32 year state of California veteran firefighter
Fire Prevention Professional
Brian Wolshon, Ph.D., P.E., P.T.O.E.
Consultant, Baton Rouge, Louisiana
May 3, 2019
City of Oceanside Planning Commission
Development Services Department
City Hall South Building
300 North Coast Highway
Oceanside, California 92054
RE: Review of the North River Farms Project Evacuation Plan
Dear Planning Commission Members,
Pursuant to a request by Preserve Calavera, I have undertaken a review of the Evacuation Plan document for the North River Farms Project. This letter summarizes my understanding of the report and the plan and is submitted for your consideration prior to Planning Commission hearing for this project currently scheduled for May 6, 2019.
The findings and opinions expressed in this letter are based on the online version of this report dated June 2018 (Dudek 2018) as well a brief telephone conversation that I had with a representative of the Preserve Calavera organization. During this conversation I was provided some additional background on the characteristics of local area and the history of development in the surrounding vicinity.
The opinions expressed here also reflect my career of research and review of evacuation planning, management and operational principles, policies, and practices as well as the application and interpretation of relevant and appropriate emergency planning. My experience also encompasses work as a practitioner and a designer of transportation facilities related to evacuation; a researcher who has studied, developed, and interpreted design, safety, and operational conditions of transportation facilities under emergencies, evacuation and other disruptive events, and as an instructor of transportation theory and application of evacuation-related principles in undergraduate, graduate, and professional development courses. This review was also undertaken within the context of wildfire emergency plans for other areas of California as well as evacuation plans for other hazards in locations throughout the United States.
I have included a very brief, summarized version of my CV that contains a small, representative cross-section of my work, experience, and products related to evacuation. Among the items of particular relevance to this letter are my leadership positions as an advisor and researcher on topics related to evacuation; reviews and evaluations of evacuation practices nationwide; the writing of federal evacuation guidance documents for the United States Nuclear Regulatory Commission, Department of Homeland Security, and Department of Transportation; my work as an expert witness in legal testimony related to evacuation; the writing of a textbook on evacuation theory and practice; and over 100 media interviews for local, national and international newspapers, magazines radio, and television outlets.
Scope of Involvement
The scope of work for this review was established to examine concerns about the traffic impacts during times of emergency in the vicinity of the proposed North River Farms Project that would likely be exacerbated by the project and create threats to public safety.
It is my understanding that, within the past year, at least one wildfire has threatened this area, precipitating an evacuation. During this event, evacuees were delayed by traffic congestion for over two hours within areas vulnerable to the fire threat. Given that this proposed project will add significant levels of traffic to the same network, there are amplified concerns about public safety. The recent history of wildfires elsewhere in the state as well as the often variable and unpredictable nature of wildfires also add to the level of unease.
As a result of these conditions, there are clear concerns that although the developer of the North River Farms project has prepared an evacuation plan, it does not adequately address community concerns. More specifically, it is felt that the full range of potential hazard-response conditions have not been thoroughly nor adequately reviewed, analyzed or planned for such emergencies. Combined, these facts lead to a basic question:
“Is the plan that has been submitted adequate to to ensure safe and timely evacuation of the entire Morro Hills area of Oceanside (not just the project site) during wildfire conditions?”
The intent of this review was to help Preserve Calavera answer that question.
Report and Content
The “DRAFT Conceptual Wildland Fire Evacuation Plan for the North River Farms Community” document was prepared for the Oceanside Fire Department in June 2018. The plan, as its title indicates, is conceptual. As such, it tends is a high-level discussion of the key needs and concepts that should be considered in developing a more detailed operational-level evacuation plan. According to the document, the plan was prepared based on the City of Oceanside (City) Emergency Operations Procedures, which themselves are based largely on the “Unified San Diego County Emergency Services Organization and County of San Diego Operational Area Emergency Operations Plan (EOP), including its Evacuation Annex.”
The plan contains seven primary sections. The first is a “plan” that would be given to each homeowner within the proposed development at change of property. This includes important actionable information about available evacuation routes, their potential vulnerability to wildfires, and contingency refuge areas along the evacuation routes. This resident information section also provides information of the location of hospitals; how to register for emergency alerts; and other key emergency-related information. It should also be noted that as there are likely to be non-english speakers within and near the proposed development, all information should be communicated in appropriate non-english languages. Guidance on emergency transportation communications, including the distribution of such information to non-resident populations (transient, visitors, tourists, workers, pass-through traffic, etc. which is also not addressed in the draft plan), can also be found in Transit Cooperative Research Program Report 150 (TCRP 2011).
The remainder of the document provides more specific background and supporting information “intended for review by emergency management agencies, including this plan’s consistency with Oceanside’s Emergency Plan and standard San Diego County Office of Emergency Services evacuation planning.” The plan incorporates much of the most current approaches to emergency planning for evacuations. For example, the document recognizes the multi-agency, multi-stakeholder, multi-jurisdictional nature of evacuations and the need to maintain cooperation and coordination between all of them; both for planning and actual operations. It also acknowledges the “unique challenges, constraints, and fluid conditions that require interpretation, fast decision making, and alternatives” that are also a part of all evacuations as well as the need to update plans based on lessons learned from other evacuations, for wildfires in California or for other hazards in other locations. As part of its broad discussion the report also explains various aspects of emergency management command and coordination structure, including the California incident command hierarchy and how it supports the coordination of personnel and resources during emergencies.
