HomeMy WebLinkAbout19 - Proposed Ordinance Designating VHFHSZAgenda Item No. 19
July 10, 2012
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: Fire Department
Scott L. Poster, Fire Chief
949 - 644 -3101, sposter .nbfd.net
PREPARED BY: Kevin Kitch, Assistant Chief
APPROVED:
TITLE: Proposed Ordinance Designating Very High Fire Hazard Severity
Zone in the City of Newport Beach
ABSTRACT:
Presentation of the proposed Very High Fire Hazard Severity Zone ( "VHFHSZ ") map for
the local responsibility area within the City of Newport Beach ( "City ").
RECOMMENDATION:
a) Introduce Ordinance No. 2012- 15 entitled, "AN ORDINANCE OF THE CITY OF
NEWPORT BEACH DESIGNATING VERY HIGH FIRE HAZARD SEVERITY
ZONES WITHIN THE CITY OF NEWPORT BEACH" (Attachment A); and pass to a
second reading on July 24, 2012; and
b) Find Ordinance No. 2012 -15 is not subject to the California Environmental Quality
Act ( "CEQA ") pursuant to Public Resources Code Section 21080(b) (1) and CEQA
Guidelines Section 15268(a) because the City's adoption of the ordinance is
mandated by Government Code Section 51179(a). Further find the adoption of the
proposed VHFHSZ map via Ordinance No. 2012 -15 does not cause significant
public safety issues based upon the substantial evidence contained in the record
and the activities required of a person who owns, leases, controls, operates, or
maintains a dwelling or structure in an area designated to be within a VHFHSZ are
mandated by Government Code Section 51182 and not subject to the discretion of
the City. The adoption of the ordinance is therefore ministerial. To the extent that
provisions of Ordinance No. 2012 -15 are considered discretionary decisions due
to the exclusion of certain areas from the map as submitted by the Director of the
California Department of Forestry and Fire Protection ( "CAL FIRE "), the excluded
areas will not be affected by the adopted VHFHSZ map or fuel management
Proposed Ordinance Designating Very High Fire Hazard Severity Zone in the City of
Newport Beach
July 10, 2012
Page 2
activities directly resulting there from, and therefore, there will be no impact to the
environment in these excluded areas. Furthermore, find Ordinance No. 2012 -15
is exempt from CEQA pursuant to CEQA Guidelines section 15304(i), which
applies to fuel clearance activities within one hundred feet (100') of a structure.
FUNDING REQUIRMENTS:
There are no direct costs to the City associated with the adoption of this ordinance;
however, there may be additional staff time associated with identifying properties
requiring defensible space maintenance and possible enforcement, should the property
owner not comply with the requirements.
BACKGROUND:
The California State Legislature has found and declared that: (1) Wildfires are extremely
costly, not only to property owners and residents, but also to local agencies; (2) wildfires
pose a serious threat to the preservation of the public peace, health, or safety; (3) it is
necessary that cities, counties, special districts, state agencies and federal agencies
work together to bring raging fires under control; and (4) preventive measures are
needed to ensure the preservation of the public peace, health, and safety. (California
Government Code Section 51175(a).)
California Government Code Section 51178 requires CAL FIRE to identify the Very High
Fire Hazard Severity Zones ( "VHFHSZ ") using consistent statewide criteria. CAL FIRE
has completed this task and maps have been sent to local agencies throughout the
state, such as Newport Beach, for adoption by the governing body as required by State
law. The VHFHSZ are based on fuel loading, slope, fire weather, vegetation types, fire
history, areas prone to high winds and other related factors.
Guidance on the local adoption process is provided in Government Code Section
51179(b) that allows local agencies with the ability to exclude areas from the VHFHSZ
identified by CAL FIRE. Specifically, an area identified as a VHFHSZ by CAL FIRE can
be excluded by the local agency following a finding supported by substantial evidence in
the record that the defensible space and other requirements of California Government
Code Section 51182 are not necessary for effective fire protection within the area. Any
modifications made by the City of Newport Beach to the recommendations of CAL FIRE
are final and not rebuttable by the Director. (California Government Code Section
51179(d).)
