject only to legally required redactions of personal contact information or private information. The Matrix should identify each substantive question or concern, the City’s response, whether the response is complete or partial, what supporting data or authority the City relies on, and what additional follow-up remains necessary. Concerned Anaheim Residents has prepared a resident-based list of questions, comments, and unresolved issues raised during and after the June 25 meeting and can provide that list to assist the City in preparing a complete Question-and-Response Matrix. The City should compare any resident-provided list against its own notes, records, staff recollections, public comments, and any available recordings to ensure that substantive questions and concerns are not lost. The City should not treat the current written comment period as a substitute for a public question- and-answer process. Written comments submitted before residents receive City responses do not provide the same opportunity as a post-release public meeting where residents can hear the City’s answers, ask follow-up questions, identify unresolved issues, and submit supplemental comments before Council action. The City should publish the Question-and-Response Matrix with enough time for residents to review the City’s answers before any staff report, Council agenda packet, public hearing, Council discussion, vote, or formal adoption of the Draft Study. Minimum Topics for the Requested Post-Release Meeting At a minimum, the requested post-release meeting should include: 1. A plain-language explanation of the confidence-interval threshold and how it would be used in future CEQA review. 2 2. Disclosure and explanation of the traffic data used, including the specific roadway segments and intersections counted, exact count dates, count hours, day of week, school-day or non-school- day status, seasonal context, whether counts reflected ordinary weekday peak conditions, whether the 6:00 p.m. to 7:00 p.m. community peak was captured, whether freeway congestion or SR-91 spillback was present, and whether commuter-bypass traffic on routes such as Cannon, Serrano, Santa Ana Canyon Road, Imperial Highway, Fairmont Boulevard, Weir Canyon Road, and related neighborhood access streets was counted, calibrated, and validated. 3. Disclosure of observed-versus-modeled turning movements, queue lengths, travel times, bottleneck locations, calibration results, validation results, and any assumptions used to adjust or normalize the data. 4. Discussion of all individual model runs, including whether any runs were excluded, rerun, adjusted, or treated as outliers. 5. Explanation of how the Study evaluates rare but severe evacuation outcomes, including gridlock, route failure, shadow evacuation, failed phasing, school pickup, family reunification, disabled residents, senior residents, and emergency access. 6. A zone-by-zone discussion of fire arrival time, route tenability, evacuation clearance time, and remaining safety margin. 7. Clarification of the timeline for when Dudek first provided preliminary findings, draft components, model results, or evacuation-time data to City staff. 8. A public written response to all substantive questions and comments raised at the June 25 meeting, with particular focus on questions that were not answered or were only partially answered. 9. Discussion of meaningful notice concerns, including how the City notified residents, which neighborhoods and Know Your Way zones were notified, when notice was provided, what methods were used, whether notices were sent in multiple formats and languages where appropriate, how the City verified effective reach, and how residents unable to attend the pre- release meeting were given equivalent access to the same information. 10. Posting of the meeting presentation, recording, transcript, written Question-and-Response Matrix, and any revised materials in a publicly accessible location. 11. Sufficient time after the second post-release public technical meeting for residents to submit supplemental comments before any Council staff report, agenda packet, public hearing, Council discussion, vote, or formal adoption. The City should not present its first comprehensive responses to resident questions only in a Council staff report or during the same meeting at which Council is asked to vote. Residents should have a meaningful opportunity to review the City’s responses and provide feedback before the matter is placed before Council for decision. Outreach, Meaningful Notice, and Participation Concerns The City’s reported outreach numbers should also be evaluated in context. The City has stated that outreach included notice to approximately 16,000 properties or residential units in Anaheim Hills, with approximately 100 workshop attendees and 250 survey responses. If the City relies on a different outreach denominator, such as 18,000 notices, properties, residential units, or residents, the City should disclose the exact figure, source, geography, and method used. These figures may show that outreach activity occurred, but they do not, by themselves, demonstrate meaningful resident awareness, understanding, access, or participation. Even using the City’s own 3 residential-unit figure as the denominator, the reported workshop attendance and survey responses appear to represent only a small fraction of the affected residential-unit base. The City should explain the denominator it used to evaluate outreach effectiveness, including affected residents, households, residential units, and Know Your Way zones. Notice to properties or residential units may show outreach activity, but it does not by itself demonstrate that the affected resident population received meaningful notice, understood the significance of the Draft Study, or had a realistic opportunity to participate. If the Draft Study is intended to become a repeatable CEQA framework for future development projects throughout Anaheim Hills and other Anaheim fire-hazard areas, then public engagement should be commensurate with that significance and reflective of the affected resident population across all relevant Know Your Way zones. A methodology that may affect future evacuation analysis, development review, mitigation requirements, and public-safety findings should not proceed to Council based only on pre-release outreach, limited participation, and a short post-release written comment period. To the extent the City relied on community members, neighborhood networks, or private social-media groups to help circulate information, that outreach may be helpful as a supplement, but it cannot substitute for official, accessible, City-controlled notice. Many affected residents may not use Facebook or other social media, may not belong to a particular private group, may not see posts due to algorithmic limitations, or may not understand that an unofficial post relates to a formal City process with potential CEQA and future-development consequences. Multi-Department Emergency Operations Questions Remain Publicly