HomeMy WebLinkAboutItem 8a - Wildland Urban Interface Code Study Session Item 8a
Department: Fire
Cost Center: 8503
For Agenda of: 10/7/2025
Placement: Study Session
Estimated Time: 120
FROM: Todd Tuggle, Fire Chief
Prepared By: Sadie Symens, Deputy City Attorney
SUBJECT: WILDLAND URBAN INTERFACE (WUI) CODE, BUILDING HARDENING,
AND DEFENSIBLE SPACE REGULATIONS STUDY SESSION
RECOMMENDATION
1. Receive a presentation on the 2025 California Wildland Urban Interface (WUI) Code,
including defensible space requirements;
2. Direct staff to return to City Council to adopt the WUI code as-is, and provide direction
on strategic next steps pertaining to WUI code implementation; and
3. Provide direction on strategic next steps on the City’s approach to community
education, inspections, and enforcement of the WUI Code and other considerations,
including real estate disclosures, risk mitigation, and the effects of the 2025 Fire
Hazard Severity Zone maps and statewide codes on existing City policies.
REPORT-IN-BRIEF
The purpose of this study session is to brief the City Council on the requirements of the
WUI Code and how they apply within Fire Hazard Severity Zones (FHSZs) and to confirm
staff’s recommendations and seek direction on certain implementation measures.
Because of the breadth and impact of the new standards included in the WUI Code, this
study session is intended to provide an opportunity to discuss the requirements in detail
and to better prepare for the code adoption process that will occur in November and
December 2025 and will be implemented in 2026. Staff have provided recommendations
for (1) adoption of the WUI Code, (2) implementation of the code’s requirements including
enforcement, and (3) community outreach and education. The goal of this item is to
confirm or obtain direction to modify these recommendations as next steps are carried
out to adopt and implement the WUI Code requirements.
This report outlines the minimum mandatory requirements in the WUI Code, which the
City must enforce, including emergency access, water supply, building construction and
hardening, and defensible space. While many of these requirements align with existing
local regulations, the updated 2025 CAL FIRE Fire Hazard Severity Zone (FHSZ) maps
have significantly expanded the number of parcels in Very High FHSZs in the City, thereby
applying regulations to a larger subset of the community. In addition, new state defensible
space requirements—including forthcoming Zone Zero regulations1 for the area
1 As will be further discussed below, “Zone Zero regulations” refer to requirements for the first five feet around a
structure (also known as the “Ember-resistant defensible zone.”)
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immediately surrounding buildings—will add further obligations for property owners. One
of the main areas of discussion in the study session will be on implementation of the WUI
Code, and City Council will be requested to provide strategic guidance on topics including
inspections and compliance.
This report will also discuss what individual property owners and com munities within the
City can do to prepare for the risk of wildfire and put themselves in the best position to
retain or receive discounts on fire insurance, as well as disclosures that must be made by
certain property owners upon transfer of real property. Finally, the report will discuss the
impact of the WUI Code and updated FHSZ designations on existing City policies.
Given the increase in regulatory burden presented by the WUI code, both on community
members and City staffing resources, alongside the quantifiable risk reduction expected
from implementing the WUI Code, staff are not recommending adoption of substantive
modifications to the state codes or the adoption of a separate, local defensible space
ordinance2. By adopting and implementing the WUI code, as published by the state, the
City will be taking a big step forward toward wildfire resilience and long-term community
safety.
Each section of the report that discusses the provisions of the WUI Code will include at
least one Key Finding in support of Strategic Next Steps. The Strategic Next Steps identify
staff’s recommendations for that portion of the WUI Code. The Strategic Next Steps
recommended in the report associated with adoption of the WUI Code are:
1. Revise the definition of “Wildland-Urban Interface Fire Area” within Chapter
15.04 of the City’s municipal code to conform to the definitions provided by state
law to include all FHSZs.
2. Include any necessary updates related to Chapter 4 of the WUI code in the City’s
upcoming engineering standards update.
3. Adopt Chapter 5 of the WUI Code as-is, carry over any local amendments to the
building code that have previously been adopted by the City, and make
necessary conforming amendments to existing provisions of Title 15 (e.g.,
references to Chapter 7A of the building code and clarifying that all building
hardening requirements of Chapter 5 are applicable Citywide.)
4. Include an amendment to WUI Code Chapter 6 that clarifies that its provisions
only apply to parcels in VHFHSZs.
5. Require new subdivision and large developments to provide Fire Protection
Plans as described in Section 602 of the WUI Code as part of the building permit
process.
6. Require a Landscape Plan for all new landscaping associated with a project that
requires a building permit within a VHFHSZ.
Similarly, the report’s discussions of the implementation of the WUI Code and its impacts
on existing City policies identifies staff’s recommendations as a number of Strategic Next
2 As described in the body of this report, state law allows the City to adopt certain local codes that are more stringent
than the state code.
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Steps. The Strategic Next Steps related to implementation of the WUI Code and the
impacts of the code and the FHSZs on existing City policies are:
7. Include an amendment clarifying that the City will enforce Chapter 6 of the WUI
Code (including referenced defensible space requirements) administratively
pursuant to Administrative Code Enforcement Procedures of the City’s Municipal
Code (Chapter 1.24).
8. Enforce state-adopted defensible space requirements in the VHFHSZ using a
complaint-based/reactive method, with an initial objective of education.
9. The Fire Department will offer a fee -based voluntary inspection program and will
continue to seek external funding that would allow the City to subsidize the cost of
voluntary inspections for property owners.
10. Do not perform AB 38 inspections upon the sale of real property in Very High or
High FHSZs at this time.
11. Adopt the WUI Code without substantive local amendments to its requirements.
12. Develop guidance and requirements for vegetation management plans as part of
the building permit application process, to be available by January 1, 2026.
13. Amend the Climate Adaptation and Safety Element of the General Plan as required
by Government Code Section 65302 to reflect the updated FHSZ maps.
14. Agendize a study session to reevaluate the prohibition in current City policies on
subdivisions within the VHFHSZ and discuss possible amendments to the Climate
Adaptation and Safety Element of the General Plan.
15. Amend the Tree Ordinance to clarify the tree removal process for trees that must
be removed under the WUI code.
The Strategic Next Steps reflect staff’s recommendations and intended actions absent
contrary direction from Council are set forth below. Council may direct staff to modify a
Strategic Next Step.
POLICY CONTEXT
Ordinance 1748 (2025 Series) adopted CAL FIRE’s Local Responsibility Area Fire
Hazard Severity Zone Maps, as required by California Government Code 51179.
The new designations, compared to the prior map revisions from 2007, increase
the number of parcels within Very High FHSZs in the City by over a hundred-fold,
add over 6,000 additional parcels to High and Moderate FHSZs, and bring 64% of
the City's total parcels within a FHSZ.
2025-27 Financial Plan Housing and Neighborhood Livability Major City Goal:
o Action 4.1.c directs staff to “Conduct a study session on implications and
implementation of State Fire Hazard Severity maps for local responsibility
areas.”
o Action 4.1.d directs staff to “Implement actions and requirements of the
State Hazard Fire Hazard Severity Maps.”
Climate Adaptation and Safety Element of the General Plan:
o 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
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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. […]3
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. […]
o 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. […]
o 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. […] 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
o 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
3 “[…]” indicates that the policy or program has additional text omitted from this section for brevity. The full text is
available in the linked Climate Adaptation and Safety Element of the General Plan. Any text omitted from this section
that is important for a particular component of the study session is included and referenced in the body of this Council
Agenda Report.
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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.
DISCUSSION
Background
As described in the City’s Climate Adaptation and Safety Element (CASE) of the General
Plan, “[…] a wildfire is defined as an uncontrolled fire spreading through vegetative fuels
that poses a threat to life and/or property. Wildfires can be ignited by natural events, such
as lightning strikes, or can be caused by damaged infrastructure (e.g., downed power
lines) or human activities (e.g., campfires, arson). Wildfires can move quickly, casting
embers into downwind areas and spreading to developed areas, putting human lives and
properties at risk.”
Although the City has experienced wildfires in the past, climate change has intensified
key drivers—higher temperatures, shifting precipitation, and reduced humidity—raising
both the overall risk of wildfire and the likelihood that fires could spread into developed
areas of the City. Recent catastrophic fires that have destroyed entire communities
illustrate that this trend extends statewide, with consequences not only for public safety
but also for the cost and availability of property insurance.
Statewide Hazard Mapping - Fire Hazard Severity Zones
California has a long history of mitigating the risks posed by natural disasters. The primary
way that California assesses statewide and local wildfire risk is through the mapping of
FHSZs. California state law requires the State Fire Marshal to identify areas throughout
the state as Moderate, High, and Very High FHSZs based on fuel loading, slope, fire
weather, and other relevant factors (Govt. Code 51178).
On March 10th, 2025, the State Fire Marshall released an updated FHSZ map for San
Luis Obispo. On June 17, 2025, the Council adopted Ordinance No. 1748 (2025 Series),
which codified the updated wildfire maps and designated Moderate, High, and Very High
FHSZs within the City as required under state law. In the 2025 update, the State Fire
Marshal included wind as a contributing risk factor when modeling the fire hazard risks
and potential for ember cast. Additionally, the 2025 update included, for the first time,
Moderate FHSZs within the Local Responsibility Area (areas within the state for which
local fire agencies, such as city and county fire departments, are responsible).
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Prior to 2025, the FHSZ maps were last updated in 2009. The 2009 FHSZ maps
designated 38 parcels in FHSZs across the City, all of which were located in Very High
FHSZs. Upon adoption of the new maps, the City now contains Moderate and High
FHSZs as well, and the total number of parcels located in a FHSZ is now 8,782, including
2,845 parcels within a Very High FHSZ.
Mitigating Wildfire Risk through Statewide Building Standards
Development in California is regulated by the California Building Standards Code
(Building Code). Updated every three years, the Building Code includes chapters that
regulate construction projects ranging from a building’s structural integrity to energy use.
The Building Code is updated every three years by a wide range of state agencies and is
formally adopted by the State Building Standards Commission. State law requires local
governments to adopt each triennial Building Code into local law in its entirety, and in
some cases, allows for amendments to the state code so long as they are more restrictive.
Historically, fire related regulations have been held in the California Code of Regulations,
Title 24, Chapter 7A (California Building Code, Chapter 3 Section R337 (California
Residential Code), and Chapter 49 (California Fire Code), as well as Title 14, Natural
Resources Code and Title 19, Public Safety Code. Fire regulations were also codified in
California statutes including the Public Resources Code, Government Code, and Health
and Safety Code. For the first time in state history, the 2025 Building Code brings all of
these fire-related and wildland-urban interface laws and regulations into a single code
book, known as the California Wildland-Urban Interface Code (WUI Code).
In July 2025, the State published the new WUI Code as Part 7 of Title 24 of the California
Building Standards Code4. Every parcel within the City is affected by some or all
components of the WUI Code. The WUI Code addresses fire spread, fire suppression
accessibility, defensible space, water supply, and other fire resilience factors for buildings
in designated FHSZs (Moderate, High, or Very High) or Wildland Urban Interface areas.
This report provides a high level summary of information about the WUI Code and a
deeper analysis of regulations related to combustible materials adjacent to a building,
also known as “Defensible Space”. For each topic, this report describes the minimum
statewide regulations the City will be required to adopt and how staff intend to educate
the public about the standards and the enforcement thereof. Each section concludes with
key findings and staff’s recommendations, identified as strategic next steps.
The City Council’s deliberations and direction in this study session will inform the adoption
and implementation of the WUI code. Staff will be returning to Council on November 18,
2025, to introduce an ordinance to adopt the 2025 Building, Fire, and WUI codes which
will be effective January 1, 2026.