During a Study Session before the City Council on March 13, 2012, staff presented
proposed changes to the VHFHSZ map identified within the City by CAL FIRE
(Attachment B). Since that time, City staff has met with numerous community and
Proposed Ordinance Designating Very High Fire Hazard Severity Zone in the City of
Newport Beach
July 10, 2012
Page 3
homeowner associations to provide an overview and increased awareness of the
proposed VHFHSZ map (Attachment C). Both the CAL FIRE proposed VHFHSZ map
and the City staffs recommendations have been available for review on the City website
http://www.newportbeachca.gov/iiidex.aspx?paqe=2022,
DISCUSSION:
Following the devastating Oakland Hills Fire, the California Legislature enacted A.B.
337 (Stats. 1992, c. 1188, § 1), the Bates Bill, in an effort to reduce damage caused by
wildfires. This legislation added Section 51175 — 51188 to the Government Code. In
summary, it required property owners to maintain defensible space around buildings
and disclose the natural fire hazard when there is a transfer of real property. In
addition, it required CAL FIRE, in cooperation with local fire authorities, to identify areas
of VHFHSZ in the Local Responsibility Areas (LRA) of Calfornia. The designation of
VHFHSZ is a key component in the process of educating property owners and residents
about the potential wildfire hazards that exist, and reducing the risks associated with
wildfires. Once identified, CAL FIRE was to notify the local government agencies of the
zones, who then had the option of: (1) adopting the model ordinance and VHFHSZ
developed by CAL FIRE; (2) including or excluding areas from the identified zone(s); (3)
indicating that they already meet or exceed the minimum fire prevention standards in
the Bates Bill, or (4) some combination of (1) — (3).
The stated legislative purpose of Government Code Section 51175 - 51189 is "to
classify lands in the state in accordance with whether a very high fire hazard is present
so that public officials are able to identify measures that will slow down the rate of
spread, and reduce the potential intensity, of uncontrolled fires that threaten to destroy
resources, life, or property, and to require that those measures be taken." (California
Government Code Section 51176.)
The requirements for increased fire mitigation measures are not new to the region.
Prior to the Newport Coast area annexation into the City of Newport Beach, Special
Fire Protection Areas (SPPA) were initially implemented on March 28, 1996 within
designated portions of Orange County's LRA.
It is well established that structural losses during wildfires are the result of two common
influences, airborne burning embers and the direct effects of heat and flames. The
provisions of Chapter 7A of the California Building Code (CBC) and Section R327 of the
California Residential Building Code (RBC), both of which have already been adopted
by the City, are intended to reduce the risk of wildfire to structures by reducing
vegetative fuel loads in the area surrounding a structure and by hardening a structure to
embers, heat and flames through the use of ignition - resistant building materials and
Proposed Ordinance Designating Very High Fire Hazard Severity Zone in the City of
Newport Beach
July 10, 2012
Page 4
design. Those structures with ignition - resistant construction that also provide for
defensible space enable firefighters to more safely protect homes during wildfires.
As to property located within a VHFHSZ, the California Government Code requires:
• Building, reconstruction and additions will require fire resistive construction
design and materials identified in CBC Chapter 7A, "Fire Resistive Construction"
and /or the RBC, Section R327, "Materials and Construction Methods for Exterior
Wildfire Exposure" (California Government Code Sections 51182(a) and 51189),
and
• Real estate transactions will require disclosure that the property is located in a
VHFHSZ (California Government Code Section 51183.5); and
• Landowners with structures that abut a wildland area will be required to reduce
flammable vegetation within thirty feet (30') of buildings and modify vegetation
within 100 feet around buildings or to their property line (whichever is less) to
create a defensible space. This may include removing trees that extend within
ten feet (10') of the outlet of a chimney or stovepipe, maintaining trees, shrubs, or
other plants adjacent to or overhanging from a building free of dead or dying
wood, and maintaining the roof of a structure free of leaves, needles or other
flammable vegetation. (California Government Code Section 51182(a).)
As stated above, the City has the ability to exclude areas from CAL FIRE's identified
VHFHSZ. This flexibility is due to the requirement in California Government Code
Section 51178, which requires CAL FIRE to use statewide criteria to identify VHFHSZ
throughout the state. Thus, on a state -wide scale, CAL FIRE's VHFHSZ map is
consistent. However, on the local level, City staff believes that the data, evidence, and
information available and pertinent to the City warrant adjustments to CAL FIRE's
VHFHSZ map and these appropriate adjustments are supported by substantial
evidence.
In reaching this conclusion, the Newport Beach Fire Department focused on local,
detailed, micro scale data, evidence and information that it considers to more accurately
identify the VHFHSZ within the jurisdictional boundaries of the City.
