This letter addressed to Mountains Recreation and Conservation Authority Project Analyst Mario Sandoval.
My wife and I have lived in Malibu over 30 years and have been through many fires. We evacuated once and were ready to evacuate on other occasions. We are extremely concerned about this project, not only because it dramatically increases the possibility of fires in a very high fire prone area, but also because of the degradation of a wonderful unspoiled Puerco Canyon by substantially increased density of use. It is hoped that the MRCA will thoroughly deal with those issues in the EIR.
Notice: I want to repeat once again our concerns about the notice and location of the scoping meeting. This particular project, since the only ingress and egress will be through Puerco Canyon and Pacific Coast Highway, and because of its location, will seriously impact the city and citizens of Malibu. Yet the scoping session was held in Pacific Palisades, not Malibu, and little or no notice was given to the residents of Malibu, especially those living just below the project who would be immediately affected by the scope and any fires that originate on the site. We continue to request that another scoping meeting occur in Malibu with sufficient notice to its citizens. While the MRDC may have technically “done all required under the law” as one representative told me, even if that is true, as a practical matter few people knew about the meeting and the project. If notice to those affected was the intent, more should have been done.
Time to raise scoping questions: We also object to the fact that the notice of the meeting is dated June 7 (we don’t know when it was sent out and to whom) but the scoping meeting did not take place until June 27, 20 days into the 30-day scoping period for comments. That left us with six working days to comment in writing before the July 9 closing date. To make matters worse, the bulk of that time is over the Fourth of July week, when many are on vacation. We strongly feel that, as a practical matter, this is insufficient time for all affected to render comments to make the EIR thorough.
That being said, below are some of the questions and issues I would like covered by the EIR. As you no doubt learned from the one scoping meeting that occurred, many Malibu residents are very concerned about this project and especially about the potential fire and other dangers to their homes, businesses and the city of Malibu. This should be a major focus of the study. Below are some questions to consider:
- What will be the ingress and egress routes to and from the camp by vehicle? If it is only by Puerco Canyon Road, what improvements will have to be done to the road and who must give permission to do so?
- Exactly to whom and when was notice of the scoping meeting sent on this project. Please be specific.
- What is the evacuation plan for the project in the case of a fire or other emergency? Please be specific. [See also question 7.]
- Has this evacuation plan been vetted with the local police and fire agencies?
- How will emergency vehicles make it up Puerco Canyon Road if panicked campers and others (there is a parking lot for 90 vehicles) are coming down in an evacuation scenario?
- Does the parking for 90 vehicles contemplate “busses” and other multi-passenger vehicles? Where will overflow parking be located?
- What type of emergency plan is in place for the following situations:
- Fire
- Landslide
- High winds
- Torrential Rains
- Active shooter
- Gangs and other crowd or individual violence
- What sort of fire equipment will be on site and what will be have to be brought in should the fire not be capable of being handled by whoever is on site. Will the fire equipment of MRCA be brought in each day or will it be resident on the site? Be specific.
- Exactly who will be on site for fire suppression each day and how many firefighters will be there? What training will they have and will they be certified by any agency other than MRCA?
- Have any studies been done by any agency or organization or individual as to the fire prone nature of the area and the site? If not, we would request such a study taking into account the location, other fires that occurred in and around the area, when they occurred, the results of those fires including any structural, ecological and damage to people and animals, the amount of fuel for a fire available in the area and any recommendations of any local or state agencies (including fire departments and environment agencies) for use of the site for the purposes requested by the MRCA.
- What are the hours and days that personnel will be on duty at the site – please break down by hours and days e.g. if 3 people will be there during the time the park is open but only one will be there when it’s not, please advise. Will someone be there 24 hours? Who and how many people?
- When the park is closed will it be accessible, like it is now, to the public? If so how will the MRCA monitor unauthorized campfires, smoking, and other dangerous activities?
- Where will the water used for the site come from:
- If trucked in by tanker, how often will tankers have to service the site?
- If stored on the property, how much water will be stored and where?
- If water is intended to come from wells, what does the testing of the water show as to whether it is drinkable?
- If from wells, who owns the water rights?
- If from wells, what will the water to service these sites do to the aquifer and how much water is available?
- How does California’s continuing drought affect the amount of water available and the restrictions on its use?
- If power fails and the water cannot be pumped from wells or tanks, what is the alternative to supply water for firefighting?
- Have water districts been approached to supply water and what have they said? Do you have a “will service” commitment and if so, what will be the cost of bringing water to the site? Who will pay that cost?
- Are parties, weddings or other events planned for the sites and if so, on what frequency?
- What sort of events are planned or will be allowed?
- How will those events be promoted and to whom?
- How many people will the events service at one time if at full capacity?
- Where will the money for the events go?
- What effect will large events, such as weddings, parties and the like have on the environment of the site and surrounding areas, specifically on plants, animals, and ESHA?
- Is this an ESHA or are there any environmental of scenic assets that will be affected by the project and if so how? Will the MCRA continue the spraying of Roundup on the site to suppress plants? If so how often and in what areas? We understand that the MRCA has been spraying roundup in the past; is this true and how often was it done?
