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HomeMy WebLinkAbout10/7/2025 Item 8a, SchmidtA Primer on Coming Fire Safety Regulations for SLO (With Points of View Likely Different from those of Regulations’ Promoters) With regard to adopting and implementing new wildfire safety regulations, I urge the city to go slowly and gently. Given the draconian negative community impacts of state proposals, this requires a lot of careful thought, and not just “doing something” for the sake of doing something. One must make sure any regulation will produce more benefit than harm, and much of what’s being talked about doesn’t pass that test. Some of possible requirements under discussion will make our homes less safe from wildfire. Other issues include 1, the massive removal of trees and other green cover that will make our neighborhoods uglier, hotter, drier, less livable, more fire-prone; 2, setting back the Climate Action Plan’s tree-based carbon sequestration programs; 3, increasing energy consumption as air conditioning becomes the norm to overcome increased urban heat island impacts of removing vegetation; 4, relying on a rigid statewide list of procrustean requirements rather than performing rational science-based analysis of what would help in a given situation; and 5, creating huge public anger towards the city as homeowners are ordered by you to undo the landscapes they love and are entitled to enjoy. For all these reasons, and more – as discussed below – this must be done more gently than it seems the city intends. In addition, in assessing any contemplated “requirement,” the city must answer the key question: What is the source of ignition for the “hazard” that must be abated? And then the corollary question: Will that source of ignition actually ignite the “hazard?” This is key to a plan that might actually make us safer. I am also concerned that my neighborhood has been falsely identified as having the highest fire hazard when clearly it does not. (“My neighborhood” for this discussion means the areas along the east and north bases of San Luis Mountain along Broad, Chorro and out Foothill to the westerly city limits.) Imposing rigid procrustean vegetation clearance regulations in such an area is just plain wrong, and makes us less safe, not more safe. You might legitimately ask who am I to make such strong contrarian statements that challenge our fire department, so let me explain. I am not a wildfire scientist, but neither are the city staff who are informing this program. I am a historian turned architect, which means I bring the research and analytical approaches of two diverse disciplines to building my own understanding of fire issues as they affect both my profession and my life. I am also experienced in living with defensible space regulations. For the past 3 decades I’ve studied, learned, and grown in my understanding of wildfire’s relationship to the built environment. I have personally experienced a wildfire’s destroying the studio where I had worked, and for more than 20 years have had responsibility for fire-preventive property maintenance in an actual very high fire danger community (high desert alpine coniferous SoCal forest). I’ve taken lessons from the fire establishment at the same time I’ve tried to keep up with the more progressive wing of fire science. I think I know a lot, and hope the city is open to learning from what I have to offer. My Neighborhood and the CalFire Hazard Map. There are a limited number of types of wildfire: 1, forest fire, with sub-types ground fire and crown fire, depending upon which part of the forest canopy is driving the fire; 2, brush fire; 3, grass fire; and 4, wind-driven ember fire, which originates as a sub-type of 1 or 2 above. The CalFire map shows my neighborhood in some sort of special danger because of its location at the base of San Luis Mountain, but what that danger comes from is not explained, and, to date, the city has been remarkably incurious in ascertaining from CalFire what it perceives the danger to be and how it arrived at that conclusion. So we have to feel our way through this informational darkness to reach our own conclusions. Can we stipulate my neighborhood is at no danger from a forest fire since there’s no forest nearby? As for brush fire danger, likewise the neighborhood is not bordered by brush, so that’s not an ignition source justifying the highest hazard rating. The undeveloped land that borders my neighborhood is grazing grassland – for miles and miles. Grass burns readily, but it has little heat capacity (which is a way of saying it lacks sufficient substance to burn hot like brush or forest), burns relatively slowly, especially downhill (which is topographically where my neighborhood is located), has a relatively cool burn which doesn’t ignite everything in its path (photos of wood fences at the borders of grass fires, slightly singed but uburnt and still protective of what’s on the other side illustrate this fact), and is readily controllable along an urban front like ours. Burning grass makes only small