MST Comments - Wildfire Impacts - Freeze Is-Mnd 7-25-19nd

Mt.
Shasta Tomorrow
A non-profit, public benefit organization
101 E. Alma Street, Suite 100-A
Mt. Shasta, California 96067
mtshastatomorrow@gmail.com
Juliana Lucchesi, City Planner jlucchesi@mtshastaca.gov

City of Mt. Shasta Planning Commission
305 N. Mt. Shasta Blvd.
Mt. Shasta, CA 96067
PUBLIC COMMENTS
WILDFIRE IMPACTS
Revised Initial Study/Mitigated Negative Declaration
Freeze Car Wash and Mini-Storage Project
Dear City Officials: July 25, 2019
Wildfires are a significant risk caused by project developments adjacent to wooded hillsides. The 2018
Camp Fire in Paradise CA last year, and the Carr Fire in Redding also in 2018, are both evidence that
wildfires are an extremely dangerous consequence of our changing climate conditions and poorly-
planned development. The 2014 Boles Fire in Weed began near a heavily-wooded hillside and destroyed
about 150 structures including many homes. With that in mind, the question arises, has the IS/MND for
this Freeze mini-storage and car wash Project adequately evaluated the risks of wildfire here adjacent to
the heavily-wooded steep slopes of Spring Hill in our City?
The IS/MND is required by CEQA to answer this question of would the Project, due to slope, prevailing
winds, and other factors, exacerbate wildfire risks or expose people to the uncontrolled spread of a
wildfire? It however failed to do that. It inexplicably reaches a conclusion that this Project will have a
less-than-significant wildfire impact without first competently analyzing that wildfire risk. How was
such a conclusion reached without the IS/MND first informing the public what the “threshold of
significance” is for a significant wildfire risk? At what point does the inherent risk of wildfire drop
below a threshold of significance? The IS/MND never sets that threshold. Instead, it violates CEQA
where it jumps to an unsupported conclusion of a less-than-significant wildfire impact without
evaluating whether:
(1) sufficient water is available for fighting a fire in the mini-storage warehouse buildings, or
whether
(2) adequate clearance between the heavily-wooded steep hillside and the warehouse buildings
and access driveways exist?
Not even a single wildfire mitigation is proposed such as requiring fire extinguishers be provided for
customers or an automatic fire sprinkler system be installed in all 153 separate mini-storage units.
Separate sprinklers are required because metal partitions divide the storage units, and without separate
sprinklers, some fires would not be doused at all or at least quickly enough.
The IS-MND (4.0-76) acknowledges this project site is in a Very High Fire Hazard Severity Zone. But
the IS-MND only considers if wildfires occurring on Spring Hill will endanger this warehouse
development at its base. The IS-MND never considers whether project users themselves, their stored
items or their activities will endanger Spring Hill's forested slopes by starting a wildfire. No protective
CEQA mitigation is being proposed to effectively prevent storage of hazardous chemicals or flammable
items in these self-storage units. This Project, located at the edge of this vulnerable wooded hillside with
a Very High Fire Hazard Severity designation, is essentially a tinderbox, a virtual time bomb waiting for
a spark to set it off. But the public and City officials are being kept in the dark by the IS/MND's failure
to evaluate this critical and unacceptable wildfire risk.
• It is not sufficient for the IS/MND to state Mr. Freeze will be required to maintain a 100-foot wide
defensible space buffer around these warehouse structures to flammable vegetation at Spring Hill
when those heavily-wooded slopes beyond the property line begin just 25 feet from the closest
proposed storage building. The IS/MND offers no explanation about how an adjacent land owner
(Crystal Geyser) can be compelled to remove 75 feet of width of underbrush and trees from its
property so that Mr. Freeze does not burn down the northern half of the City? These warehouses
have been squeezed so far north on the Project site that not only are their driveways and fences to
be built atop the City’s sewer easement, but the Project fencing may be constructed beneath some
overhanging trees on Spring Hill on other peoples’ property if Mr. Freeze does not illegally cut
those trees too.
• Extending a water line to the mini-storage warehouse building site is not sufficient if the City cannot
supply sufficient water flows at sufficient pressure to fight fires within these storage units. The
IS/MND never discusses whether sufficient water volume and pressure will be available though.
The IS/MND notes that Spring Hill is adjacent to the site’s northern boundary and is forested with native
vegetation, which may pose a wildland fire hazard risk to the Project site. But the IS/MND fails to
support its determination that this Project will have a less-than-significant impact upon wildfire risks
with substantial evidence.
NO EVIDENCE OF ADEQUATE WATER PRESSURE AND FLOW RATE

