Overview of Key Safety Issues
Our Most Critical Comments are ALL Safety Related
Aesthetic Standards, such as the building is too high, we don't like the parking, no more traffic are not strong points to be made. High Density Housing projects can only be addressed on specific safety issues which are not adequately mitigated, such as not enough access for emergency vehicles, or conditions exist which will block traffic (not just add traffic, but block traffic). Below are our key Safety Concerns.
Where Is the Evacuation Analysis?
A Wildfire Changes Everything. San Elijo Hills has limited evacuation routes, and many residents remember the severe congestion experienced during the 2014 Cocos Fire. This project would add approximately 70 residents and additional vehicles directly along San Elijo Road—one of the community's critical evacuation corridors—while emergency responders may be trying to travel in the opposite direction. The San Elijo Hills Fire Safe Council has specifically requested a comprehensive evacuation analysis
including the impacts on the entire community, residents evacuating while firefighters and emergency vehicles are trying to enter, and the evacuation of the two schools directly across from the project.
Before this project is approved, where is the current, project-specific analysis showing how evacuation will actually work under realistic wildfire conditions?
Where Is the Fire Protection Plan?
Fire Safety Should Come Before Approval. The project site is within a Very High Fire Hazard Severity Zone, yet the materials reviewed by the community indicate that preparation of the project's Fire Protection Plan has been deferred until a later permitting stage. That means important questions involving wildfire protection and emergency operations may not receive meaningful public review before the project's major entitlements are approved.
We believe the Planning Commission and community should be able to review the project's fire-protection strategy before—not after—the decision is made to approve the project.
Setbacks & Space Concerns
Can Fire Apparatus Safely Operate at the Site?
Getting Firefighters In While Residents Are Getting Out. A five-story building requires more than showing that a fire truck can physically drive through the site. Firefighters must be able to position and operate engines and ladder trucks under real emergency conditions. The Fire Safe Council has identified roadway grade, available operating space, turning radius, setbacks, overhead obstructions and stabilization requirements as important site-specific considerations and has requested an independent operational analysis.
The critical question is whether emergency apparatus can enter, position, deploy and operate effectively while residents and surrounding community traffic may simultaneously be evacuating.
Have the Height and Setback Waivers Been Proven Safe?
Waiving a Standard Shouldn't Mean Waiving Safety. The applicant is seeking Density Bonus waivers from development standards that otherwise limit the building to 45 feet and three stories and require greater setbacks. Its Density Bonus submission states that these standards would physically preclude construction of the proposed project and therefore seeks waivers, including from the 45-foot height, three-story and 10-foot front-setback standards.
The community's question is not whether Density Bonus Law exists—it does—but whether the safety consequences of putting a taller building substantially closer to the roadway at this particular fire- and evacuation-sensitive location have been adequately demonstrated and addressed.
And there's more . . .
Have School Traffic and Sight Distance Been Adequately Analyzed?
This Is Not an Ordinary Residential Street. The project sits along San Elijo Road near schools and proposes driveway access onto a 35-mph roadway where residents have raised concerns about curves, sight distance, existing congestion, pedestrians, bicycles/e-bikes and school arrival and dismissal traffic. The materials submitted by residents specifically question whether current Stopping Sight Distance (SSD) and Intersection Sight Distance (ISD) analyses adequately address the proposed driveways.
The relevant safety condition isn't simply average daily traffic—it includes school-hour congestion, occupied street parking, project vehicles, pedestrians and emergency conditions. Before approval, has that real-world combination actually been analyzed?
Where Is the Current Project-Specific Environmental Analysis?
Today's Project Deserves Today's Analysis. Community comments and the Fire Safe Council have questioned reliance on environmental documents prepared before today's wildfire designation, population, traffic conditions and evacuation concerns. The Fire Safe Council specifically states that the environmental documents being relied upon predate San Elijo Hills' Very High Fire Hazard Severity Zone designation and requests updated environmental review addressing current wildfire and emergency-response conditions. CEQA provides circumstances in which substantial project changes, changed conditions, or important new information can require additional environmental review.
Before approving this specific five-story project, the community is asking the City to determine—on a complete and current record—whether a project-specific or subsequent EIR or other additional CEQA review is required to address wildfire evacuation, traffic and school-area safety, emergency response, construction impacts and the project's cumulative effects on the surrounding community.
The City is proposing CEQA Infill Exemption EX25-034, which would allow this project to proceed without a new project-specific EIR. City staff concludes that the project qualifies for the Class 32 exemption.
But categorical exemptions have limits, including where cumulative impacts or unusual circumstances may result in significant environmental effects. Given this site’s wildfire exposure, constrained evacuation routes, school traffic, emergency-response demands, and requested height and setback waivers, has the City adequately demonstrated that an infill exemption is appropriate for this particular project and location?