Among the other key areas discussion include animal evacuations; shelter-in-place concepts; evacuation timing; the need for and use of safety zones; the evacuation of special needs populations; animal evacuations; and the management of post-event reentry. In Section 4 of the report, the plan covers more location- and condition-specific information related directly to the proposed development. This includes its location, level of threat, road network, and how the areas road system could be used during and emergency evacuation. This section also includes several maps to illustrate the location of the development relative to prior fire events and “trigger points” for potential fires that would necessitate an evacuation notice.
The report also includes a discussion of hazard awareness and the need for residents of the proposed community to be aware of potential hazards and have personal readiness plans in the event of an emergency. These are further supported by the supplementary documents in Appendices A and B. This is vitally important information and reflects lessons-learned in recent past history in evacuations. Ultimately, the decision to evacuate (or not) as well as the decisions of when to make it, where to go, and what routes to take are personal/household decisions. Because of this individual residents and households must take a leading role to insure their personal safety in times of emergency.
Based on my review of the plan it clearly documents many of the key topics and issues that are necessary to develop and support an evacuation plan. However, this document does not represent a “plan” per se. Rather, as the title suggests it is “conceptual” and it discusses many of the important concepts and needs of evacuations and presents a general framework for it, from which, a plan (with additional analyses and planning) could be developed. Additionally, the document states that:
“this Emergency Evacuation Plan is to be considered a tool that supports existing pre-plans and provides for citizens who are familiar with the evacuation protocol, but is subservient to emergency event-specific directives provided by agencies managing the event.”
Relative to the specific issues of concern to the Preserve Calavera organization, there no way to determine whether or not the plan is adequate to ensure safe and timely evacuation of the area under a wildfire condition. This is true both for the Morro Hills area of Oceanside as well as the project site. In fact, there is no evidence within the report to suggest that an evacuation traffic study of any kind was conducted for the development itself or, more comprehensively, for the greater region surrounding it. Such form the foundation of evacuation assessments.
Obviously, one of the fundamental factors in determining the adequacy and effectiveness of an evacuation for conditions such as this is to understand the route travel times and delay conditions expected during the event. From a traffic/transportation perspective this is commonly done using traffic modeling and simulation under certain sets of behavioral response assumptions. The results of these assessment are used to estimate of evacuation clearance time, another fundamental component of evacuation planning. They also support protective action decision-making and often are used for the development of traffic management plans, including the assignment of traffic control points and estimating resources needed for the development of plans for transportation-dependent populations.
Evacuation plan development for other hazards, particularly point source hazards like nuclear power plants, must follow regulatory guidance (Jones et al 2011) including the development of evacuation time estimates that require analyses that reflect of a range of possible conditions (weather, participation rate, response time, direction of travel, etc.) that would impact evacuation clearance times. Hurricane evacuation planning, as another hazard of note, follows similar a similar structure.
This report does not show any quantification or analysis of traffic conditions, nor factors of the other key factors that would govern the scope and scale of an evacuation, nor its timeliness. This includes, for example, an estimate of the number of people and vehicles involved in an evacuation, nor the timing at which they would respond to a notice to evacuate and enter the road network. Similarly, there is no assessment or discussion of the traffic conditions on the area road network. As the proposed development is in a highly populated region, it would be expected that the area road network would be carrying other evacuating traffic as well as background and or “pass through” traffic that would normally be in the area at any time of day. Finally, while the document mentions the need to plan for special needs populations, there are no specifics in terms or the resources, procedures, and management required for evacuating these individuals.
No plan or plan document is ever able to account for all conditions that might be encountered during an evacuation event associated with a major emergency. However, there many sets of assumptions that could be used to estimate clearance times and assess how an evacuation process might take place under ranges of conditions on a road network at different times of the day/week/year. However, these assessment were not included in this report. Similarly, there was no discussion of the resources needed and or available to manage an evacuation. This includes, most notably, the people and agencies that would need to coordinate and direct critical elements of the plan, including the movement and/or accommodation of special needs populations, pets, etc.
Broadly, this report has similarities to other county wildfire emergency plans that I have reviewed. While they contain useful information, they often do not include “evacuation plans” as such. The non-inclusion of evacuation-specific traffic analysis in emergency plans is not uncommon, however. The past history of major emergencies across the work has consistently and repeatedly shown that truly detailed and effective planning rarely takes place before an emergency happens. More commonly, it takes place after a major disaster has occurred – and often after significant loss of life.
If you have any questions or require additional information with regard to this matter, please contact me.
P. Brian Wolshon, Ph.D., P.E., P.T.O.E.
10741 Spring Fest Lane
Baton Rouge, Louisiana 70810
PAID FOR BY: LET OCEANSIDE VOTE