There simply is not sufficient water pressure with adequate flows to protect these storage buildings from
fire. The documents in the City’s Freeze Project files prove that point.
First, the IS/MND does not identify any reasonable threshold of significance for adequate water supply
to both fight structural fires here and prevent spreading wildfire impacts. At the very least, that threshold
would be the minimum amount of water required by the 2016 California Fire Code. Of course the truly
applicable threshold would be higher. It would include additional water to both fight structural fires and
also nearby wildfires that could extend beyond the Project site. It would also include the City being able
to supply other nearby homeowners and business owners with water for preventative yard watering and
structure defense if an out-of-control wildfire were to threaten their homes.
The 2016 California Fire Code1 Table BB105.1 (“Minimum Required Fire-Flow and Flow Duration for
Buildings”) requires this Project’s storage buildings to have at least 3,750 gallons per minute (gpm) of
water available for at least three hours. (See attached Table BB105.1 below)2
1
See California 2016 Fire Code, available at: https://www.citymb.info/Home/ShowDocument?id=28089
MST Comments: WILDFIRE IMPACTS

Freeze Mini-Storage and Car Wash Project’s Revised IS/MND 7-25-2019 Page 2 of 11
NOTE: The City failed to notify Mt. Shasta Tomorrow (MST) about this Project’s Revised IS/MND as is required by CEQA § 21092 after
we requested on 8/18/2017 such future notice. ("A lead agency that is preparing... a negative declaration .. shall provide public
notice of that fact within a reasonable period of time prior to ... adoption of the negative declaration . " (See CEQA § 21092) An
agency's failure to comply with public notice requirements invalidates the subsequent adoption of the negative declaration and its
conclusions. The City is currently refusing to extend the public comment deadline to provide MST with the full 30-days for public
review and comments that others have received. Accordingly MST reserves the right to submit additional comments beyond the
City’s comment deadline.
2
In correspondence in the Project file, the City Manager misstated that amount of water flow to be 3,250 gpm for three
minutes. Perhaps he simply misread this Table BB105.1 which allows that smaller flow rate for Type IIB buildings only up to
25,900 square feet in Fire Area. Here though, Mr. Freeze is proposing 29,858 square feet of storage buildings.

These metal storage buildings would have a total “Fire Area” of 29,858 square feet in floor area and
would be Type IIB according to the Project plans. The Fire Code thus requires either a minimum of
3,750 gpm for three hours or requires that automatic fire sprinklers be installed in all of these separate
153 storage units with at least 1,500 gpm of fire-fighting water available for three hours.
Why is that information not in the IS/MND? It is not for lack of trying. On March 22, 2018, City
Manager Bruce Pope wrote to David Young (who works with the the IS/MND preparer planning firm
Michael Baker International) asking that the IS/MND show that the City is requiring a water supply flow
of 3,250 gpm for at least 3 hours. But that information or threshold of significance never got included in
the IS/MND. Apparently David Young failed to follow through. Apparently that missing information
also escaped the attention of other City officials who subsequently reviewed the Draft Revised IS/MND.
City documents also reveal that on 2/21/18, Mr. Pope emailed Mr. Freeze and wrote that he is not happy
with how Michael Baker International handled this fire issue in the IS/MND. These consultants went
over their budget and wanted more money than they had agreed to, and they wouldn't include an
analysis of the placement of the water line for fire fighting purposes either. On 2/28/18, Mr. Pope wrote
again suggesting the City consider firing Michael Baker International, starting over with another
planning firm, ENPLAN, or having City Staff do its own IS/MND. This is further evidence that the
IS/MND is incomplete regarding the wildfire risk impact issue. That planning firm certainly did not do
its job in providing our community with an adequate and safe analysis of this risky warehouse Project.
The only way the City can approve this Project with a lesser flow rate than 3,750 gpm according to the
2016 California Fire Code is if an exception is made and an approved automatic fire sprinkler system is
installed in these storage units:
“Exception: A reduction in required fire flow of up to 75 percent is allowed when the building is
provided with an approved automatic sprinkler system. When a reduction in fire flow is used,
fire flow shall not be less than 1500 GPM.”
But even then at least 1,500 GPM is required, yet there is no evidence in the IS/MND or other available
City documents for this Project’s file that even that bare minimum of 1,500 GPM will be available.
Moreover, for purposes of CEQA, even complying with the minimum standards of the Fire Code will
not in all circumstances imply that the fire or wildfire risk is less-than-significant.3 The immediately-
adjacent proximity of the heavily-wooded steep slopes of Spring Hill will require much more water be
available if these storage units potentially filed with very flammable contents are allowed.
3
Berkeley Keep Jets Over The Bay Committee v. Board Of Port Commissioners of the City of Oakland
http://resources.ca.gov/ceqa/cases/2001/berkeley_keep_083001.html
"We find it noteworthy that CEQA appendices G and I could have defined significant . . . . impacts simply in terms
of whether a project would violate applicable local, state, or federal noise standards. Instead, by adopting a site-
sensitive threshold of significance for . . . . , the Guidelines mirror the proposition that "[a]n ironclad definition of
significant effect is not always possible because the significance of an activity may vary with the setting. For
example, an activity which may not be significant in an urban area may be significant in a rural area." (CEQA
Guidelines, § 15064, subd. (b).) (See Comment, Reconciling Environmental Protection with the Need for Certainty:
Significance Thresholds for CEQA (1995) 22 Ecology L.Q. 213, 234-236, 273.)"

