HomeMy WebLinkAbout9-14-26 Afternoon Enderle Ctr Dr.URGENT FIRE SAFETY OBJECTION TO PROPOSED STREET VACATION (RESOLUTION NO. 26-30)
PROJECT: Campo on 17th / Enderle Center Drive Closure Hearing
HEARING DATE: Tuesday, September 15, 2026, at 6:00 PM
SUBMITTED BY: Concerned Residents of Tustin
TO THE ORANGE COUNTY FIRE AUTHORITY, THE HONORABLE MAYOR, MEMBERS OF THE TUSTIN
CITY COUNCIL, AND CITY ATTORNEY: 300 CENTENNIAL WAY. TUSTIN. CA. 92780
We formally object to the proposed vacation and closure of Enderle Center Drive. Granting this street
closure to accommodate a private developer's design configuration creates an Immediate, catastrophic
threat to human life regarding fire evacuation and emergency response. Approving this resolution
exposes the City of Tustin to Immense long-term civil liability.
1. CRITICAL THREAT TO LIFE: Wildilre and Structural Fire Evacuation Bottlenecks
Enderle Center Drive is a vital neighborhood emergency egress route. Ellmtnating this right-of-way
clusters local traffic into a severely restricted bottleneck.
• Evacuation Traps: In a fast-moving fire event, hundreds of escaping residents will be forced onto
fewer roads, creating gridlock that could trap citizens in the path of a fire.
• Emergency Delays: Entering Orange County Fire Authority (OCFA) heavy apparatus and ladder
trucks will be forced to compete with fleeing resident traffic on a single, choked access point,
delaying life-saving Intervention when seconds matter.
2. Absolute Discretionary Immuitty, Waiver and Future Tort Liability
While public entitles generally enjoy immunity for "poorjudgment" in planning decisions,'Design
Immunity' (Gov. Code § 830.6) Is legally broken If a city approves a plan despite having clear notice of a
hidden, highly dangerous condition. By approving this closure over the explicit safety warnings of the
neighborhood, the City of Tustin knowingly creates a public property hazard. This completely strips the
city of Its statutory Immunities, leaving Tustin strictly liable for any future wrongful deaths, personal
Injuries, or property losses caused by fire -related gridlock.
3. Strict Constitutional Liability vie Inverse Condemnation
Under settled California Supreme Court precedent (Bmidert v. Southern Pacific Co.), property owners
possess a private easement of Ingress and egress to the general public street system. Severing this
critical access route—especlally when It destroys emergency egress —constitutes a "substantial
impairment" of access. This renders the City strictly lable for financial damages under Inverse
Condemnation for the resulting drop in neighborhood property values.
4. ExpIIcR Violation of Streets & Highways Code § 8324
Under California law, this Council has zero legal authority to vacate a public road unless It makes a formal
finding that the street Is "unnecessary for present or prospective public use." Because this road Is
actively used and serves a vital public safety purpose, a finding that It Is "unnecessary" Is legally
fraudulent. Any approval hased on this finding Is vulnerable to an Immediate Writ of Administrative
Mandate (CCP § 1094.5) to halt construction.
CONCLUSION & REQUESTED ACTION
We demand that the City Council DENY Resolution No. 26-30. At minimum, we request a Continuance of
this hearing until the Orange County Fire Authority Issues a certified, unconditioned written safety report
explicitly guaranteeing that closing Enderle Center Drive will result In zero net delay to neighborhood
evacuation times and fire department response capabilities.
URGENT FIRE SAFETY OBJECTION TO PROPOSED STREET VACATION (RESOLUTION NO. 26-30)
PROJECT: Campo on 17th / Endede Center Drive Closure Hearing
HEARING DATE: Tuesday, September I lip 2026, at 6:00 PM
SUBMITTED BY: Concerned Residents of Tustin
TO THE ORANGE COUNTY FIRE AUTHORITY, THE HONORABLE MAYOR, MEMBERS OF THE TUSTIN
MW COUNCIL, AND CITY A'iTORli 300 CENTRi M. TUSTIN, CA, 92780
We formally object to the proposed vacation and closure of Enderle Center OrNe. Grunting this street
closure to accommodate a private developer's design configuration creates an Immediate, catastrophic
threat to human life regarding fire evacuation and emergency response. Approving this resolution
exposes the City of Tustin to Immense long -farm civil liability.
I. CRITICAL THREAT TO LIFE: Wildfire and Structural Fire Evacuation Bottlenecks
E-nd• rleCerri Oslveisat9@af nelghberhead enuxgeacyegress roe.Re, fY.ntlrsrtiagahis right-c€reay
clusters local traffic Into a severely restricted bottleneck.
• Evacuation Traps: In a fast-moving fire event, hundreds of escaping residents will be forced onto
fewer luada, creating gridlock that could trap citizens In the path of a 8re.
• Emergency Delays: Entering Orange County Fire Authority (OCFA) heavy apparatus and ladder
trucks will be forced to compete with fleeing resident traffic on a single, choked access point,
clelaylag 41fa vhgInterventionwhen seconds matter.