Unresolved The June 25 meeting was addressed primarily by Public Works and traffic/engineering staff, with additional participation or comments from elected and communications representatives. However, several operational evacuation questions involve multi-department coordination among Public Works, Traffic Engineering, Anaheim Fire & Rescue, Anaheim Police Department, Communications, the Emergency Operations Center, Caltrans, CHP, school districts, and other partner agencies. Residents were not provided a dedicated public opportunity to receive coordinated answers from the departments and agencies responsible for implementing evacuation operations in real time. Several questions remain publicly unresolved regarding fire-response assumptions, evacuation implementation, emergency staffing, traffic control, contraflow timing, signal operations, alert procedures, school evacuation, vulnerable residents, emergency access, route tenability, and interagency coordination. This concern is not directed at any individual official or department representative. Rather, it identifies that the Draft Study relies heavily on operational assumptions and multi-agency coordination, while the public meeting did not provide residents a complete opportunity to test those assumptions with the departments responsible for carrying them out. Requested Action Meaningful public engagement requires more than a pre-release presentation. It requires that affected residents be able to review the document, understand the proposed threshold, ask questions based on the released materials, hear the City’s answers publicly, ask follow-up questions, and submit informed comments before the Study is brought to Council. 4 The City has repeatedly described the Study as transparent, consistent, and technically defensible. If the Study and its proposed methodology can withstand scrutiny, a post-release public technical meeting should strengthen public confidence rather than delay or undermine the process. For these reasons, Concerned Anaheim Residents respectfully requests that the City: 1. Extend or reopen the public comment period until after a post-release public technical meeting is held; 2. Publish a complete Question-and-Response Matrix addressing questions and comments raised at the June 25 meeting and during the public comment period; 3. Hold a second post-release public technical meeting after the Question-and-Response Matrix is published; 4. Allow residents to ask follow-up questions at that meeting based on the released Draft Study, the City’s written responses, and the underlying data; 5. Make the meeting available online with livestream access, remote participation, captioning or transcript access, posted recording, and posted materials; 6. Keep the public comment period open, or reopen and extend it, for a reasonable period after the second meeting so residents can submit informed supplemental comments before any Council vote or formal adoption; 7. Confirm that all comments, questions, written responses, recordings, transcripts, presentations, and supporting materials will be included in the administrative record; and 8. Confirm the City staff member or department responsible for coordinating this request and responding publicly. Please confirm receipt of this request and confirm whether the City will extend or reopen the comment period to allow meaningful post-release public engagement. Respectfully, The Stakeholder Audit Team A Collective of Concerned Anaheim Hills Resident Stakeholders 5 Susana Barrios From:Concerned Anaheim Residents <concernedanaheimresidents@gmail.com> Sent:Monday, July 27, 2026 11:19 PM To:Cory Wilkerson Cc:Public Comment; City Attorney; City Clerk; Robert Fabela; Mike Lyster; Rudy Emami; Rafael Cobian; Ashleigh Aitken; Eric Anderson; Patrick Russell; mcid@anaheimpd.com Subject:\[EXTERNAL\] Timely Supplemental Public Comment Submitted Before 11:59 p.m. Deadline – Draft Wildfire Evacuation Study You don't often get email from concernedanaheimresidents@gmail.com. Learn why this is important 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 Mr. Wilkerson, City Clerk, Mayor, and City Councilmembers, Please accept this timely supplemental public comment regarding the Draft Wildfire Evacuation Study and include it in the administrative record. This supplemental comment is being sent to the same City recipients as the earlier procedural comment submitted today so that the record remains complete and connected. This supplemental comment is being submitted before 11:59 p.m. on July 27, 2026, consistent with the City of Anaheim’s public representation that comments on the Draft Wildfire Evacuation Study would be accepted until 11:59 p.m. today. This comment supplements the earlier public comment submitted today by Concerned Anaheim Residents regarding the need for a post-release public technical meeting, written responses, online access, and an extended or reopened comment period. Because this Study involves technical wildfire-evacuation modeling, CEQA methodology, traffic assumptions, public-safety operations, and future development-review thresholds, this supplemental comment is organized in plain language so that residents, City Councilmembers, City staff, consultants, and the public can evaluate the issues without needing specialized traffic-engineering, fire-modeling, or statistical terminology. Nothing in this comment is intended as a personal criticism of any individual City official, staff member, consultant, or department. The purpose is to identify technical, procedural, and public-safety issues that require clarification before the Draft Study is adopted or relied upon as a CEQA threshold or repeatable project-review framework. The central concern is this: the Draft Study may be useful as a planning and modeling document, but the City has not yet demonstrated that its proposed confidence-interval methodology is a valid wildfire life-safety threshold, CEQA significance threshold, or repeatable basis for evaluating future Anaheim Hills development projects. 