Examples of how fires within self-storage units spread quickly throughout the structure, especially
when fire fighters cannot readily break through hundreds of separate doors to fight such fires.
For CEQA review purposes, 1,500 gpm of water flows will not be available, as far as the public can tell.
The City Engineer in Project documents in 2016 stated: “but less than 450 gpm was available, and even
then, the water pressure could drop to zero if two or more fire hydrants were turned on.” The City
Engineer calculated to get that flow rate, a new well and a water storage tank near Spring Hill was
required costing nearly $2 million. (See correspondence below) None has been provided though.
The City Director of Public Works Rod Bryan on March 1, 2016 wrote: “Please see the attached fire
flow analysis for the proposed project. It's better than we thought. It looks like we can provide up to
1200 gpm. Please note that this is dependent upon the completion of the Big Lakes Water Line
Replacement Project and the completion of the remaining work on the Supply Line Replacement
Project.” His correspondence too is evidence of an insufficient water supply because 1,200 gpm is less
than the 1,500 gpm minimum which the Fire Code at least requires if approved automatic fire sprinklers
are installed throughout the 153 storage units.
But there is no evidence that automatic fire sprinklers will be installed in all 153 storage units, or that
they would be maintained functionally over the years. If not required by a mitigation, the public would
have no means of enforcing such maintenance. Nothing in the way of a mitigation in the IS/MND
requires them. To the contrary, in a 3/20/2018 letter from the City Manager to Mr. Freeze, the City
reverses its earlier direction to include sprinklers in the warehouse units and states Freeze will not need
to provide sprinklers unless he wishes to:
"Fire Flow & Fire Hydrants

The initial topic of last week’s meeting was to clarify the fire flow and hydrant requirements.
The development does not need to provide a fire sprinkler system for the development,
unless the applicant chooses to.”

“The City Water Improvement model prepared at the beginning of this project determined that
the project has access to 1100 gallons per minute. Based on the draft plans submitted to date the
mini-storage development would need 20 feet of separation between buildings, add at least one
4 hour fire wall separation in each building, reduce each building to less than 5,900 square feet,
and improve water service to achieve 1,500 gallons per minute per Table BB105.1 of the
California Fire Code with Fire Chief exception. These requirements are dependent on the
building construction material which is metal in the current plans. Changes to the building
materials would result in new fire code requirements.”
(emphasis added)
So, to repeat this point because it is important, if there are no functioning automatic fire sprinklers, then
even 1,500 gpm of water flows for fire fighting will be inadequate. Clearly the IS/MND has not
supported its conclusion that this Project at this location will result in a less-than-significant wildfire
impact.
The following emails between the City Engineer and City officials demonstrate the problem that has not
been solved with supplying water for this Project’s fire fighting purposes:


SELF-STORAGE WAREHOUSES ARE A WELL-KNOWN FIRE HAZARD
Furthermore, as evidence that self-storage warehouse units are fire-prone, this information from a
credible source is available on the Internet and has been posted to a local website:
10/01/2016 BY JOSEPH T. BERRY