2. Absolute Discretionary Immunity Waiver and Future Tort Liability
While public entitles generally enjoy immunity for 'poor judgment* in planning decisions, "Deal
tmmunlry" (GOV. Code § 83D.6) Is legally broken if a city approves a plan despite having clear notice cf a
hidden, highly dangerous condition. By approving this closure over the explicit safety warnings of the
neighborhood, the City of Tustin knowingly creates a public property hazard. This oempletely strips the
city of ltsslatutory hrax filer.leatng TuadaSbtctlylcable for any future wrongful deaths, personal
Injuries, or property losses caused by firerelatedgridlock.
3. Strict Constitutional Liability via inverse Condemnation
Under settled California Supreme Court precedent fyreldart v Southam Pact0c Cc 1, property owners
possess a private easement of Ingress and egress to the general public street system. Severing this
critical access route —especially when Itdestroys emergency egress —constitutes a "substantial
Impairment" of access. This renders the City strictly liable for financial damages under Inverse
Condemnation for the resulting drop in neighborhood property values.
4. Explicit Violation of Streets & Highways Code § 8324
Under California law, this Council has zero legal authority to vacate a public road unless it makes a formal
finding that the street is "unnecessary for present or prospective public use." Because this road is
actively used and serves a vital public safety purpose, a finding that it is "unnecessary' Is legally
fraudulent. Any approval based on this finding is vulnerable to an Immediate VhR of Administrative
Mandate (CCP § 1094.6) to halt construction.
CONCLUSION & REQUESTED ACTION
We demand that the City Council DENY Resolution No. 26.30. At minimum, we request a Continuance of
this hearing until the Orange County Fire Authority issues a certified, unconditioned written safety report
explicitly guaranteeing that closing Enderle Center Drive will result In zero net delay to neighborhood
evacuation tines and fire department response capabilities.
URGENT FIRE SAFETY OBJECTION TO PROPOSED STREET VACATION (RESOLUTION NO. 26.30)
PROJECT: Campo on 17thI Enderle Center Drive Closure Hearing
HEARING DATE: Tuesday, September 16, 2026, at 6:00 PM
SUBMITTED BY: Concerned Residents of Tustin
TO THE ORANGE COUNTY FIRE AUTHORITY, THE HONORABLE MAYOR, MEMBERS OF THE TUSTIN
CITY COUNCIL, AND CITY ATTORNEY: 300 CENTENNIAL WAY.TUSTIN CA 92760
We formally object to the proposed vacation and closure of Enderle Center Drive. Granting this street
closure to accommodate a private developer's design configuration creates an immediate, catastrophic
threat to human life regarding fire evacuation and emergency response. Approving this resolution
exposes the City of Tustin to immense long-term civil liability.
1. CRITICAL THREAT TO LIFE: WIIdi and Structural Fire Evacuation Bottlenecks
EndedeCenter Crweieavital mighborhoodemergency egirmef our& EumaneRvtgtkis aght-os-wey
clusters local traffic into a severely restricted bottleneck.
• Evacuation Traps: In a fasts oving fire event, hundreds of escaping residents will be forced onto
fewer roads, uealing gddlock that arulu' asp citiZeifd ill lire petit of a sue.
• Emergency Delays: Entering Orange County Fire Authority (OCFA) heavy apparatus and ladder
trucks will be forced to compete with fleeing resident traffic on a single, choked access polm,
delaying lifrsavin9Sntervtm#�when a coacIsmatter.
2. Absolute Discretionary Immunity Walver and Future Tort Liability
While public entities generally enjoy Immunity for "pooryudgmenV in planning decisions, "Design
immunity" (Gov. Code § 330,6) Is rally broken if a city approves a plan despite having clear notice of a
hidden, highly dangerous condition. By approving this closure over the explicit safety warnings of the
neighborhood, the City of Tustin knowingly creates a public property hazard. This completely strips the
city of Be stetulmyimmunities,leavng Tusfinsttlotly Reba for any future wrongful deatha.personal
Injuries, or property losses caused by fireaeimed grid look,
3. Strict Constitutional Liability via imrerse Condemnation
I ruder settled California Supreme Court precedent (Rreldartv Southern Pacifir. Co), property owners
possess a private easement of Ingress and egress to the general public street system. Severing this
critical access mate —especially when it destroys emergency egress —constitutes a "substantial
Impairment" of access. This renders the City strictly liable for financial damages under Inverse
Condemnation for the resulting drop In neighborhood property values.
4. Explicit Violation of Streets & Highways Code § 6324
Under California law, this Council has zero least authority to vacate a public road unless it makes a formal
finding that the street is "unnecessary for present or prospective public use." Because this road Is
actively used and serves a vital public safety purpose, a finding that it is "unnecessary' Is legally
fraudulent. Any approval based on this finding is vulnerable to an Immediate Wilt of Administrative
Mandate (CC'P g' 1 Ov4.6) to hah construction.
CONCLUSION & REQUESTED ACTION
We demand that the City Council DENY Resolution No. 26.30. At minimum, we request a Continuance of
this hearing until the Orange County Fire Authority issues a certified, unconditioned written safety report
explicitly guaranteeing that closing Enderle Center Drive will result In zero net delay to neighborhood
evacuation times and fire department response capabilities.