4 The WUI Code in its entirety is available at: https://codes.iccsafe.org/content/CAWUIC2025P1.
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The California Wildland-Urban Interface Code
As described above, the WUI Code is intended to establish requirements to reduce the
likelihood of life and property loss due to wildfire. Table 1 summarizes the substantive
components of the WUI Code.5
Table 1: WUI Code Applicability Matrix
Chapter 3
WUI Areas
Chapter 4
Fire Access and
Water Supply
Standards
Chapter 5
Building Construction
and Hardening
Standards
Chapter 6
Fire Protection Plans,
Landscape Plans, and
Defensible Space
Applicable
Zones
All Fire Hazard
Severity Zones
(FHSZs)
All Fire Hazard
Severity Zones
(FHSZs)
Citywide
Very High Fire Hazard
Severity Zones
(VHFHSZs)
Applicable
Scope
Fire service access to
subdivisions and new
development
New Construction
+ remodels on
buildings built after
July 1, 2008
New landscaping +
existing landscaping
within 100 feet of
buildings
The remainder of this section provides an overview of each substantive chapter of the
WUI Code, including a summary of the major changes that will result from adopting and
implementing code, with a focus on changes that will directly impact residents and
property owners in the City. Each WUI code chapter is hyperlinked in the body of this
report.
The requirements outlined below would be the result of adopting the WUI code as -is.
Alternatives to the statewide WUI Code, such as expanding the area designated as
“wildland urban interface” or adopting optional appendices of the Code, are discussed
later in this report.
WUI Code - Chapter 3: Designation of Wildland-Urban Interface Areas
Chapter 3 provides that Wildland-Urban Interface Areas in Local Responsibility Areas
(LRAs) are to be mapped by the State Fire Marshall as FHSZs in accordance with
Government Code 51175 through 51189. Chapter 3 further states the code official (in the
City’s case, the Fire Chief) shall reevaluate and recommend modification to the wildland-
urban interface areas on a 5-year basis or more frequently as deemed necessary.
Chapter 3 - Local Code Consistency
The City will need to update its definition of “Wildland-Urban Interface Fire Area” within
the municipal code to conform with the definitions provided by state law. Section
15.04.090 currently defines the wildland-urban interface as “areas designated as Local
Very High Fire Hazard Severity Zones,” since, prior to 2025, there were no areas in the
City designated as High or Moderate FHSZs. While the definition is outdated, the City is
compliant with this part of the code because the State FHSZ maps were adopted per
5 Chapter 1 covers administration of the code, and Chapter 2 provides applicable definitions.
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state law (Ordinance No. 1748.) Under the WUI Code, the wildland-urban interface area
must include, at least, all areas designated by the State Fire Marshal and adopted by the
City (as required by Government Code 51187) as a Moderate, High, or Very High FHSZ.
Staff will recommend a revision to the Wildland-Urban Interface Fire Area definition to
conform with the state law as part of the 2025 Building Code update.
Key Finding: With the identification and adoption of High and Moderate fire hazard
severity zones within the City, the City’s definition of “Wildland-Urban Interface Fire
Area” is outdated because it only includes Very High FHSZs.
Strategic Next Step #1: Upon adoption of the Building Code in November, revise the
definition of “Wildland-Urban Interface Fire Area” within Chapter 15.04 of the City’s
municipal code to conform to the definitions provided by state law to include all FHSZs.
WUI Code - Chapter 4: Fire Access and Water Supply Standards
Chapter 4 Applicability
The Fire Access Standards of Chapter 4 apply to subdivisions, developme nt, and roads
within all FHSZs. Although most of Chapter 4, applies to new development and
construction, existing buildings and roadways within a FHSZ must now adhere to the
Section 403 requirement to display address and road markers, respectively, that
sufficiently support fire suppression efforts and access. These requirements for existing
buildings and roadways formerly existed in the Fire Code and are not new requirements.
Fire Access (Section 403)
Chapter 4, Section 403 states that public and private roads and driveways shall provide
for safe access for emergency wildfire equipment and civilian evacuation concurrently,
and shall provide unobstructed traffic circulation during a wildfire emergency. Section 403
sets forth specific requirements for minimum turn radius on streets, inclusion of
turnarounds on long driveways, design standards to accommodate the weight of fire
apparatuses on fire access roads, and minimum standards for horizontal and vertical
curvature of roadways.
Water Supply Requirements (Section 404)
Section 404 sets forth requirements for water supply, including that the City’s water
system must be capable of supplying the required fire flow for structural fire protection
and wildland fire exposure.
Chapter 4 - Local Implementation
Generally, the requirements of Chapter 4 are aligned with the City’s existing engineering
standards that are required citywide. There are some minor instances where
requirements set forth in Section 403 exceed the City’s existing engineering standards.
An example includes the WUI code requirement that driveways have a minimum width of
24-feet in WUI areas, whereas the City’s existing engineering standard 2120 allows for
residential driveway widths between 10 and 16-feet.
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The City’s water system complies with the Fire Code, and consists of water storage
reservoirs, tanks, booster stations, and mains capable of providing the required fire flow.
The City also continues to review private development projects to ensure the project’s
engineered design incorporates the necessary infrastructure (such as fire riser rooms and
fire pumps) to provide fire suppression consistent with Code requirements. No
modifications to the City’s water storage and distribution system are required.
To ensure local code consistency, in advance of the WUI code going into effect on
January 1, 2026, staff will include targeted updates that reference the requirements of
Section 403 for inclusion in the City’s upcoming 2025 engineering st andards update,
which will be recommended for Council’s adoption in Fall 2025. This ensures that the
City’s engineering standards meet the requirements of Chapter 4 in WUI areas (or exceed
it where the City’s standards are already more restrictive). Once the City’s engineering
standards are updated, the requirements of Chapter 4 will be enforced through the
building permit and subdivision process.
Key Finding: The requirements of Chapter 4 related to water supply are fully met by the
City’s systems and standards. Minor updates to the City’s engineering standards related
to fire access are needed.
Strategic Next Step #2: Include any necessary updates related to Chapter 4 of the WUI
code in the City’s upcoming engineering standards update.
WUI Code - Chapter 5: Special Construction Regulations: Building Hardening Standards
Ignition-Resistant Construction (Section 504)
Section 504 of the WUI Code sets forth additional new requirements for new buildings
and additions and remodels to buildings constructed after July 1, 20086. The requirements
address materials used in construction, roof standards, eave standards, underfloor
enclosure standards, and door and window standards. The requirements include, but are
not limited to:
Specific underlayment for tile roofs: a requirement for use of specific underlayment
for tile roofs that create a void between tile and substrate (roof base), which helps
with fire safety
Gutter protection: requirement for protection such as screens to prevent debris
accumulation in gutters
Underfloor enclosure or underside protection: requirement to cover or seal the
open space beneath a building, porch or deck to increase fire safety
Heavy timber or fire-resistant construction for unenclosed accessory structures: a
requirement to use specific materials for things attached to buildings, such as
trellises, patio covers, decks, bay windows, porches, or other proje ctions
6 As a result of a devastating fire season in 2008, the building code was amended in 2028 to include WUI standards
including stricter construction requirements. All subsequent Building Code cycles have included a provision that
remodels and additions to homes built after July 1, 2008, are required to be constructed to current Chapter 7A/ R337
standards, which are now reflected in Chapter 5 of the WUI code.
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Deck materials: requirement to use State Fire Marshall approved materials for
decks
Vents: requirement that ventilation openings for attics, gable ends, ridge ends,
eaves, etc. Shall be covered with ember resistant vents
Windows: requirement that exterior windows be tempered glass or equivalent
Exterior doors and garage doors: requirement that exterior doors and garage doors
comply with certain standards for fire safety
Chapter 5 Applicability
The Building Standards in Chapter 5 (formerly found in Chapter 7A of the CA Building
Code) apply throughout the City, regardless of the FHSZ of a property, to all new
construction and to remodels/renovations of buildings built after July 1, 2008. Chapter 5
will apply throughout the City because San Luis Obispo has, since at least 2012, been
designated as a “Community at Risk from Wild Fires” by the California Department of
Forestry and Fire Protection7 (see Health & Safety Code §13108.5(d).).
The provisions of Chapter 5 will not impact existing structures in the City, unless a building
permit is sought for a renovation/remodel to a building constructed after July 1 , 2008. At
that time, the area of renovation/remodel would then need to comply with the new
regulations, but there would not be a requirement to bring other parts of the building into
compliance. If a renovation/remodel does not trigger the need for a buil ding permit, then
the project does not need to comply with these standards, but applicants are encouraged
to meet these standards for enhanced fire safety (meaning, the City will not enforce the
standards for these projects, but property owners are encouraged and welcome to meet
the standards voluntarily for enhanced fire protection). Additionally, small (maximum 120
square feet) accessory structures not used for habitation (e.g., sheds or carports) and
Group U agricultural buildings8 located at least 50 feet away from applicable (non-exempt)
buildings, are exempt from the construction requirements of Chapter 5.
Chapter 5 Compliance
Compliance with Chapter 5 requirements will be verified through the building permit
process, including providing information to property owners at the counter, checking for
compliance during building plan check, and verifying compliance during inspections.
Key Finding: Compliance with requirements of Chapter 5 related to ignition-resistant
building materials and construction will be verified through the City’s building permit
process upon adoption of the WUI code, starting January 1, 2026. No further action is
needed. To support permit applicants and City plan reviewers, in the fall of 2025, the City
7 Following that designation, in 2012 City Council adopted an ordinance amending Title 15 of the Municipal Code to
“require a limited application of the Chapter 7A building codes new construction Citywide” and thus increased the fire
resistance of new structures citywide. The “limited application of Chapter 7A” included only those requirements
specified in the municipal code (Ignition resistant exterior wall coverings; Fire sprinkler protection in attic areas (at least
one “pilot head”); Ember resistant vent systems for attics and under floor areas, protected eaves, and Class ‘A’ roof
coverings as identified in the California Building Code Chapter 7A), not all Chapter 7A building requirements that applied
to structures within the VHFHSZ. In 2012, the City’s VHFHSZ (the only FHSZ designated in the City at the time)
contained 38 parcels.
8 Group U agricultural buildings are classified by the following uses: livestock and poultry shelters or buildings, barns,
equipment storage facilities, horticultural structures including greenhouses, sheds, grain silos, and stables.
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will begin training internal staff on the WUI code and will continue to support ongoing
external stakeholder education as described in the public engagement section of this
report.
Strategic Next Step #3: Adopt Chapter 5 of the WUI Code as-is, carry over any local
amendments to the building code that have previously been adopted by the City, and
make necessary conforming amendments to existing provisions of Title 15 (e.g.,
references to Chapter 7A of the building code and clarifying that all building hardening
requirements of Chapter 5 are applicable Citywide.)
WUI Code - Chapter 6: Fire Protection Requirements: Vegetation Management,
Landscape Plans, and Defensible Space
Chapter 6, Section 602 and 603 define how the City, as the local jurisdiction, will inspect
and verify that private property owners have adequately mitigated fire hazards for new
construction on parcels in VHFHSZs. Section 604 sets forth specific defensible space
requirements in VHFHSZs. Maintaining defensible space consists of managing or
removing vegetation and combustible materials in a buffer around a structure, which can
slow or stop a wildfire approaching a structure and can provide a safe place for firefighters
to defend the structure.
Chapter 6 Applicability
Staff would recommend clarifying in the adopting ordinance for the WUI code that Chapter
6 only applies to the VHFHSZ. The language of Chapter 6 could be construed as internally
inconsistent otherwise.9 However, staff’s position is that Chapter 6 only applies to the
VHFHSZ because 1) Chapter 6 expressly imposes maintenance responsibilities only on
properties within the VHFHSZ (see section 604.3), unless the local agency designates by
ordinance some other area as a wildland-urban interface area, and 2) the defensible
space regulations found in Government Code Section 51182 and Chapter 7 of Title 14 of
the California Code of Regulations only apply to the VHFHSZ (see 14 C.C.R. 1270.02 et
seq.).
Key Finding: Chapter 6 only applies to the VHFHSZ as described in the user notes in the
beginning of the chapter, and as supported by other existing law such as Government
Code 51182 and Section 1299.03 of Title 14 of the California Code of Regulations .
