HomeMy WebLinkAboutItem 6a - Introduce a Draft Ordinance adopting the CALFIRE Local Responsibility Area Fire Hazard Severity Maps as Required by GC 51178Council Agenda Report
FROM: Todd Tuggle, Fire Chief
Prepared By: Todd Tuggle, Fire Chief
Item 6a
Department:
Fire
Cost Center:
8503
For Agenda of:
6/3/2025
Placement:
Public Hearing
Estimated Time:
120 minutes
SUBJECT: INTRODUCE A DRAFT ORDINANCE ADOPTING THE CALFIRE LOCAL
RESPONSIBILITY AREA FIRE HAZARD SEVERITY ZONE MAPS AS
REQUIRED BY GOVERNMENT CODE 51178
RECOMMENDATION
Adopt an Ordinance entitled "An ordinance of the City of San Luis Obispo, California,
designating the Fire Hazard Severity Zones as identified by the State Fire Marshal."
(Attachment A)
REPORT -IN -BRIEF
Government Code 51179 requires local agencies to adopt the State's Fire Hazard
Severity Zone maps in order to require certain standards in each of the three hazard
severity zones (Very High, High, and Moderate). Each zone has different risk mitigation
requirements and procedures, but generally covers building code requirements,
defensible space requirements, and real estate transaction disclosures for properties
located in the respective zones. The State published the Fire Hazard Severity Zone maps
for the area including San Luis Obispo on March 10, 2025 (Attachment B).
Government Code 51179 requires a public review and comment period, which began on
March 24. During this time, the City published and provided access to the Fire Hazard
Severity Zone maps and the opportunity to provide comments through the Open City Hall
portal, City social media outlets, and an informational page on the City's Fire Department
web page. Comments will be accepted until June 16t", at which time any additional
feedback received between the first reading of the Fire Hazard Severity Zone ordinance
adoption and the second reading will be communicated via agenda correspondence. City
staff also conducted a community workshop on May 22, 2025, where the public was
invited to provide comments and staff answered questions.
This report presents information about the State published maps and outlines the impact
that the adopted maps will have on property owners in the City through requirements
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Item 6a
related to home hardening, defensible space, and real estate disclosures. Consistent with
Government Code 51179, the City Council must adopt Fire Hazard Severity Zone Maps
by July 8, 2025 (120 days from the State Fire Marshal's publication of the hazard maps
on March loth). At this time, staff is recommending that the City Council adopt the map,
as provided by the State, without amendments.
POLICY CONTEXT
Under Government Code 51179, each jurisdiction must adopt by ordinance their
respective CALFIRE Local Responsibility Area Fire Hazard Severity Zone maps within
120 days of the publish date by the State Fire Marshal. New maps applicable to San Luis
Obispo were published by the State Fire Marshall on March 10, 2025. The recommended
action for this agenda item is the first reading of the City's ordinance adopting the state
maps and provides an opportunity for the City Council and community to discuss the
implications of the hazard maps. A second reading of the ordinance and adoption is
proposed to occur on June 17tn
Government Code 51179 allows the City to modify the State Fire Marshal's map to add
parcels in the moderate, high, and very high severity zones based on substantial evidence
that the designations are necessary for effective fire protection within the area, but the
City may not remove parcels from a severity zone nor decrease the level of severity zone
for any area identified by CALFIRE. Staff are not recommending modifications to the fire
zones as identified and designated by CALFIRE. The new designations, compared to the
prior map adopted in 2011, increase the number of parcels within the very high severity
zone in the City by over a hundred -fold, add over 6,000 additional parcels to high and
moderate severity zones, and bring 64% of the city's total parcels within a fire hazard
severity zone.
The City's Climate Adaption and Safety Element (CASE) of the General Plan (2023)
includes the prior Fire Hazard Severity Zone (FHSZ) map and the following related
policies and programs:
Policy FI-5.1: Reduce Wildfire Risk — The City shall reduce the risk of wildfires in city open
spaces and in the wildland urban interface through timely implementation of the City's Community
Wildfire Protection Plan and the Vegetation Management Plan (VMP).
Program FI-5.15: Wildland-Urban-Interface Defensible Space and Home Hardening
Program - Implement a program to assist homeowners, landlords, and business
owners in improving the defensible space for structures in or near the very high
fire hazard severity zones. The program will serve to connect participants to
contractors with experience in developing or improving home hardening
improvements (e.g., fire -safe building materials, fire resistant home vent
upgrades). The program will seek funding to supplement the costs associated with
defensible space improvements, prioritizing low-income participants and elderly or
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Item 6a
disabled residents who would not be able to implement defensible space
improvements on their own. The program would be developed and administered
in close collaboration with the City's Fire Department and CAL FIRE to ensure
appropriate standards for defensible space are implemented as part of the
program consistent with AB 3074 ("Fire Prevention: wildfire risk: defensible space:
ember -resistant zones").
Program FI-5.19: Fire Protection Plans Related to New Development - Develop
standards for new development in the Very High Fire Hazard Severity Zones or Wildland-
Urban Interface Zones requiring preparation of project -specific fire protection plans, in
addition to complying with all applicable state and local building and fire code regulations.
Fire protection plans may include a risk analysis, discussion of fire response capabilities,
compliance with fire safety requirements (defensible space, fire protection infrastructure,
building ignition resistance, etc.), appropriate mitigation measures and design
considerations for any nonconforming fuel modification, maintenance, and education for
residents.
Policy FI-5.2: City -Wide Fire -Smart Land -Use Planning - The City shall minimize fire risk
in land -use planning decisions including updates to zoning, subdivision codes and
design criteria to mitigate wildfire hazards and reduce risks to new development.
Promote the following risk reduction measures in future land use planning efforts in the
city:
• New subdivisions shall be prohibited in areas of "Very High" wildland fire hazard
severity zone as shown in Figure 11 unless part of conservation or open space
acquisition program. Development of existing parcels shall require a development
plan to manage fuels, maintain a buffer zone, and provide adequate fire protection
to the approval of the Chief Building Official. The development plan must be
consistent with Policies required by the City's Conservation and Open Space
Element.
• Use wildfire risk analysis resources such as the CAL FIRE's Fire and Resource
Assessment Program data in updates to future housing site constraints analyses.
• Promote the use of clustered development patterns for subdivisions to require less fire
suppression resources and that are easier to defend during wildfire events.
Policy FI-5.3: City -Wide Fire -Smart New Development - The City shall only approve
development when adequate fire suppression services and facilities are available or will
be made available concurrent with development, considering the setting, type, intensity,
and form of the proposed development. Ensure that new development projects include
adequate measures to minimize fire hazards while remaining in compliance with housing
laws regarding objective design standards and discretionary review.
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Item 6a
Fire protection plans should address wildland fuel transition zones surrounding the
development and include the following components:
• Provisions for the maintenance of vegetation within the subdivision to reduce
wildfire risk
• Requirements for hardening of structures to mitigate fire risk that meets or exceed
the California Building Code
• Landscaping and defensible space design around a proposed structure that reduces
wildfire risk.
Policy FI-5.4: Fire -Smart Buildings and High or Very High Fire Hazard Severity Zone - The
City shall reduce wildfire risk associated with new development by requiring all new
development located within any CAL FIRE designated High or Very High Fire Hazard
Severity Zone to:
• Meet or exceed the State's Fire Safe Regulations (title 14, CCR, division 1.5,
chapter 7, subchapter 2, articles 1-5 commencing with section 1270) and Fire
Hazard Reduction Around Buildings and Structures Regulations (title 14, CCR,
division 1.5, chapter 7, subchapter 3, article 3 commencing with section 1299.01).
• Include designs to minimize pockets or peninsulas or islands of flammable
vegetation within a development.
• Include additional access roads, where feasible, to ensure adequate access for
emergency equipment and civilian evacuation concurrently. More than one
evacuation route is required for substantial development (as defined in policy OP-
7.3 Emergency Access and Evacuation) in Very High Fire Hazard Severity Zones.
All requirements and any deviations will be at the discretion of the Fire Code
Official.
• Meet or exceed the California Building Code for Materials and Construction
Methods for Exterior Wildfire Exposure (Title 24, part 2, Chapter 7A).
