Memes cut through the complexity and capture the essence of the debate.
Are we going to acknowledge our fire hazard?
Or are we going to pretend it doesn’t exist?
Are we going to adopt the safety measures that the Fire District told us almost a year ago are needed to protect lives?
Or, are we going to pretend that there is no need for any additional safety measures?
Background
The video version of this meme examines two examples of Portola Valley grossly understating its fire hazard.
Portola Valley’s submission for the Federal Emergency Management Agency (FEMA) Hazard Mitigation Plan
In formal submissions to the FEMA, Portola Valley and Woodside reported identical risk due to all natural hazards … except for one: wildfire.
Woodside identified wildfire its greatest threat, by far!
Not Portola Valley.
It reported that the risk to lives and property due to wildfire is barely outside the low range — barely more significant than that of flooding and drought!!!
Portola Valley’s submission for its State-mandated environmental analysis
In a State-mandated environmental analysis, Portola Valley ignored the General Plan’s comprehensive fire hazard assessment – an assessment that was rigorously conducted at taxpayer expense.
Instead, it used a map that the Fire District repeatedly told town officials is inaccurate, unsafe, and not suitable for development planning.
Why deny our fire hazard?
Who, exactly, are we trying to kid?
Our fire hazard is obvious to both insurers and potential home buyers. What they want to know is whether our Town is being honest about our hazards and adopting appropriate safety measures.
Shouldn’t we protect lives, insurability and our property values by candidly acknowledging our hazards and implementing the measures that the Fire District says are necessary?
Supporting Documentation
The following sections provide links to supporting documents.
FEMA Risk Ranking Scores For Natural Hazards
The Risk Ranking Scores were submitted to the County and to FEMA by the towns of Portola Valley and Woodside. They can be found in Vol 2 of the Hazard Mitigation Plan.
The Risk Ranking Score, Rank, and Risk Category are found in Table 15-12 for Portola Valley and 21-12 for Woodside.
Wildfire Hazards – What the General Plan said
The General Plan’s Fire Hazards Map provides a comprehensive and rigorous assessment of wildfire hazard severity in Portola Valley. The analysis included critical factors such as slope steepness, slope aspect, topographical features such as canyons and chimneys, typical wind and humidity during fire season, and vulnerability of evacuation routes. The methodology was presented at Portola Valley’s Wildfire Preparedness Committee on Feb 1, 2022.
That fire hazard assessment was carefully vetted by the Fire District, Town Staff, and the Town Council before its adoption into the General Plan in 2010. See page 15 of the current (2010) version of the Safety Element and page 56 of the current (2015) version of the Housing Element.
In contrast to recent mischaracterizations of the Moritz map as a mere “vegetation map”, it was in fact commissioned and conducted as a fire hazard assessment, and it was recognized as such when it was incorporated into the General Plan:
“A Fire Hazards Map (44), which designates areas subject to significant fire hazards, has been prepared for the town by Moritz Arboricultural Consulting.”
Safety Element, current (2010) version, page 15, paragraph 4138
Wildfire Hazards – What Portola Valley told the State
The General Plan’s assessment of Portola Valley’s wildfire hazards was completely ignored in the Town of Portola Valley’s State-mandated environmental analysis. Instead, an earlier Cal Fire assessment that the Fire District repeatedly (e.g., Sept 13, 2022 letter) told the Town is inaccurate and unsafe was used to depict fire hazard severity in Portola Valley.
On the basis of that discredited Cal Fire assessment, the Town of Portola Valley asserted that none of the proposed development sites were in or near areas of severe fire hazard, except for one – the Christ Church site. (See Initial Study/Mitigated Negative Declaration (IS/MND), approved by 3 of 5 Town Council members, with 2 abstaining, on March 29, 2023, Figure I-3, page 135)
In fact, however, Portola Valley’s own fire hazard assessment, as vetted and adopted into the General Plan, had previously determined that all of the proposed sites are in areas of significant fire hazards.