1. Confidence Interval Methodology Should Not Be Treated as a Safety Threshold Without Further Justification 1 The Draft Study appears to convert model run-to-run variability into a project significance threshold. During the pre-release presentation and discussion, the confidence interval was described in simplified terms as “no change,” “normal variation,” or the threshold above which a project would create an impact. That framing requires further scrutiny. A confidence interval may help describe uncertainty or variation in repeated model runs. However, a confidence interval does not automatically prove that a project causes no meaningful delay, no safety impact, or no CEQA-significant effect. A more accurate plain-language description would be: A project increase within the confidence interval may be difficult to distinguish from model variability under the City’s chosen analysis. That is not the same as saying: The project caused no meaningful change, no resident delay, no safety risk, or no impact. The City should not treat statistical detectability as equivalent to wildfire evacuation safety. Model uncertainty should not become an allowance for development-created delay unless the City demonstrates, with substantial evidence, that the selected threshold corresponds to safe and reasonable evacuation conditions. Before adoption, the City should explain: 1. Why the confidence interval is an appropriate CEQA significance threshold; 2. Why the full width of the baseline confidence interval appears to be used as the allowable project- related increase; 3. Whether the threshold measures safety or only model variability; 4. Whether a project can be considered less than significant if existing evacuation conditions are already unsafe; 5. Whether a project-related delay inside the confidence interval could still reduce an already inadequate safety margin; 6. How the City will evaluate contrary evidence showing that a project may create or worsen evacuation risk even if the increase falls within the proposed threshold. A confidence interval may be a useful modeling tool, but it should not be adopted as a wildfire life- safety threshold unless the City demonstrates why it protects residents under real evacuation conditions. 2. Same Random Seed Sets and Paired Baseline/Project Differences Should Be Disclosed The Draft Study indicates that baseline and project scenarios use the same random seed set to ensure comparability. In plain language, a random seed is the starting input a computer uses to create one 2 repeatable “virtual evacuation day.” Different seeds create different versions of driver behavior, traffic flow, lane changes, gaps, hesitations, queues, and other model variation. If the same random seeds are used for baseline and project scenarios, then each virtual evacuation condition can be compared directly:  Baseline Run 1 without project;  Project Run 1 with project;  Difference caused by the project in that matching run. This matters because the most direct question is not only how much the baseline varies from run to run. The more project-specific question is: For the same virtual evacuation conditions, how much delay did the project add? For example, if baseline runs vary from 165 to 200 minutes, but a project adds four minutes in every matched run, the baseline variability does not make the project-created delay disappear. The project effect may be consistent even if the baseline varies. The City should disclose: 1. All baseline run results; 2. All project run results; 3. The random seed used for each run; 4. The paired project-minus-baseline difference for each matching run; 5. Whether the City analyzed the distribution of project-caused differences; 6. Whether the City calculated confidence intervals around the project-caused differences; 7. Why the threshold appears to be based on baseline variability rather than the paired distribution of project-related delay. Baseline variability alone does not prove that a project-related increase is harmless, especially if the project adds delay consistently across paired runs. 3. Tail-Risk Outcomes Must Be Evaluated, Not Averaged Away In a wildfire evacuation, the tail of the distribution can matter more than the average because life safety may depend on whether even a relatively uncommon combination leaves residents trapped before fire reaches roads. The Study should not focus only on average evacuation time or mean project-related delay. It should also evaluate severe but plausible outcomes, including: 1. Gridlock; 2. Queue spillback; 3. Route failure; 4. Failed phased evacuation; 5. Increased shadow evacuation; 6. Freeway congestion or SR-91 spillback; 3 7. Stalled vehicles or crashes; 8. Signal failure; 9. Communication failure; 10. Emergency-vehicle conflicts; 11. Parents driving toward schools; 12. Family reunification traffic; 13. Smoke-reduced speeds; 14. Delayed public warning; 15. Delayed traffic-control deployment; 16. Road tenability loss before clearance. The City’s commute analogy may help explain that simulation results vary. However, ordinary commute variability is not an adequate analogy for wildfire life-safety risk. In normal commuting, an unusually long travel time may be treated as an outlier. In a wildfire evacuation, a severe congestion outcome may be the most important result to understand. The City should disclose whether any model runs were excluded, rerun, adjusted, replaced, corrected, or treated as outliers. If any run was excluded, the City should identify the run, the predefined exclusion criterion, the technical reason for exclusion, who approved the exclusion, and the results with and without the excluded run. A severe evacuation run should not be discarded merely because it falls outside the central tendency of repeated model runs. 4. Grandison Research Should Not Be Used Beyond What It Establishes The Draft Study’s confidence-interval approach should be carefully distinguished from the purpose of the evacuation-modeling literature it appears to rely on. Grandison and colleagues are credible evacuation-modeling researchers. The concern is not their qualifications. The concern is whether their work is being applied beyond what it establishes. Grandison’s work uses confidence intervals to evaluate model precision and convergence — in other words, whether enough random evacuation simulations have been run and whether the modeled estimate is stable enough. That is different from using the full width of a baseline confidence interval as an allowable development-created delay. The City should clarify whether the cited confidence-interval research supports: 1. A precision/convergence test for repeated simulations; 2. A CEQA significance threshold; 3. A wildfire life-safety standard; 4. A land-use entitlement threshold; 5. An allowable increase in evacuation delay. These are not the same concepts. 4 Confidence intervals may help determine whether enough simulation runs were performed. They do not automatically establish that project-created delay within the baseline confidence interval is safe, insignificant, or legally acceptable. 5. Existing Unsafe Conditions Cannot Be Treated as an Acceptable Baseline The Draft Study should evaluate whether existing evacuation conditions are already unsafe. It is not enough to ask whether a future project adds more delay than the proposed confidence-interval threshold. A project can worsen an already unsafe condition even if the additional delay appears numerically small. A project can reduce an already inadequate safety margin. A project can add residents, vehicles, visitors, employees, or vulnerable populations into an area that already may not evacuate safely before fire, smoke, congestion, or route failure creates untenable conditions. The City should answer the following threshold question: Can a project be considered less than significant if existing evacuation clearance times already exceed fire-arrival time, route-tenability time, or safe evacuation windows? Before adopting the Study, the City should provide zone-by-zone safety information, including: 1. Existing evacuation clearance time; 2. Fire arrival time; 3. Road and route tenability time; 4. Warning and alert issuance time; 5. Resident pre-movement and preparation time; 6. Project-added delay; 7. Remaining safety margin before project; 8. Remaining safety margin after project; 9. Remaining safety margin after proposed mitigation. The Study should not treat existing danger as acceptable merely because it is the baseline. 