• For all remodeled or rebuilt structures, require projects to meet current ignition resistance
construction codes included in the State's Fire Safe Regulations.
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Background
In California, fire protection responsibility is divided between the state and local entities.
State Responsibility Areas (SRAs) are lands where the state, through CAL FIRE, is
responsible for wildfire prevention and suppression. Local Responsibility Areas (LRAs)
are areas where local agencies, like city and county fire departments, are responsible.
State Responsibility Areas (SRAs):
• CAL FIRE provides fire protection for SRA lands, which are generally wildland
areas, including national forests, private forests, and some undeveloped areas.
Page 248 of 275
Item 6a
• CAL FIRE's responsibility includes preventing and suppressing wildfires,
maintaining fire protection infrastructure, and managing fire -related risks on these
lands.
• SRA designations are reviewed every five years, with annual updates for
incorporations, annexations, and ownership changes.
Local Responsibility Areas (LRAs):
• LRAs encompass incorporated cities, urban areas, agricultural lands, and some
desert areas.
• Local fire agencies, such as city and county fire departments, are responsible for
fire protection and emergency response within their jurisdiction.
• In LRAs, local agencies may also have responsibility for fire hazard severity
zones and building codes related to wildfire safety.
Assembly Bill 337 (Bates 1992), prompted by the devastating fire that occurred in the
Oakland and Berkeley Hills in 1991, calls for CALFIRE to evaluate fire hazard severity
in the Local Responsibility Area and to make a recommendation for mitigation strategies
to the local jurisdiction where Very High Fire Hazard Severity Zones exist (CA Govt.
Code 51175 et seq).
The process to designate fire hazard severity zones in the City last occurred in 2011
and is directed by state law. Fire Hazard Severity Zones consist of Very High, High, and
Moderate designations. Of note, when the current maps were released in 2011 the High
and Moderate designations did not apply to the Local Responsibility Area, and only Very
High designations were required to be adopted by the City Council. Senate Bill 63 (Stern,
2021) amended Government Code 51178 to add the Moderate and High Fire Hazard
Severity Zones in the Local Responsibility Area.
Changes to Fire Hazard Severity Zone Maps in the City
The CALFIRE recommended Fire Hazard Severity Zone maps have substantially
increased the affected parcels in the 2025 Local Responsibility Area maps, including in
the City of San Luis Obispo. The factors considered by CALFIRE in determining fire
hazard within wildland areas are fire history, flame length, terrain, local weather, and
potential fuel over a 50-year period. Mitigation measures such as vegetation
management, defensible space and home hardening are not considered in CALFIRE's
development of the hazard maps. Nor do the CALFIRE maps consider local factors
such as structure separation distance, year of construction, construction type, or
roadway design and capacity.
The previous 2011 CALFIRE Hazard Maps covered a small portion of the City both in
acres and in number of parcels within the Very High designation. The 2025 maps,
however, added two more zones to the City's responsibility area, the High and
Moderate designations. Not only did the Very High zone grow by a factor of 100, but
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Item 6a
the two additional zones were also added, bringing over 60% of parcels in the City into
a Fire Hazard Severity Zone.
The following table shows the number of parcels and the acreage for each zone within
the City under the 2025 maps.
Fire Hazard
Severity Designation
Number of Parcels
within City Limit
Total
Acreage
Total %
Of City Area
Very High
2,845
2520
28.6%
High
1,632
905
10.3%
Moderate
4,305
2210
25.1 %
Non-Wildland
7,943
3175
36.0%
Total
16,725
8823
100%
The following map shows a comparison between the 2011 Fire Hazard Severity Zone
maps for the San Luis Obispo Local Responsibility Area and the 2025 Fire Hazard
Severity Zone maps that include all three hazard severity zones and reflect enhanced
vegetation fire spread modeling, especially ember cast projections.
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Item 6a
Fire Hazard Severity Zone (FHSZ) Changes
within Local Responsibility Areas [LRA] in San Luis Obispo, CA
Recommended 201 1
Proposed March 2025
Fire Hazard Severity
Zones Description
= Very High
it High
Moderate
City Limit
:'FHSZ has same description and color
scheme [or both LocaJ Responsibility
Area [within City Limit] and Stare
Responsibility Area (outside city Limitl
201 I Very High FHSZ Facts:
Acreage - 756
Parcels Intersected _ 38
2025 Very High FHSZ Facts:
Acreage - 2,520
Parcels Intersected - 2,845
Mote - There is not an immediate risk to
these properdes. The zones indicate
hazard potential, not immediate risk, and
do not account For fire prevention
efforts, such as adding defensible space.
r' Para Collected From
Cal Fire Office of the
w t State Fire Marshal
s
on March 10. 2025
Projection: NAQ 83 California Teak Albers
0 0-5 1 2 Miles
I i I IIi I[[
S LOGIS
May 2025
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Item 6a
An interactive map that shows the change from the previous Fire Hazard Severity Zone
maps to the 2025 maps can be found here:
https://www. slocity. org/government/department-directory/fire-department/prepare-
slo/fire-hazards. This map is searchable by address so residents can easily identify the
zone that applies to their property.
A close review of the new map shows that some parcels are bisected by two different
zones. For instance, a portion of a parcel may be in a very high hazard severity zone
while another portion is in the high hazard severity zone. The ordinance proposed for
introduction (Attachment A) includes language to clarify that, for these parcels, the
requirements that apply to the more severe zone shall apply to the entire parcel.
Application and Impact of the Fire Hazard Severity Zone Requirements
With the adoption of the Local Responsibility Area Fire Hazard Severity Zone maps, there
are specific requirements that properties located in each of the designated zones must
follow.
All properties in areas designated as Very High Fire Hazard Severity Zones must, at a
minimum, follow the vegetation management rules in Government Code Section 51182.
These vegetation management rules are referred to as "Defensible Space"
requirements. In addition, any new buildings —or major remodels considered new
construction by the Building Official —must meet the ignition -resistant building standards
in Chapter 7A of the Building Standards Code. These ignition -resistant building standards
are referred to as "Home Hardening," 7A," or "WUI" (Wildland Urban Interface)
requirements. Furthermore, new or reconstructed homes in very high fire hazard severity
zones have additional certification requirements. New occupied structures, or occupied
structures previously damaged by a fire in a very high fire hazard severity zone, must
obtain a certification and final inspection report from the local building official confirming
that the structure complies with applicable building standards and must provide that
documentation, upon request, to the insurance carrier that insures the structure.
In areas designated as High Fire Hazard Severity Zones, all new construction, or major
remodels classified by the Building Official as new construction, are required to meet
home hardening construction requirements included in Chapter 7A of the Building
Standards Code.
Residential properties within the Very High and High Fire Hazard Severity Zones must
conduct a natural hazard real estate disclosure at time of sale per Civil Code 1102.19 and
1102.6f (AB 38, 2019). This is commonly referred to as an "AB 38 Disclosure."
There are currently no state -mandated requirements that apply to properties identified in
the Moderate Fire Hazard Severity Zones.
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Item 6a
The following Table 1 summarizes the requirements that apply to each severity zone
category:
Severity
Zone
Defensible
Space
Home
Hardening
Certification
of Home
Hardening
AB 38
Disclosure
Very High
X
X
X
X
High
X
X
Moderate
• Defensible Space
Spread of wildfire into the built
environment occurs through two main
mechanisms, direct flame contact of
vegetation near a structure and
embers landing near a structure
starting adjacent vegetation or the
structure itself on fire.
Em�
Radtatrve
Heat
ao�
windows
deck
Defensible space,' or modification of
was
the vegetation around a structure,
provides a critical buffer to the spread
of vegetation fires to structures. Further, homes that are not directly abutting vegetation
are at risk of ember cast which can start a vegetation fire adjacent to a structure, creating
the start point for structure fires. Once a structure does ignite, the predominate fuel that
spreads fire becomes the structures themselves. Once multiple structures are involved,
the capacity of firefighters and the hydrant water infrastructure to contain fire spread are
exceeded. With multiple burning structures turning into entire neighborhoods burning,
urban conflagration occurs. Slowing the spread of vegetation fires into the built
environment buys firefighters time to extinguish the fires before structure -to -structure fire
spread can take hold and urban conflagration occur.
Government Code 51182 requires property owners within very high fire hazard severity
zones to maintain defensible space at all times consistent with the following:
1 Government Code 51172 defines "defensible space" as "the area adjacent to a
structure or dwelling where wildfire prevention or protection practices are implemented
to provide defense from an approaching wildfire or to minimize the spread of a structure
fire to wildlands or surrounding areas."
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Item 6a
1. 100 foot zone - Defensible space must be maintained within 100 feet from each
side and from the front and rear of the structure to the property line.
a. A greater distance may be required by state law, local ordinance, rule, or
regulation. Fuel modification beyond the property line may only be required
by state law, local ordinance, rule, or regulation in order to maintain 100 feet
of defensible space from a structure. Fuel modification on adjacent property
shall only be conducted following written consent by the adjacent
landowner. A local ordinance may include provisions to allocate costs for
any fuel modification beyond the property line.
i. The proposed ordinance provided in Attachment A does not
recommend extending defensible space requirements beyond the
property line nor beyond 100 feet at this time.
b. The intensity of fuels management may vary within the 100-foot perimeter
of the structure, with more intense fuel reductions being used between 5
and 30 feet around the structure, and an ember -resistant zone being
required within 5 feet of the structure, based on regulations promulgated by
the State Board of Forestry and Fire Protection, in consultation with the
Office of the State Fire Marshal, to consider the elimination of materials in
the ember -resistant zone that would likely be ignited by embers. The
regulations may also alter the fuel reduction required between 5 and 30 feet
to integrate the ember -resistant zone requirements.
i. On February 6, 2025, the Governor issued Executive Order N-18-25
that includes an order to the Board of Forestry and Fire Protection to
create regulations for an ember -resistant zone within 0 to 5 feet of a
home ("Zone 0 regulations") and to complete the formal rulemaking
process no later than December 31, 2025. Draft regulations have
been posted to the Board of Forestry and Fire Protection's website
and have begun the rule -making process.
ii. Property owners will have up to three years to comply with the
ember -resistant zone regulations (Zone 0 regulations) following
adoption by the Board of Forestry and Fire Protection.
iii. The Board of Forestry and Fire Protection website provides the
following depiction of the different fuel reduction measures for
illustration purposes:
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Item 6a
-1 _; �sl
sy
r SL .6 - J
iv. Other LRAs have established jurisdiction -specific regulations
defining the level of defensible space required in the 0-5, 5-30, and
30-100 foot zones around a structure to assist property owners and
enforcement agencies in the administration of the requirements of
Government Code 51182. The City has not yet developed its own
set of regulations, but staff are evaluating available models and will
present options for consideration by Council at a future study
session, as discussed in more detail below.
c. An insurance company that insures an occupied dwelling or occupied
structure may require a greater defensible space distance than 100 feet if a
fire expert, designated by the fire chief or fire official from the authority
having jurisdiction, provides findings that the fuel modification is necessary
to significantly reduce the risk of transmission of flame or heat sufficient to
ignite the structure, and there is no other feasible mitigation measure
possible to reduce the risk of ignition or spread of wildfire to the structure.
The greater distance may not be beyond the property line unless allowed
by state law, local ordinance, rule, or regulation.
i. The proposed ordinance provided in Attachment A does not include
findings or recommendations to require defensible space greater
than 100 feet pursuant to this subsection of Government Code
51182.
2. Defensible space definitions - Fuels shall be maintained and spaced in a
condition so that a wildfire would be unlikely to ignite the structure. This includes
consideration of the following:
a. The amount of fuel modification necessary shall consider the flammability
of the structure as affected by building material, building standards, location,
and type of vegetation.
b. Defensible space requirements do not apply to single specimens of trees or
other vegetation that are well -pruned and maintained so as to effectively
Page 255 of 275
Item 6a
manage fuels and not form a means of rapidly transmitting fire from other
nearby vegetation to a structure or from a structure to other nearby
vegetation or to interrupt the advance of embers toward a structure.
c. Consistent with fuels management objectives, steps should be taken to
minimize erosion, soil disturbance, and the spread of flammable nonnative
grasses and weeds.
d. The property owner must remove any portion of a tree that extends within
10 feet of the outlet of a chimney or stovepipe.
e. The property owner must maintain a tree, shrub, or other plant adjacent to
or overhanging a building free of dead or dying wood.
f. The property owner must maintain the roof of a structure free of leaves,
needles, or other vegetative materials.
Government Code 51189 also directs the Office of the State Fire Marshal to develop a
model defensible space program for use by local jurisdictions in the enforcement of the
defensible space provisions of Section 51182. The Office of State Fire Marshal has
published some information regarding defensible space on its website, including a model
defensible space inspection guide. The Department of Forestry and Fire Prevention has
also published a set of guidelines for the creation of defensible space, which are focused
on fuel reduction in the area of 30-100 feet from structures and buildings. Additionally, the
Fire Code (Chapter 49 of the 2022 California Fire Code, Title 24, Part 9) contains
requirements for new plantings to meet defensible space standards for properties within
very high fire hazard severity zones. These requirements are typically applied when new
construction occurs that trigger Chapter 7A standards.
The City does not currently have an adopted defensible space ordinance delineating
locally applicable definitions and requirements that build upon the state statutes and
regulations mentioned above. However, staff are currently evaluating these otherwise
applicable standards and researching other model programs and will develop a set of
recommendations for discussion at a future study session with the City Council. The
goal of this future study session will be to, first, recommend definitions and standards
for defensible space in the 0-5, 5-30, and 30-100 foot spaces around a structure or
building that take into account current state regulations, including the Zone 0
regulations that are currently underway, and that also incorporate plant lists that are
appropriate for the San Luis Obispo climate and ecosystem. Second, staff will propose
options for an inspection and enforcement program that will assist in implementation
of the defensible space requirements. It is anticipated that this study session will occur
by the end of 2025, depending on the status of the Zone 0 regulations. A defensible
space ordinance will then be completed and presented for consideration by the end of
the next fiscal year.
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Item 6a
• Home Hardening
All new construction within the Very High and High Hazard Severity Zones will require
Chapter 7A Building Code compliant construction. Additionally, any remodels exceeding
50% of the existing structure's value will require an upgrade to Chapter 7A compliance.
Government Code 51182 also requires homes within Very High Fire Hazard Severity
Zones that were damaged by wildfire to meet Chapter 7A requirements, and certification
requirements apply to all new homes in very high zones as described above.
Structural hardening according to Chapter 7A provides an additional layer of defense that
buys time for the responders to extinguish wildland fires. If a fire can spread through
managed fuels and progress through defensible space, home hardening is another layer
of protection.
Chapter 7A of the California Building Code focuses on fire resistant materials and
methods of construction. Building a new home to meet Chapter 7A standards in the City
of SLO does not appear to dramatically increase construction costs compared to a
standard home. Estimates indicate that a code -compliant wildfire -resistant home can be
built for about the same cost as a typical home. This is because some upgrades (like
fiber -cement siding) may reduce costs, offsetting the added expense of other features.
Overall, the cost premium for Chapter 7A compliance in new construction ranges
between 0-5%. The table below, from Headwater Economics, itemizes the estimated
cost impact for each required feature, assuming a baseline new home built with
conventional materials (as might be used outside fire zones):
Table 2: Estimated Added Cost for Building Code Chapter 7A Features — New
2,500 sq. foot home
Feature
Baseline (Non-
7A)
Standard
Chapter 7A
Requirement
Estimated
Added Cost
(New
Construction)
Class A Roof
Class C/B roof (e.g.
Class A fire -rated roof
+$5,860 (+27% vs. a
Assembly
wood shakes) or
(e.g. composition
typical roof). Covers
basic asphalt
shingles) plus
upgraded vents,
shingles
enclosed eaves,
soffits
fireproof soffits, metal
& gutter guards.
drip edges, etc.
Tempered Glass
Dual -pane windows
Dual -pane windows
+$1,000—$2,000
Windows
(tempered only where
with at least one
(approx. $7 extra
building code
tempered glass pane
per sq ft of glass) for
requires,
each (often both
a whole -house
e.g. near doors)
panes)
window package
(e.g. —15 windows).
Page 257 of 275
Item 6a
Estimated
Baseline (Non-
Chapter 7A
Added Cost
Feature
7A)
Requirement
(New
Standard
Construction)
Ember -Resistant
Standard
Wildfire -rated ember-
+$500 (assuming --10-
Vents
attic/foundation
and flame -resistant
20 vents at -$50 each
vents (1/4-inch
vents (:51/8-inch mesh
vs. --$10 each
mesh)
or intumescent)
standard)
Covered Gutters
Standard
Metal gutters with non-
+$800 (for --120 If
aluminum gutters
combustible mesh
of gutter; gutter
(open, no covers)
covers ("gutter guards")
guard
to prevent debris
--$4-$12 per If in
buildup
Berkeley. Minimal if
gutters are already
metal.
Non -Combustible
Wood or vinyl
Fiber -cement siding or
-$0 (cost -neutral on
Siding
siding
stucco (non-
average). Using fiber -
(combustible)
combustible Class A)
cement lap siding can
save up to -$12,190
compared to cedar
wood siding,
offsetting other costs.
Underfloor Protection
Open crawl space or
5/8" Type X gypsum
+$2,500 (if needed).
exposed eaves/floor
sheathing or other
Approx. $1.24 per sq ft
appendages
protection under
of area to cover
exposed
(Homes on slab or with
floors/eaves
enclosed crawlspace
incur $0 extra cost.)
Fire -Resistant
Wood deck (e.g.
Deck boards of non-
+$1,850 (-19%
Decking
redwood or
combustible or ignition-
premium) for a typical
cedar)
resistant material
deck (e.g. 300-400 sq
(composite, trex, etc.)
ft). Composite decking
and metal flashing at
costs -$2-$5 more
wall interface
per sq ft than wood.
Total Premium: Approximately $0—$40,000 added, depending on baseline choices. In
many cases the net premium is under 2% of construction cost and can be near zero.
For example, a 2,500 sq. ft. wildfire -resistant home studied by Headwaters Economics2
actually cost 2% less than the same home with typical materials, because the cheaper
fiber -cement siding outweighed the added expense of vents, soffits, and other upgrades.
Comparatively, a 2020 report for the National Association of Home Builders estimates
an overall increase in cost of $1800-$38,000 in total cost for a two-story house3. In any
2 Headwater Economics, (November 2018), Building a Wildfire -Resistant Home: Codes and Costs,
https:Hheadwaterseconomics.org/wildfire/homes-risk/building-costs-
codes/#:-:text=Wildfire, neighbori ng%20home%20spacing%2C%20not%20alI
3 Home Innovation Research Labs. Cost Impact of Building a House in Compliance with IWUIC. Report
No. CR1328-2-12-302020. For the National Association of Home Builders, December 2020.
Page 258 of 275
Item 6a
event, research indicates that the added Chapter 7A features may add a few dollars per
square foot of cost to the construction of new homes.
Since 2012, San Luis Obispo Municipal Code 15.04.090.NN has declared the entire City
a "Community at Risk", making certain portions of Chapter 7A applicable to all new
construction in the City. Construction modifications such as ignition resistant exterior wall
coverings, ember resistant vent systems for attics and under floor areas, protected eaves,
and Class `A' roof coverings resist the impacts of embers and the radiant heat of direct
flame contact for much longer than traditional construction means. There are numerous
examples of homes surviving wildfires because of home hardening, defensible space and
vegetation management practices of the community and the property owners. This is
important to note, as construction that has taken place since 2012 has already
incorporated some home hardening components that will be required per 7A
requirements.
• AB 38 Disclosure
Enacted in 2019, AB 38 requires sellers of residential properties after January 1, 2021,
that are within very high or high fire hazard severity zones and that were built before
January 1, 2010 (before Chapter 7A was developed), to provide certain disclosures upon
sale, as codified in Civil Code 1102.6f. Those disclosures include:
(1) A statement as follows: "This home is located in a high or very high fire hazard
severity zone and this home was built before the implementation of the Wildfire
Urban Interface building codes which help to fire harden a home. To better protect
your home from wildfire, you might need to consider improvements. Information on
fire hardening, including current building standards and information on minimum
annual vegetation management standards to protect homes from wildfires, can be
obtained on the internet website http://www.readyforwildfire.org."
(2) On or after July 1, 2025, a list of low-cost retrofits developed and listed pursuant
to Section 51189 of the Government Code. The notice shall disclose which listed
retrofits, if any, have been completed during the time that the seller has owned the
property.
(3) A list of the following features that may make the home vulnerable to wildfire
and flying embers. The notice shall disclose which of the listed features, if any, that
exist on the home of which the seller is aware:
(A) Eave, soffit, and roof ventilation where the vents have openings in
excess of one -eighth of an inch or are not flame and ember resistant.
(B) Roof coverings made of untreated wood shingles or shakes.
(C) Combustible landscaping or other materials within five feet of the home
and under the footprint of any attached deck.
(D) Single pane or nontempered glass windows.
(E) Loose or missing bird stopping or roof flashing.
(F) Rain gutters without metal or noncombustible gutter covers.
Page 259 of 275
Item 6a
AB 38 also provides that, if, pursuant to Government Code 51182, a seller has obtained
a final inspection report showing home hardening compliance, the seller shall provide to
the buyer a copy of that report or information on where a copy of the report may be
obtained. Additionally, AB 38 adds Section 1102.19 to the Civil Code to require
documentation of compliance with defensible space requirements for properties in very
high or high fire hazard severity zones that are within the State Responsibility Area or that
are subject to local vegetation management ordinances. The City does not currently have
an adopted local vegetation management ordinance that would trigger the additional
disclosure requirement of Civil Code 1102.19.
Impact of Adopted Maps on Development Potential
In addition to the impact that the newly adopted maps will have on existing properties,
City staff are also working to understand the impact that the maps may have on
development potential in the community, particularly as it relates to housing
development. For example, several State laws passed in recent years provide "by -
right," or non -discretionary approvals for subdivisions of properties and/or the addition
of units and ADUs. These new laws limit local discretion over land use decisions, and
further study is likely necessary in order to determine how the designation of new areas
in the adopted Fire maps will impact the applicability of these laws. At this time, staff
has clarity on the following aspects:
Impact on Minor Urban Lot Splits & Two Unit Developments (SB 9)
Minor Urban Lot Splits (a.k.a., SB 9 Lot Split) allow a property owner to subdivide their
single-family zoned property into two new lots of relatively equal size. Each resulting lot
is allowed to have two residential dwelling units for a maximum of four dwelling units on
the property originally subdivided. The provisions of SB 9 and subsequent related
legislation also allow for "Two Unit Developments," where a property owner can develop
two primary residences on their single-family zoned property and up to two ADUs or an
ADU and a JADU where permitted. Lots with a "Two Unit Development" under these
provisions are prohibited from conducting a Minor Urban Lot Split ("ULS".)
Per Chapter 16.15 of the City's Subdivision Regulations and California Government
Code Section 66411.7, Minor Urban Lot Splits are not permitted for properties that fall
within the Very High Hazard Severity Zone. California Government Code Section
65852.21 similarly prohibits (by reference to Government Code Section 65913.4(a)(6))
"Two Unit Development" projects that fall within the Very High Fire Hazard Severity
Zone.
• Minor ULS and "Two Unit Development" projects are not subject to this provision
if located on a site that has adopted fire hazard mitigation measures pursuant to
existing building standards or state fire mitigation measures applicable to the
Page 260 of 275
Item 6a
development, including, but not limited to, standards established under the
following or their successor provisions:
o Section 4291 of the Public Resources Code or Section 51182 (as
applicable)
o Section 4290 of the Public Resources Code
o Chapter 7A of the California Building Code (Title 24 of the California Code
of Regulations).
In other words, a Minor Urban Lot Split or a Two Unit Development may be allowed,
pursuant to State law, in a Very High Fire Hazard Severity Zone if the project has been
developed consistent with the defensible space and home hardening requirements
described above. Staff are continuing to evaluate the extent to which the City's General
Plan policies, specifically CASE Policy FI-5.2 which prohibits new subdivisions in very
high fire hazard severity zones, might continue to prohibit Minor Urban Lot Splits for
properties in very high fire hazard severity zones. Additional clarification will be provided
when the study session is held later this year to future define the City's defensible space
program.
Impact on Major Urban Lot Splits & Associated Housing Development (SB 684)
Major Urban Lot Splits allow a property owner to subdivide a multifamily zoned property
to create up to ten new lots, each being at least 600 square feet in size and required to
have at least one dwelling unit up to a maximum of ten dwelling units on the property
originally subdivided. This kind of subdivision can also be conducted on a single-family
zoned property, but it must be vacant, less than 1.5 acres in size, and have a minimum
lot size of 1,200 square feet.
Per Chapter 16.15 of the City's Subdivision Regulations and California Government
Code Section 66499.41, Major Urban Lot Splits and their associated housing
development projects are not permitted for properties that fall within the High or Very
High Hazard Severity Zones.
Impact on Accessory Dwelling Units (ADU) and JuniorAccessory Dwelling Units (JADU)
Article 2, inclusive of Sections 66314 through 66332, of Chapter 13, Division 1, Title 7
of the California Government Code, does not include specific language that prohibits
ADUs and JADUs based on the fire severity zone that a property falls under. However,
per California Government Code Section 66314, a local agency may, by ordinance,
designate areas within its jurisdiction where ADUs and JADUs are allowed. This
designation may be based on the adequacy of water and sewer services and the impact
of ADUs and JADUs on traffic flow and public safety. Therefore, the City may determine
that residential areas that fall under the Very High Fire Hazard Severity Zone could
constitute a traffic flow and/or public safety concern during an emergency scenario if
density were increased through the development of ADUs and/or JADUs. Currently, the
City permits ADUs in the AG, C/OS, C-N, C-C, C-R, C-D, C-T, C-S, M, R-1, R-2, R-3,
Page 261 of 275
Item 6a
R-4, and O (Office) zones on lots with an existing or proposed residential structure,
unless otherwise stated in the City's Municipal Code or state law. JADUs are permitted
on properties where the existing or proposed use is single-family residential. The City's
Municipal Code does not limit the development of ADUs or JADUs based on the
applicable fire hazard severity zone, nor does the ordinance provided in Attachment A
propose to change this at this time.
Regarding the review of ADU and JADU applications, these projects, if allowed within
the Very High Fire Hazard Severity Zone, will be subject to additional requirements. This
includes additional Defensible Space, WUI, and water standards, as well as a
requirement to provide a vegetation management plan pursuant to Chapter 49 of the
Fire Code. The future study session will provide an opportunity to further explore
whether the City should prohibit ADUs or JADUs in very high or high fire hazard severity
zones.
Financial Considerations
The financial implications of disasters throughout the United States have initiated much
stricter inquiries in municipal debt offerings. Most recently, Los Angeles saw its
municipal bond rating drop, creating cost implications for recovery efforts. As rating
agencies evaluate the impacts of post disaster abilities to repay bond obligations, rating
agencies are looking at future bond recipients with increased scrutiny for their ability to
protect the economic capacity of a community from disaster. Rating agencies are
already evaluating municipal preparedness and mitigation actions as a proxy for
resiliency from disaster4.
The financial impacts of fire insurance have also hit local residents, property owners and
business owners. Increasingly, fire insurance has impacted the affordability of home
purchases. The number of homeowners forced to take on the California Fair Access to
Insurance Requirements FAIR plan (insurer of last resort) statewide has grown from just
over 200,000 to over 450,000 since 20205. Total property liability exposure for the FAIR
plan in the two largest zip codes for the City of SLO, 93401 and 93405, has gone from
$51,412,816 and $26,642,407 to $273,150,938 and $193,181,824 respectively between
2020 and 20246.
Resilient communities with strong risk mitigation strategies are essential to lowering the
risk for property owners and insurance companies alike. The Safer from Wildfires
Initiative through the California Department of Insurance requires Insurance carriers in
4 https://www.poIitico.com/newsletters/caIifornia-climate/2025/02/25/the-monster-at-the-end-of-this-fire-
00206132#:-:text=MONEY%20PROBLEMS%3A%20The%20Los%20Angeles,of%20a11%201oca1%20Cali
fornia%20governments
5 https://www.cfpnet.com/key-statistics-data/
6 California FAIR Plan Property Insurance, Key statistics and Data.
Page 262 of 275
Item 6a
California to consider defensible space and home hardening measures for insurance
discounts'. The California FAIR has also published discount offerings, including 5% for
defensible space measures and 10% for home hardening measures$. Additionally,
Discounts are available from Community level efforts such as FIREWISE community
Certifications and the Fire Risk Reduction Community Designation which the City of San
Luis Obispo obtained in 2024.
Community Resilience Strategy
A comprehensive strategy to exclude fire from structures in the City is crucial to a
resilient economy and sustainable community. The actions embedded in the Fire Hazard
Severity Zone maps and accompanying legislation provide a road map to resiliency
through multiple phases, as outlined in a recent paper from a wildfire planning team
entitled "City Scale Wildfire Loss and Relative Fire Speed: A Framework for Meaningful
Community -Scale Risk Reduction.9" The foundational principle of the paper is to exclude
a vegetation fire from entering the community by slowing the progress of a fire from the
vegetation to the built environment. Increasing the amount of time it takes a fire to enter
and ignite the built environment gives firefighters a chance to protect structures in the
community. Time allows more resources, in the form of more engines, airplanes,
helicopters, dozers and handcrews to get to the incident and extinguish a fire before it
transitions to an urban conflagration.
Vegetation Management, Defensible Space, Home Hardening, proficient emergency
response and community preparedness comprise a multiprong strategy to improve
resilience in the community and be prepared for the eventuality that wildfire will again
impact the City.
Vegetation Management — Vegetation Management is crucial to slowing the spread of
wildfire thorough the trees, brush and grasses, buying time for firefighters to extinguish a
fire before it ever reaches the City.
The City of San Luis Obispo owns and manages over 4,000 acres of open space lands
within the San Luis Obispo Greenbelt. The Irish Hills Natural Reserve, Cerro San Luis
Natural Reserve, and Bowden Ranch Open Space are key properties that form portions
of the wildland-urban interface in areas mapped in the Very High Fire Hazard Severity
Zone.
https://www.insurance.ca.gov/01-consumers/200-wrr/Safer-from-Wildfires.cfm
8 chrome-extension://efaidnbmnnnibpcajpcglclefindmkaa/https://www.cfpnet.com/wp-
content/uploads/2025/05/FAIR-Plan-Discounts-One-Pager.pdf
9 Farley, Scott, and Dave Winnacker. City Scale Wildfire Loss and Relative Fire Speed: A Framework for
Meaningful Community -Scale Risk Reduction. XyloPlan, 2025.
Page 263 of 275
Item 6a
Government Code 51184 provides that Section 51182 (defensible space requirements in
very high fire hazard severity zones) does not apply to land or water areas acquired or
managed for one or more of the following purposes or uses specified in subsection (a):
(1) Habitat for endangered or threatened species, or any species that is a
candidate for listing as an endangered or threatened species by the state or federal
government.
(2) Lands kept in a predominantly natural state as habitat for wildlife, plant, or
animal communities.
(3) Open space lands that are environmentally sensitive parklands.
(4) Other lands having scenic values, as declared by the local agency, or by state
or federal law.
Staff are conducting a detailed analysis of all of the City's open space areas within the
Very High Fire Hazard Severity Zone to determine whether they fall under the definitions
stated above. This will further dictate the appropriate level of vegetation management to
ensure compliance with the new fire hazard maps and other regulations. Section 51184
further provides that, in the event that improved land next to these areas are subject to
Section 51182, "the obligation to comply with Section 51182 shall be with the person
owning, leasing, controlling, operating, or maintaining the occupied dwelling or occupied
structure on the improved lands" and that "[a]II maintenance activities and other fire
prevention measures required by Section 51182 shall be required only for the improved
lands, not the land and water areas described in" Section 51184(a). In other words, the
statutes provide that open space lands meeting the definitions in Section 51184(a) are
not required to comply with defensible space requirements. Owners of improved lands
adjacent to the open space, however, are required to maintain defensible space on their
properties. As discussed above, the proposed ordinance provided in Attachment A does
not propose to extend defensible space or maintenance requirements beyond a property
line. Therefore, a property owner in the City will not be required under Section 51184 to
conduct maintenance on City open space properties that are adjacent to their properties
at this time.
The City currently employs a suite of management approaches to complete vegetation
treatment in City open space, including cultural, mechanical, or chemical methods.
Examples of cultural methods include livestock grazing such cattle pasturing and the
targeted use of goats and sheep, as well as the recent successful partnership with yak
tityu tityu yak tikhini, Northern Chumash Tribe of San Luis Obispo County and Region and
Cal Fire to complete both spring and fall cultural burns at Johnson Ranch Open Space;
as these experiences and partnerships continue to build, the potential use and feasibility
of safe and controlled cultural fires and prescribed fires in City open space closer to the
urban environment will increase. Examples of mechanical methods include weed
whipping of grasses, shaded fuel breaks using chainsaws and chippers, and mastication
using heavier equipment. Chemical methods are oftentimes the only viable means of
treating invasive species that are fire prone such as French broom (Genista
Page 264 of 275
Item 6a
monspessulana) and pampas grass (Cortaderia jubata), as well as distaff thistle
(Carthamus lanatus) and yellow star thistle (Centaurea solstitialis) that have the capability
of converting a grassland pasture to the extent that grazing is no longer a viable treatment
method because the thistles are unpalatable to livestock; in all cases, chemical treatment
methods are undertaken using Integrated Pest Management (IPM) protocols promulgated
by the University of California Cooperative Extension.
The City was recently awarded grant funding from the State Coastal Conservancy that
will support a comprehensive update of the City's Vegetation Management Plan (VMP).
The VMP will identify treatment practices such as grazing, invasive species removal,
shaded fuel breaks, and the use of cultural fire and prescribed fire, while also identifying
important natural resource values and sensitive status plant and wildlife species. Staff will
take a "planning and doing" approach, meaning that vegetation management will continue
to be implemented while this planning effort is underway. It is anticipated that the VMP
will also serve as a basis for additional, future grant applications for implementation
funding.
Emergency Response — SLO City Fire is comprised of four stations, staffed with 14
firefighters a day, including a Chief Officer. SLO PD is staffed with 12-15 officers and 2-3
Sergeants on duty in a 24-hour period in addition to specialty assignments such as
detectives and traffic patrol. The strategy of SLO City Fire is to get to a wildfire quickly
and extinguish it before it rapidly overwhelms local resources. To augment staffing and
equipment, SLO City Fire has a robust mutual aid plan with SLO County Fire, CalFire and
SLO County Sheriff to augment the response to a wildfire either in, or near San Luis
Obispo. As of 2025, SLO City Fire and Cal Fire have a Mutual Threat Zone agreement
whereby any vegetation fire within a half mile buffer of the city boundary will elicit a
wildland response from State resources, which includes helicopters, tankers, wildland
engines, dozer, hand crews and additional law enforcement staffing. Additional resources
take time to arrive though, reinforcing the importance of slowing the progress of a wildland
fire into the built environment before resources become overwhelmed by an urban
conflagration.
Community Preparedness - The last piece of San Luis Obispo's strategy to create
resilience is Community Preparedness. This includes coordinated efforts to ensure
residents know how to respond to emergencies and support one another, especially those
who may need extra assistance.
Preparedness begins at the individual level through programs like "Ready, Set, Go",
CERT, LISTOS, and "Know Your Zone" (a SLO County led effort to know your Evacuation
Zones10). Each of these programs are designed to educate and develop community
awareness about what to do when disaster occurs. Communication tools connect first
10 https://www.prepareslo.org/en/evacuation-zones.aspx
Page 265 of 275
Item 6a
responders and the community, ensuring fast, reliable information during emergencies.
Alert SLO, Reverse 911, Wireless Emergency Alerts, social media, and door-to-door
notifications provide critical information quickly. History shows rapid evacuations save
lives and one of the highest priorities during a disaster is fast and accurate
communication.
Community resilience depends on strong neighborhood connections, between
neighbors and especially with those most in need, beginning long before the emergency
occurs. This involves knowing neighbors and engaging in important conversations to
ensure that everyone has a plan to evacuate. Events like community chipping days,
volunteer days, community forums, FireWisell Communities and community -based
planning create the space to develop local resilience efforts.
NEXT STEPS
The ordinance provided in Attachment A is proposed for introduction at this public hearing
and, if introduced, will be brought back for a second reading on June 17, 2025. The
ordinance would then take effect within 30 days. Within 30 days of adoption, staff will
transmit the ordinance to the State Board of Forestry and Fire Protection as required by
Government Code 51179.
Staff will monitor the ongoing development of applicable state regulations governing
defensible space and home hardening requirements and will incorporate this information
into a study session to be held by the end of 2025 that will describe potential defensible
space and vegetation management programs. The outcomes of the study session will be
incorporated into a defensible space ordinance that will be presented for consideration by
the end of the next fiscal year.
Additionally, the State Building Code, Fire Code and forthcoming WUI codes will be
published in July. Staff from Fire and Building and Safety will be reviewing the new codes
and recommending local amendments. The local amendments will also provide an
opportunity to hear input from the community and for Council to provide direction on
specific items to be incorporated into the local amendments.
The City's Climate Adaption and Safety Element (CASE) of the General Plan (2023)
includes the prior Fire Hazard Severity Zone (FHSZ) map. Staff will prepare an update
to the CASE to include the new FHSZ map and anticipate working to complete that task
at the same time that other local FHSZ implementing ordinances are adopted during the
2025-26 fiscal year. The existing policies and programs related to fire hazard in the CASE
remain appropriate, though staff will review for any text updates that are needed to remain
contemporary with applicable statutes and best practices.
11 https://readyforwildfire.org/prepare-for-wildfire/firewise-communities/
Page 266 of 275
Item 6a
Previous Council Action
Resolution No. 10337 (2012) series —
1.
2.
3.
Proposed General Plan amendment
Proposed amendments to the Safety Element Policies and Maps
Negative Declaration to potential significant environmental impacts
Ordinance No. 1575 (2012 series) —
1. Application of certain building code sections to structures not within the Very High
Hazard Severity Zones.
Public Engagement
An Open City Hall topic was posted on March 24, 2025, to receive public comments on
the draft fire hazard severity maps. Feedback generally covered the following areas:
• Several respondents made arguments that the zones were inaccurate, incorrect or
otherwise did not adequately represent the City and the local hazards from the
vegetative fuels. Although requests were made to contract the zones, that is not
an option available to the Council per Government Code 51179.
• Insurance is a common concern among respondents. CalFire and the California
Department of Insurance have clarified the FHSZ maps are intended to drive local
planning decisions, not insurance decisions. The reason is that insurance
premiums take into account risk which factors in mitigation measures (vegetation
management, defensible space and home hardening) that the Hazard maps do not
consider.
• A consistent theme arose regarding how people are going to afford to do the work
demanded by the regulations within the zones, specifically defensible space and
home hardening.
• Several comments asked about information campaigns to get the word out about
the requirements of the hazard maps and how they are going to know what is
expected.
• There is some concern about parcels that are split between multiple zones.
Through discussion internally and advisement from outside legal advisors, the Fire
Code requires the most restrictive regulations in instances where two relevant
sections of code are in conflict. If a parcel is split between multiple zones, the
requirements of the higher severity zone will be applied to the entire parcel and
codified in the forthcoming defensible space ordinance.
The Open City Hall topic will remain open until June 16t" and any additional comments
received will be distributed to the Council via agenda correspondence in advance of the
second reading of the ordinance at the June 17t" Council meeting.
Page 267 of 275
Item 6a
City Staff leveraged multiple sources to share the message about the Hazard Maps and
their impact on constituents. Social media such as Facebook and Instagram shared
updates to the programs. The City's website, including the Fire Department landing page
provides a host of information about the impacts of the maps, as well as a map showing
the zone lines with parcel maps embedded in it''-. A community forum was held on May
22nd to actively engage with the public and listen to the needs of the community.
Public engagement will not end with adoption of the proposed fire hazard map. As the
Building Code, Fire Code, and WUI Codes are released and the defensible space
program study session is held, several additional opportunities will be provided for the
consideration of public comment. Once programs are established, community outreach
will follow the City's Public Engagement and Noticing Manual and information will be
shared with the public through mailed notices to impacted addresses, community
meetings, social media linking to a web page on the City's website, FAQs, etc.
CONCURRENCE
The Community Development Department, Administration and IT, and City Attorney's
Office concur with this report and have been active in its development.
ENVIRONMENTAL REVIEW
The recommended action is exempt from environmental review under the California
Environmental Quality Act (CEQA) under CEQA Guidelines Section 15308 (actions by
regulatory agencies for protection of the environment) because it is a regulatory action
mandated by state law to identify and mitigate wildfire hazards, thereby protecting the
environment and public safety. Adoption of the maps does not authorize physical
development. Additionally, designation of Fire Hazard Severity Zones as identified and
recommended by the State Fire Marshal is statutorily exempt from the California
Environmental Quality Act (CEQA) pursuant to Public Resources Code section
21080(b)(1) and CEQA Guidelines section 15268, as a ministerial action, required by
Government Code section 51179(a).
FISCAL IMPACT
Budgeted: No
Funding Identified: No
Fiscal Analysis:
Budget Year: 2025-27
12 https://www.slocity.org/government/department-directory/fire-department/prepare-slo/fire-hazards
Page 268 of 275
Item 6a
Funding
Sources
Total Budget
Available
Current
Funding
Request
Remaining
Balance
Annual
Ongoing
Cost
General Fund
$0
$
$
$0
State
Federal
Fees
Other:
Total
$0
$
$
$0
The study session to be held by the end of 2025 that will describe potential defensible
space and vegetation management programs will also contemplate the development of
cost recovery strategies, such as fees for inspections, and other funding options for
homeowners and the City.
Staff will continue to evaluate vegetation management requirements from the FHSZ maps
in City open spaces. City staff have secured and are actively applying to external grant
programs to assist this effort.
Staff are aware that there will be additional fiscal and work program effects that are still
materializing. As steps in the Fire Hazard Severity Zone implementation are completed,
such as map and code adoption, Council will remain apprised of the pending fiscal
impacts and programmatic needs as they are developed.
ALTERNATIVES
1. Council may expand the maps proposed by the Office of the State Fire Marshal.
Local Governments, per Government Code 51179(b)(3) may expand the coverage of
the zones. Should the Council pursue expansion of the maps, additional staff time will
be required to develop substantial evidence that justifies the decision to expand the
zones. Expanding the proposed zones would require reintroduction of the expanded
hazard maps at a subsequent public hearing, which would likely prevent the City from
adopting the maps by the statutory deadline of July 8, 2025.
ATTACHMENTS
A - Draft Ordinance adopting Designating the Fire Hazard Severity Zones as Identified by
the State Fire Marshal.
B — Local Responsibility Area map of Fire Hazard Severity Zones for the City of San Luis
Obispo.
Page 269 of 275
Page 270 of 275
ORDINANCE NO. (2025 SERIES)
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF SAN LUIS
OBISPO, CALIFORNIA, DESIGNATING THE FIRE HAZARD SEVERITY
ZONES AS IDENTIFIED BY THE STATE FIRE MARSHAL
WHEREAS, under California Government Code Section 51178, the State Fire
Marshal is required to classify lands within the state into Fire Hazard Severity Zones
(FHSZ) and provide these classifications to local agencies; and
WHEREAS, on March 10, 2025, the State Fire Marshal released updated FHSZ
maps designating areas within the City of San Luis Obispo as Moderate, High, or Very
High Fire Hazard Severity Zones; and
WHEREAS, Government Code Section 51178.5, within 30 days after the State
Fire Marshal's transmittal of the FHSZ identifications, a local agency must make the
information available for public review and comment; and
WHEREAS, on March 26, 2025, the City published the FHSZ maps (Exhibit 1) and
information on the City's website and invited public comment via Open City Hall, ensuring
community engagement in the adoption process; and
WHEREAS, State Government Code Section 51179 mandates that a local agency
designate, by ordinance, fire hazard severity zones in its jurisdiction within 120 days of
receipt of FHSZ recommendations from the State Fire Marshal; and
WHEREAS, the City of San Luis Obispo recognizes the importance of adopting
these designations to enhance public safety, inform land use planning, and implement
appropriate building standards to mitigate wildfire risks; and
WHEREAS, these FHSZ designations will require compliance with specific
building codes, defensible space regulations, and real estate disclosure requirements as
stipulated by state law; and
WHEREAS, the FHSZ maps published by the State Fire Marshal on March 10,
2025, identify some parcels as subject to more than one fire hazard severity zone
designation, which may create confusion for property owners as to which requirements
or standards apply; and to help minimize confusion, the City ordinance adopting the FHSZ
map will clarify that the more severe zone designation requirements will apply to the
entirety of any such parcel;
WHEREAS, the City Council finds that adopting the updated FHSZ designations
as recommended by the State Fire Marshal is in the best interest of the health, safety,
and welfare of the residents of San Luis Obispo.
NOW, THEREFORE, BE IT ORDAINED by the Council of the City of San Luis
Obispo as follows:
Page 271 of 275
Ordinance No. (2025 Series) Page 2
SECTION 1. Findings. The above recitals are incorporated herein as the Findings
of the City Council.
SECTION 2: Action.
1. The City of San Luis Obispo hereby designates the Fire Hazard Severity Zones
as identified and recommended by the State Fire Marshal pursuant to
Government Code Section 51178 on March 10, 2025.
2. The official FHSZ map for the City of San Luis Obispo, as provided by the State
Fire Marshal, is attached as Exhibit 1 and incorporated herein by reference and
entitled "City of San Luis Obispo Fire Hazard Severity Zones."
3. For any parcel that is identified in the official map as being subject to two
different fire hazard severity zones, the requirements of the more severe zone
shall apply to the entire the parcel.
4. The City Manager, or their designee, is directed to submit this ordinance and
all required documentation to the State Board of Forestry and Fire Protection
within 30 days of adoption, as mandated by California State Government Code
Section 51179.
SECTION 3. Environmental Review. The designation of Fire Hazard Severity
Zones as identified and recommended by the State Fire Marshal is statutorily exempt
from the California Environmental Quality Act (CEQA) pursuant to Public Resources Code
section 21080(b)(1) and CEQA Guidelines section 15268, as a ministerial action, required
by Government Code section 51179(a). Additionally, designation of the zones is exempt
under CEQA Guidelines section 15308 (actions by regulatory agencies for protection of
the environment) because it is a regulatory action mandated by state law to identify and
mitigate wildfire hazards, thereby protecting the environment and public safety.
Page 272 of 275
Ordinance No. (2025 Series) Page 3
SECTION 4. A summary of this ordinance, together with the names of Council
members voting for and against, shall be published at least five (5) days prior to its final
passage, in The New Times, a newspaper published and circulated in this City. This
ordinance shall go into effect at the expiration of thirty (30) days after its final passage.
INTRODUCED on the 3rd day of June, 2025, AND FINALLY ADOPTED by the
Council of the City of San Luis Obispo on the 17th day of June, 2025, on the following
vote:
AYES:
NOES:
ABSENT:
Mayor Erica A. Stewart
ATTEST:
Teresa Purrington
City Clerk
/_1»:3o1•LI21D7_V 2r01Is] VLVA5
J. Christine Dietrick
City Attorney
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the
City of San Luis Obispo, California, on
Teresa Purrington
City Clerk
Page 273 of 275
Page 274 of 275
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Fire Hazard Severity Zones (FHSZ) in Local Responsibility
Area (LRA), as Identified by the State Fire Marshal
= Very High High Moderate
Fire Hazard Severity Zones in State Responsibility
Area (SRA), Effective April 1, 2024
. Very High High Moderate
Mi 0 1 2
Km 0 1 2 3
Projection: NAD 83 California Teale Albers
Scale: 1:41,000 at 11' x 17"
Incorporated City ® Waterbody
Unzoned LRA Federal Responsibility
Area(FRA)
Government Code section 51178 requires the State Fire statewide criteria and based on the severity of fire hazard that is and other relevant factors including areas where winds
Marshal to identify areas in the state as moderate, high, expected to prevail in those areas. Moderate, high, and very high fire have been identified by the Office of the State Fire Marshal
and very high fire hazard severity zones based on consistent hazard severity zones shall be based on fuel loading, slope, fire weather, as a major cause of wildfire spread.