Re ectfu ly subm0
�a
SIGINITURE DATE
ckd4mj 6A
URGENT FIRE SAFETY OBJECTION TO PROPOSED STREET VACATION (RESOLU'I ION NO. 26-30)
PROJECT: Campo on 17thI Endede Center Drive Closure Hearing
HEARING DATE: Tuesday, September 15, 2026, at 6:00 PM
SUBMITTED BY: Concerned Residents of Tustin
TO THE ORANGE COUNTY FIRE AUTHORITY, THE HONORABLE MAYOR, MEMBERS OF THE TUSTIN
CTiTCOUNCIL, AND Ciit AT ORNEY: SWCENT UNIALWAY. TUSTIN, CA, S27B0
We formally object to the proposed vacation and closure of Enderle Center Drive. Grunting this street
closure to accommodate a private developer's design configuradon creates an immediate, catastrophic
threat to human life regarding fire evacuation and emergency response. Approving this resolution
exposes the City of Tustin to immense long-term civil liability.
1. CRITICAL THREAT TO LIFE: Wildfire and Structural Fire Evacuation Bottlenecks
Enderle Center Drive isev" neighborhood emeegeneyegfess saute. E14nnetingthisright-of-wey
clusters local traffic Into a severely restricted bottleneck.
" Evacuation Traps: In a fast-moving fire event, hundreds of escaping residents will be forced onto
fewer roads, creating gnidiuck Drat could trap citizens in the path of a fire.
" Emergency Delays: Entering Orange County Fire Authority (OCFA) heavy apparatus and ladder
trucks will be forced to compete with fleeing resident traffic on a single, choked access point,
d'plaYh+g I ltesevkrg Intervention when seconds mstter.
2. Absolute Discretionary Immunity Wagner and Future Tort Liability
While public entities generally enjoy Immunity for 'poor judgment" in planning decisions, "Design
Irrmucii Ggv. Coda " IV legally broken If a one., I n despite havl c!car noCoo of a § v nrp legally Cii] uYpr, 'u plan Y rA
hidden, highly dangerous condition. By approving this closure over the explicit safety warnings of the
neighborhood, the City of Tustin knowingly creates a public property hazard. This completely strips the
city of dastaWtory Tustinstrictty liable for any future wrongful deaImpersonal
Injuries, or property losses caused by fire -elated gridlock.
3, Strict Constitutional liability via Inverse Condemnation
Under settled California Supreme Court precedent (RT.Idert It Spurtram PeclDc Cn). property owners
possess a private easement of ingress and egress to the generel public street system. Severing this
critical access route —especially when it destroys emergency egress —constitutes a "aubstantlel
impairment" of access. This renders the City strictly liable for financial damages under Inverse
Condemnation for the resulting drop in neighborhood property values.
4. Explicit Violation of Streets At Highways Cade § 0324
Under Califomia law, this Council has zero legal authority to vacate a public road unless it makes a formal
finding that the street is "unnecessary for present or prospective public use." Because this road Is
actively used and serves a vital public safety purpose, a finding that It Is "unnecessary' is legally
fraudulent. Any approval based on this finding is vulnerable to an immediate writ of Administrative
Mandate ITCP § 1094,5) to halt construction.
CONCLUSION & REQUESTED ACTION
We demand that the City Council DENY Resolution No. 26-30, At minimum, we request a Continuance of
this hearing until the Orange County Fire Authority issues a certified, unconditioned written safely report
explicitly guarenteeing that closing Enderle Center Drive will result In zero net delay to neighborhood
evacuation times and fire department response capabilities.
URGENT FIRE SAFETY OBJECTION TO PROPOSED STREET VACATION (RESOLUTION NO.26-30)
PROJECT: Campo on 17th / Enderle Center Drive Closure Hearing
HEARING DATE: Tuesday, September 15, 2026, at 6:00 PM
SUBMITTED BY: Concerned Residents of Tustin
TO THE ORANGE COUNTY FIRE AUTHORITY, THE HONORABLE MAYOR, MEMBERS OF THE TUSTIN
CITY COUNCIL, AND CITY ATTORNEY: aDO CENTENNIAL WAY TUSTIN CA 92780
We formally object to the proposed vacation and closure of Enderle Center Drive. Granting this street
closure to accommodate a private developer's design configuration creates an immediate, catastrophic
threat to human life regarding fire evacuation and emergency response. Approving this resolution
exposes the City of Tustin to immense long-term civil liability.
1. CRITICAL THREAT TO LIFE: Wildfire and Structural Fire Evacuation Bottlenecks
Enderle Center Drive is a vital neighborhood emergency egress route. Eliminating this right-of-way
clusters local traffic into a severely restricted bottleneck.
• Evacuation Traps: In a fast-moving fire event, hundreds of escaping residents will be forced onto
fewer roads, creating gridlock that could trap citizens in the path of a fire.
• Emergency Delays: Entering Orange County Fire Authority (OCFA) heavy apparatus and ladder
trucks will be forced to compete with fleeing resident traffic on a single, choked access point,
delaying lifesaving intervention when seconds matter.