The self-storage facilities considered below are generally one- or two-story buildings featuring
prefabricated lightweight metal or concrete-block construction. Although they share similar problems and
hazards with all self-storage facilities, these construction types seem to suffer the most at fire incidents.
The incident commander’s (IC’s) major concerns operating at a fire at a self-storage building are the
lightweight construction’s collapse potential; the enormous amount of sometimes densely packed,
combustible contents; and the unknown hazardous materials or liquids stored within. Self-storage
facilities are in almost every large city, suburb, and rural area throu...
https://www.fireengineering.com/articles/print/volume-169/issue-10/features/storage-unit-fires-hazards-
unknown.html
"Light-gauge metal partition walls separate units from one another on the sides and back. The partitions
do not extend to the underside of the roof, leaving an opening at the ceiling level between each unit. This
lets fire travel horizontally and unimpeded throughout the building. A fire in one unit could extend to the
neighboring units once the metal partition wall heats up and conducts to the contents of adjoining units.
Firefighters can expect to find fire in numerous units upon arrival."
https://www.firehouse.com/operations-training/article/10498637/selfstorage-facilities-part-1-lightweight-
metal-storage-buildings

INADEQUATE DEFENSIBLE SPACE FIRE CLEARANCES

These mini-storage warehouse units would be less than 20 feet from mature conifers on City property along North
Mt. Shasta Boulevard to the west. They would also be about 25 feet from the heavily-wooded steep hillside to the
north as shown on a simulated aerial photo of the Project on the next page. Those distances are measurable on
documents submitted by the Project applicant. But those distances do not provide sufficient defensible space to
comply with California laws.
According to California defensible space regulations in Public Resources Code § 4291, large trees do not have to
be cut and removed within 100 feet of the mini-storage warehouse units as long as all of the plants beneath the
large trees are removed. This eliminates a vertical “fire ladder.” However removing all the plants beneath the trees
within 100 feet of the mini-storage warehouse units would remove all the visual shielding such lower vegetation
provides against this Project’s incompatible aesthetic impacts from North Mt. Shasta Boulevard. That would
create an aesthetic impact that this IS/MND fails to analyze.
Within 30 feet though of these mini-storage warehouse units, this Project owner would also have to remove all
flammable vegetation or other combustible growth. That would include vegetation on the City’s and on Crystal
Geyser’s properties. Removing brush and flammable vegetation on Crystal Geyser’s property would cause
damaging soil erosion and surface water pollution on its steep hillside.
By squeezing too many warehouse units on this Project site and placing them too close to the property lines, the
applicant has reduced critical and State-required defensible space clearance opportunities. While California
defensible space laws are somewhat relaxed when distances to property lines are less than those minimum § 4291
clearances, that does not imply that the Project’s fire safety risk with shorter distances to property lines is less-
than-significant under CEQA. Those relaxed regulations are meant to make these regulations more easily
implemented on smaller properties. But there are reasons for those minimum distances, and those dimensions are
effectively thresholds of significance for this Project’s fire and wildfire safety impact analysis. The IS/MND
never evaluated such risks, and as a result, its conclusion of a less-than-significant wildfire risk is incorrect and
unsupported by evidence.

The applicant submitted a photo showing the heavily-wooded steep hillside of Spring Hill at the north edge of his
Project site:
These trees would be about 25 feet from the nearest mini-storage buildings that could catch on fire:

CONCLUSION
Thank you for considering these comments about the Project’s significant fire safety and wildfire
impacts. Because this Project's Revised IS/MND is so inadequate, please require an EIR be prepared to
properly evaluate the Project's impacts.
Please notify our organization, Mt. Shasta Tomorrow, should any future opportunities arise to review
and comment on this Project.
Sincerely,
Dale La Forest
Director, Mt. Shasta Tomorrow


MST Comments - Wildfire Impacts - Freeze Is-Mnd 7-25-19nd

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Juliana Lucchesi, City Planner jlucchesi@mtshastaca.gov

NO EVIDENCE OF ADEQUATE WATER PRESSURE AND FLOW RATE

MST Comments: WILDFIRE IMPACTS

MST Comments: WILDFIRE IMPACTS

MST Comments: WILDFIRE IMPACTS

"Fire Flow & Fire Hydrants

MST Comments: WILDFIRE IMPACTS

MST Comments: WILDFIRE IMPACTS

MST Comments: WILDFIRE IMPACTS

10/01/2016 BY JOSEPH T. BERRY

MST Comments: WILDFIRE IMPACTS

INADEQUATE DEFENSIBLE SPACE FIRE CLEARANCES

MST Comments: WILDFIRE IMPACTS

MST Comments: WILDFIRE IMPACTS

MST Comments: WILDFIRE IMPACTS

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