Strategic Next Step #4: Include an amendment to WUI Code Chapter 6 that clarifies that
its provisions only apply to parcels in VHFHSZs.
Fire Protection Plans (Section 602)
Chapter 6, Section 602 authorizes the code official to require a Fire Protection Plan for
9 For example, the User Notes state that “this chapter contains requirements for development and construction in
Local Responsibility Areas (LRA) designated as Very High Fire Hazard severity Zones…,” but section 601 of that
Chapter states that “the provisions of this chapter establish general requirements for new and existing buildings,
structures and premises located within wild-land-urban interface (WUI) areas,” where WUI areas are defined as all
areas within a FHSZ.
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new construction projects in VHFHSZs. If required by the code official, a Final Fire
Protection Plan must include the following information:
Total size of the project, information on the adjoining properties, current land use,
existing structures and densities, planned construction, natural vegetation,
environmental restoration plans, roads, and parks.
A map with all project boundary lines, slope contour lines, proposed structure
footprints, roads and driveways. The map shall identify project fuel modification
zones10, identification of irrigated and non-irrigated zones, and all proposed plants
with specific information including the plant life-form; scientific and common name;
and the expected height and width for mature growth.
Requirements for vegetation reduction around emergency access and evacuation
routes, and identification of access for equipment and personnel to maintain
vegetation in common areas.
Legally binding statements regarding community responsibility for maintenance of
fuel modification zones, as well as legally binding statements to be included in
covenants, conditions and restrictions regarding property owner responsibilities for
vegetation maintenance.
Section 602 Applicability
Section 602 is applicable to new construction in VHFHSZs. As the code official, the Fire
Chief has discretion to require a Fire Protection Plan for new construction projects in
VHFHSZs. Because the required elements of a Fire Protection Plan are most applicable
to subdivisions and larger scale developments (e.g. providing information about current
land use, existing structures and densities, identifying and maintaining emergency access
and evacuation routes, and identification of vegetation maintenance responsibilities
related to covenants, conditions and restrictions (CCRs)), staff recommends only
requiring Fire Protection Plans for large scale developments, such as subdivisions,
seeking building permits in VHFHSZs.
Section 602 – Local Implementation
The City does not currently require a separate Fire Protection Plan as a building permit
condition. However, nearly all of the mandatory elements of a Fire Protection Plan
established by Section 602 are already required as part of the City’s plan review process
for subdivisions and large-scale developments. By requiring Fire Protection Plans as
described in Section 602 for future larger scale developments, the City would improve on
its existing building permit process by bringing all of the information related to fire hazard
mitigation into a single package, facilitating a more streamlined review.
Key Finding: Fire Protection Plans are an optional requirement, but if they are required
by the code official, must include a prescriptive list of mandatory items. A majority of the
mandatory Fire Protection Plan items set forth by Section 602 are only applicable to larger
scale developments. In the City, these items are already required for subdivisions and
larger developments during the plan review process.
10 Fuel modification, as defined by the WUI Code, is a method of modifying fuel load by reducing the amount of non-
fire-smart vegetation or altering the type of vegetation to reduce the fuel load. The methods and requirements are
different depending on the Defensible Space Zones.
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Strategic Next Step #5: Require new subdivisions and large developments11 to provide
Fire Protection Plans as described in Section 602 of the WUI Code as part of the building
permit process.
Vegetation Plan (Section 603)
Chapter 6, Section 603 states that all new plantings of vegetation in a VHFHSZ shall
comply with the conditions set forth in Section 603, and that landscape plans shall be
provided when required by the code official.
Landscape (vegetation) plans must show that new shrubs and new and existing trees
comply with Section 603 regarding location and spacing, as summarized below:
New fire-safe shrubs shall not exceed 6 feet in height, and if planted in groupings
shall be limited to a combined diameter of 10-feet and be separated from other
groupings by a minimum of 15 feet. Shrub groupings shall be separated from
structures a minimum of 30 feet. Lastly, where shrubs are located below or within
a tree’s drip line, the lowest tree branch shall be a minimum of three times the
height of the understory shrubs or 10 feet, whichever is greater.
New fire-safe or existing trees located within 30-feet of a structure shall be planted
and maintained so that the tree’s drip line at maturity is a minimum of 10 -feet from
a structure, so that the horizontal distance between crowns of new trees and
crowns of adjacent trees shall not be less than 10-feet, and that existing trees
maintain a minimum separation of 10-feet from chimney and stovepipe outlets.
New non-fire-smart trees shall be permitted, provided the tree is planted so that
the tree’s drip line at maturity is a minimum of 30 feet from an applicable (non -
exempt) structure and that the tree’s drip line at maturity is a minimum of 10 feet
from any combustible12 structure, and is well pruned and maintained.
Section 603 defines fire-smart vegetation13 as plants that have high moisture content and
low resin or oil content, which makes them less likely to ignite and spread fire. Nonfire -
smart vegetation has characteristics opposite to fire-safe vegetation and includes plants
and trees such as conifers, palms, pepper trees, and eucalyptus species. These types of
plants are not prohibited, but Chapter 6 provides strict standards as to how nonfire-smart
vegetation is maintained and where it is located relate to structures.
Section 603 Applicability
Section 603 applies to new construction and new plantings of vegetation in VHFHSZs.
11 In this case, “large developments” refer to projects that may not require a subdivision, but would benefit from a Fire
Protection Plan, such as a large commercial development, apartment complex, hotel, or business park development.
12 “Combustible” does not have a single fixed definition within the WUI Code or the Building Code. It is context-specific
but “combustible” materials are generally materials that are readily ignitable by a spark or flame.
13 The code states that to be considered fire-smart vegetation, vegetation must meet one of the following: (a) be
identified as fire-smart vegetation in an approved book, journal, or listing from an approved organization; (b) be
identified as fire-smart vegetation by a licensed landscape architect with supporting justification; (c) plants considered
fire-smart vegetation and approved by the local enforcing agency. Appendix F of the 2025 WUI Code provides further
information on characteristics of fire-smart vegetation.
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Section 603 – Local Implementation
Per Chapter 6, the code official may specifically require a Vegetation Plan, also more
commonly known as a Landscape Plan, for new landscaping within a VHFHSZ. While all
building permits are currently required to show the location of existing trees on the site,
the City does not currently require landscape plans for new structures that only require a
building permit. However, under the City’s current regulations, a new structure that
receives discretionary approval is required to provide a landscape plan.
Under the 2025 WUI code as published by the state, a landscape plan will be required for
both discretionary and non-discretionary projects and will need to include both the
proposed new vegetation and existing vegetation . Staff recommends adjusting the City’s
current building permit process to require a landscape/vegetation plan for projects that
include new landscaping in VHFHSZs, including information about vegetation
maintenance, as having this information during the building permit review process allows
for any changes to be made on paper rather than after construction or landscaping is
initiated. Staff do not recommend requiring a Vegetation Plan for all new landscape
plantings on properties within a VHFHSZ unless it would otherwise be required as part of
a discretionary or non-discretionary permit process, such as a building permit.
Key Finding: Section 603 sets forth detailed requirements for Vegetation Plans, which
can be used by the City to verify compliance with Section 603 and the WUI code more
broadly. As verification of the defensible space elements described above will be required
for final sign-off of a building permit in a VHFHSZ, requiring landscape/vegetation plans
as a condition of a building permit in a VHFHSZ will likely make development (and final
occupancy) in these areas more efficient for both City staff and permit
applicants/developers by ensuring compliance with the state’s requirements under the
WUI Code.
Key Finding: All new plantings in the VHFHSZ will need to comply with the conditions
outlined in Section 603, regardless of whether the new plantings are associated with a
development and required to be reviewed by the City or not. If new plantings are installed
that do not need review by the City prior to installation and do not comply with the
conditions in Section 603, the property owner may be subject to enforcement for non-
compliance on a complaint basis. Additional detail about the staff’s recommendation for
inspection and compliance of the WUI code can be found later in the report under the
header “Section 604 – Local Implementation”.
Strategic Next Step #6: Require a Landscape Plan for all new landscaping associated
with a project that requires a building permit within a VHFHSZ.
Maintenance of Defensible Space (Section 604)
Chapter 6, Section 604 states that hazardous vegetation and fuels shall be managed to
reduce the severity of potential exterior wildfire exposure to buildings and structures, and
to reduce the risk of fire spreading to buildings. Section 604 requires that defensible
space—defined as “the buffer that landowners are required to create on their property
between a “Building or Structure” and the plants, brush and trees or other items
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surrounding the “Building or Structure” that could ignite in the event of a fire ”—be
managed around all buildings and structures located in VHFHSZs.
Section 604.3 requires that defensible space be maintained in accordance with state
codes and regulations, including Government Code Section 51182 and Section 1299.03
of Title 14 of the California Code of Regulations, which provide zone-specific guidance
for areas surrounding a structure. The latest draft regulations to implement Government
Code section 51182, published by the Board of Forestry and Fire Protection on
September 22, 2025, introduces an additional zone—Zone 014. As the WUI Code
references and requires compliance with Section 1299.03, by adopting the WUI Code,
the City will also adopt, by reference, the Zone 0 requirements as issued by the state
(including any future amendments). The Zone 0 requirements are anticipated to take
effect on January 1, 2026, for new structures, and on January 1, 2029, for existing
structures.
The draft Zone 0 defensible space requirements are summarized as follows:
Zone 0 (0 - 5 feet from structure):
1. Remove all grass, ornamental or native plants, shrubs, fallen leaves and
tree needles, weeds, and combustible mulches including bark and
woodchips, with the exception of potted plants under certain conditions15.
2. Maintain trees so there are no dead or dying branches, and all live branches
are 5 feet above the building’s roof, 10 feet away from chimneys and
stovepipe outlets, and 5 feet away from the sides of any building.
3. Remove combustible items (e.g. combustible boards, timbers, firewood,
synthetic lawn, attached window boxes, trellises).
4. Remove all dead and dying plants, weeds, and debris from the roof, gutter,
deck, porch, stairways, and under any areas of the building.
5. Replace combustible fencing, gates, and arbors attached to the home with
noncombustible alternatives within 5-feet of the building.
6. Outbuildings are not permitted.
Zone 1 and 2 requirements already exist (as codified in Section 1299.03 of Title 14 of the
California Code of Regulations) and apply to properties located within the VHFHSZ.
These requirements, as proposed for amendment by the Board of Foresty along with
adoption of the new Zone Zero requirements, are as follows:
14 In 2021, the California legislature introduced the idea of a “Zone 0,” which refers specifically to the area between
zero and five feet around a structure, also referred to as the “ember resistant zone.” In 2021, the legislature directed
the State Board of Forestry and Fire Protection (the “Board”) to issue “Zone 0” regulations. In 2025, the Board released
draft Zone 0 regulations. These regulations are expected to take effect for new structures on January 1, 2026, and, for
existing structures, on January 1, 2029 (Govt. Code 51182(c)(2), 51186(b)(2)). Until 2021, defensible space
requirements only included two “zones,” Zone 1 and Zone 2, which referred to the first 30 feet around a structure, and
the area between 30 and 100 feet from a structure, respectively.
15 Plants in pots are allowable if they are in areas that are not directly beneath, above, or in front of a window, glass
door, or vent; are kept in an unaffixed, not combustible pot or container that is no larger than five (5) gallon capacity;
and set apart by one and a half (1.5) times the height of the plant or twelve inches (12”), whichever is greater, from the
structure and each other. These plants shall be no greater than 18 inches in height. Dead or dying material on the
plants shall be removed.
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Zone 1 (5 - 30 feet from structure and deck, or to property line)
1. Clear all dead or dying plants, grass, shrubs, trees, branches, and weeds.
2. Move all firewood and wood piles to Zone 2.
3. Ensure outbuildings and LPG tanks have 10 feet of clear space to bare soil
and no flammable vegetation within an additional 10 feet around them .
Zone 2 (30 - 100 feet from structure, or to property line)
1. Cut or mow annual grass down to a maximum height of four inches.
2. Create horizontal space between shrubs and trees. (See Figure 2)
3. Create vertical space between grass, shrubs and trees. (See Figure 2)
4. Remove fallen leaves, needles, twigs, bark, cones, and small branches.
However, they may be permitted to a depth of three inches.
5. Keep 10 feet of clearance around exposed wood piles, down to bare mineral
soil, in all directions.
6. Clear areas around outbuildings and propane tanks. Keep 10 feet of
clearance to bare mineral soil and no flammable vegetation for an additional
10 feet around their exterior.
Below, Figure 1 visually displays Defensible Space Zones 0, 1, and 2. The houses
displayed in Figure 1 are compliant with the forthcoming Zone 0 regulations. Figure 2
shows the horizontal and vertical space clearance requirements for vegetation in Zone 2.
Figure 1: Defensible Space Zones
Source: California Board of Forestry and Fire Protection
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Figure 2: Zone 2 Vertical and Horizontal Vegetation Spacing
Source: California Governor’s Office of Emergency Services
Section 604 Applicability
Defensible space requirements set forth by Chapter 6 Section 604, including forthcoming
“Zone Zero” requirements from the State Board of Forestry, will apply to all parcels
including both new and existing structures in VHFHSZs16. In the City of San Luis Obispo
16 Government Code § 51183 and 51184 clarify that certain building types and areas within a VHFHSZ are exempt
from the defensible space requirements. Under Section 51183, the City may exempt from the defensible space
requirements structures with exteriors constructed entirely of nonflammable materials. Section 51184 clarifies that
certain open spaces preserved for environmental, habitat, or species protection are not subject to the defensible space
requirements of Section 51182.
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this includes 2,520 acres and 2,845 parcels in VHFHSZs, as designated in the 2025 FHSZ
maps.
Section 604 – Local Implementation
The City is required to notify property owners within the VHFHSZ of the requirements
within Government Code 51182. In late September, staff sent out a postcard to all affected
property owners with information on defensible space requirements, the new rules that
are anticipated to become effective January 1, 2026, and emergency preparedness
information. The City has also updated its wildfire preparedness website with
requirements for each zone, as well as evacuation information, the community wildfire
protection plan, and other critical information.
Fire Department staff also intend to host in-person workshops after implementation of the
Zone Zero regulations designed to educate homeowners, general contractors, landscape
contractors, arborists, and landscape architects on defensible space requirements. These
sessions will be recorded and made available for virtual training as well. City staff have
developed a comprehensive communications plan that includes key seasonal messages,
such as spring preparation and red flag warnings. Staff’s outreach efforts will utilize social
media, newsletters, town hall meetings, and local media , as well as flyers, checklists, and
before-and-after visuals to promote fuel reduction. Fire Department staff also intend to
assist communities within the City in obtaining a Firewise USA Community designation
(discussed further below) and hold workshops for landscape contractors to train them in
best practices.
Given the significant expansion of the VHFHSZ areas (and, therefore, of defensible space
requirements) within the City, staff’s intention is to lead with education and support for
voluntary compliance. Neither the WUI code nor the Government Code mandates any
particular inspection protocol, but Government Code 51186 does require the City to notify
property owners who are in violation of the defensible space requirements of Government
Code 51182 and authorizes (but does not mandate) the City to correct the violations at
the property owner’s expense.
Staff recommends pursuing administrative enforcement of the WUI code where
enforcement steps become necessary. Chapter 6 of the WUI Code mandates compliance
with the defensible space requirements of Government Code § 51182 and Section
1299.03 of Title 14 of the California Code of Regulations (which includes [or will include]
the specific requirements for each “Zone,” as discussed above). This covers all applicable
defensible space requirements that a property owner within the VHFHSZ will be expected
to comply with. The City will be authorized to administratively enforce violations of the
Building, Fire, and WUI Code, once adopted and codified by reference in Title 15 of the
SLO Municipal Code. The City can, in its adoption of the WUI Code, make explicit that
violations thereof are citable as violations of the municipal code. Administrative
enforcement involves issuing Notices of Violation /Notices to Correct and, if necessary,
administrative citations and fines.
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Key Finding: Adoption of the WUI Code as-is will give property owners within the VHFHSZ
sufficient clarity about what is required of them without additional amendments to or
modification to the code language. Adoption of the WUI Code w ill also give the City the
tools it needs to educate the community and, if necessary, enforce violations as the
community adjusts to the drastically expanded applicability of these defensible space
requirements.
Strategic Next Step #7: Include an amendment clarifying that the City will enforce Chapter
6 of the WUI Code (including referenced defensible space requirements) administratively
pursuant to Administrative Code Enforcement Procedures of the City’s Municipal Code
(Chapter 1.24).
As noted above, neither the Government Code nor the WUI Code mandate any particular
type of defensible space inspection. However, the City is required to “notify” prop erty
owners in the VHFHSZ of violations of the defensible space requirements of Government
Code 51182. The City may either proceed with this notification via a complaint-
based/reactive inspection program (as is typical with other code enforcement activitie s),
a proactive/mandatory inspection program, a voluntary/self -refer inspection program,
and/or inspections upon sale of real property.
Complaint-based (“reactive”): Under this system, the Fire Department would
respond to complaints received by community members of violations of defensible
space. Inspections could proceed under the existing administrative procedures of
Chapter 1.24 and/or the Fire Code (as adopted by the City). The Fire Department
would have the discretion to notify the property owner of the violation and educate
them of the defensible space requirements, or to escalate enforcement (e.g.,
Notices of Violation and administrative citations) if necessary.
Mandatory (“proactive”): A proactive inspection program would require regular fire
inspections for all properties within the VHFHSZ to ensure compliance with
applicable defensible space requirements. Staff is not recommending a mandatory
inspection program at this time.
Voluntary: A voluntary inspection program would allow property owners to request
inspections of their own properties. Each Defensible Space Inspection would be
customized to meet the specific needs of the homeowner seeking guidance. At this
time, the Fire Department is prepared to offer a fee-based voluntary inspection
program. Staff have identified the Supplemental Fire Inspection fee (currently
$282.34) as an applicable existing fee that can cover the staffing resources
required for a Voluntary Inspection Program. Staff will monitor the cost of offering
voluntary inspections and will recommend adjustments to the fee if and when
necessary. The Fire Department was recently awarded a FEMA Fire Protection
and Safety Grant to support these inspections by training current staff, supporting
two additional interns, and providing necessary equipment to cover the initial
stages of an inspection program (discussed further in the Fiscal Impact section
below.) Staff will continue to pursue external funding to support, and hopefully
subsidize the inspection costs for property owners.
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Inspections upon sale: California Assembly Bill 38 (2021) (“AB 38”) authorizes
local jurisdictions to require sellers of single-family residential properties within a
VHFHSZ to obtain documentation, upon sale, that the property is in compliance
with the jurisdiction’s defensible space requirements. If the City required this
documentation, the City would also likely need to offer the “AB 38 inspections” in
order for sellers to provide this documentation. As the City does not, by ordinance,
require this compliance documentation, the City does not need to conduct AB 38
inspections at this time. If the City chooses to adopt a local Vegetation
Management Ordinance (commonly known as a Defensible Space Ordinance),
then the City may need to provide AB 38 inspections. AB 38 does not directly
address whether fire agencies may charge a fee to the property owner/seller to
offset the cost of defensible space inspections. However, multiple agencies have
adopted AB 38 defensible space inspection fees, including the City of Murrieta,
Los Angeles County, Woodside Fire Protection District, and the City of Berkeley
(reinspection only.) The City does not currently have an AB 38 inspection fee
established.
Key Finding: Staff recommend pursuing a complaint-based or reactive inspection
program, as is typical with other code enforcement activities in the City. This approach
will enable staff to prioritize limited resources on community educatio n in the near term,
and on supporting a voluntary, fee-for-service based inspection program. Additionally, as
the City does not currently have a Defensible Space Ordinance, the City is not currently
obligated to provide AB 38 inspections at this time.
Strategic Next Step #8: Enforce state-adopted defensible space requirements in the
VHFHSZ using a complaint-based/reactive method, with an initial objective of education.
Strategic Next Step #9: The Fire Department will offer a fee-based voluntary inspection
program and will continue to seek external funding that would allow the City to subsidize
the cost of voluntary inspections for property owners.
Strategic Next Step #10: Do not perform AB 38 inspections upon the sale of real property
in Very High or High FHSZs at this time.
Other requirements of Chapter 6 (Sections 605 – 612)
Chapter 6 also includes various other fire protection requirements related to spark
arrestors (Section 605)17, liquified petroleum gas (Section 606)18, storage of firewood and
other combustible materials (Section 607)19, building siting and setbacks (Section 608)20,
17 Spark Arrestors are required for chimneys that utilize solid or liquid fuel.
18 Liquified Petroleum Gas containers and tanks shall be located within defensible space only in accordance with the
California Fire Code and have a minimum clearance of 10 feet from fire-safe vegetation.
19 Storage of Firewood and other Combustible Materials either needs to be located within an enclosed structure or
completely covered by fire-resistant material or located 30 feet from any structure.
20 Due to the urban nature of the City, most of the properties located within the VHFSZ qualify for reductions from
Building Siting and Setbacks, as long as the property includes alternative methods to reduce structure -to-structure
ignition by incorporating protective features such as, but not limited to: (1) Noncombustible block walls or fences; or
(2) Noncombustible material extending 5 feet from the furthest extent of the building; or (3) Hardscape landscaping;
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ridgelines and fuel breaks (Section 609)21, Fire Safe Development Regulations (Section
610)22, Subdivision Review Surveys (Section 611)23, and General Plan Safety Elements
(Section 612)24. These provisions do not represent new regulations but are carried over
from Chapter 49 of the 2022 Fire Code. These sections apply only in the VHFHSZ.
Sections 605, 606, 607, 609 and 611 apply to both existing buildings and subdivisions
and new construction in VHFHSZs. Sections 608 and 610 apply only to new construction
in VHFHSZs. Section 612 applies to the General Plan for entire City.
Sections 605 - 612 – Local Implementation
As these sections of Chapter 6 are carried over by the 2022 Fire Code, no further action
is needed at this time to implement them locally.
Potential Local Amendments to the State WUI Code
The above discussion describes how the substantive components of the WUI Code would
apply if the City adopted it as-is; that is, without any amendments or adoption of optional
appendices. The following section provides alternatives available to the City. Staff do not
currently recommend proceeding with any of these alternatives. Alternatives include:
Alternative 1: Adopt More Restrictive Building Standards. The City may adopt
“more restrictive building standards reasonably necessary because of local
climatic, geological, or topographical conditions.” The City has already evaluated
and amended prior iterations of the California Building Code and adopted
additional building standards as a “Community at Risk,” as discussed above.
Those standards will now apply throughout the City and staff believe this is
sufficiently protective in light of the City’s climatic, geological, and topographical
conditions.25
or (4) A reduction of exposed windows on the side of the structure with setback less than 30 feet; or (5) The most
protective requirements in Chapter 5 of the WUI code.
21 The City is required to assess and enforce, if necessary, ridgelines and fuel breaks (as those terms are defined in
the WUI Code)
22 Fire Safe Development Regulations shall be applied to all residential, commercial and industrial building
construction located within the VHFSZ as specified in Title 14, Division 1.5, Chapter 7, Subchapter 2.
23 The California State Board of Forestry and Fire Protection shall complete a Subdivision Review Survey within the
VHFSZ to identify existing subdivisions without a secondary egress route that are at significant fire risk and provide
recommendations to the City to improve the subdivision’s fire safety. Currently, the State Fire Marshals' Office is
working with SLO Fire Department inspectors to identify Subdivisions within the VHFHSZ with only one access route.
The State Fire Marshals' office is expected to have reviewed these subdivisions through their GIS program and then
confer with SLO Fire in January 2026. Once all subdivisions are appropriately identified, another individual from the
State Fire Marshals' office will do a site visit in the coming months to provide recommendations to the City. This
process is expected to take approximately three to four months in total.
24 The General Plan Safety Element is to be reviewed and updated as necessary to address the risk of fire within
VHFSZ and submitted to the Board of Forestry and Fire Protection and local fire agencies for review.
Recommendations from the Board or local agencies shall be considered by the City, prior to adoption of any updates
/ amendments to the Element.
25 State law allows the City to adopt standards more restrictive than the California Building Code across multiple code
areas. As an example, the City has historically adopted more restrictive standards for building energy use. As discussed
at the July 15, 2025 study session on this topic, staff anticipates proposing several energy efficiency standards that are
more restrictive than the state code as part of the 2025 California Buil ding Code update, which will be presented for
Council’s consideration later this year.
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Alternative 2: Expand Designated WUI Areas. The City may designate additional
areas as “WUI areas,” expanding the scope of the WUI Code’s substantive
provisions. This is because “wildland-urban interface area” is defined in the WUI
code as “a geographical area identified by the state as a ‘Fire Hazard Severity
Zone’ in accordance with…Government Code Sections 51175 through 51189, and
other areas designated by the enforcing agency to be at a significant risk from
wildfires.” The WUI area already includes all FHSZs but could include additional
areas if identified and adopted by the City. Staff is not recommending the
expansion of the WUI area at this time. The 2025 state fire maps exponentially
expanded the FHSZ areas within the City covered by an FHSZ – as such, the WUI
area now covers 64% of the total City acreage. However, because Chapter 5’s
building hardening requirements apply throughout the City (because of the
Community at Risk designation) and Chapter 6’s defensible space regulations
apply to only the VHFHSZ, expanding the WUI area would only expand the
applicability of fire access and water supply standards of Chapter 4.
Alternative 3: Adopt Supplemental Fire Protection Measures (Appendix A of the
WUI Code). The City may adopt the optional Appendix A of the WUI Code to
provide fire protection measures supplemental to those found in Chapter 6.
Appendix A includes detailed requirements for vegetation control; authority for the
code official to close wildland-interface areas in times of high fire danger; control
of outdoor fires, fireworks usage and other sources of ignition; storage of
hazardous materials and combustibles, hazardous waste dumping; disposal of
ashes and coals in wildland-urban interface areas; protection of pumps and water
supplies; and prohibitions on temporary uses (e.g., fairs, carnivals, and temporary
exhibitions) within the wildland-urban interface areas without a permit from the Fire
Chief. Staff does not recommend adopting Appendix A at this time. In some cases,
this is because the City’s current regulations cover the contents of Appen dix A
(e.g., the City’s Municipal Code allows for closing open space access during high
fire hazard times). Additionally, the regulatory requirements set forth by the new
FHSZ map and WUI Code already present significant financial burdens for
community members and capacity constraints for the City. However, staff plan to
reevaluate the potential value of Appendix A over time.
Alternative 4: Adopt State established Vegetation Management Plan
Requirements (Appendix B of the WUI Code). The City may adopt the optional
Appendix B to provide state established criteria for Vegetation Management Plans.
If Fire Protection Plans are required by a code official for large new developments
in VHFHSZs (see Strategic Next Step #5), Vegetation Management Plans are a
required component of Final Fire Protection Plans and would describe how a
property owner will maintain proposed landscape in compliance with regulations
over time. Staff do not recommend adopting Appendix B, which would
unnecessarily create a “one size fits all” prescription for vegetation management
plans for all types of buildings and projects, whether commercial or residential and
regardless of other unique and relevant factors. Instead, Community Development
and Fire Department staff recommend developing City-specific guidance for permit
applicants on how to best demonstrate their plans for ongoing maintenance of
defensible space when a vegetation management plan is required as part of the
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building permit process. This will allow requirements to be tailored to the unique
needs of various types of properties and projects and ensure that the plans are
effective but not overly burdensome. Community Development and Fire
Department staff will develop this guidance prior to January 1, 2026, and it will be
provided to applicants during the building permit process.
Key Finding: Each substantive chapter of the WUI Code will require adjustments to how
City staff, applicants, and property owners evaluate and develop properties located within
the applicable zones (or, in the case of building hardening requirements, citywide).
Complying with the “as-is” requirements of the WUI Code, without additional local
amendments, will require significant changes that will help ensure that the community is
taking the necessary steps to prepare for and mitigate the risks and effects of wildfires.
In order to ensure proper implementation of new requirements given current resources,
the City should adopt the WUI Code without additional local amendments.
Strategic Next Step #11: Adopt the WUI Code without substantive local amendments to
its requirements.
Strategic Next Step #12: Community Development Department and Fire Department staff
will develop guidance and requirements for vegetation management plans as part of the
building permit application process, to be available by January 1, 2026.
Other Considerations
The WUI Code and the FHSZ maps have wide reaching effects. This section identifies
several topical areas that will be affected by adoption of the se items, including risk
mitigation, real estate disclosures, and city policies.
Risk Mitigation & Insurance
Much of the public inquiry received by the Fire Department has been related to what
property owners can do to make sure they retain their fire insurance. There is no particular
set of requirements the City could impose that would guarantee retention of fire protection
coverage. Staff encourage property owners to contact their insurance companies directly,
since wildfire coverage and/or discounts may require fire protection measures beyond
those required under the WUI Code or Government Code § 51182.
According to the California Department of Insurance, there are certain actions under the
Safer from Wildfires program that can qualify property owners for insurance discounts.
Property owners are encouraged to visit the CA Department of Insurance’s Safer from
Wildfires webpage for a complete list of action items and more information. Some of these
actions include:
Class-A fire rated roof
5-foot ember resistant zone, including fencing
Ember- and fire-resistant vents
Enclosed eaves
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Upgraded windows
Defensible space compliance
Additionally, community-level mitigation designation (such as Firewise USA designation
by the National Fire Protection Association or Fire Risk Reduction Community designation
by the California Board of Forestry) is a mandatory factor insurers must consider in their
wildfire risk models. Firewise communities learn about wildfire risks and are provided with
additional resources to ensure their community is assessed adequately for vulnerabilities.
Firewise communities are self-sufficient and draw very few resources from City
employees. Firewise communities also have special access and priority to funding and
grant assistance programs for fuel mitigation and wildfire safety26. There are currently no
Firewise USA communities within the City27.
The City of San Luis Obispo applied for and received recognition on the Fire Risk
Reduction Community List in 2024 and will be reapplying this fall for designation in 2026.
This designation is given to cities with VHFHSZs that meet best practices for local fire
planning. Fire Risk Reduction Communities are prioritized for Cal Fire wildfire prevention
grants. Additionally, insurance companies are required to consider a community’s
designation as a Fire Risk Reduction Community, which may result in maintained
coverage or possible insurance discounts.
Real Estate Disclosures
As discussed above, the 2025 FHSZ maps dramatically increased the number of parcels
within High and VHFHSZs. As a result, many additional property owners within the City
will be required under existing state law to make certain disclosures upon transfer of real
property. Persons selling property within a VHFHSZ are required to disclose to any
prospective purchaser that the property is located within a VHFHSZ and subject to the
requirements of Government Code section 51182 (Government Code § 51183.5.).
Persons selling single-family residential property with a High or VHFHSZ that was built
before 2010 must disclose that the property is in a High or VHFHSZ (whichever applies),
along with a list of low-cost home hardening retrofits and disclosure of features of the
home (if any) that make the home particularly susceptible to wildfire. See Civil Code
section 1102.6f for complete details of the required disclosure. These disclosure
requirements apply as a result of existing state law and do not require any additional
action from the City.
Other City Policy Implications
General Plan
Adoption of the updated FHSZ map and WUI Code will require amending the General
Plan and also expands the applicability of existing General Plan policies as follows:
26 Firewise communities that are USAA members in California may also get discounts on homeowner insurance by
being recognized as a Firewise USA site. For information on how to become a fire-wise community, residents should
visit the CalFire Firewise Communities website.
27 The closest Firewise community is San Luis Bay Estates in Avila Beach. See all Firewise USA communities here.
Page 632 of 638
Item 8a
25
General Plan Amendment: Pursuant to Government Code 65302(g)(3), the City
must update its Climate Adaptation and Safety Element of the General Plan in light
of the expanded designation of VHFHSZs. There is no mandated timeline for this
update; however, the City must submit a draft update to the State Board of Forestry
and Fire Protection at least 90 days prior to adoption and to the California
Geological Survey of the Department of Conservation (“Geological Survey”) at
least 45 days prior to adoption. The Geological Survey and the Board of Forestry
may recommend changes which the City Council must consider and respond to in
accordance with Government Code 65302.5.
Subdivision Policy: The Climate Adaptation and Safety Element of the City’s
General Plan, Policy FI-5.2 (summarized in the Policy Context above), curren tly
prohibits subdivision within VHFHSZs. Under this policy, any project that includes
a subdivision within a VHFHSZ would be required submit an application for a
General Plan amendment for the City’s consideration. The adoption of the updated
FHSZ map substantially increased the number of parcels that are subject to this
policy.
Specific Plan Impacts: With the adoption of the updated FHSZ map, the majority
of the Froom Ranch Specific Plan area is now designated VHFHSZ, thereby
prohibiting development as previously contemplated in the Plan. A Specific Plan
amendment, and corresponding General Plan Climate Adaptation and Safety
Element amendment, would be needed to allow previously contemplated
development in the VHFHSZ areas of Froom Ranch Specific Plan. Staff is currently
working with the applicant on this identified issue.28
Key Finding: The Climate Adaptation and Safety Element must be updated under state
law to reflect the new FHSZs and will require revision if the City intends to allow
subdivisions within the VHFHSZ. The Froom Ranch Specific Plan will require revision if
the City intends to allow development within VHFHSZs in the Froom Ranch Specific Plan
area.
Strategic Next Step #13: Amend the Climate Adaptation and Safety Element of the
General Plan as required by Government Code section 65302 to reflect the updated
FHSZ maps.
28 The Froom Ranch Specific Plan, Policy 7.4.1, states that “Development will not occur in the Local Very High Fire
Hazard Severity Zone.” In 2020, at the time of the Froom Ranch Specific Plan adoption, only 13 acres of the Froom
Ranch site within the upper western terrace near the Irish Hills Na tural Reserve were designated VHFHSZ, with the
remaining 102 acres designated Moderate FHSZ. All development was designed to avoid higher elevation areas of
VHFHSZ, as analyzed in the Froom Ranch Environmental Impact Report, and an Open Space Easement has since
been recorded for this area. Upon adoption of the updated FHSZ Maps in June 2025 as discussed above, the majority
of the Froom Ranch Specific Plan area is now designated VHFHSZ, thereby prohibiting development as previously
contemplated. Future development in a VHFHSZ with the Froom Ranch Specific Plan area will require an application
for a Specific Plan amendment for the City’s consideration.
Page 633 of 638
Item 8a
26
Strategic Next Step #14: Agendize a study session to reevaluate the prohibition on
subdivisions within the VHFHSZ and discuss possible amendments to the Climate
Adaptation and Safety Element of the General Plan29.
Tree Ordinance
While staff have not identified any direct conflicts between the Tree Ordinance and the
new WUI Code requirements, staff is assessing the Tree Ordinance in order to determine
what changes may be necessary to address any policies, requirements, or provisions that
may act as a barrier to encouraging fire safety. Staff intends to recommend to Council a
code revision that clarifies the tree removal process that would apply if a tree must be
removed in order to comply with the WUI code and Government Code § 51182. This may
be a standalone amendment to the Tree Ordinance or part of a comprehensive update to
that Ordinance. Staff have set a goal of completing the amendments by early 2026.
Key Finding: The City’s Tree Ordinance is not directly inconsistent with the WUI Code,
but tree removals necessary for WUI Code compliance could be streamlined to reduce
the burden on property owners.
Strategic Next Step #15. Amend the Tree Ordinance to clarify the tree removal process
for trees that must be removed under the WUI code.
NEXT STEPS
Staff requests that the Council review the Strategic Next Steps (replicated below) and
direct staff to move forward with those recommendations as presented or as modified by
the Council. Staff will return to Council in November to introduce adoption of the California
Building Code (including the WUI Code) for final adoption in December and
implementation in January 2026. Once the state finalizes the “Zone Zero” regulations,
those regulations will be codified into state law and incorporated as defensible space
requirements enforceable through the WUI Code. Once finalized, the “Zone Zero”
requirements will take effect immediately for new construction, but existing structures will
have three years from the date of adoption to comply with the requirements. Staff will
develop and implement a communication strategy to inform the public of the ne w Zone
Zero regulations, once they are finalized by the state.
Strategic Next Steps:
1. Revise the definition of “Wildland-Urban Interface Fire Area” within Chapter 15.04
of the City’s municipal code to conform to the definitions provided by state law to
include all FHSZs.
2. Include any necessary updates related to Chapter 4 of the WUI code in the City’s
upcoming engineering standards update.
29 While Specific Plan changes will be necessary to accommodate the development of the Froom Ranch Specific
Plan area, staff recommends considering this item upon request of the property owner, consistent with the
discussions that staff and the property owner have had thus far.
Page 634 of 638
Item 8a
27
3. Adopt Chapter 5 of the WUI Code as-is, carry over any local amendments to the
building code that have previously been adopted by the City, and make necessary
conforming amendments to existing provisions of Title 15 (e.g., references to
Chapter 7A of the building code and clarifying that all building hardening
requirements of Chapter 5 are applicable Citywide.)
4. Include an amendment to WUI Code Chapter 6 that clarifies that its provisions only
apply to parcels in VHFHSZs.
5. Require new subdivision and large developments (as defined in Footnote 11) to
provide Fire Protection Plans as described in Section 602 of the WUI Code as part
of the building permit process.
6. Require a Landscape Plan for all new landscaping associated with a project that
requires a building permit within a VHFHSZ.
7. Include an amendment clarifying that the City will enforce Chapter 6 of the WUI
Code (including referenced defensible space requirements) administratively
pursuant to Administrative Code Enforcement Procedures of the City’s Municipal
Code (Chapter 1.24).
8. Enforce state-adopted defensible space requirements in the VHFHSZ using a
complaint-based/reactive method, with an initial objective of education.
9. The Fire Department will offer a fee-based voluntary inspection program and will
continue to seek external funding that would allow the City to subsidize the cost
of voluntary inspections for property owners.
10. Do not perform AB 38 inspections upon the sale of real property in Very High or
High FHSZs at this time.
11. Adopt the WUI Code without substantive local amendments to its requirements.
12. Develop guidance and requirements for vegetation management plans as part of
the building permit application process, to be available by January 1, 2026.
13. Amend the Climate Adaptation and Safety Element of the General Plan as required
by Government Code Section 65302 to reflect the updated FHSZ maps.
14. Agendize a study session to reevaluate the prohibition on subdivisions within the
VHFHSZ and discuss possible amendments to the Climate Adaptation and Safety
Element of the General Plan.
15. Amend the Tree Ordinance to clarify the tree removal process for trees that must
be removed under the WUI code.
PREVIOUS COUNCIL ACTION
June 17, 2025 - Council adopted Ordinance No. 1748 (2025 Series), which codified
the updated wildfire maps and designated Moderate, High, and Very High FHSZs
within the City. Council also directed staff to return with a study session on the
topic ahead of the 2025 Building Standards Code Update. This adoption date
follows the first reading of the ordinance, which occurred on June 3, 2025.
January 17, 2023 – Council adopted the Climate Adaptation and Safety Element
of the General Plan, which established wildfire and WUI policies and programs as
described in the report.
March 6, 2012 – Council adopted Resolution No. 10337 (2012 Series), which
updated the General Plan to include new wildfire related maps and policies, and
Page 635 of 638
Item 8a
28
introduced Ordinance No. 1575 (2012 Series), which applied certain fire prevention
standards via the building code to structures not within the VHFHSZ.
PUBLIC ENGAGEMENT
The City engaged the community in Spring 2025 when CALFIRE released the draft Fire
Hazard Severity Zones. This included public information sessions, e-notifications, a topic
on Open City Hall seeking public input, social media posts, a Study Session with Council,
public hearings, and more. This resulted in a significant amount of community
engagement. In fact, the e-notification announcing adoption had more opens than any
other email communication sent to subscribers during the summer months, and the Open
City Hall topic had 180 visitors and 44 responses, which equates to about 2.2 hours of
public comment at 3 minutes per response. The input provided staff with a better
understanding of community concerns about how the new Fire Hazard Severity Zones
would affect everything from split parcels to future affordability, including insurance and
the work required to comply with defensible space and home hardening regulations. The
feedback also demonstrated that the community has high expectations for information
around the state and local requirements and expectations of property owners.
Leading up to October 2025, the City of San Luis Obispo launched a public information
effort to raise awareness of this study session discussion among interested and impacted
community members. This included a postcard that was mailed directly to addresses
located in Very High Fire Hazard Severity Zones, dedicated information on the City’s
website, mentions in various social media posts from the Fire Department and the main
City Government accounts, a news release to encourage local media coverage, e-
notifications to interested community members, direct email communications from the
Fire Department to interested and impacted community members, printed flyers, and
more.
On September 24, 2025, the Fire Department was approved for award of a Fire
Prevention and Safety (FP&S) grant through FEMA to support community-level wildfire
preparedness outreach and education. Fire Department staff will return to Council on
October 21, 2025, for authorization to accept the award in the amount of $57,671.42.
Following the study session, the City will launch a public information effort based on the
City’s Public Engagement and Noticing Manual to help property owners understand and
comply with new and existing statewide requirements for defensible space and home
hardening in recently adopted FHSZs, based on the new WUI Code. The public
information plan will focus on ensuring that homeowners, business owners, and
community partners clearly understand their responsibilities under the State’s WUI Code,
including the new Zone Zero regulations once they are finalized by the state . Public
outreach tools will include digital communications, direct mail, print materials, events and
informational meetings, media and advertising, and outreach through trusted community-
based organizations and industry partners.
Page 636 of 638
Item 8a
29
CONCURRENCE
This report has been prepared by staff from the Fire, Utilities, Community Development,
Public Works, Administration, and City Attorney departments, and they concur with the
information and recommendations presented in this report.
ENVIRONMENTAL REVIEW
The recommended action (to receive a presentation and conduct a study session) is not
subject to environmental review because it is not a “project” under CEQA Guidelines
15378. Adoption of the WUI Code, including permissible amendments, would be
statutorily exempt from CEQA under Public Resources Code §21080.49 (wildlife risk
reduction projects).
FISCAL IMPACT
Budgeted: Yes Budget Year: 2025-26
Funding Identified: Yes
Fiscal Analysis:
Funding
Sources
Total Budget
Available
Current
Funding
Request
Remaining
Balance
Annual
Ongoing
Cost
General Fund $0 $ $
State
Federal
Fees
Other:
Total $0 $ $ $
There is no net fiscal impact associated with receiving and filing the report. However,
there will be costs associated with implementing the changes required by State law. The
exact costs are unknown at this time but include staff time to develop and carry out new
processes and procedures, complete training related to the new codes, and conduct
outreach and education to the public about the changes.
The changes to the development review process (such as building permit review) may
result in additional time required to review building permits to ensure compliance with the
new regulations. Because staff are recommending that new construction projects in
VHFHSZs that include landscaping (estimated at 25-40 applicable projects per year)
include landscape plans, the City will need to allocate staff time and resources to review
these plans and to evaluate compliance as part of the final inspection. Additionally, the
Fire Department will provide final inspections on these permits, which would be subject
to the City’s existing $329.04 fee for Supplemental Plan Review to recoup the cost of staff
time. This fee is adjusted each July 1, by the annual change to CPI, in accordance with
Section 2 – User Fee Cost Recovery Goals of the Council-adopted Fiscal Policies. By
Page 637 of 638
Item 8a
30
policy, staff is to review all user and regulatory fees every three years as a part of Citywide
fee studies, to ensure that fees are set at a level to recover the cost of providing various
services.
Existing staffing resources are sufficient to provide complaint-based inspections. If non-
compliant property owners do not comply with the law in the stipulated time frame, they
would be cited and fined as per the administrative citation process.
For voluntary inspections, staff have identified the Supplemental Fire Inspection fee30 as
an applicable existing fee that can cover the staffing resources required for a Voluntary
Inspection Program. The Fire Department is also actively seeking outside funding to
support such a program.
ALTERNATIVES
Council may choose to provide direction to staff to modify any of the Strategic Next
Steps identified in the report. The Strategic Next Steps reflect staff’s recommendations
as supported by the discussion and the Key Findings in the report. Council may choose
to modify any of the recommendations related to adoption of the WUI Code. Staff will
incorporate Council’s direction when returning in November to introduce an Ordinance
adopting the Building Standards Code (including the WUI Code). Council may also modify
any of the Strategic Next Steps related to the implementation of the WUI Code or to the
impacts of the WUI Code on existing City policies, including the Climate Adaptation and
Safety Element, the Safety Element, and the Tree Ordinance. The Safety Element of the
General Plan must be updated to reflect the new FHSZ maps , but the Government Code
does not require this to be done by any particular deadline.
Council may direct staff to adopt local amendments to the WUI Code and/or adopt
optional appendices. These options are discussed on pages 20-22 of this report. Staff
recommend that adoption of the WUI Code as-is would provide the community sufficiently
clear and protective guidelines. However, if Council directs staff to adopt local
amendments and/or optional WUI Code appendices, that direction will be reflected when
staff returns in November to introduce an Ordinance adopting the Building Standards
Code (including the WUI Code).
30 If staff finds that these inspections are consistently greater than the 1.5 hours contemplated by the Supplemental
Fire Inspection fee, the fee may need to be revisited.
Page 638 of 638
Wildland Urban Interface (WUI) Code,
Building Hardening, and Defensible Space
Regulations Study Session
City Council Study Session –October 7, 2025
1
Recommendation
1.Receive a presentation on the 2025 California Wildland Urban Interface
(WUI) Code, including defensible space requirements;
2.Direct staff to return to City Council to adopt the WUI code as-is, and provide
direction on strategic next steps pertaining to WUI code implementation; and
3.Provide direction on strategic next steps on the City’s approach to community
education, inspections, and enforcement of the WUI Code and other
considerations, including real estate disclosures, risk mitigation, and the
effects of the 2025 Fire Hazard Severity Zone maps and statewide codes on
existing City policies.
2
Previous il Action
3
Background
3
Policy Context
Adoption of CAL FIRE’s 2025 Fire Hazard Severity Zone Maps
•Ordinance 1748 (2025) adopted new FHSZ designations
2025-27 Major City Goal Work Program
•Implement State Fire Hazard Severity Zone Maps and related
requirements (tasks 4.1.c and 4.1.d)
•Adopt and implement the 2025 Buildings Standards Code,
which includes the WUI Code (task 4.3.c)
Climate Adaptation and Safety Element of the General Plan
•Fire Smart Buildings and High or Very High FHSZs (FI-5.2)
•WUI Defensible Space & Home Hardening Program (FI-5.15)
•Fire Protection Plans for New Development (FI-5.19)
4
California maps Fire Hazard
Severity Zones (FHSZs) based
on factors such as fuel, slope,
fire weather, and (since 2025)
wind and ember cast.
•March 10, 2025: California
released updated FHSZ maps
for San Luis Obispo.
•June 17, 2025: City Council
adopted new designations
Designations cannot be
reduced by City
Statewide Hazard Mapping
5 5
In 2025, the City went from
38 to 8,782 parcels in FHSZs.
Fire Hazards are Increasing in San Luis Obispo
City Parcels Designated in FHSZs (2025)
Wildfire Risk in the WUI
•Pre-1800’s, under indigenous
stewardship California burned 4.5 million
acres per year
•Today, 12.7%of Californians live in a
WUI zone
•2025 Palisades and Eaton
•30 fatalities
•16,000+ structures destroyed
•at least $28 billion in property losses
7
Photo by the Atlantic of the Palisades fire
Four Components of Wildfire Risk
Mitigating Wildfire Risk: Statewide Building Standards
9 9
WUI Code is Part 7 of 12 Parts
Previous il Action
10
The California Wildland-Urban Interface Code
10
City Adoption: Requirements and Parameters
11 11
•City is required to adopt the WUI Code
•Can only make more restrictive
•Can assist in clarity
•Staff's recommendation:
•Adopt the WUI Code "as is"
Definitions
WUI:
Wildfire Urban Interface
Includes all Fire Hazard
Severity Zones
12
Definitions
FHSZ:
Fire Hazard Severity Zones
Includes Moderate (yellow),
High (orange), and Very High
(red)
13
Definitions
VHFHSZ:
Very High Fire Hazard
Severity Zones
14
Definitions
Fuel Modification Zones:
Defined areas around a building with prescriptive defensible space objectives, including:
•Zone 0
•Zone 1
•Zone 2
15
16 16
Chapter 3
WUI Areas
Chapter 4
Fire Access and
Water Supply
Standards
Chapter 5
Building Construction
and Hardening
Standards
Chapter 6
Fire Protection Plans,
Landscape Plans, and
Defensible Space
Applicable
Zones All Fire Hazard
Severity Zones
(FHSZs)
All Fire Hazard
Severity Zones
(FHSZs)
Citywide
Very High Fire Hazard
Severity Zones
(VHFHSZs)
Applicable
Scope
Fire service access to
subdivisions and new
development
New Construction
+ remodels on
buildings built after
July 1, 2008
New landscaping +
existing landscaping
within 100 feet of
buildings
Where does the WUI Code apply?
17 17
Chapter 3 – Designation of WUI Area
18 18
Chapter 3 – Designation of WUI Areas
Strategic Next Step #1:
Revise the definition of “Wildland-Urban
Interface Fire Area” in the municipal code to
include all FHSZ as defined by state law.
19 19
Chapter 4 – Fire Access and Water
Supply Standards
Strategic Next Step #2:
Include minor WUI-code related
updates in the City’s engineering
standards update in Fall 2025 / Winter
2026 to align with the WUI Code.
Chapter 4: Fire Access & Water Supply Standards
20 20
Applies to new development
and construction in all
FHSZs
21 21
Chapter 5 – Special Construction
Regulations, Building Hardening Standards
SLO FD
at the Palisades Fire
22
Chapter 5:
Why building hardening, defensible
space, and access are essential
Chapter 5: Special Building Construction Regulations
Graphic by Beverly Hills Fire
What is building hardening?
23
Protected |
Graphic by Scientific American 180
24
Chapter 5: Special Building Construction Regulations
What is building hardening?
Meant to increase fire
resistance of structures
through requirements for:
•Building materials
•Roofs and eaves
•Underfloor enclosure
•Door and window
25 25
Chapter 5: Special Building Construction Regulations
Applies to new development and
construction citywide
•New Buildings
•Remodels/additions to homes built after
7/1/2008, and only the project area
needs to comply.
•Chapter 5 will only impact projects with
building permit. Will not apply
retroactively to existing structures if no
changes to the structure are proposed.
Building hardening compliance will be
confirmed through building permit
process (e.g. plan check and inspections).
Will begin upon adoption of the WUI code
on January 1, 2026.
To support compliance, the City will
continue to train internal staff and support
ongoing education for external stakeholders.
26 26
Chapter 5: Special Building Construction Regulations
27 27
Chapter 5: Special Building Construction Regulations
Strategic Next Step #3:
a) Adopt Chapter 5 of the WUI
Code as-is
b) Carry over any local
amendments to the building
that have previously been
adopted
c) Make necessary conforming
amendments to Title 15
28 28
Chapter 6 – Fire Protection Requirements:
Vegetation Management, Landscape Plans,
and Defensible Space
Image source:
USA Today
30 30
Chapter 6 focuses on mitigating
fire hazards outside of buildings
through:
•Fire Protection Plans and
Vegetation Plans for new
development
•Verification and enforcement of
ongoing defensible space
maintenance
Chapter 6: Fire Protection Requirements
Photo by CAL FIRE
31 31
Strategic Next Step #4:
Include an amendment to WUI Code
Chapter 6 that clarifies that its provisions
only apply to parcels in VHFHSZs.
Chapter 6: Fire Protection Requirements
Applies to Very High Fire
Hazard Severity Zones
Fire Protection Plans (Section 602)
Chapter 6: Fire Protection Requirements
Applicable to new
construction in VHFHSZs.
The WUI Code authorizes the City to require a Fire Protection Plan for a
new construction project in the VHFHSZ.
33 33
Chapter 6: Fire Protection Requirements Fire Protection Plans (Section 602)
A Fire Protection Plan must address:
•Size and nature of project
•Map identifying fuel modification
zones,proposed plants, access routes
•Reducing vegetation around access and
evacuation routes, common areas
•Legally binding statements regarding community
responsibility for maintenance of fuel zones
•Fire Protection Plans are most
applicable to subdivisions and
larger scale developments
•The City’s current entitlement
review process for subdivisions
and larger developments
already requires information in
a Fire Protection Plan
34 34
Chapter 6: Fire Protection Requirements Fire Protection Plans (Section 602)
Strategic Next Step #5:
Require Fire Protection Plans for
subdivisions and larger scale development
projects as part of the building permit process
35 35
Chapter 6: Fire Protection Requirements Fire Protection Plans (Section 602)
Vegetation Plan (Section 603)
Chapter 6: Fire Protection Requirements
Also known as a “landscaping plan”
Applicable to new construction
and all new plantings in
VHFHSZs.
Landscape plan example provided by Ten Over Studio
•Sets the standard for new
plantings of vegetation in
VHFSZ
•Defines fire-smart
vegetation (shrubs, trees)
•Specifies planting distances and
maintenance within 30 feet of
buildings
38 38
Photo by Yana Valchovic
Limb Branches
Chapter 6: Fire Protection Requirements Vegetation Plan (Section 603)
Strategic Next Step #6:
Require a Landscape Plan for all
new landscaping associated with
a project that requires a building
permit within a VHFHSZ.
39 39
Chapter 6: Fire Protection Requirements Vegetation Plan (Section 603)
Maintenance of Defensible Space (Section 604)
Chapter 6: Fire Protection Requirements
Applies to all parcels including new
and existing structures in VHFHSZs.
41 41
Chapter 6: Fire Protection Requirements Maintenance of Defensible Space (Section 604)
42 42
Fuel Modification Zones:
Zone 0 = 0-5 ft (DRAFT): Ember-
Resistant Zone around the structure, kept
free of all combustible material.
Zone 1 = 5-30 ft : Fuel Reduction Zone,
where fuel is reduced and fire-resistant
plants are used.
Zone 2 = 30-100 ft: Reduced Fuel Zone,
focuses on maintaining space and
reducing vegetation height to slow fire
spread, with increased spacing on slopes
and where vegetation is more flammable
Chapter 6: Fire Protection Requirements Maintenance of Defensible Space (Section 604)
Zone 1 and Zone 2
regulations are
enforceable now for all
parcels in VHFHSZ.
Zone 0 (DRAFT):
•Will apply to new
construction upon WUI
code adoption
•For existing buildings
3-year grace period for
existing structures
All new plantings in the VHFHSZ
must comply with WUI code
requirements for vegetation spacing,
location, and defensible space.
Compliance is required even if new
vegetation is installed as part of routine
maintenance, landscaping services,
replanting gardens in the spring, etc.
44 44
Chapter 6: Fire Protection Requirements Maintenance of Defensible Space (Section 604)
Strategic Next Step #7:
Include an amendment clarifying that the
City will enforce Chapter 6 administratively
(including referenced defensible space
requirements)
45 45
Chapter 6: Fire Protection Requirements Maintenance of Defensible Space (Section 604)
Enforcement Options
•Complaint-based
(DSI-reactive)
•Mandatory
(DSI-proactive fee based)
•Voluntary
(DSI – fee based)
•Inspection upon sale
(AB 38 inspection)
46 46
Chapter 6: Fire Protection Requirements Maintenance of Defensible Space (Section 604)
Strategic Next Step #8:
Enforce state-adopted defensible space
requirements in the VHFHSZ using a
complaint-based/reactive method, with
an initial objective of education
47 47
Chapter 6: Fire Protection Requirements Maintenance of Defensible Space (Section 604)
48 48
Strategic Next Step #9:
The Fire Department will offer a
fee-based voluntary inspection
program and will continue to seek
external funding to create a
subsidy for voluntary inspections.
Chapter 6: Fire Protection Requirements Maintenance of Defensible Space (Section 604)
49 49
Strategic Next Step #10:
Do not perform AB 38
inspections upon the sale of
real property in Very High or
High FHSZs at this time.
Chapter 6: Fire Protection Requirements Maintenance of Defensible Space (Section 604)
50 50
Chapter 3
WUI Areas
Chapter 4
Fire Access and
Water Supply
Standards
Chapter 5
Building Construction
and Hardening
Standards
Chapter 6
Fire Protection Plans,
Landscape Plans, and
Defensible Space
Applicable
Zones All Fire Hazard
Severity Zones
(FHSZs)
All Fire Hazard
Severity Zones
(FHSZs)
Citywide
Very High Fire Hazard
Severity Zones
(VHFHSZs)
Applicable
Scope
Fire service access to
subdivisions and new
development
New Construction
+ remodels on
buildings built after
July 1, 2008
New landscaping +
existing landscaping
within 100 feet of
buildings
Where does the WUI Code apply?
One home spared on a street devastated by fire in Pacific Palisades
From YouTube: https://youtube/Bm7247crWdM?si=gspnX7KGlpmBKP92
Previous il Action
52
Potential Local Amendments
to the WUI Code
52
Key Findings:
•Complying with the “as-is” requirements will require significant changes to
help ensure the community is taking necessary steps to prepare for and
mitigate the risks and effects of wildfires.
•However, the City could adopt more restrictive building standards, expand
designated WUI areas, and adopt supplemental appendices regarding Fire
Protection Methods and/or Vegetation Management Plan Requirements.
Potential Local Amendments to the WUI Code
53 53
•Strategic Next Step #11:
Adopt the WUI Code without substantive local
amendments to its requirements.
•Strategic Next Step #12:
Community Development Department and Fire
Department staff will develop guidance and
requirements for vegetation management plans
as part of the building permit application process.
Potential Local Amendments to the WUI Code
54 54
Previous il Action
55
Other
Considerations
55
•Property owners concerned about retaining fire insurance; some may
qualify for discounts.
•SLO is still a Fire Risk Reduction Community; which means improved
access to grants and potential insurance benefits for locals.
Risk Mitigation and Insurance
56 56
•Sellers of property in a Very High and High must disclose the
designation and related requirements.
•Sellers of single-family homes in High or Very High FHSZs built before
2010 must disclose their zone, provide a list of low-cost hardening
retrofits, and note any wildfire-vulnerable features.
•These state law requirements are not new, but with adoption of the
updated FHSZ maps, they apply to a much larger number of
parcels/property owners
Real Estate Disclosures
57 57
General Plan Update: The City must amend
the Climate Adaptation and Safety Element
to reflect expanded VHFHSZ designations.
Subdivision and Specific Plan Impacts:
Updated FHSZ maps expand parcels
restricted from subdivision (Policy FI-5.2)
and place much of the Froom Ranch
Specific Plan in VHFHSZ, requiring General
Plan and Specific Plan amendments to allow
previously planned development.
City Policy Implications
58 58
•Strategic Next Step #13:
Amend the Climate Adaptation and Safety Element
of the General Plan as required by Government
Code section 65302 to reflect the updated FHSZ
maps.
•Strategic Next Step #14:
Agendize a study session to reevaluate the
prohibition on subdivisions within the VHFHSZ and
discuss possible amendments to the Climate
Adaptation and Safety Element of the General Plan.
City Policy Implications (continued)
59 59
Tree Ordinance
60 60
The City’s Tree Ordinance is not
directly inconsistent with the WUI
Code but can be amended to
facilitate WUI Code compliance
and reduce the burden on property
owners.
Tree Ordinance
61 61
Strategic Next Step #15:
Amend the Tree Ordinance to clarify
the process for trees impacted by the
WUI code.
Previous il Action
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Public Engagement
62
Public Engagement and Education
63 63
•Spring 2025: Extensive public
engagement on draft FHSZs via
sessions, Open City Hall, social
media, and Council Study Sessions.
•Pre-October 2025: Targeted
outreach to affected residents and
stakeholders through mail, digital
communications, and media.
64 64
Public Engagement and Education
Post-Study Session: Build awareness and reduce confusion about new requirements, and
encourage compliance over time through:
•Core City Communications Channels and Tools (e.g., slocity.org, news stories, email
updates, social media campaigns, explainer videos on social media and Channel 20, media
outreach, Ask SLO, etc.)
•Partnerships (e.g., HOAs, landscapers’ networks, Downtown SLO, SLO Chamber of
Commerce, Developer’s Roundtable, neighborhood groups and community-based
organizations, trade associations, property management groups, etc.)
•Paid advertisements: TV, radio, print, social media, online search, apps
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Wrap up and Recommendations
66
Recommendation
1.Receive a presentation on the 2025 California Wildland Urban Interface
(WUI) Code, including defensible space requirements;
2.Direct staff to return to City Council to adopt the WUI code as-is, and provide
direction on strategic next steps pertaining to WUI code implementation; and
3.Provide direction on strategic next steps on the City’s approach to community
education, inspections, and enforcement of the WUI Code and other
considerations, including real estate disclosures, risk mitigation, and the
effects of the 2025 Fire Hazard Severity Zone maps and statewide codes on
existing City policies.
Do you agree with the following strategic next steps?
1.WUI Code Chapter 3: Revise the definition of “Wildland-Urban Interface Fire
Area” within Chapter 15.04 of the City’s municipal code to conform to the
definitions provided by state law to include all FHSZs.
2.WUI Code Chapter 4: Include any necessary updates related to Chapter 4 of
the WUI code in the City’s upcoming engineering standards update.
3.WUI Code Chapter 5: Adopt Chapter 5 of the WUI Code as-is, carry over any
local amendments to the Building Code that have previously been adopted by
the City, and make necessary conforming amendments to existing provisions of
Title 15 (e.g., references to Chapter 7A of the building code and clarifying that all
building hardening requirements of Chapter 5 are applicable Citywide.)
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Council Feedback on Strategic Next Steps (1/5)
Do you agree with the following strategic next steps?
4.WUI Code Chapter 6: Include an amendment to WUI Code Chapter 6 that
clarifies that its provisions only apply to parcels in VHFHSZs.
5.WUI Code Chapter 6, Section 602: Require new subdivision and large
developments to provide Fire Protection Plans as described in Section 602 of the
WUI Code as part of the building permit process.
6.WUI Code Chapter 6, Section 603: Require a Landscape Plan for all new
landscaping associated with a project that requires a building permit within a
VHFHSZ.
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Council Feedback on Strategic Next Steps (2/5)
Council Feedback on Strategic Next Steps (3/5)
Do you agree with the following strategic next steps?
7.WUI Code Chapter 6, Section 604: Include an amendment clarifying that the City will enforce Chapter 6 of the WUI Code (including referenced defensible space requirements) administratively pursuant to Administrative Code Enforcement Procedures of the City’s Municipal Code (Chapter 1.24).
8.WUI Code Chapter 6: Enforce state-adopted defensible space requirements in the VHFHSZ using a complaint-based/reactive method, with an initial objective of education.
9.WUI Code Chapter 6: Continue to seek external funding to support voluntary inspections
10.WUI Code Chapter 6: Do not perform AB 38 inspections upon the sale of real property in Very High or High FHSZs at this time.
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Council Feedback on Strategic Next Steps (4/5)
Do you agree with the following strategic next steps?
11. Potential Local Amendments to the State WUI Code: Adopt the
WUI Code as-is without substantive local amendments.
12. Potential Local Amendments to the State WUI Code: Develop
guidance and requirements for vegetation management plans as
part of the building permit application process.
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Council Feedback on Strategic Next Steps (5/5)
Do you agree with the following strategic next steps?
13. Other Considerations: Amend the Climate Adaptation and Safety
Element to reflect the updated FHSZ maps.
14. Other Considerations: Agendize a study session to reevaluate the
prohibition on subdivisions within the VHFHSZ and discuss possible
amendments to the Climate Adaptation and Safety Element of the
General Plan.
15. Other Considerations: Amend the Tree Ordinance to clarify the
tree removal process for trees that must be removed under the WUI
code.
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Questions and Discussion
Appendix
74 74
Chapter 6: Fire Protection Requirements Vegetation Management, Landscape Plans, and Defensible Space
Fuel Modification Zone Requirements:
Zone 0 = 0-5 ft (DRAFT)
•Remove plants: Remove all grass, ornamental or native plants, shrubs and branches, with the exception
of potted plants under certain conditions.
•Maintain trees so there are no dead or dying branches, and all branches are 10 feet above the building’s
roof, 10 feet away from chimneys and stovepipe outlets, and 5 feet away from the sides of any building.
•Use hardscape materials like gravel, pavers, or concrete. No mulch or combustible bark.
•Eliminate dead vegetation: Remove all dead and dying plants, weeds, and debris (leaves, needles,
etc.) from the roof, gutter, deck, porch, stairways, and under any areas of the building.
•Replace combustible fencing, gates, and arbors attached to building with noncombustible alternatives.
•Remove combustible items including combustible boards, timbers, firewood, synthetic lawn, attached
window boxes, and trellises. Consider relocating garbage and recycling containers, boats, RVs, vehicles,
and other combustible items outside this zone.
75 75
Chapter 6: Fire Protection Requirements Vegetation Management, Landscape Plans, and Defensible Space
Fuel Modification Zone Requirements:
Zone 1 = 5-30 ft (or to property line)
•Clear all dead or dying plants, grass, shrubs, trees, branches, and weeds.
•Regularly trim trees to maintain a 10-foot gap from others.
•Maintain space between trees, shrubs, and flammable items like patio
furniture.
•Move all firewood and wood piles to Zone 2.
•Ensure outbuildings and LPG tanks have 10 feet of clear space to bare soil
and no flammable vegetation within an additional 10 feet around them.
76 76
Chapter 6: Fire Protection Requirements Vegetation Management, Landscape Plans, and Defensible Space
Fuel Modification Zone Requirements:
Zone 2 = 30-100 ft (or to property line)
•Clear all dead or dying plants, grass, shrubs, trees, branches, and weeds.
•Regularly trim trees to maintain a 10-foot gap from others.
•Maintain space between trees, shrubs, and flammable items like patio
furniture.
•Move all firewood and wood piles to Zone 2.
•Ensure outbuildings and LPG tanks have 10 feet of clear space to bare soil
and no flammable vegetation within an additional 10 feet around them.
Zone 2 - Horizontal Clearance Requirements
Zone 2 - Vertical Clearance Requirements
Continuous Canopy Compliance Method for Zone 2
Link to Detailed FHSZ Map
https://experience.arcgis.com/experience/a51155e46
d504bfab3b7a107c3eb6643/page/Planning/
Four Components of Wildfire Risk
•Hazard:natural or built condition that has the
potential to initiate or exacerbate wildfire
exposure or spread
•Probability:the likelihood or chance that a
hazard event will occur within a given timeframe
or under given conditions
•Vulnerability:the susceptibility of exposed
assets to suffer damage given the hazard event
•Consequence: the outcome if the hazard occurs
What is Home Hardening?
Home-hardening is increasing the ignition resistance of your home
thereby assisting in structural survivability.
Best practices are...
•Class A roof assembly
•Enclosed eaves
•Gutters, downspouts, and exterior doors made of noncombustible material
•Exterior glazing
•Ember resistant vents
What is the WUI Code?
Chapter Overview Roadmap:
a)Chapter Applicability and Intent
b)Code Content
c)Local Implementation
d)Key Findings and Strategic Next Steps
The California Wildland-Urban Interface Code
83 83
Appendix Chapter 5
•Key Findings: Compliance with requirements of Chapter 5
related to ignition-resistant building materials and construction
will be verified through the City’s building permit process upon
adoption of the WUI code, starting January 1, 2026. No further
action is needed. To support permit applicants and City plan
reviewers, in the fall of 2025, the City will begin training internal
staff on the WUI code and will continue to support ongoing
external stakeholder education.
•Strategic Next Step #3: Adopt Chapter 5 of the WUI Code as-
is, carry over any local amendments to the building that have
previously been adopted by the City, and make necessary
conforming amendments to existing provisions of Title 15 (e.g.,
references to Chapter 7A of the building code and clarifying
that all building hardening requirements of Chapter 5 are
applicable Citywide.)
Chapter 5 (Acontinued)
85 85
•Overview: States that WUI Areas in Local Responsibility Areas
(LRAs) are to be mapped by the State Fire Marshal as FHSZs.
•Key Finding: 2025 CAL FIRE maps designate High and Moderate
FHSZs within the City, making the City’s definition of WUI Area
outdated because it only includes Very High FHSZs.
•Strategic Next Step #1: Upon adoption of the Building Code in
November, revise the definition of “Wildland-Urban Interface Fire
Area” within City’s municipal code to conform to the definitions
provided by state law to include all FHSZs.
Chapter 3: Designation of WUI Areas
86 86
Appendix Chapter 6
Section 602:
•Overview: Chapter 6, Section 602 authorizes the code official to require a Fire
Protection Plan for a new construction project in VHFHSZs.
•Applicability: Section 602 is applicable to new construction in VHFHSZs. As the
required elements of a Fire Protection Plan are most applicable to subdivisions
and larger scale developments, staff recommends only requiring Fire Protection
Plans for large scale developments, such as subdivisions, seeking building
permits in VHFHSZs.
Chapter 6: Fire Protection Requirements Vegetation Management, Landscape Plans, and Defensible Space
88 88
•Overview: Chapter 6 defines how the City will inspect and verify that private
property owners have adequately mitigated fire hazards for new construction on
parcels in VHFHSZs, and sets forth specific requirements for managing or
removing vegetation and combustible materials in a buffer around a structure.
•Key Finding: Chapter 6 only applies to the VHFHSZ as described in the user
notes in the beginning of the chapter, and as supported by other existing law
such as Government Code 51182 and Section 1299.03 of Title 14 of the
California Code of Regulations.
•Strategic Next Step #4: Include an amendment to WUI Code Chapter 6 that
clarifies that its provisions only apply to parcels in VHFHSZs.
Chapter 6: Fire Protection Requirements Vegetation Management, Landscape Plans, and Defensible Space
89 89
Sections 605-612:
•Overview:These provisions do not represent new regulations but are carried
over from various other locations:California Building Code, California Fire Code,
or California Code of Regulations.These sections are related to spark arrestors
(Section 605), liquified petroleum gas (Section 606), storage of firewood and
other combustible materials (Section 607), building siting and setbacks (Section
608), ridgelines and fuel breaks (Section 609), Fire Safe Development
Regulations (Section 610), Subdivision Review Surveys (Section 611 ), and
General Plan Safety Elements (Section 612).
•Applicability:No further action is currently required.
90 90
Chapter 6: Fire Protection Requirements Vegetation Management, Landscape Plans, and Defensible Space
•Require new subdivisions and large developments to provide Fire Protection
Plans as described in Section 602 of the WUI Code as part of the building permit
process
91 91
Chapter 6: Fire Protection Requirements
Visual Depiction of Current Zone 1 and Zone 2 for Residential Building
Rural Home Compliant with Zone 0, 1, 2 Requirements
Zone Zero Compliant Fence
Five Pillars of Disaster Management
95