2. Absolute Discretionary Immunity Waiver and Future Tort Liability
While public entities generally enjoy immunity for 'poor judgment" in planning decisions, "Design
Immunity" (Gov. Code § 830.6) is legally broken if a city approves a plan despite having clear notice of a
hidden, highly dangerous condition. By approving this closure over the explicit safety warnings of the
neighborhood, the City of Tustin knowingly creates a public property hazard. This completely strips the
city of its statutory immunities, leaving Tustin strictly liable for any future wrongful deaths, personal
injuries, or property losses caused by fire -related gridlock.
3. Strict Constitutional Liability via Inverse Condemnation
Under settled California Supreme Court precedent (f3reided v Southern Pacific CO.), property owners
possess a private easement of ingress and egress to the general public street system. Severing this
critical access route —especially when it destroys emergency egress —constitutes a "substantial
impairment' of access. This renders the City strictly liable for financial damages under Inverse
Condemnation for the resulting drop in neighborhood property values.
4. Explicit Violation of Streets & Highways Code § 8324
Under California law, this Council has zero legal authority to vacate a public road unless it makes a formal
finding that the street is 'unnecessary for present or prospective public use." Because this road is
actively used and serves a vital public safety purpose, a finding that it is "unnecessary" is legally
fraudulent. Any approval based on this finding is vulnerable to an immediate Writ of Administrative
Mandate (CCP § 1094.5) to halt construction.
CONCLUSION & REQUESTED ACTION
We demand that the City Council DENY Resolution No. 26-30. At minimum, we request a Continuance of
this hearing until the Orange County Fire Authority issues a certified, unconditioned written safety report
explicitly guaranteeing that closing Enderle Center Drive will result in zero net delay to neighborhood
evacuation times and fire department response capabilities.
S�IGINITURE ' . DATE
0/
7�g/Q/eiA Y. ,Ufa
NAME
URGENT FIRE SAFETY OBJECTION TO PROPOSED STREET VACATION (RESOLUTION NO. 26-30)
PROJECT: Campo on 17th / Enderle Center Drive Closure Hearing
HEARING DATE: Tuesday, September 15, 2026, at 6:00 PM
SUBMITTED BY: Concerned Residents of Tustin
TO THE ORANGE COUNTY FIRE AUTHORITY, THE HONORABLE MAYOR, MEMBERS OF THE TUSTIN
CITY COUNCIL, AND CITY ATTORNEY: 300 CENTENNIAL WAY, TUSTIN, CA. 92780
We formally object to the proposed vacation and closure of Enderle Center Drive. Granting this street
closure to accommodate a private developer's design configuration creates an immediate, catastrophic
threat to human life regarding fire evacuation and emergency response. Approving this resolution
exposes the City of Tustin to immense long-term civil liability.
1. CRITICAL THREAT TO LIFE: Wildfire and Structural Fire Evacuation Bottlenecks
Enderle Center Drive is a vital neighborhood emergency egress route. Eliminating this right-of-way
clusters local traffic into a severely restricted bottleneck.
• Evacuation Traps: In a fast-moving fire event, hundreds of escaping residents will be forced onto
fewer roads, creating gridlock that could trap citizens in the path of a fire.
• Emergency Delays: Entering Orange County Fire Authority (OCFA) heavy apparatus and ladder
trucks will be forced to compete with fleeing resident traffic on a single, choked access point,
delaying life-saving intervention when seconds matter.
2. Absolute Discretionary Immunity Waiver and Future Tort Liability
While public entities generally enjoy immunity for "poorjudgment" in planning decisions, "Design
ImmunitV' (Gov. Code § 830.6) is legally broken if a city approves a plan despite having clear notice of a
hidden, highly dangerous condition. By approving this closure over the explicit safety warnings of the
neighborhood, the City of Tustin knowingly creates a public property hazard. This completely strips the
city of its statutory Immunities, leaving Tustin strictly liable for any future wrongful deaths, personal
injuries, or property losses caused by fire -related gridlock.
3. Strict Constitutional Liability via Inverse Condemnation
Under settled California Supreme Court precedent (Breidert v Southem Pacific Co.), property owners
possess a private easement of ingress and egress to the general public street system. Severing this
critical access route —especially when it destroys emergency egress —constitutes a "substantial
impairment" of access. This renders the City strictly liable for financial damages under Inverse
Condemnation for the resulting drop in neighborhood property values.
4. Explicit Violation of Streets & Highways Code § 8324
Under California law, this Council has zero legal authority to vacate a public road unless it makes a formal
finding that the street is "unnecessary for presem or prospective public use." Because this road is
actively used and serves a vital public safety purpose, a finding that it is "unnecessary" is legally
fraudulent. Any approval based on this finding is vulnerable to an immediate Writ of Administrative
Mandate (CCP § 1094.5) to halt construction.
CONCLUSION & REQUESTED ACTION
We demand that the City Council DENY Resolution No. 26-30. At minimum, we request a Continuance of
this hearing until the Orange County Fire Authority issues a certified, unconditioned written safety report
explicitly guaranteeing that closing Enderle Center Drive will result in zero net delay to neighborhood
evacuation times and fire department response capabilities.