6. Zone-by-Zone Safety Margins Should Be Provided The City should provide a safety-margin framework that residents can understand. In plain language, the relevant question is: How much time is available before a route becomes unsafe, and how much time do residents actually need to receive warnings, prepare, load vehicles, enter the road network, and clear the area? A useful framework would compare: 5 Time before the route becomes unsafe minus warning time, preparation time, loading time, and travel/clearance time equals remaining safety margin. If the result is negative, the area does not clear in time. If the result is very small, the area may be highly vulnerable to ordinary real-world disruptions, including delay, confusion, school pickup, elderly or disabled residents, stalled vehicles, smoke, panic, or traffic-control limitations. The City should identify for every relevant zone and scenario: 1. Ignition location; 2. Fire progression timing; 3. Fire arrival time; 4. Ember exposure and spot-fire timing, if applicable; 5. Time when routes become untenable due to flame, heat, smoke, embers, falling debris, congestion, or emergency access conflict; 6. Warning and alert timing; 7. Resident pre-movement assumptions; 8. Vehicle-loading assumptions; 9. Evacuation clearance time; 10. Emergency access needs; 11. Remaining safety margin; 12. Whether the project reduces that safety margin. A model that estimates evacuation time but does not clearly compare that time to route tenability and fire-threat timing does not fully answer the life-safety question. 7. Ember Cast, Spot-Fire Timing, and Fire-Progression Mapping Require Clarification The Draft Study acknowledges that structures may be threatened not only by direct flame contact, but also by radiant heat, ember cast, ember intrusion, wind-transported embers, and short-range spotting. This is important because wind-driven wildfires can threaten homes and communities through embers and spot fires ahead of the main fire front. For that reason, the City should clarify whether Figures 7 through 9 and the associated fire-progression timing analysis incorporate ember spotting, ember arrival, spot-fire ignition, and structure-to-structure ignition risk, or whether they primarily represent main fire-front progression and arrival contours. This distinction matters because the Draft Study appears to use fire-progression modeling to inform evacuation procedures, trigger points, firefighter safety zones, escape routes, and lead time needed for notification and evacuation. If the Study estimates structure exposure or evacuation lead time primarily from main fire-front arrival, without separately evaluating ember cast and spot-fire ignition timing, the Study may overestimate the time available for warning, preparation, evacuation, traffic control, and emergency response. 6 The City should disclose: 1. Whether FlamMap spotting capability was used in the fire-progression modeling; 2. The spotting probability, spotting delay, ember transport, ember ignition, and spot-fire assumptions used, if any; 3. Whether ember arrival times were mapped separately from main fire-front arrival times; 4. Whether spot fires ahead of the main fire front were modeled as potential evacuation triggers or route-tenability constraints; 5. Whether Figures 7 through 9 show only fire-front progression or also incorporate ember-driven spot-fire exposure; 6. Whether the 500-foot structure-buffer analysis accounts for ember cast and spot-fire ignition, or only proximity to modeled fire progression; 7. Whether the zone-by-zone evacuation timing analysis changes if ember cast or spot-fire ignition creates earlier exposure than the main fire front; 8. Whether road tenability was evaluated for ember exposure, smoke, radiant heat, direct flame contact, spot-fire activity, and structure-to-structure spread. The City should not adopt the Draft Study as a CEQA wildfire-evacuation threshold or project- review framework until it clearly explains how ember-driven ignition risk and spot-fire timing are incorporated into evacuation trigger points, route availability, structure-exposure timing, and safety-margin analysis. 8. Fire Scenario and Wind Assumptions Need Further Explanation The Draft Study should also explain the basis for its selected fire-weather assumptions and whether additional sensitivity testing was performed. The City should disclose: 1. Why the selected wind speed was chosen; 2. Whether that wind speed reflects average, severe, extreme, or historical Santa Ana conditions; 3. Whether higher wind speeds or gust conditions were tested; 4. Whether spotting and ember cast were tested under stronger winds; 5. Whether multiple simultaneous ignitions were considered; 6. Whether fires from additional plausible ignition points were modeled; 7. Whether route-loss scenarios were modeled; 8. Whether smoke impacts on roadway capacity and speed were modeled; 9. Whether the conclusions would change under more severe but still plausible fire-weather conditions. The City should not rely on a narrow set of fire scenarios if more severe but plausible conditions could produce materially different evacuation risk. 9. Traffic Data, Calibration, and Model Transparency Are Essential The Draft Study should disclose the traffic data underlying the model so that residents and independent reviewers can evaluate whether the model reflects actual Anaheim Hills conditions. 7 This is especially important because residents have previously raised concerns that traffic studies may use count windows or assumptions that do not reflect actual community peak conditions. The City should disclose: 1. The specific roadway segments counted; 2. The specific intersections counted; 3. Exact count dates; 4. Count hours; 5. Day of week; 6. School-day or non-school-day status; 7. Seasonal context; 8. Whether ordinary weekday peak conditions were captured; 9. Whether the 6:00 p.m. to 7:00 p.m. community peak was captured; 10. Whether SR-91 congestion or spillback was present; 11. Whether freeway incidents were present; 12. Whether special events were present; 13. Whether commuter-bypass traffic and freeway-avoidance traffic were captured, including but not limited to Cannon Street, Serrano Avenue, Imperial Highway, Santa Ana Canyon Road, Weir Canyon Road, Gypsum Canyon Road, La Palma Avenue, Yorba Linda Boulevard, Fairmont Boulevard, Canyon Rim Road, Nohl Ranch Road, and related neighborhood access streets; 14. Raw turning-movement counts; 15. Raw traffic volumes; 16. Observed queue lengths; 17. Observed travel times; 18. Modeled queue lengths; 19. Modeled travel times; 20. Calibration results; 21. Validation results; 22. Adjustments or normalized data; 23. Model network files; 24. Demand matrices; 25. Route assignment assumptions; 26. Whether the model results were independently peer reviewed. Residents cannot evaluate whether the model reflects actual Anaheim Hills evacuation conditions without the traffic counts, calibration, validation, and observed-versus-modeled comparisons. 