One Better Road is Still One Road

Widening the existing two-lane road to three lanes is the crux of the developer’s argument. Since the intent of the relevant fire code is to ensure safe evacuation, the developer’s reasoning is that a three-lane road will allow for faster evacuation than a two-lane road.

What’s interesting about this proposal is, if simply making the road into 3 lanes was all that is necessary to mitigate the danger, why didn’t Cal Fire write the code that way? Why doesn’t the regulation read, “except for when the dead-end road is 3 or more lanes”?

They didn’t write the code that way because simply widening a section of the road does not address the limitations of only having a single way to enter or exit the community. A single exit that can become blocked by fire or vehicle collisions in a panicked evacuation.

In 2016, Cal Fire and the State Board of Forestry and Fire Protection contracted fire experts to examine the current dead-end road standards and their effectiveness. After modeling evacuation times for single-access subdivisions in Southern California, researchers at the California Polytechnic State University, San Luis Obispo, addressed this very issue in their report to Cal Fire:

“Simply adding an additional lane to the primary single access road for evacuation does not appear to improve evacuation time. Adding a true second access that is independent of the first (meaning the two exits are neither close together nor access the same through road) offers a significant reduction in clearance time.” ¹

Even if the single evacuation route does not become blocked in a wildfire, the HGVS project will add over 1500 vehicles to Country Club Dr. during an evacuation. The HGVS Evacuation Plan states it could take as long 1.25 to 2.25 hours to complete a community wide evacuation, and double that or longer if a Harmony Grove/Eden Valley-wide evacuation is declared.³ Meanwhile the county’s Wildfire Risk Analysis estimates the fire travel time from Escondido, in average Santa Ana wind conditions, would be 1-2.5 hours. Fire starting closer to the proposed development site could produce much shorter run times.⁴

Evacuation takes 1.25 hours and a fire will take less than an hour to reach the development.

Lessons from Thomas and Tubbs

The community of Rincon Ridge in Fountaingrove, burned by the Tubbs Fire, Oct. 2017. Photo Credit: Kent Porter / Press Democrat

After the three-land road, the fire protection plan moves to fire-resistant building and landscaping. This is referred to “as one layer of the fire protection system alternative measures for mitigating secondary access/long dead end road length constraints.” Implicit in this statement is that fire-resistant features mean HGVS won’t burn down and that residents staying home during a fire will be equally safe as the evacuation that would have been provided by the missing secondary exit.

This is at odds with California’s Ready, Set, Go! policy and the events of California’s 2017 fire season.

In the Tubbs fire, twenty-two people were killed and the fire decimated large swaths of Santa Rosa. In the Fountaingrove neighborhood, homeowner groups had spent heavily on protection measures to prepare for a wildfire. Like Harmony Grove, the neighborhood was located in a very high fire hazard severity zone. Santa Rosa imposed a series of code restrictions on home construction in Fountaingrove, requiring such things as safe roof materials, mesh screen over vents — to keep out wind-whipped embers — and fire-resistant construction of eaves.

Homeowners paid dues to an association whose mission was to reduce the danger of 200 acres of open space in the area. The association spent nearly $3 million since 2009 to reduce weeds, remove brush and dead or dying trees, maintain fire breaks and promote fire-resistant native plant species such as manzanita.⁵

Still, almost 1,800 structures were destroyed in Fountaingrove, including a newly built $4 million fire station, Santa Rosa Fire Station 5. The station, opened only two years earlier, was designed to improve the department’s ability to respond to fire and medical calls in the area.

In the aftermath of Ventura County’s Thomas Fire, inspectors found more than 90 percent of all the structures damaged or destroyed had fire-resistant roof construction, and roughly 80 percent had fire-resistant exterior siding. At least 45 percent had multi-paned windows and 43 percent had eave screens.

As evidenced by the destruction of the Thomas and Tubbs fires, fire-resistant features included in modern building codes do not make homes fire-proof. Still, the HGVS fire protection plan is banking on such building features to allow residents to shelter-in-place in the likelihood they won’t be able to evacuate.

The Shelter-in-Place Experiment

Shelter-in-place is a concept in the United States inspired by an official Australian policy, called Stay and Defend or Leave Early (SDLE). In the SDLE policy, the idea is that residents can use basic firefighting equipment, water and garden hoses, to put out small fires around their house caused by airborne embers. This policy came under intense scrutiny following the worst wildfires in Australian history, which occurred in the southern state of Victoria on February 7, 2009 — “Black Saturday.” Those fires killed 173 people, 113 of them in or near buildings.

In the U.S., shelter-in-place is considered the last resort during a fire, used when high intensity wildfire threatens escape routes, denying residents an opportunity for escape. Despite the problematic history of shelter-in-place policies, it‘s in the developer’s interest to position this controversial policy as a mainstream strategy for a fire plan.