NAMF
URGENT FIRE SAFETY OBJECTION TO PROPOSED STREET VACATION (RESOLUTION NO. 26-30)
PROJECT: Campo on 17th / Enderle Center Drive Closure Hearing
HEARING DATE: Tuesday, September 15, 2026, at 6:00 PM
SUBMITTED BY: Concerned Residents of Tustin
TO THE ORANGE COUNTY FIRE AUTHORITY, THE HONORABLE MAYOR, MEMBERS OF THE TUSTIN
CITY COUNCIL, AND CITY ATTORNEY: 300 CENTENNIAL WAY. TUSTIN, CA. 927fW
We formally object to the proposed vacation and closure of Enderle Center Drive. Granting this street
closure to accommodate a private developer's design configuration creates an immediate, catastrophic
threat to human life regarding fire evacuation and emergency response. Approving this resolution
exposes the City of Tustin to immense long-term civil liability.
1. CRITICAL THREAT TO LIFE: Wildfire and Structural Fire Evacuation Bottlenecks
Enderle Center Drive is a vital neighborhood emergency egress route. Eliminating this dghtof-way
clusters local traffic into a severely restricted bottleneck.
• Evacuation Traps: In a fast-moving fife event, hundreds of escaping residents will be forced onto
fewer roads, creating gridlock that could trap citizens in the path of a fire.
• Emergency Delays: Entering Orange County Fire Authority (OCFA) heavy apparatus and ladder
trucks will be forced to compete with fleeing resident traffic on a single, choked access point,
delaying life-saving intervention when seconds matter.
2. Absolute Discretionary Immunity Waiver and Future Tort Liability
While public entities generally enjoy immunity for "poorjudgment" in planning decisions, "Design
Immur (Gov. Code § 830.6) is legally broken if a city approves a plan despite having clear notice of a
hidden, highly dangerous condition. By approving this closure over the explicit safety warnings of the
neighborhood, the City of Tustin knowingly creates a public property hazard. This completely strips the
city of its statutory immunities, leaving Tustin strictly liable for any future wrongful deaths, personal
injuries, or property losses caused by firetelated gridlock.
3. Strict Constitutional Liability via Inverse Condemnation
Under settled California Supreme Court precedent (Breidert v. Southern Pacific Co.), property owners
possess a private easement of ingress and egress to the general public street system. Severing this
critical access route —especially when it destroys emergency egress —constitutes a "substantial
impairment" of access. This renders the City strictly liable for financial damages under Inverse
Condemnation for the resulting drop in neighborhood property values.
4. Explicit Violation of Streets & Highways Code § 8324
Under California law, this Council has zero legal authority to vacate a public road unless it makes a formal
finding that the street is "unnecessary for present or prospective public use." Because this road is
actively used and serves a vital public safety purpose, a finding that it is "unnecessary" is legally
fraudulent. Any approval based on this finding is vulnerable to an immediate Writ of Administrative
Mandate (CCP § 1094.5) to halt construction.
CONCLUSION & REQUESTED ACTION
We demand that the City Council DENY Resolution No. 26-30. At minimum, we request a Continuance of
this hearing until the Orange County Fire Authority issues a certified, unconditioned written safety report
explicitly guaranteeing that closing Enderle Center Drive will result in zero net delay to neighborhood
evacuation times and fire department response capabilities.
URGENT FIRE SAFETY OBJECTION TO PROPOSED STREET VACATION (RESOLUTION NO.26-30)
PROJECT: Campo on 17th/ Endede Center Drive Closure Hearing
HEARING DATE: Tuesday, September 15, 2026, at 6:00 PM
SUBMITTED BY: Concerned Residents of Tustin
TO THE ORANGE COUNTY FIRE AUTHORITY, THE HONORABLE MAYOR, MEMBERS OF THE TUS11H
CITY COUNCIL AND CITY ATTORNEY: SIX) CENTENWAt WAY TUSTIN. CA. 22780
We formally object to the proposed vacation and closure of Endede Center Drive. Granting this street
closure to accommodate a private developers design configuration creates an immediate, catastrophic
threat to human life regarding fire evacuation and emergency response. Approving this resolution
exposes the City of Tustin to Immense long-term civil liability.
1. CRITICAL THREAT TO LIFE: Wlidl and Structural Fire Evacuation Bottlenecks
Enderle£emer IirivefsaWtsl na!ghberhoedemergeney egreasrrrEs. Ellminatka<ythds dgut'ot'+�y
clusters local traffic Into a severely restricted bottleneck.
• Evacuation Traps: In a fast-noving fire event hundreds of escaping residents will be forced onto
fewer rudtis, creonrig gridlock that could trap citizens ht the path of a Sre.
• Emergency Delays: Entering Orange County Fire Authorlty(OCFA) heavy apparatus and ladder
trucks will be forced to compete with fleeing resident traffic on a single, choked access point,
delaying life-savingIntervention when seconds. matter.
2. Absolute Discretionary Immunity Walver and Future Tort Liability
While public entities generally enjoy Immunity for *poorjudgmene In planning decisions,'Dmlgn
1#11111,x1W (Co•:. Coda § 830.6) is legally broken Ill city approves a plan despite having clear notice cf a
hidden, highly dangerous condition. By approving this closure over the explicit safety warnings of the
neighborhood, the City of Tustin knowingly creates a public property hazard. This completely strips the
city of Itsatatutony Immunitles,leaving Tustin, atri ly Sable for any full wrongful deaths,personat
Injuries, or property losses caused by fire -related gridlock.