and ephemeral embers unlikely to be large enough or long-lived enough to ignite any building. Does this potential source of ignition justify the highest fire hazard zone CalFire has applied? Again, no. Which leaves wind-driven ember fires. For these, we need two things: a significant source of burning embers, and wind sufficient to turn them into firebombs. A potential source for burning embers is elusive. True, there are scattered oak groves and isolated islands of brush high up on the east and north slopes of San Luis Mountain. But oak groves are fire resistant, and live oaks have been found to be fire protective, not fire hazards. So they would be an odd justification for designating a highest hazard zone due to an ember fire. As for islands of brush, “islands” is exactly what fire science teaches us to make in brush zones to prevent or slow the advance of damaging brush fires. The fact these islands are isolated means they do not become the flaming masses that cause catastrophic city-edge building fires, nor the source for overwhelming streams of embers, many of which – if there were to be embers -- would be intercepted by their neighboring live oaks. So, we have no plausible ember ignition source from the trees and brush high on the mountain. But if you refuse to admit that, carry the analysis a step further and introduce wind, the second essential ingredient for a wind-driven ember fire. Wind is straightforward in that we know what directions it comes from. Prevailing summer wind comes off Morro Bay, and blows from the northwest. Fire weather wind comes from the east to northeast, blowing down the hills and canyons from the national forest. South wind is rare, and is pretty much isolated to winter storms, when it blows rain into the city. West to southwest wind is also rare, and is associated with wet winter storms. So, what direction of wind would create an ember storm into my neighborhood from burning vegetation high up San Luis Mountain? South wind. So we would be at risk, if CalFire is saying our hazard is from an ember storm from the mountain, only when it’s raining! And that makes no sense. The only other potential source for embers that could ignite our westerly-facing and southerly- facing neighborhood prior to neighborhoods to our east would be the Irish Hills, which are miles away, across miles of grazing land, with Laguna Lake neighborhoods not designated by CalFire as very high hazard miles closer to the ember source, and sure to be affected by embers long before we would be. As for wind, it would take very strong west to southwest wind to blow embers our way, and that wind, again, is mainly associated with wet winter weather. So what is the source of ignition for the “hazard” CalFire claims for our neighborhood? There doesn’t appear to be one. That said, however, I am not naïve. We could face the potential for an ember fire – but from the east, not from the west or south. I can envision a fire blowing out of the national forest, propelled by fire winds from the east/northeast at velocities never experienced here (as contrasted with SoCal where the fire winds have long been legendary in their force), and blowing into the city, turning into a building-to-building fire as it burns across town and eventually reaches us. But that remote potential scenario does not justify the very high hazard designation for my neighborhood and the draconian measures that sets into play. Thus, we have a problem: The CalFire very high hazard designation for my neighborhood is obviously wrong. Since CalFire has not been open about how it arrived at this designation, and the city’s incuriosity has prevented the city’s unscrambling the riddle, we are left to speculate. CalFire says these new maps were created with advanced computer technology, and that perhaps gives us a clue. Computer output is only as good as computer input; since the beginning of computing we’ve spoken of GIGO = garbage in, garbage out. It seems likely CalFire employed AI in its computations, and that ups the GIGO likelihood since AI is notorious for making stuff up – “hallucinating” – if it can’t find a real answer. So, could our neighborhood’s incorrect hazard designation be nothing more than an AI hallucination carelessly reflected in the map? I don’t want to sound harsh about CalFire – they were given a huge task to create new maps on an unreasonable schedule, and doubtless there were errors just because of that. But we, and our neighborhood’s environment, shouldn’t have to suffer draconian consequences because of CalFire’s error. It gets worse – neighborhood fire hazard zone inequities. To our north, along the city’s northerly edge, is the Twin Ridge-Skyline neighborhood, which borders the city’s edge, backing to grazing grassland like mine does. Superficially the neighborhood-grazing interface looks the same. One significant difference, however, is in the summer this neighborhood’s potential grassland fuel is directly upwind of the neighborhood, whereas our neighborhood’s summer winds come from the direction of Bishop’s Peak, over