Using aerial reconnaissance of terrain and vegetation, existing SFPA, and fire modeling
rules that reflect the topography, weather, and infrastructure of Newport Beach, the Fire
Department has produced a VHFHSZ map specific to the City and which it contends
more accurately identifies the VHFHSZ when compared to the State's map.
Specifically, the Fire Department observed the following:
Proposed Ordinance Designating Very High Fire Hazard Severity Zone in the City of
Newport Beach
July 10, 2012
Page 5
The higher elevation of the Newport Coast areas of Los Trancos, Muddy Canyon
and Upper Buck Gully are steep and deep canyons with an average depth of
more than one hundred fifty feet (150'). These canyons contain heavy, non -
irrigated and unmaintained fuel loads consisting mainly of California native
chaparral and a mix of native trees and tree form shrubs. Heavy, non - irrigated
and unmaintained trees and tree form shrubs are considered to be a high fuel
load for fires. In dry seasons, or under drought conditions, the non - irrigated trees
and tree form shrubs become dry fuel that wildfires can feed off of. These
canyons are also subject to strong, non - dissipated Santa Ana winds and have a
low humidity. Additionally, these canyons have a history of wildfires as the
majority of this area was burned in the 1993 Laguna Canyon fire. The
combination of deep and steep canyons, high fuel loads, low humidity, dry fuel,
stronger non - dissipated Santa Ana winds, and fire history makes these areas a
very high fire hazard area with increased ember travel distance into the
neighboring communities and warrants their inclusion within the VHFHSZ; and
• The Coyote Canyon landfill consists mainly of flat grassland maintained by the
County. Maintained grassland is a light fuel load. This light fuel load and
predominately flat, level terrain decreases the fire hazard in that area and
warrants its exclusion from the VHFHSZ; and
• Lower Buck Gully and Morning Canyon are moderately sloped, shallow riparian
areas with an average depth of thirty feet (30'). These areas experience
constant water flow to the ocean. This water flow acts as irrigation within these
areas and provides vegetation with high moisture levels year round which limits
the spread of fire. The vegetation in these areas consists mainly of ornamentals,
shrubs, and trees. This type of vegetation, when properly maintained and
irrigated, is not considered to contribute to the spread of large scale wildfires.
Further, these areas are subject to Newport Beach's Hazard Reduction
Guidelines which require existing homes with vegetation abutting these special
fire protection areas within one hundred feet (100') of a structure to maintain
their properties by removing dead vegetation, trimming ladder fuels, providing a
ten foot (10') clearance between trees and chimneys, locating firewood at a
minimum of fifteen feet (15') from structures, and maintaining roofs and rain
gutters tree from needles, leaves, and other combustible matter. In addition to
following the requirements within the Hazard Reduction Guidelines, any new or
reconstructed homes must also provide and maintain a fuel modification zone
consistent with existing standards. Further, these areas experience relatively
high humidity and dissipated Santa Ana winds. The combination of moderately
sloped, shallow areas of relatively high humidity, dissipated Santa Ana winds,
Proposed Ordinance Designating Very High Fire Hazard Severity Zone in the City of
Newport Beach
July 10, 2012
Page 6
irrigated vegetation, maintained fuel loads, and the application of the Hazard
Reduction Guidelines and fuel modification zones decrease the likelihood of
large scale wildfires, and represent a lower hazard for these areas and warrant
exclusion from the VHFHSZ; and
Pelican Hill golf course consists mainly of predominately irrigated grassland and
maintained mixed vegetation. Irrigated grassland and maintained mixed
vegetation is considered to be a light fuel load. Areas located in the lower
elevation of Newport Coast are not subject to high fuel loads or severe Santa
Ana winds. Therefore, these areas represent a lower hazard area and warrants
exclusion from the VHFHSZ; and
The lower elevation of the coastal area of Crystal Cove is bounded by the
Pelican Hill Golf Course on the West, and Crystal Cove State Park on the East.