S. Strict Constitutional Liability via Inverse Condemnation
Under settled California Supreme Court precedent (Rreldert v. Smrthem PaclDc Co), property owners
possess a private easement of ingress and egress to the general public street system. Severing this
critical access route —especially when R destroys emergency egress —constitutes a'substantial
impairment" of access. This renders the City strictly liable for financial damages under Inverse
Condemnation for the resulting drop In neighborhood property values.
4. Explicit Violation of Streets & Highways Code § 8324
Under California law, this Council has zero legal authority to vacate a public road unless it makes a formal
finding that the street is "unnecessary for present or prospective public use." Because this road is
actively used and serves a vital public safety purpose, a finding that it is "unnecessary is legally
fraudulent, Any approval based on this finding is vulnerable to an Immediate Writ of Administrative
Mandate (CCP § 1094,6) to haft construction.
CONCLUSION 6 REQUESTED ACTION
We demand that the City Council DENY Resolution No. 25.30. At minimum, we request a Continuance of
this hearing until the Orange County Fire Authority issues a certified, uncondmoned written safety report
explicitly guaranteeing that closing Enderle Center Drive will result In zero net delay to neighborhood
evacuation times and the department response capabilities.
SIGINITURE Q D4TE
�IM IYi}}1Lvrf�
ADDRESS PHONE
URGENT FIRE SAFETY OBJECTION TO PROPOSED STREET VACATION (RESOLUTION NO.26.30)
PROJECT: Campo on 17th/ Enderle Center Drive Closure Hearing
NEARING DATE: Tuesday, September 15, 20260 at 6:00 PM
SUBMITTED BY! Concerned Residents of Tustin
TO THE ORANGE COUNTY FIRE AUTHORITY, THE HONORABLE MAYOR, MEMBERS OF THE TUSTIN
CITY COUNCIL, AND CITY ATTORNEY. 300CENTENNtAL WAY,TUSTIN CA.92}88
We formally object to the proposed vacation and closure of Enderle Center Drive. Granting this street
closure to accommodate a private developer's design configuration creates an immediate, catastrophic
threat to human life regarding fire evacuation and emergency response. Approving this resolution
exposes the Ctly of Tustin to Immense long-term civil liability.
1. CRITICAL THREAT TO LIFE: Wildfire and Structural Pre Evacuation Bottlenecks
Enderle Center ONveis avitatneigHkwrAosdsrtser®eneyyegressroutcs mF�4ktgEhlaeighFoLvrey
clusters local traffic into a severely restricted bottleneck.
• Evacuation Traps: In a fast-moving fire event, hundreds of weeping residents will be forced onto
fewer wads, treating gridlock that could trap citizens in the path of a fire.
• Emergency Delays: Entering Orange County Fire Authority (OCFA) heavy apparatus and ladder
trucks will be forced to compete with fleeing resident traffic on a single, choked access point,
cleFaYfrg0%.savhegln•»rvewlnp when sacendsme#er.
2. Absolute Discretionary Immunity Waiver and Future Tart Liability
While public entities generally enjoy immunity for "poor judgment" In planning decisions, "Design
Immrelity" (Gov. Code § 830.6) Is legally broken if a city approves a plan despite having clear notice of a
hidden, highly dangerous condition. By approving this closure over the explicit safety warnings of the
neighborhood, the City of Tustin knowingly creates a public property hazard, This completely strips the
Injuries, or property losses caused by fire- related gridlock.
S. Strict Constitutional Liability via Inverse Condemnation
Under settled California Senrame Court precedent fHrefdart v. 3nutharn Paci ir. Co.); property owners
possess a private easement of ingress and egress to the general public street system. Severing this
critical access route —especially when it destroys emergency egress —constitutes a "substantial
Impairment" of access. This renders the City strictly liable for financial damages under Inverse
Condemnation for the resulting drop in neighborhood property values.
4. Explicit Violation of Streets & Highways Code § 0324
Under California law, this Council has zero legal authority to vacate a public road unless it makes a formal
finding that the street is "unnecessary for present or prospective public use." Because this road is
actively used and serves a vital public safety purpose, a finding that it is "unnecessary" is legally
fraudulent. Any approval based on this finding is vulnerable to an Immediate Writ of Administrative
Mandate (MR § 1094M to heft construction.
CONCLUSION & REQUEST® ACTION
We demand that the City Council DENY Resolution No. 26.30. At minimum, we request a Continuance of
this hearing until the Orange County Fire Authority issues a certified, unconditioned written safety report
explicitly guaranteeing that closing Enderle Center Drive will result in zero net delay to neighborhood
evacuation times and fire department response capabilities.