10. Commuter Bypass, SR-91 Spillback, Adjacent-Jurisdiction Traffic, and Freeway-Access Routes Should Be Specifically Addressed The Study should clearly demonstrate whether current commuter-bypass behavior, SR-91 congestion, adjacent-jurisdiction traffic, and freeway-access patterns were included in the traffic model. Residents have repeatedly raised concerns that drivers use Anaheim Hills roadways to bypass freeway congestion and access SR-91 ramps, including routes such as Cannon Street to Imperial Highway, 8 Imperial Highway to Santa Ana Canyon Road, Santa Ana Canyon Road to Weir Canyon Road, Weir Canyon Road to Gypsum Canyon Road, La Palma Avenue to Weir Canyon Road, La Palma Avenue to the Gypsum Canyon freeway entrance, Yorba Linda Boulevard toward SR-91 access, and other routes involving Cannon, Serrano, Imperial, Santa Ana Canyon, Weir Canyon, Gypsum Canyon, La Palma, and related corridors. If these patterns are not counted, calibrated, and validated, the evacuation model may understate congestion at the exact times, road segments, intersections, and freeway-access points that matter most. The City should answer: 1. Were Cannon Street, Serrano Avenue, Imperial Highway, Santa Ana Canyon Road, Weir Canyon Road, Gypsum Canyon Road, La Palma Avenue, Yorba Linda Boulevard, Fairmont Boulevard, Canyon Rim Road, Nohl Ranch Road, and related neighborhood access streets included in the modeled network? 2. Were counts taken at the intersections and roadway segments where commuter-bypass and freeway-access traffic enter, exit, or cut through Anaheim Hills? 3. Were freeway-bypass commuter patterns included, including traffic traveling from or through Yorba Linda and other adjacent jurisdictions toward SR-91 access points? 4. Were SR-91 eastbound and westbound bottlenecks, ramp queues, freeway incidents, and spillback conditions included? 5. Were routes such as Cannon-to-Imperial, Imperial-to-Santa Ana Canyon, Santa Ana Canyon-to- Weir Canyon, Weir Canyon-to-Gypsum Canyon, La Palma-to-Weir Canyon, La Palma-to-Gypsum Canyon, and Yorba Linda Boulevard-to-SR-91 access evaluated? 6. How did the Study account for commuters entering, passing through, or rerouting within Anaheim Hills during evacuation conditions? 7. What happens if SR-91 ramps are congested, closed, metered, blocked, or unavailable? 8. What happens if freeway congestion spills back into local evacuation routes? 9. What happens if inbound commuter traffic conflicts with outbound evacuation traffic? A wildfire evacuation study for Anaheim Hills should not assume away freeway-related congestion, commuter-bypass traffic, adjacent-jurisdiction traffic, route spillback, or freeway-access conflicts without disclosing the data and validation supporting that assumption. 11. Emergency-Response Assumptions Should Not Be Treated One-Sidedly The Study excludes many emergency actions from the model because they are uncertain, incident- specific, or difficult to predict. That may be reasonable as a modeling choice. However, the City has also repeatedly reassured residents that real-world emergency actions would likely improve evacuation conditions. That framing treats uncertainty unevenly if the Study excludes favorable emergency actions from the model but then relies on those same unmodeled actions to reassure the public. The City should equally consider factors that may worsen evacuation conditions, including: 9 1. Delayed police deployment; 2. Delayed fire response; 3. Insufficient staffing; 4. Blocked routes; 5. Stalled vehicles; 6. Crashes; 7. Signal failures; 8. Communication failures; 9. Smoke-reduced speeds; 10. Simultaneous regional incidents; 11. Failed phased evacuation; 12. Greater-than-assumed shadow evacuation; 13. Parents driving toward schools; 14. Residents trying to retrieve pets or family members; 15. Inbound emergency vehicles conflicting with outbound evacuation traffic. It is reasonable to say actual emergency response may improve conditions. It is not reasonable to present that favorable direction as nearly assured without equally evaluating factors that may worsen conditions. 12. Multi-Department Emergency Operations Questions Remain Publicly Unresolved The June 25 meeting was addressed primarily by Public Works and traffic/engineering staff, with additional participation or comments from elected and communications representatives. However, several operational evacuation questions involve multi-department coordination among Public Works, Traffic Engineering, Anaheim Fire & Rescue, Anaheim Police Department, Communications, the Emergency Operations Center, Caltrans, CHP, school districts, care facilities, mutual-aid partners, and other agencies. Residents were not provided a dedicated public opportunity to receive coordinated answers from the departments and agencies responsible for implementing evacuation operations in real time. Several questions remain publicly unresolved, including: 1. How quickly can contraflow be implemented? 2. Which roads have contraflow plans? 3. Who staffs each traffic-control point? 4. How many officers or personnel are needed? 5. Where are personnel staged? 6. How quickly can personnel arrive during a fire? 7. What happens if routes are blocked before staff arrives? 8. What signal systems are currently operational? 9. What cameras and remote controls currently exist? 10. Which improvements are currently funded and operational versus merely recommended? 11. How will SR-91 ramps be controlled? 12. How will inbound traffic be prevented or managed? 10 13. How will parents, schools, elderly residents, disabled residents, medically vulnerable residents, pets, and care facilities be handled? 14. How will emergency vehicles enter while residents evacuate? 15. What happens if traffic-control measures are unavailable? 16. Has the system been field-tested under realistic evacuation conditions? The Draft Study relies heavily on operational assumptions and multi-agency coordination, but residents have not yet been provided a complete public opportunity to test those assumptions with the departments and agencies responsible for carrying them out. 13. Pre-Release Statements Should Be Reconciled with the Draft Study and Supporting Data The City should reconcile assertions made during the pre-release June 25 meeting and presentation with the language, data, and assumptions in the Draft Study. Residents were asked to hear and react to several important statements before they had access to the 176-page Draft Study, the technical appendices, the model inputs, the model outputs, or the underlying traffic data. Those statements included, among others, that the Study was transparent, consistent, technically defensible, intentionally conservative, required by CEQA in its chosen form, and that the confidence interval would function as the City’s proposed significance threshold. Because those assertions were made before residents could review the Draft Study, the City should publish a written comparison identifying: 1. Each material assertion made during the June 25 presentation regarding CEQA requirements, Attorney General guidance, emergency-response assumptions, confidence intervals, traffic modeling, fire progression, evacuation timing, and future project review; 2. The specific page, table, appendix, model output, data source, or legal authority in the Draft Study supporting each assertion; 3. Whether the assertion reflects a legal requirement, a City policy choice, a consultant recommendation, a modeling assumption, or a professional judgment; 4. Whether any assertion made during the presentation was simplified, incomplete, or different from the written Draft Study; 5. Whether public comments have identified corrections or qualifications that should be added before Council consideration. A pre-release explanation should not become the public’s only opportunity to question the City’s framing. Residents should be able to compare the City’s pre-release statements with the released document, receive written answers, ask follow-up questions, and submit supplemental comments before any Council staff report, hearing, discussion, vote, or formal adoption. 14. CEQA, Attorney General Guidance, and City Policy Choices Should Be Clearly Distinguished 11 The City was broadly correct that CEQA requires disclosure and that the Attorney General encourages evacuation-related thresholds. However, the City should not present discretionary methodological choices as though they are legally mandated. The City should clearly distinguish between: 1. What CEQA requires; 2. What Attorney General guidance recommends; 3. What the City selected as a policy choice; 4. What Dudek recommended as a consultant methodology; 5. What assumptions were chosen for modeling convenience or consistency; 6. What assumptions were selected because they reflect actual Anaheim Hills conditions. The City should clarify whether CEQA or Attorney General guidance specifically requires: 1. Use of the full width of a baseline confidence interval as the significance threshold; 2. Treatment of project delays within the confidence interval as “no change”; 3. The exact emergency-response assumptions used; 4. The exact fire-weather assumptions used; 5. The exact traffic-count windows used; 6. The exact number of model runs used; 7. The specific treatment of existing unsafe evacuation conditions. The City should clearly distinguish between legal requirements, professional judgment, consultant methodology, and discretionary policy choices. 15. Future Anaheim Hills Development Projects, Festival, Deer Canyon Preserve, Cumulative Development, and Timing Transparency The Draft Study is not merely an academic exercise. It appears intended to create a repeatable framework for evaluating future development projects in Anaheim Hills, including future CEQA wildfire- evacuation analysis, project-level thresholds, mitigation requirements, and public-safety findings. That makes the timing, adoption, and application of the Study especially important. Residents raised wildfire-evacuation concerns during the City’s consideration of the controversial Festival proposal and requested that the City wait until the wildfire-evacuation study was available before proceeding. The Festival project was approved before residents had access to the Draft Study and before residents could evaluate whether the City’s proposed future project-review methodology would have changed, clarified, or affected the evacuation analysis for that project. Residents are also concerned that the timing of the Study’s release, adoption, and application — and whether it is applied consistently to pending and future Anaheim Hills development proposals — could materially affect projects such as Festival, SALT Development: Deer Canyon Preserve, Builder’s Remedy Project Proposal, and other major development proposals in wildfire-evacuation areas. Depending on when and how the City applies this methodology, the Study could affect whether a project is evaluated 12 under the proposed confidence-interval threshold, whether impacts are characterized as significant or less than significant, whether mitigation is required, whether cumulative evacuation risk is recognized, and whether public-safety concerns are treated as a basis for further review. This concern is not an assertion that any individual intentionally delayed public release of the Study or intends to apply it inconsistently. Rather, it is a request for transparency because the timing of the Study’s release and adoption may affect whether residents, decisionmakers, and the public can meaningfully evaluate wildfire-evacuation issues before major Anaheim Hills development decisions are made. The City should disclose: 1. When Dudek first provided preliminary findings, draft components, evacuation-time results, threshold concepts, model outputs, or methodology recommendations to City staff; 2. Which City departments, consultants, attorneys, or officials received those materials; 3. Whether any portion of the Study, methodology, modeling results, or threshold approach was available before the Festival hearings or votes; 4. Whether any preliminary findings or draft components were discussed internally in connection with Festival, SALT Development: Deer Canyon Preserve, Builder’s Remedy Project Proposal, Builder’s Remedy issues, or other pending Anaheim Hills development proposals; 5. Whether the public release date of the Draft Study was affected by the timing of the Festival proposal, SALT Development: Deer Canyon Preserve, Builder’s Remedy Project Proposal, Council hearings, project approvals, or any pending development application; 6. Whether the City intends to apply the Draft Study, the final Study, or the proposed confidence- interval threshold to SALT Development: Deer Canyon Preserve, Builder’s Remedy Project Proposal, or other pending Anaheim Hills development proposals; 7. If the Study will apply to SALT Development: Deer Canyon Preserve, Builder’s Remedy Project Proposal, or other pending proposals, when and how it will apply; 8. If the Study will not apply to SALT Development: Deer Canyon Preserve, Builder’s Remedy Project Proposal, or other pending proposals, why not; 9. Whether Festival would pass under the proposed confidence-interval methodology if it were evaluated today; 10. If the City does not know whether Festival would pass under the proposed methodology, why the project has not been run through the model; 11. Whether Festival’s approved traffic and evacuation demand will now be included in the baseline for future Anaheim Hills projects; 12. Whether SALT Development: Deer Canyon Preserve, Builder’s Remedy Project Proposal, or other pending or proposed projects would be evaluated against a baseline that already includes Festival; 13. Whether using approved but not-yet-built projects as part of the future baseline could allow evacuation congestion to increase incrementally while each later project is evaluated against a progressively more congested baseline; 14. How the City will prevent the proposed methodology from normalizing cumulative evacuation risk over time; 15. Whether adoption timing could affect which projects are analyzed under the new framework and which projects are not; 13 16. What application number, case number, entitlement number, or development-review identifier the City has assigned to SALT Development: Deer Canyon Preserve, Builder’s Remedy Project Proposal, if any, and where that identifier is publicly posted. The City should also address how it treats inactive but entitled uses in the baseline. If inactive uses are modeled as active baseline traffic, a future project may appear to create less impact than residents experience under real-world current conditions. The City should disclose: 1. What traffic was assumed for inactive or underused commercial uses; 2. What evidence supports those assumptions; 3. Whether actual observed traffic was also analyzed; 4. Whether sensitivity testing was performed using real-world current conditions; 5. How conclusions change under actual current traffic conditions. Because this Study is intended to guide future Anaheim Hills development review, the City should not adopt it without disclosing when the methodology, model results, threshold concepts, and evacuation findings were first available internally, whether that timing affected public or Council review of the Festival proposal, and whether the Study will be applied to SALT Development: Deer Canyon Preserve, Builder’s Remedy Project Proposal or other pending Anaheim Hills development proposals. 16. Outreach and Meaningful Notice Concerns Remain Relevant to the Technical Record Concerned Anaheim Residents separately requested a post-release public technical meeting, online access, written responses, and an extended or reopened comment period. Those procedural issues are also relevant to the technical record because residents cannot meaningfully evaluate a technical study without access to the document, the data, the assumptions, and the City’s answers. The City’s reported outreach numbers may show that outreach activity occurred, but they do not, by themselves, demonstrate meaningful resident awareness, understanding, access, or participation. The City should explain: 1. How many residents, households, properties, residential units, and Know Your Way zones were affected; 2. Which denominator the City used to evaluate outreach effectiveness; 3. Whether outreach reached the entire affected resident population across Anaheim Hills; 4. How residents unable to attend the pre-release meeting were given equivalent access to the same information; 5. Whether the presentation, transcript, recording, questions, and answers were posted in a searchable public location; 6. Whether the City maintained a complete question log; 7. Whether resident questions will be publicly answered before Council action. 14 If the Draft Study is intended to become a repeatable CEQA framework for future development projects throughout Anaheim Hills and any other Anaheim areas where the City intends to apply this wildfire-evacuation methodology, then public engagement should be commensurate with that significance and reflective of the affected resident population across all relevant Know Your Way zones. 17. Independent Multidisciplinary Peer Review Should Occur Before Adoption Before the City adopts or relies on the Draft Study as a CEQA significance threshold or repeatable project-review framework, the Study should receive independent multidisciplinary peer review. At minimum, independent review should include: 1. A statistician experienced in random simulation models; 2. A transportation microsimulation or evacuation-modeling expert; 3. A wildfire-behavior specialist; 4. A fire-protection engineer; 5. An emergency-operations specialist; 6. An accessibility, disability, and access-and-functional-needs specialist; 7. CEQA counsel not involved in preparing or defending the methodology; 8. Local operational input from Fire, Police, Public Works, Emergency Operations, Caltrans, CHP, school districts, and care-facility representatives. Independent review should evaluate: 1. The confidence-interval formula; 2. The use of the full baseline confidence-interval width as a threshold; 3. Paired random-seed analysis; 4. Whether 20 runs are sufficient; 5. Tail-risk treatment; 6. Outlier handling; 7. Safety-margin analysis; 8. Traffic-count adequacy; 9. Model calibration and validation; 10. Fire scenario selection; 11. Ember cast and spot-fire timing; 12. Route-tenability analysis; 13. Emergency operations assumptions; 14. Accessibility and vulnerable-population assumptions; 15. Future project-level applicability. Independent review should occur before the Draft Study is adopted, not after the methodology has already been embedded into future project review. 18. Requested Action 15 For the reasons described above, Concerned Anaheim Residents respectfully requests that the City not adopt the Draft Wildfire Evacuation Study, its confidence-interval threshold, or its proposed CEQA project-review framework in its current form. Before adoption or reliance, the City should: 1. Release the underlying traffic and model data; 2. Disclose all individual simulation runs; 3. Explain and justify the confidence-interval methodology; 4. Analyze paired baseline/project differences; 5. Evaluate tail-risk evacuation outcomes; 6. Disclose outlier, rerun, adjustment, and exclusion protocols; 7. Provide zone-by-zone safety-margin analysis; 8. Address whether existing evacuation conditions are already unsafe; 9. Explain how ember cast, spot fires, and route tenability are incorporated; 10. Disclose and justify fire-weather assumptions; 11. Disclose traffic-count dates, locations, timeframes, calibration, and validation; 12. Address SR-91 spillback, commuter-bypass traffic, adjacent-jurisdiction traffic, route spillback, and freeway-access conflicts; 13. Reconcile pre-release assertions with the written Draft Study; 14. Clearly distinguish CEQA requirements from City policy choices and consultant methodology; 15. Explain how cumulative development, moving baselines, inactive entitled uses, and pending projects will be handled; 16. Publicly answer resident questions in a complete Question-and-Response Matrix; 17. Hold a post-release public technical meeting after those answers are published; 18. Allow residents to ask follow-up questions; 19. Keep the comment period open, or reopen it, for supplemental comments after the post-release meeting; 20. Obtain independent multidisciplinary peer review; 21. Confirm that threshold compliance will not override contrary substantial evidence of significant wildfire-evacuation risk; 22. Disclose whether and how the Study will apply to pending Anaheim Hills development proposals, including SALT Development: Deer Canyon Preserve, Builder’s Remedy Project Proposal, and whether adoption timing could affect project review. Until those steps are completed, the Study may remain useful as a planning document, but it should not be adopted as a CEQA significance threshold or relied upon as a legally or scientifically sufficient wildfire-evacuation safety framework. Please confirm receipt of this timely supplemental public comment and confirm that it will be included in the administrative record for the Draft Wildfire Evacuation Study. If the City contends that this comment was not timely submitted, please identify the specific deadline, source, and legal basis for that position and preserve this comment in the record as a disputed-timeliness submission. Respectfully, Concerned Anaheim Residents Resident advocacy account for wildfire evacuation safety, CEQA accountability, and public transparency 16 Susana Barrios From:Concerned Anaheim Residents <concernedanaheimresidents@gmail.com> Sent:Monday, July 27, 2026 11:51 PM To:Cory Wilkerson; Public Comment Cc:City Attorney; City Clerk; Robert Fabela; Mike Lyster; Rudy Emami; Rafael Cobian; Ashleigh Aitken; Eric Anderson; Patrick Russell; mcid@anaheimpd.com Subject:\[EXTERNAL\] Timely Supplemental Public Comment – Preservation of All Questions, Comments, and Issues from the June 25 Pre-Release Meeting – Draft Wildfire Evacuation Study You don't often get email from concernedanaheimresidents@gmail.com. Learn why this is important 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 Mr. Wilkerson, City Clerk, Mayor, and City Councilmembers, Please accept this additional timely supplemental public comment regarding the Draft Wildfire Evacuation Study and include it in the administrative record. This comment is being submitted before 11:59 p.m. on July 27, 2026, consistent with the City of Anaheim’s public representation that comments on the Draft Wildfire Evacuation Study would be accepted until 11:59 p.m. today. It supplements the public comments submitted earlier today by The Stakeholder Audit Team. This submission is intended to preserve one specific issue: the City should not lose, omit, selectively summarize, or defer resident questions, comments, concerns, and issues raised during the June 25 pre-release meeting or during the Draft Study comment period. For avoidance of doubt, The Stakeholder Audit Team requests that all questions, comments, concerns, and issues raised during the June 25 pre-release meeting be treated as part of the Draft Study public-comment record, included in the administrative record, publicly posted in the City’s Question- and-Response Matrix, and answered before any Council staff report, agenda packet, hearing, discussion, vote, formal adoption, or reliance on the Study. This request includes questions, comments, concerns, and issues that were answered orally, not answered, only partially answered, deferred, or addressed without a durable public written record. Any redactions should be limited to legally required redactions of personal contact information, private information, or legally protected material. Redactions should not be used to omit, paraphrase away, or selectively summarize the questions, comments, concerns, or issues raised by residents. The Stakeholder Audit Team respectfully requests that the City’s public Question-and-Response Matrix include all resident questions, comments, concerns, and issues raised during: 1. The June 25, 2026 pre-release community meeting; 1 2. Any virtual or in-person outreach meetings related to the Draft Study; 3. Written public comments submitted during the comment period; 4. Emails submitted to City staff, Public Works, City Council, the City Clerk, or other City representatives; 5. Resident-provided notes, recollections, written summaries, question lists, emails, and other written materials submitted for the public record. For each question, comment, concern, or issue raised, the Matrix should identify the issue raised, the City’s response, whether the response is complete or partial, the supporting data or authority relied upon, and whether additional follow-up, data disclosure, peer review, or public discussion remains necessary. If the City did not create a complete question log, meeting summary, staff notes, or other record sufficient to reconstruct all questions, comments, concerns, and issues raised at the June 25 meeting, the City should disclose that absence and use all available sources, including resident-provided notes, recollections, written summaries, question lists, emails, and other written materials submitted for the public record, to prepare the Question-and-Response Matrix. The Stakeholder Audit Team may submit resident-provided notes, recollections, written summaries, question lists, emails, or a resident-prepared June 25 Meeting Question-and-Comment Record as supplemental supporting material after those materials are compiled. Any later submission should be treated as supporting material to these timely public comments and used to help prepare the City’s Question-and-Response Matrix. The City should not treat the close of the written comment period as a substitute for a public question- and-answer process. Written comments submitted before residents receive City responses do not provide the same opportunity as a post-release public meeting where residents can hear the City’s answers, ask follow-up questions, identify remaining issues, and submit supplemental comments before Council action. For these reasons, The Stakeholder Audit Team respectfully requests that the City: 1. Publish a complete Question-and-Response Matrix before any Council staff report, agenda packet, public hearing, Council discussion, vote, formal adoption, or reliance on the Study; 2. Include all questions, comments, concerns, and issues raised during the June 25 pre-release meeting as part of the Draft Study public-comment record; 3. Include resident-provided notes, recollections, written summaries, question lists, emails, and other written materials submitted for the public record as sources for preparing the Matrix; 4. Hold a post-release public technical meeting after the Matrix is published; 5. Allow residents to ask follow-up questions based on the City’s written responses and the underlying data; 6. Keep the comment period open, or reopen it, for supplemental comments after that meeting; 7. Confirm that all questions, comments, responses, meeting materials, presentations, supporting materials, and supplemental submissions will be included in the administrative record. Please confirm receipt of this timely supplemental public comment and confirm that it will be included in the administrative record for the Draft Wildfire Evacuation Study. If the City contends that this comment was not timely submitted, please identify the specific deadline, source, and 2 legal basis for that position and preserve this comment in the record as a disputed-timeliness submission. Respectfully, The Stakeholder Audit Team A Collective of Concerned Anaheim Hills Resident Stakeholders 3