cityscape rather than grassland. One would think this higher danger than our neighborhood faces might register on the hazard maps, but it doesn’t. This neighborhood is outside the very high hazard zone. There’s a second potential hazard for this neighborhood which ours doesn’t face – an actual source for an ember fire. Anyone who’s hiked the Felsman Loop through city open space knows there are miles of dense brush on the sides of Morros not far from this neighborhood. Even though grassland separates the neighborhood from brush, the hazard potential in a stiff summer wind is not negligible. So the Twin Ridge-Skyline neighborhood has two strikes our’s doesn’t, but still gets a lower hazard rating from CalFire. Why the differential treatment of the two neighborhoods? It gets still worse. The affluent top portion of Highland Drive isn’t adjacent to grassland, it’s right inside the native oak/brush habitat. It is also close to and downwind from a lot of brush, including that mentioned for the Twin Ridge-Skyline neighborhood. If ever there was a very high fire zone, this is it. It’s so obvious one marvels that the CalFire map gives it a lower hazard rating. Again, why? So, there are serious problems with the CalFire map, and now the city is set to compound the injury to my middle-class neighborhood with regulations that are truly draconian and unjust, and demanded of us only due to a mapping error. Thus my request that the city “go slowly and gently” with any regulations it may choose to enact. Defensible Space. The centerpiece of regulations our fire department wants the council to enact is something called “defensible space.” Who could be against that? Turns out there are ample reasons progressive fire scientists are critical of applying this fire establishment holy grail to the urbanscape, and tell us some “commonsense” aspects of defensible space actually make our urban homes less safe. So, if this is unfamiliar territory, please listen up. Defensible space as a protective concept originated as a way to protect rural homes situated within native firescapes, like forests or brushlands. The assumption about the nature of fires in such places was that a “fire front” of flames and super-heated gases would sweep in and ignite buildings. To save a structure, the idea was to divorce its site from its native surroundings by modifying flammable vegetation within a large area around the structure. Vegetation modification would begin 100 feet or more from a building and become step-wise more draconian until it reached the building’s walls. Vegetation modifications include reducing the number of trees and shrubs by requiring wide minimum spacing between them (10 to 30 feet for trees, 2 to 6 times a shrub’s height1), eliminating a lot of additional stuff at ground level, eliminating “ladder fuels” (which refers to vegetation growing beneath a tree), and so on, till one gets to a 5-foot low fuel zone immediately next to the building. Creating such defensible space involves massive amounts of vegetation removal. Note that this scheme was explicitly designed for large properties within hazardous wild landscapes, where native vegetation becomes ever more desiccated as the dry season progresses. Bear this desiccation in mind as we proceed, for urban vegetation is likely to be well hydrated, not desiccated, and that changes the entire relationship between vegetation and fire. Over time, as defensible space became institutionalized, this same clearance regime – with the same extreme spacing demands for trees and shrubs -- was imposed on development very different from that for which it had been invented – like cityscapes that aren’t within wild landscapes and where properties don’t extend 100 feet from buildings. If you look at any of the widely published diagrams of “defensible space,” you’ll see the concept is still designed for large rural properties, not for urban lots. What our city is dealing with now is the ultimate administrative imposition of defensible space’s procrustean vegetation-removal approach to fire unsafety, developed for large rural parcels, to small urban parcels where the concept is inappropriate. 1 https://www.fire.ca.gov/dspace This is a defensible space diagram from a CalFire website; as is typical of such diagrams, it shows a large rural property, not urban property. Fire strategies featuring vegetation removal developed for forested rural areas are regarded by experts as irrelevant distractions in urban fire safety planning. I was unaware of defensible space when my former employer’s home and studio burned in the mid-1990s. The property had 2 wood-sided homes plus the studio. One home and the adjacent studio burned to the ground, the second home, about 100 feet away, was unscathed. How could that have happened? Luck? In the 1990s, press accounts began to note anomalies in suburban fire outcomes with and without defensible space. One early account that fascinated me, as an architect trying to increase his fire understanding, was of an Orange County brush fire where a row of homes facing