RKedatIRRA
All macr<S
,:Z_la7
DATE
URGENT FIRE SAFETY OBJECTION TO PROPOSED STREET VACATION (RESOLUTION NO. 26.50)
PROJECT: Campo on 17th / Enderle Center Drive Closure Hearing
HEARING DATE: Tuesday, September 150 2026, at 6:00 PM
SUBMITTED BY: Concerned Residents of Tustin
TO THE ORANGE COUNTY FIRE AUTHORITY, THE HONORABLE MAYOR, MEMBERS OF THE TUSTIN
CITYCOUNCIL AND'C" ATTORfiE1."SffiCEkITENNIIAL WAY TUSEM, CA, 92790
We formally object to the proposed vacation and closure of Enderle Center Drive, Granting this street
closure to accommodate a private developers design configuration creates an Immediate, catastrophic
threat to human fife regarding fire evacuation and emergency response. Approving this resolution
exposes the City of Tustin to Immense long-term civil liability.
1. CRITICAL THREAT TO LIFE: Wlldibe and Structural Fire Evacuation Bottlenecks
Enii- Carrier Orbre lsaWiaf egressveute,EN aDims-
clusters local traffic late a severely restricted bottleneck.
• Evacuation Traps: In a fast-moving fire event, hundreds of escaping residents will be forced onto
fewer iuuds, t eaiing gridiuck dial could crap efitzens in the path of a flue.
• Emergency Delays: Entering Orange County Fire Authority (OCFA) heavy apparatus and ladder
trucks will be forced to compete with fleeing resident traffic on a single, choked access point,
'felayir fil&savh 44taventlea whmseaondssnetter.
2. Absolute Discretionary Immunity Waiver and Future Tort Liability
While public entities generally enjoy immunity for °poor judgmenC in planning decisions, "Design
Immra•;ty' (Cu;. Code 930.6j Is legally broker. it a y spproves a plan desplts having c!aar net!ce of a
hidden, highly dangerous condition. By approving this closure over the explicit safety warnings of the
neighborhood, the City of Tustin knowingly creates a public property hazard, This completely strips the
injuries, or property losses caused by flre•rehded gridlock.
S. Strict Constitutional Liability via Inverse Condemnation
Under settled California RLnmme CnAirt precedent (R-rejdwr S uthem P ifl Co.), pronerty owners
possess a private easement of ingress and egress to the general public street system. Severing this
critical access route —especially when it destroys emergency egress —constitutes a'substantial
Impairment" of access, This renders the City strictly liable for financial damages under Inverse
Condemnation for the resulting drop In neighborhood property values.
4. Explicit V!olatlon of Streate & Highways Code § 0524
Under California law, this Council has zero legal authority to vacate a public road unless It makes a formal
finding that the street is "unnecessary for present or prospecibre public use." Because this road is
actively used and serves a vital public safety purpose, a finding that it is "unnecessary" Is legally
fraudulent. Any approval based on this finding Is vulnerable to an immediate Writ of Administrative
Mandate (CCP`§-1gTd.6) tohaft construe lon.
CONCLUSION S REQUESTED ACTION
We demand that the City Council DENY Resolution No. 26-50. At minimum, we request a Continuance of
this hearing until the Orange County Fire Authority Issues a certified, unconditioned written safety report
explicitly guaranteeing that closing Enderle Center Drive will result in zero net delay to neighborhood
evacuation times and fire department response capabilities.
autivil arxt " ,DATE
AM0.116 t Lan MA
NAME
URGENT FIRE SAFETY OBJECTION TO PROPOSED STREET VACATION (RESOLUTION NO.26,30)
PROJECT: Campo on 17thI Enderle Center Drive Closure Hearing
HEARING DATE: Tuesday, September 15, 2026, at 6:00 PM
SUBMITTED BY: Concerned Residents of Tustin
TO THE ORANGE COUNTY FIRE AUTHORITY, THE HONORABLE MAYOR, MEMBERS OF THE TUSTIN
CITY COUNCIL, AIM CfTtATTORNEY. SW CENMAKWAY TMIN, CA. 9178O
We formally object to the proposed vacation and closure of Enderle Center Drive. Grunting this street
closure to accommodate a private developer's design configuration creates an Immediate, catastrophic
threat to human life regarding fire evacuation and emergency response. Approving mis resolution
exposes the City of Tustin to immense long-term civil liability.
1. CRITICAL THREAT TO LIFE: Wildfire and Structural Fire Evacuation Bottlenecks
LadevinCen�t E#Wefea�ta4naigflbodrooderr®t�gawsyagressr»We. ENminating4hkssigk#-o4-way
clusters local traffic into a severely restricted bottleneck.
• Evacuation Turps: In a fast+noving fire even, hundreds of escaping residents will be forced onto
fewer 14ade, creaiilig giidiuck final cauid'u'&p iiiizai is in uia pai11 of a 1re.
• Emergency Delays: Entering Orange County Fire Authority (OCFA) heavy apparatus and ladder
trucks will be forced to compete with fleeing resident traffic on a single, choked access pole,
delaying fills a"Ang kHeFvaitim wherroirmoda.matter..
2. Absolute Discretionary Immunity Waiver and Future Tort Liability
While public entities generally enjoy immunity for 'poor judgment' In planning decisions, "Design
.:,h'i (Coy..,., a § S 6) is lagaLJ bucks*,^ "I appm1.,.. a pia^ d �'plt',",'• I:,g clear notice of s
hidden, highly dangerous condition. By approving this closure over the explicit safety warnings of the
neighborhood, the City of Tustin knowingly creates a public property hazard. This completely strips the
M of Its atetub ryimmunities,feavina Tustinstrictly liable for any.future wrongful deatWpersonat
Injuries, or property losses caused by fire -related gridlock.