- What affect will the entire project have on the surrounding environment, including plants, animals and ESHA?
- When was the last time that the area of the camp and the surrounding area burned?
- What abatement procedures are planned so that fire personnel will be assisted in fighting fires on or around the site?
- What sort of fires will be allowed on the site, specifically at the camps and in any cooking facilities that are on or around the site? What are the plans in place to mitigate any fire risks? How effective are mitigation efforts given other MRCA and State park sites?
- Will smoking be allowed on the site and even if not, how will the MCRA prevent illegal campfires, illegal smoking, candles or the rouge match that is tossed in the bushes.
- What sort of electrical power be used by the site and how much?
- How will the power be supplied? Gas generators, by power poles, solar, wind or other means? Describe what percentage from each source.
- What power or electric companies have been contacted and have they agreed to supply power to the site? Will power lines or other infrastructure have to be built to provide power and if so describe? Who will pay for the infrastructure? Will there be open or buried wires and if open, what will be done to protect against sparking?
- What sort of medical facilities and personnel will be on site?
- What are the evacuation plans if Puerco Canyon is blocked for any reason, like fire, rock slide, gridlock of vehicles escaping, traffic accident etc. and how will emergency vehicles reach the site in such an event?
- What jurisdiction will pay for fire, police and medical protection in the event the personnel on site cannot handle the situation? Has MRCA gotten a commitment from any jurisdiction to do so and if the answer is yes, what jurisdiction? If no, what jurisdictions does the MRCA plan to approach and on what basis?
- Has there been a very recent traffic and engineering study done at the corner of Puerco Canyon Road and Pacific Coast Highway, one of the very dangerous intersections in Malibu and the only intersection servicing the site? If not one should be done as part of the EIR?
- What effect will the substantially increased traffic flow up and down Puerco Canyon have on the surrounding neighborhood and its character, the safety of the road, the possible gridlock and other similar issues?
- What affect will the additional car exhausts from the increased vehicle traffic have on the surrounding environment, including plants, animals and people?
- Please compare and contrast the activity planned by the MRCA to the activity of the MRCA on Ramirez canyon and indicate how it differs and what can be done to mitigate it.
- What will be the hours of the operation of the site? For operation after sunset, what light sources will there be and how will what is provided vary from the Dark Skys legislation Malibu has considered or has passed.
- What affect will increased light on the site after dark have on plants, animals (especially those who feed at night) and the environment generally?
- Where does the funding come from for this site? Is it from bond money and if so what bonds specifically?
- How much will the full build out of this site, including brush clearance, building of structures and facilities etc. cost?
- What will be the yearly budget for the operation of the sites? Where will the funding to maintain the site come from? If from Bonds which specific bonds? How can we be assured that the MRCA will have the budget to maintain the site in the future? If it does not have the budget what will become of the site?
- Will the site be opened during high wind, red flag or excessive temperature days? What are the plans for those days? Will any personnel be on site during those days?
- How many MRCA personnel will be on site during the operation of the camp? Please list the number, their job, their training.
- What will be done to maintain the site, keep it clean, and keep fire danger down? Given the condition of other areas that have been opened by the MRCA it seems to work on a limited budget? What has been the maintenance history of the MRCA once they have opened a site? Are there complaints and problems that have been associated with MRCA’s operation of other sites?
- What sort of wastewater disposal including toilet output, be on the site? Will there be septics or if not what other source of disposal?
- Given showers, water fountains, kitchens, campsites etc., there will potentially be a lot of water run off.
- How much water run-off will there be?
- Where will the run off go?
- What affect will the insertion of the water into the ground have on the geological composition of the site, including the potential for land slides?
- Will or can a biological study be done to verify the stability of the land and the affect of the increased traffic, people and water?
- What is the nature of the fill on the property? How stable is it and was it compacted in a way to comply with current safety and health standards?
- What was in the compaction, i.e. what was used to fill?
- What other geological issues does the land have and how will they be affected by this project?
- Who will be liable for damage from fire, and other uses of the site, as well as landslides exacerbated by the operation of the site? What sort of resources will the MRCA have to cover such liability?
- What sort of insurance and what limits will be maintained on the site?
- What agency will actually operate the site?
- Are there any plans to work with the city of Malibu on the site since a portion of the site and Puerco Canyon Road are in the city of Malibu? If so what will that cooperation be and when will it start?
- What sort of disaster and evacuation plan is in place regarding the Pet Hotel at the bottom of Puerco Canyon Road which I understands often boards 100 dogs and had to be evacuated in connection with previous fires?
- How much was paid for the site and were there any restrictions placed on the property when it was sold? Who is the actual owner of the property, which agency?
- Given the severe drought situation in California and the incredibly high risk that this area has for burning, and the substantial increased use of the site (way in excess of the current hiking allowed) is this the best place for this use of such a site with all the activities that are planned on it?
I would appreciate if all of the above concerns and questions are addressed in the EIR. Thank you for your consideration.
E. Barry Haldeman