Safety Measures – What the Fire District told Portola Valley
In a Jan 4, 2023 letter, WFPD identified additional safety measures that it said are needed for the dense, new development that the Town is envisioning. These measures…
“…to protect against structure-to-structure and neighborhood-to-neighborhood fire spread should be adopted and
WFPD Jan 4, 2023 letter, page 10
implemented before any amendments that increase structural density and fuel loading are adopted.”
However, faced with pressure from certain Town officials, and assured that its January 4 concerns would be fully and promptly addressed before a new Housing Element was approved, the Fire District agreed to “withdraw” its letter.
Contrary to those assurances, however, the Fire District’s concerns were not addressed. As the District’s attorney wrote to the Town’s attorney on March 28:
“In January of this year, Fire Marshal Don Bullard sent a letter to the Town’s planning department, detailing a number of problems with the then-current draft HEU [Housing Element Update], safety element and Mitigated Negative Declaration (copy attached). At staff’s request he withdrew the letter upon assurance that the final documents would address his concerns. Apparently, that did not happen.”
“According to the Fire Marshal, the crux of the problem is twofold. First, the IS/MND’s analysis is based on the Cal Fire Map instead of the Moritz Map. Second, the draft Safety element would remove some of the important fire safety measures contained in the current Safety element. These are serious problems that should be rectified before the Town Council adopts the IS/MND.”
Fire District’s March 28, 2023 email
Since the necessary safety measures identified by Fire District had not been incorporated despite assurances that they would, the Fire Marshal resubmitted the recommendations to the Town, this time in a public forum – the March 29, 2023 Town Council meeting.
Safety Measures – What Portola Valley told the State
Portola Valley’s submission to the State ignored the Fire District’s repeated warnings.
Instead, in its State-mandated environmental analysis, the Town of Portola Valley asserted that the 20% population growth in an 8 year period with dense, new development in areas that our General Plan documents as having significant fire hazard represents NO significant impact on wildfire risk and, therefore, that no additional mitigation measures are necessary. See Table T, page 280, of the Initial Study/Mitigated Negative Declaration, approved by 3 of 5 Town Council members, with 2 abstaining, on March 29, 2023.
In May 2023, the Town Council approved the Housing Element without first adopting the safety measures that the Fire District said are necessary for the safety of residents and of firefighters.
Additional supporting material
Town officials were repeatedly told about the superiority of the fire hazard assessment in the General Plan relative to the Cal Fire assessment, including at the Jan 18, 2023 Housing Element committee meeting by both the Fire Marshal and the Town’s fire safety consultant and in multiple letters from the Fire District, such as the Sept 13, 2022 and Jan 4, 2023 letters.
The Fire District also repeatedly cautioned the Town about the inadequacy of its State-mandated environmental analysis, noting that an analysis based on the General Plan’s current hazard assessment will yield very different conclusions than if based on the erroneous Cal Fire map. For example,
“The district believes that any CEQA [California Environmental Quality Act] analysis of the impact of the Town’s proposed General Plan and Municipal Code amendments on wildfire hazard and risk should be based on the Moritz map, not the 2008 Cal Fire map, and that a CEQA analysis of the Town’s proposed amendments based on the Moritz map will differ significantly from the assessment currently provided in the IS/MND [Initial Study/Mitigated Negative Declaration].”
Fire District letter to Portola Valley, Jan 4, 2023, page 3
“As noted above, the IS/MND is based on an erroneous characterization of the existing wildfire hazards and risks in Portola Valley, in conflict with maps adopted in the 2010 Safety Element and provides no competent assessment of the impacts that the Town’s proposed amendments would have on the documented wildfire hazards and risks that exist throughout the Town. Nor does it assess how the changes reflected in its proposed amendments would interact to cumulatively impact wildfire hazard and risk over time”
Fire District letter to Portola Valley, Jan 4, 2023, page 13
In stark contrast to the District’s explicit warning, the Town of Portola Valley approved its deeply flawed assessment that its new Housing Element would have no significant impact on wildfire hazard, and on that basis adopted its proposed new Housing Element without first implementing any of the Fire District’s requested safety mitigations.