S. Strict Constitutional Liability via Imrerse Condemnation
Under settled California Supreme Court precedent (Rre.kieo v. Soothe PaelHc Co), property owners
possess a private segment of Ingress and egress to the general public street system. Severing this
critical access route —especially when It destroys emergency egress—constftutes a "substantial
Impairment" of access. This renders the City strictly liable for financial damages under Inverse
Condemnation for the resulting drop in neighborhood property values.
4. Explicit Violation of Streets & Highways Code § 8324
Under California law, this Council has zero legal authority to vacate a public road unless it makes a formal
finding that the street Is "unnecessary for present or prospective public use." Because this road is
actively used and serves a vital public safety purpose, a finding that it Is "unnecessary' Is legally
fraudulent. Any approval based on this finding is vulnerable to an Immediate Writ of Administrative
Mendota (CW§ T044.5)to halt construction.
CONCLUSION & REQUESTED ACTION
We demand that the City Council DENT' Resolution No. 26.30. At minimum, we request a Continuance of
this hearing until the Orange County Fire Authority Issues a certified, unconditioned written safety report
explicitly guaranteeing that closing Enderle Center Drive will result In z®m net delay to neighborhood
evacuation times and fire department response capabilities.
Respectfully submitted,
SIGATUtIE DATE
AIvoSWX Sr,LnlPI?ZcI
NAME
URGENT FIRE SAFETY OBJECTION TO PROPOSED STREET VACATION (RESOLUTION No, 26-30)
PROJECT: Campo on 17th / Endele Center Drive Closure Hearing
HEARING DATE: Tuesday, September 154 20261, at 6d10 PM
SUBMITTED BY: Concerned Residents of Tustin
TO THE ORANGE COUNTY FIRE AUTHORITY, THE HONORABLE MAYOR, MEMBERS OF THE TUSTIN
CITY COUNCIL, AND CITY ATTORNEY: 30II CENTENNIAL WAY TUSTIN CA g2780
We formally object to the proposed vacatlon andclosure of Ecdorle Center Drive. Orentingthiastreet
closure to accommodate a private developer's design configuration creates an immediate, catastrophic
threat to human life regarding fire evacuation and emergency response. Approving this resolution
exposes the City of Tustin to immense long -tens civil liability,
1. CRITICAL THREAT TO LIFE: Wildfire and Structural Fire Evacuation Bottlenecks
C-mlerleCenter Drivers evha+nefghborhoodemsegeareyegress route. H "this tighFof-avay
clusters local traffic Into a severely restricted bottleneck.
Evacuation Traps: In a fast-moving Ore event, hundreds of escaping residents will be forced onto
fewer roads, lYeating gddiouk that could hap citizens in fire path of a ,ire.
• Emergency Delays: Entering Orange County Fire Authority(OCFA) heavy apparatus and ladder
trucks will be forced to compete with fleeing resident traffic on a single, choked access polm,
"aydmg,Nfe•savhtgintsrvs»iionuihen-sscoadsrnNter.
2. Absolute Discretionary Immunity Waiver and Future Tort Liability
While public entities generally enjoy immunity for "poor judgment'in planning decisions, "Deslgn
lmmurlty (Oov. Code § 0=6) is legally broken if a city approves a plan despite string clear rot!ce of a
hidden, highly dangerous condition. By approving this closure over the explicit safety warnings of the
neighborhood, the City of Tustin knowingly creates a public property hazard. This completely strips the
G4 of U.s.statutory tramuri tles,..leaving. Tustin sIddy liable for any Uwe wrongful deaths,.personsl
injude%or property losses caused by fire -related gridlock.
3. Strict Constitutional llablllty via Inverse Condemnation
Under settled California Supine a Court precedent Rm/darr v. Snrtha.m Pacific Co.), property owners
possess a private easement of Ingress and egress to the general public street system. Severing this
critical access route —especially when it destroys emergency egress —constitutes a'substantial
impairmerrt" of access. This renders the City strictly liable for financial damages under Inverse
Condemnation for the resulting drop in neighborhood property values.
4. Explicit Violation of SUeets B Highways Code P 8324
Under California law, this Council has zero legal authority to vacate a public road unless It makes a formal
finding that the street is'unnecessary for present or prospective public use." Because this road Is
actively used and serves a vital public safety purpose, a finding that it is "unnecessary" Is legally
fraudulent. Any approval based on this finding is vulnerable to an Immediate Writ ofAdmiMstrmive
'Mbntlafte MCP '§" 11fg4.V to halt constrUcrion.
CONCLUSION & REWBSTED ACTION
We demand that the City Council DENY Resolution No. 26-30. At minimum, we request a Continuance of
this hearing until the Orange County Fire Authority issues a certified, uncondhloned written safety report
explicitly guaranteeing that closing Enderle Center Drive will result In zero net delay to neighborhood
evacuation times and Ore department response capabilities.
ADDRESS PHONE