Updated Fire Hazard Severity Zones
Presentation to SLO City Council on the Implementation of the Fire Hazard Severity Zone Maps
Council Action
Staff recommendation is to adopt the Fire Hazard Severity
Zone Maps as published by the Office of the State Fire
Marshal on March 10, 2025
Council has discretion to expand the zones, but not reduce
them
If Council direction is to expand the hazard zones, there will
need to be additional work to provide substantial evidence
of findings, which will push adoption date past the State
imposed deadline of July 8th
California State Policy Context
Assembly Bill 337 (Bates, 1992), prompted by the devastating fire that
occurred in the Oakland and Berkeley Hills in 1991, calls for CALFIRE to
evaluate fire hazard severity in the Local Responsibility Area (LRA) and to
make a recommendation to the local jurisdiction where Very High Fire Hazard Severity Zones exist (CA Government Code 51175 et seq)
The Local Responsibility Area includes incorporated cities,urban regions,
agriculture lands,and portions of the desert where the local government is
responsible for wildfire protection (California Public Resources Code 4125)
Senate Bill 63 (Stern, 2021) amended CA Government Code 51178 to add
the Moderate and High Fire Hazard Severity Zones in the Local Responsibility
Area
CA Government Code 51179 requires local agencies to adopt the State’s
FHSZ 120 days from the publication date of March 10th
Climate Adaption and Safety Element (CASE)
Includes the 2011 Fire Hazard Severity Zone Map
Policies and Programs
Policy FI-5.1: Reduce Wildfire Risk
Program FI-5.15: Wildland-Urban-Interface
Defensible Space and Home Hardening
Program
Program FI-5.19: Fire Protection Plans
Related to New Development
Policy FI-5.3: City-Wide Fire-Smart New
Development
Policy FI-5.4: Fire-Smart Building and High or
Very High Fire Hazard Severity Zone
Local Policy Context
What are the FHSZ maps?
Hazard Maps help communities understand where
wildfire hazards are located so they can reduce wildfire
impacts
Hazard – defined by vegetation, slope and predominant
and severe winds which drives the “ember cast” model
Urban or Built environment considered in the hazard
maps
Risk – defined as a combination of probability,
vulnerability and consequence from the hazard
What is required for property owners in each Hazard Zone?
Defensible Space Requirements – Existing Structures
Requirements for Very High Severity Zones
Zone Zero - Ember resistant from 0-5’ from
structure (state regs underway)
Defensible space 100 feet from structures or the
property line, whichever comes first
Remove the portion of a tree that extends within
10’ of the outlet of a chimney or stovepipe
Maintain a tree, shrub or other plant adjacent to or
overhanging a building free of dead or dying wood
Maintain the roof of a structure free of leaves,
needles or other vegetative materials
**The City is currently developing a Defensible Space Ordinance and
corresponding Inspection Program
Defensible Space Requirements – Fire Code Examples
Plantings must be “fire-resistant” per landscape architect, an approved book,
journal, listing, or a local agency list
Shrubs – not to exceed 6’ in height
Shrub groupings at least 30' from structures
Shrub groupings no larger than 10' in diameter
Shrub groupings no closer than 15' to each other
Trees within 30’ zone
Dripline at least 10’ from combustible structures
Horizontal crown distance not less than 10’
Goal: Create an additional layer of defense against ember cast from vegetation fires that can ignite structures
Chapter 7A building code focuses on fire
resistant materials and methods of construction
to protect against fire:
Non-combustible roofs
Attic vents and boxed eaves
Non-combustible exterior coverings
Dual pane and tempered glass windows
Ignition resistant decking
**CBC Chapter 701A.5 requires Defensible Space specification CFC 4906
Home Hardening
7A Feature Cost Differential
Class A Roof Assembly + $5,860
Tempered Glass Windows + $1,000-$2,000
Ember-Resistant Vents + $500
Covered Gutters + $800
Non-combustible siding $0 cost neutral
Underfloor Protection $2,500
Fire Resistant Decking $1,850
Total cost Approximately 2% of
total cost
Requires sellers of residential properties that were built before January
1, 2010, to provide certain disclosures upon sale:
1.A statement that the home is in a very high or high fire zone
2.On or after July 1, 2025, a list of low-cost retrofits during the time the owner
has owned the home
3.A list of features that make the home vulnerable to wildfire and flying embers
4.Seller to provide the buyer with a copy of the final inspection report (if
available)
AB 38 Disclosure
Impact of Adopted Maps
Development potential
General Plan has policy prohibiting subdivision in Very High
Zone
By-Right/Ministerial Minor Urban Lot Splits & 2-Unit
Developments – Generally not permitted for properties that fall
in Very High Zone
Permitted: if site has adopted fire hazard mitigation
measures, Section 51182 and Chapter 7A
Ministerial Major Urban Lot Splits – Not permitted for
properties that fall in Very High and High Zones
Accessory Dwelling Units (ADU) and Junior Accessory
Dwelling Units (JDU)
If permitted by City within Very High Zone, will likely be
subject to additional requirements (defensible space, WUI,
water, vegetation management plan)
Financial Considerations
Bond rating drop, creating cost implications for recovery
efforts
Fire Insurance
California Fair Access to Insurance Requirements FAIR plan
(Insurer of last resort)
Safer from Wildfires Initiative through the California
Department of Insurance requires insurance carriers in
California to consider defensible space and home hardening
measures for insurance discounts
Resilience Strategy
Goal: Proactively exclude and/ or slow the progress of a vegetation fire
from entering the built environment and cascading into Urban
Conflagration
A commitment to strong fire safety regulations, emergency response,
and community preparedness benefits the entire community
An integrated set of tactics provides whole community risk reduction
creating a safer environment for all residents
Buys time for firefighters to extinguish the fire
Buys time for the public to evacuate
Vegetation Management City Open Space
Goal: Reduce hazardous fuels to slow the spread of wildfire
and maintain fire resistant natural communities
Vegetation Management Plan Update
Coastal Conservancy Grant
Community Wildfire Defense Grant - Implementation
Prop 4 Wildfire Preparedness Funds – Implementation
Gov Code Section 51184 & Adopted Conservation Plans
Reservoir Canyon Natural Reserve, Irish Hills Natural
Reserve, Cerro San Luis Natural Reserve
Other open space properties in high or moderate severity
zones or outside the City
Vegetation Fuel Treatments
Cultural, Mechanical, Chemical
Defensible Space and Home Hardening
Ember cast from vegetation to vegetation
can ignite structures far from the wildland
urban interface
Home hardening and defensible space to
protect against embers, slowing the spread
of fire
Approximately 80% of noncombustible
structures survived Palisades and Eaton
Fires
Emergency Response
Goal: Reach incidents within a 7:00
minute response time and extinguish
fires quickly
4 strategically placed stations
Staffed with 14 firefighters a day
Mutual Aid Plan with SLO County Fire
Mutual Threat Zone – Any
vegetation fire within a half mile
buffer of the city will elicit a wildland
response from State resources
Community Preparedness
Goal: Ensure residents know how to respond to emergencies
Ready, Set, Go
Evacuations
Know Your Zone
Alerts
Reverse 911
Alert SLO
Social Media
Firewise Communities
Public Engagement
Open City Hall posted March 14, 2025
Social Media
Community Forum May 22, 2025
Ongoing
Next Steps and Timeline
Fiscal Year 2025/26
•WUI, fire, and building code released by the state
•Study session - Defensible space ordinance
•1st reading of building, fire and WUI code adoption.
•Building, fire, and WUI code adoption, with defensible space
ordinance adoption
•Zone zero regulations effective for new structures
•Programmatic and budget proposals for supplemental budget
Fiscal Year 2026/27
•Defensible space inspection program implementation
January 2029
•Zone zero regulations enforceable on existing structures
Questions?