the fire were destroyed, with one exception. That one exception had neglected brush clearance while all the destroyed homes had religiously complied with defensible space clearance recommendations. In time we learned that at best, defensible space was only a weak part of improving safety – that other factors were more important: in the case of my boss’ house, location on the landscape at the top of a draw doomed his place by funneling fire uphill through the draw, while the nearby undamaged house’s location in the woods a hundred feet back from the draw saved it. In Orange County the way the surviving house was built saved it despite lack of brush clearance. With the Paradise fire, something else became clear: the assumption we’re dealing with wildfire in urban fires was incorrect, and what we were in fact dealing with was an ember fire in which fire spread from building to building, not from tree to tree or shrub to shrub. Proof was found in two places: 1, in the astonishing photos from Paradise which showed green trees surrounding burned buildings; and 2, in the fact Paradise was aflame while the wildfire’s front was still miles away. This town-fire wasn’t a primary vegetation fire, and it seems town vegetation that did burn mainly did so because it was ignited by burning buildings.2 Similar photos have since come from nearly every major urban fire – burned buildings among living trees and shrubs. To summarize, the premise of defensible space when it was invented was to alter the larger native landscape to protect a building from wildfire. Today, however, in urban fire settings, it’s the buildings that are burning and igniting the landscape. Defensible space was invented to deal with a different kind of fire, in a different kind of landscape, in a different century’s fire regime. So, isn’t it time to move beyond what’s clearly a largely obsolete notion for good urban protective measures? Eaton fire. Trees weren’t spreading the fire, burning buildings were. Poor trees, singed but survived. Many experts argue that’s what’s needed, even that the state’s proposed requirements for vegetation removal near houses is “dangerously bad advice.” A UC Berkeley study of recent California wildfire damage in populated areas concluded that of the top 10 ways to protect homes, defensible space ranks 8th, and may have ranked lower if the study had considered vegetation hydration differences between wildlands and cities as a variable. (For the record, window replacement, which our fire department also wants to mandate, ranked even lower than defensible space.) Yet such facts aren’t slowing the march ahead for the city’s adopting inappropriate, unwise and counterproductive “fire safety” regulations under a pretext of necessity. So, what’s the fuss about? Much of it centers on the wholesale removal of vegetation from urban housing sites. Turns out such vegetation, provided it’s maintained, is likely to be 2 For a description of Paradise situation, see Chad T. Hanson, Smokescreen; Debunking Wildfire Myths to Save Our Forests and Our Climate, University Press of Kentucky, 2021. protective, not hazardous. Urban yards are not wild landscapes that may go 8 rainless months and become desiccated by fall fire season. We irrigate. We keep our plants hydrated. Even a seldom-irrigated urban landscape is wet compared to a wild one in October. That matters. There’s also misunderstanding about the role of shrubs and trees in urban fires. Sure, there can be bad unmaintained trees, like this SLO palm with enough dead fronds to torch an entire neighborhood in a windy fire. But the city doesn’t need new regulations to deal with this; the fire department already has authority to abate it. The city needs no new regulations to abate rental property fire hazards like this. If trees are maintained to remove dead branches, most are not only fire safe even if canopies touch, many are fire protective. For example, since the January LA fires, many experts have commented on how large trees like live oaks and even conifers intercepted flying embers sufficiently to help slow the fire’s spread to nearby houses. So it’s senseless to mandate cutting down our urban trees in the interests of fire safety. To do so may make us less safe. In short, the concept of defensible space as commonly defined is not a good one on which to base our city’s urban fire prevention planning. Zone Zero Specific defensible space rules have long been called out for a 5-foot strip immediately next to buildings. Till now the rules have been gentle and unobjectionable. For decades, each spring I’ve raked up truckloads of pine needles that accumulate next to the cabin during our mountain winters and hauled them off to the community greenwaste site. I’ve been unable, however, in my research, to find any scientific evidence for the 5-foot dimension; why not 3 feet, or 7, or whatever? Nada. It seems somebody just decided “5” and after decades 5 goes unquestioned. Under the proposed Newsom fire regime, however, the rules in this 5-foot “zone 0” have become absolutist: ESSENTIALLY, NO