This area consists of moderately sloped, shallow canyons and flat developed
residential areas and is sheltered from the North East Santa Ana winds by the
higher elevation of upper Crystal Cove. This area is also protected by the
irrigated and maintained Pelican Hill Golf Course to the West, and the relatively
shallow area of Muddy Canyon as it diminishes near the coast. This area does
not contain the fuel load, wind speed, and terrain to support a large scale
wildfire. Therefore, this area represents a lower hazard area and warrants
exclusion from the VHFHSZ; and
• Crystal Cove State Park's jurisdictional boundary alongside the coast west of the
lower crystal cove development lay outside of the City's LRA. Therefore this area
should be excluded from the map as the City does not have jurisdiction over it.
The Newport Beach Fire Department has provided substantial evidence showing that
the revised VHFHSZ map is required for effective fire protection. For those areas
identified for exclusion from the VHFHSZ, Fire Department staff believes, based on their
professional training and experience, that the requirements of California Government
Code Section 51182 are not necessary for effective fire protection within those areas.
The VHFHSZ map also accurately depicts the areas within Newport Beach where a
large scale wildfire could occur, as evidenced by local knowledge, local fuel modeling,
weather, fire history, topography, fuel load, and fuel management.
The RED areas on the attached map (Attachment B) show the VHFHSZ submitted by
the CAL FIRE which includes 7,038 parcels totaling 9.51 square miles of area. City
staffs recommended area for local VHFHSZ designation is shown as the hatched
portion of Attachment B which includes 2,744 parcels totaling 5.04 square miles of area.
Proposed Ordinance Designating Very High Fire Hazard Severity Zone in the City of
Newport Beach
July 10, 2012
Page 7
The Fire Department believes that available information, data and evidence supports
exclusion of the red non - hatched area from the VHFHSZ submitted by the CAL FIRE.
ENVIRONMENTAL REVIEW:
Staff recommends the City Council find the ordinance is not subject to the California
Environmental Quality Act ( "CEQA ") pursuant to Public Resources Code section
21080(b) (1) and CEQA Guidelines section 15268(a) because the City's adoption of the
ordinance is mandated by Government Code section 51179(a). Further, the adoption of
the proposed VHFHSZ map does not cause significant public safety issues based upon
the substantial evidence contained herein and the activities required of a person who
owns, leases, controls, operates, or maintains a dwelling or structure in an area
designated to be within a VHFHSZ are mandated by Government Code Section 51182
and not subject to the discretion of the City.
The City's adoption of the ordinance is therefore ministerial. To the extent that
provisions of the ordinance are considered discretionary decisions of the City due to the
exclusion of certain areas from the map as submitted by CAL FIRE, the excluded areas
will not be affected by the proposed VHFHSZ map or fuel management activities directly
resulting there from, and therefore, there will be no impact to the environment in these
excluded areas. Furthermore, the ordinance is exempt from CEQA pursuant to CEQA
Guidelines section 15304(i), which applies to fuel clearance activities within one
hundred feet (100') of a structure.
NOTICING:
The agenda item has been noticed according to the Brown Act (72 hours in advance of
the meeting at which the City Council considers the item).
� -1
744 Subm ed b
Scott L. Poster
Fire Chief
Attachment A: Ordinance
Attachment B: Proposed Very High Fire Hazard Severity Zone Map
Attachment C: Community Outreach. Group Meetings and Notifications
ORDINANCE NO. 2012 -15
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
NEWPORT BEACH, ADDING SECTION 9.04.140 TO THE
NEWPORT BEACH MUNICIPAL CODE TO ADOPT THE VERY
HIGH FIRE HAZARD SEVERITY ZONE MAP
The City Council of the City of Newport Beach finds as follows:
WHEREAS, the legislature has declared in Government Code Section 51175,
Subdivision (a)that: (1) wildfires are extremely costly, not only to property owners and
residents, but also to local agencies; (2) wildfires pose a serious threat to the
preservation of the public peace, health, and safety; (3) it is necessary that cities,
counties, special districts, state agencies, and federal agencies work together to bring
raging fires under control; and (4) that preventative measures are needed to ensure the
preservation of the public peace, health, or safety; and
WHEREAS, the Legislature has declared in Government Code Section 51175,
Subdivision (b), that the prevention of wildland fires is not a municipal affair, but is,
instead, a matter of statewide concern; and
WHEREAS, pursuant to Government Code Section 51178, the California Director of
Forestry and Fire Protection ( "CALFIRE ") has identified areas within the City of Newport
Beach as Very High Fire Hazard Severity Zones ( "VHFHSZ "); and
WHEREAS, Government Code Section 51179 subdivision (b) allows local agencies to
exclude an area identified as a very high fire hazard severity zone by CAL FIRE
following a finding supported by substantial evidence in the record; and
WHEREAS, the creation of this map relied upon the use of current scientific methods
which assessed, vegetation, slope, fire history, weather patterns and significantly
improved accuracy by establishing the impact of flames, heat, and flying embers; and
WHEREAS, pursuant to Government Code Section 51179 the City of Newport Beach
has published a new map depicting areas designated as a VHFHSZ; and Government
Code Section 51179 requires the City of Newport Beach to designate by ordinance
VHFHSZ in its jurisdictional area after receiving the recommendation from CAL FIRE;
and
WHEREAS, the Newport Beach Fire Department staff has reviewed CAL FIRE's map,
and has made recommendations based upon their professional training and experience
that the proposed local responsibility area map attached hereto accurately represents
the VHFHSZ within the City; and
ATTACHMENT A
WHEREAS, there is substantial evidence in the record, Including, but not limited to, all
the information presented to this Council during a Study Session presentation on March
13, 2012 and the Staff Report presented on July 10, 2012, together with all other
written, oral and visual communications, that supports the exclusion of certain areas
from VHFHSZ as the requirements of Government Code section 51182 are not
necessary in those certain areas for effective fire protection.
NOW, THEREFORE, the City Council of the City of Newport Beach does hereby ordain
as follows:
SECTION 1: Chapter 9.04,140 of the City of Newport Beach Municipal Code is hereby
added to read in its entirety as follows:
9.04.140 Very High Fire Hazard Severity Zone_
The City of Newport Beach designates those areas identified in green on the map
attached hereto and on file with the City Clerk as the Very High Fire Hazard Severity
Zone for the City in accordance with Section 51179 of the California Government Code.
SECTION 2: Pursuant to Government Code section 51179(b), the City Council finds
that there is substantial evidence in the record that supports the exclusion of certain
areas from VHFHSZ as the requirements of Government Code section 51182 are not
necessary in those certain areas for effective fire protection.
SECTION 3: The City Council finds that this ordinance is not subject to the California
Environmental Quality Act ( "CEQA ") pursuant to Public Resources Code section
21080(b) (1) and CEQA Guidelines section 15268(a) because the adoption of the
ordinance is mandated by Government Code section 51179(a). Further, the adoption of
the VHFHSZ map does not cause significant public safety issues based upon the
substantial evidence contained in the record and the activities required of a person who
owns, leases, controls, operates, or maintains a dwelling or structure in an area
designated to be within a VHFHSZ are mandated by Government Code Section 51182
and not subject to the discretion of the City. The adoption of this ordinance is therefore
ministerial. To the extent that provisions of this ordinance are considered discretionary
decisions of the City due to the exclusion of certain areas from the map as submitted by
CA!_ FIRE, the excluded areas will not be affected by the VHFHSZ map or fuel
management activities directly resulting there from, and therefore, there will be no
impact to the environment in these excluded areas. Furthermore, this ordinance is
exempt from CEQA pursuant to CEQA Guidelines section 15304(i), which applies to
fuel clearance activities within 100 feet of a structure.
SECTION 4: If any provision, section, paragraph, sentence, clause or phrase of this
ordinance, or any part thereof, or the application thereof to any person or circumstance
is for any reason held to be invalid or unconstitutional by a court of competent
jurisdiction, such decision shall not affect the validity of the remaining portions of this
Ordinance, or any part thereof, or its application to other persons or circumstances. The
City Council hereby declares that it would have passed and adopted each provision,
section, paragraph, subparagraph, sentence, clause or phrase thereof, irrespective of
the fact that any one or more sections, paragraphs, subparagraphs, sentences, clauses
or phrases, or the application thereof to any person or circumstances, be declared
invalid or unconstitutional.
SECTION 5: The Mayor shall sign and the City Clerk shall attest to the passage of this
ordinance. The City Clerk shall cause the same to be published once in the official
newspaper of the City, and it shall be effective thirty (30) days after its adoption.
This ordinance was introduced at a regular meeting of the City Council of the City of
Newport Beach, held on the day of 2012, and adopted on the day
of , 2012, by the following vote, to wit:
AYES, COUNCIL MEMBERS
NOES, COUNCIL MEMBERS
ABSENT COUNCIL MEMBERS
NANCY GARDNER, MAYOR
ATTEST:
LEILANI BROWN, CITY CLERK
vwff'Tey�i OHIO]
, CITY ATTORNEY
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ATTACHMENT B
Community Outreach
Meetings and Notifications
Proposed VHFHSZ Map
March 13, 2012
City of Newport Beach Council Chambers Study Session
March 28, 2012
Oasis Senior Center
April 2, 2012
Newport Coast Community Center
April 18, 2012
Corona del Mar Town Hall Meeting
May 9, 2012
Newport Beach Yacht Club (Speak Up Newport)
May 23, 2012
Cameo Shores Community Annual Board Meeting
May 24, 2012
Crystal Cove HOA Board Meeting
ATTACHMENT C
Jul 10 2012 3:38PM
Hawkins Law Offices (949) 650 -1181 P.1
R EIVED
Law Offices of Robert C. Dawkins
110 Newport Center Drive, Suite 200
Newport Beach, California 92660
(949) 650 -5550
Fax: (949) 650-1181
7.017 JUL 10 P1 4: 2 u
'A /..
�C "RECEIVED AFTER AGENDA FA3K COV ER SHEP Ioi"
TRANSNU YIEDTO:
NAME
Leilani Browc
From:
Client/Matter:
Date:
Documents:
Pages:
COMMENTS:
Clerk
(949) 644 -3039
Robert C. Hawkins
Firm
July 10, 2012
Comments on Agenda Items Nos. 15 and 19
4"
Original will follow as indicated.
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Jul 10 2012 3:38PM Hawkins Law Offices (9491 650 -1181 p.2
LAW OFFICES OF ROBERT C. HAWKINS
July 10, 2012
Via Facsimile
Nancy Gardner, Mayor
Members of the City Council
City of Newport Beach
3300 Newport Blvd,
Newport Beach, California 92663
f:Rlli
Dear Honorable Mayor and Members of the City Council:
Thank you for the opportunity to comment to comment on the captioned matter. This firm
represents Friends of Dolores and others in the City in connection with the captioned matter. We welcome
the Fire Department's revisions to the captioned Very High Fire Hazard Severity Zone Map (the "Map "),
but have concerns about the administrative record for and the environmental determination on the Map.
The Staff Report for the captioned matter recommends that the Project is exempt from review for
several reasons:
The Ordinance for the Map is mandated by Government Code sections 51175 et seq.
The City's revised Map which excludes certain areas recommended by the State due not
cause public safety hazards based upon substantial evidence that the revised Map provides
the same protections as the State's recommended map and that the State Map is mandated
by Sections 51174 et seq.
3. The Ordinance is ministerial because it is mandated.
4. To the extent that the Ordinance involves discretion, the City is excluding certain areas so
that there is no change in circumstance for those excluded areas.
The Ordinance is exempt under Guidelines sections 15304(1).
All of these are problematic. The first three are incorrect, because the fourth option admits that the
City is exercising discretion in its revised Map. And, let's face it, the Ordinance is discretionary: the City
is excluding certain areas from the State Map based upon its own analysis of the safety factors involved.
110 Newport Center Drive, Suite 200
Newport Beacb, California 92660
(949) 6505550
Fax: (949) 650, 1181
Jul 10 2012 3:38PM Hawkins Law Offices 1949) 650 -1181 P.3
The Hon. Mayor Gardner
Members of the City Council .2 - July 10, 2012
To suggest that this is not a change in circumstance is too clever by half. It ignores the
requirements of Government Code section Government Code section 51179(b). Section 51179(b) allows
the City to exclude certain areas with a finding supported by substantial evidence that the requirements of
Government Code section 51182 are not necessary for effective fire protection for the area.
The City's findings of substantial evidence that the protections are not needed ignores the fact that
the State recommended that such protections were needed. A change to that reconnnendation is a change
in how excluded areas are regulated. That change in regulations requires environmental analysis and
review.
We urge you to require the Department to propose the appropriate findings, after adequate
environmental review and adequate notice and public hearings,
Thank you for the opportunity to comment on the captioned matter. Please provide me with notices
regarding the captioned Project. We will provide further and additional comments on the captioned matter
in a timely manner.
Of course, should you have any questions, please do not hesitate to contact me.
RC14/kw
cc: Lei] ani Brown, City Clerk
Sincerely,
C. HAWIGNS
110 Newport Center Drive, Suite 200
Newport Beach, California 92660
(949) 650.5550
Fax (949).650.1181