Harold Schaitberger has served as President of the International Association of Firefighters since 2000 and strongly rejects shelter-in-place, writing for the L.A. Times:

“Hearing anyone suggest that homeowners should not get out of harm’s way is appalling. Hearing a public safety professional make the suggestion is shameless. Stay-and-defend is clearly a half-baked idea from people who believe that saving money is more important than saving lives.”

Existing residents are all but forgotten in the developer’s shelter-in-place plan. Most of the existing Harmony Grove homes were built decades before fire-resistant techniques were incorporated into building codes. The HGVS Wildfire Risk Analysis considers these ‘legacy homes’ as “un-defendable against critical fire behavior.” Yet because of the HGVS housing development’s impact on the ability to evacuate, they will be forced to attempt to weather a firestorm anyway.

The Local Fire Authority

Fire Chief Tony Michel, who last week submitted his retirement notice to the board of the Rancho Santa Fe Fire Protection District (RSFFPD), is the local fire authority that signed off on the fire plan of HGVS. The fire code allows the local fire authority with jurisdiction to approve a modification that meets the intent and purpose of the code as long as the modification does not lessen health, life, and fire safety requirements.

The county has created guidelines to assist County staff in determining the validity of mitigating measures for development projects. On the topic of wildland fires the guide states:

In order to allow flexibility in project design, many wildland fire regulations are written using language that is often subject to interpretation (e.g. water supply may consist of reservoirs, pressure tanks, elevated tanks, water mains or other fixed systems …”) as opposed to codes that are absolute (e.g. “Class “A” roofing material shall be required”). This may allow some projects with unique geographic and topographic conditions to adequately mitigate wildland fire risks through project design.⁶

In the case of the fire regulations for dead-end roads, the state and county did not opt to write the code with wiggle room. 800ft maximum is very specific.

The guide also includes a section listing situations where it is unlikely that sufficient mitigation could be provided to address wildfire risk. Relevant to HGVS:

(1) Project site is surrounded by large wildland areas with little existing or planned surrounding development.

In a story by the Voice of San Diego, Max Moritz, a UC Berkeley fire ecologist, is cited as saying the relationship between wildfire and new development looks like a bell curve. With the first few projects in undeveloped areas, fire risk jumps exponentially. But if development continues, eliminating all of the flammable vegetation and bringing new firefighting resources to the area, the risk reaches a peak and eventually plummets.

HGVS will never reach the other side of the bell curve because the site is surrounded by preserve land, and the so-called legacy homes, to the east, south, and west.

(2) Project site is surrounded by steep slopes and significant topographical constraints that could intensify fire behavior or limit fire suppression operational flexibility.

The proposed site for HGVS is surrounded on all sides, except to the immediate northwest, by a continuing series of hills and canyons, with approximately 20 ridgetops. The site topography is even one of the reasons the developer claims a second evacuation route can’t be built.

Consider the following:

With the existing infrastructure, common logic and the HGVS evacuation/fire plans show a fire is very likely to threaten the community before evacuation can safely occur

Shelter-in-place is not a mainstream policy in the U.S. but is a core element of the HGVS plan

An exception to the fire code in this scenario is seemingly in conflict with the county’s own guidelines on when mitigation is appropriate

There is an undisputed housing crisis in San Diego (although the reasons for the shortage are very debatable)

Some might think Fire Chief Tony Michel’s approval of the exception shouldn’t be questioned. I answer — it is naive to believe that local fire officials are not effected by the political and economic forces that are driving the trend of unsafe land planning decisions in California.

As Thomas J. Cova, a researcher at the Center for Natural and Technological Hazards, wrote:

“Economic pressure is strongly toward developing fire-prone communities to a density beyond which the egress system can safely handle in an urgent wildfire evacuation. The beneficiaries of new home development include new residents, developers, construction companies, and property tax collectors among many others. ” ⁷

The Final Vote

Current San Diego Board of Supervisors who are scheduled to vote on the HGVS housing development and the fate of existing residents on Wednesday July 25, 2018.

Approval of HGV South will be decided on Wed. July 25th, along with the Valiano and Otay developments.

Developers often cry NIMBYism (Not In My Backyard) when area residents oppose a housing project. It would be difficult to believe this is the case for Harmony Grove. In 2007, the Elfin Forest and Harmony Grove Town Council and San Dieguito Community Planning Group both gave their support to a major housing development project, Harmony Grove Village.

This time around both the town council and San Dieguito planning group recommended the supervisors deny HGVS, with fire concerns a chief factor.

The six-member County Planning Commission voted 4–2 in favor of the proposed HGVS project. Commissioners Michael Beck and Michael Seiler voted against the project. “This thing is not ready for prime time,” Seiler said. Commissioner Beck stated he has not seen or understood an evacuation plan that shows it will work.⁸

Given that California is expected to experience drier climates, increased Santa Ana wind events, hotter temperatures, and longer droughts, our risk of wildfire only grows. We need housing. But when we disregard the regulations that are in place to protect us, we erode the progress we make in society to have better lives. Rahn Conservation Consulting, brought in by the community to review the fire risk, wrote it best: