Community Venture Partners, Inc. reached out to unbiased fire safety experts, regarding the City's plan to permanently reduce the Parkway section of Miller Avenue from two lanes in each direction to one lane in each direction. The letters by fire experts are attached to this comment sent to the City Council this morning.
Dear Mill Valley City Council:
After conferring with fire safety experts we are submitting these additional comments to clarify and emphasize our opposition to the City’s stated intention to ignore the State Fire Code and FEMA Guidelines, for 20 feet of free and clear roadway width on Miller Avenue, as required to provide adequate access (ingress and egress) for emergency responders, firefighting vehicles, and equipment. Further, the City is intending to make its decision without regard for the requirement for evidenced-based assessments to inform that decision, as required under the California Environmental Quality Act (CEQA).
Attached please find comment letters by two eminently qualified experts in the field of fire safety and wildfires,Marcelo M Hirschler, Ph.D. of Mill Valley, and Joseph B. Zicherman Ph.D., SFPE, and President of the Mendocino Fire Safe Council. Both express unequivocal opposition to the City’s proposals, including the City’s proposed evacuation plans.
Based on a review of the facts and circumstances in jurisdictions where this type of one lane thoroughfare plan has led to catastrophic results (e.g., the Town of Paradise, CA) and citations of regulations in our letter of February 28, 2019, we find that the City’s proposal will potentially create unassessed and significant impacts and hazardous conditions for existing users / residents of the City, which must be fully assessed under CEQA prior to any decision by the City Council.
In his letter, fire expert Joseph Zicherman calls the one lane plan “an exceedingly bad idea.” And in commenting on the City’s proposed evacuation plan, he states, “Mill Valley's fire evacuation plan relies on "controlling all intersections" in a catastrophic event. This is a similar approach to that followed by Paradise in Butte County where that plan failed very early in the recent fire and where the terrain is far less challenging than in Mill Valley.”
The Addendum to the Mitigated Negative Declaration fails to address or assess these potentially significant impacts and hazardous conditions, and fails to provide any evidence, third party studies or other analysis whatsoever related to fire and emergency access safety, to justify its consideration or approval of the preferred Option (Option #5), or any other option that reduces Miller Avenue from two lanes in each direction to one lane in each direction.
City Staff has not undertaken an adequate assessment of fire hazard and public safety impacts, or its evacuation plans, and no such assessments are included or referenced in the MND or the Addendum to the MND. In fact the only instance where fire safety was even addressed during the Pilot Project process, was when the City informally asked the Fire Chief his opinion of whether or not the Pilot Project seemed “okay,” at a hearing prior to starting the Pilot Project. At that hearing, without the benefit of any actual project plans, specifications or dimensioned drawings or an adequate project description (per CEQA), the Fire Chief yielded to the Council’s predetermined conclusion.
The City’s “process” utterly failed to address CEQA requirements for evidence-based decision making, which were enumerated in my letter of February 28, 2019. The City’s proposals and process have failed to demonstrate in any way or with any evidence that the Pilot Project plan or its recommended Option #5 will provide superior public safety or bicyclist safety in the Parkway section of Miller Avenue. At the same time the public and experts in the field of fire safety and planning have clearly argued that the City’s plans and proposals will most certainly decrease public safety and increase the potentially hazardous conditions that will result in the event of a catastrophic canyon fire event.
I am also attaching the as-built roadway dimensions prepared by resident John Palmer and two published news articles on this issue, in support of the contentions made herein. Thank you for your consideration and this opportunity to submit our comments.
Cc: Jim McCann, Patrick Kelly, Kelsey Rogers
Attached: Letters by fire experts:
Attached: Information and New articles:
Here's how Paradise ignored warnings and became a deathtrap, by Paige St. John, Joseph Serna and Rong-Gong Lin II, DEC 30, 2018
Lessons from Camp Fire: Staying alive in California fire country, by Lisa M. Krieger, Nov. 17, 2018