PLANTS MAY GROW THERE, giving appropriate pathos to the zone 0 name. And existing plants must be removed, which makes zone 0 very mean and nasty. This is complete over-reach of the legislative intent of the law the state’s board of forestry is supposedly implementing. In fact, the assembly member who wrote that legislation, now- Congress member Laura Friedman, is angry at what’s being proposed in her bill’s name. She recently reminded the forestry board that her bill calls for regulations that provide “regionally appropriate vegetation management suggestions that preserve and restore native species that are fire resistant or drought tolerant, or both.” (“Suggestions” rather than mandates seems telling.) Friedman went on: her bill “calls for fuels to be maintained in a condition so that wildfires burning under average weather conditions will be unlikely to ignite structures nearby” and urged the Board to “prioritize regulations that are both scientifically informed and reasonably attainable to ensure maximum compliance.” It’s unclear exactly what’s driving the forestry board’s over-zealous regulation-making. Some suspect response to insurance lobbyists is behind Zone 0’s plant prohibition. We do know the board responds to industry lobbyists: an early rule draft prohibited plastic turf in Zone 0, such turf being far more flammable than plants and having a multiple of the heat energy potential of plants to turn into flames, but when industry lobbyists objected, that sensible prohibition was dropped. Mandating that no plant material may be in Zone 0 and what’s there must be removed will disrupt much that we consider wonderful or valuable in our yards and community.3 And it does this without having evidence it’s helpful in stopping building ignitions and a good bit of evidence it will increase the likelihood of building ignition. It will also contribute to the annihilation of urban beauty and joy, replacing soul-warming places with frigid ugliness. The LA Times posed this latter issue with this photo, of a beautiful public walkway that under proposed zone 0 regulations would have to be denuded. 3 I’m a bit touchy here. My landmark ancient bougainvillea is in zone zero; it not only enlivens and beautifies the small rooms of our home, it brings enjoyment to strangers who view it from street. Why kill that wonder? I recently tested its flammability by trying to ignite a cut branch with a torch. I couldn’t get it to ignite! So, is this draconian approach to zone 0 justified by fire science? No, according to many fire scientists whose work is not financially tied to the fire establishment. This dissent is no longer some hidden secret – the objections of serious scientists are simply being ignored by political operators. Here’s one small example of why fire scientists say the zone 0 regulations are unwise. These photos are from this year’s Palisades fire, before and after. What’s interesting is that the tall, dense hedge between the two homes lies mostly within zone 0. This was a wind-driven ember fire in which homes were burning and vegetation was not for the most part. In addition to avoiding ember ignition, the second home would have to resist the intense radiant heat from the burning home next to it. So how did it resist that heat? The hedge “absorbed” enough of it to prevent the home’s igniting while not itself igniting. Note that this well-hydrated urban shrubbery scorched on the side towards the fire, and that illustrates its protective role. I’ll talk more about the physics of vegetation ignition in the next section of this primer. Had zone 0 proposals been in place, it’s pretty likely the undamaged home would have burned due to flying embers plus radiant heat from next door. Critics of zone 0 say its requirements are way ahead of scientific evidence of their effectiveness. Two academic plant ignition scientists (one UCSB, one SDSU) stated this flatly in a recent article.4 “The state’s proposed Zone 0 regulations oversimplify complex conditions in real neighborhoods and go beyond what is currently known from scientific research regarding plant 4 https://www.latimes.com/opinion/story/2025-06-02/california-fire-risk-zone-0-landscaping- plants flammability,” the scientists wrote. “Green, well-maintained plants can slow the spread of a fire by serving as heat sinks, absorbing energy and even blocking embers.” Regulations “need to recognize the protective role that well-managed plants can play, along with many other benefits of urban vegetation,” they continued. “We believe . . . widespread clearing of landscaping immediately around homes could do little to reduce risk and could even aggravate the danger.” These are cutting edge scientific experts speaking, and we need to pay attention to their findings. Their last comment is echoed and amplified by another critic: plants near a home “can intercept embers, cool surrounding air, and deflect wind-borne firebrands before they reach structures. Removing these living barriers may leave homes as the first—and only—obstacle to embers, turning residences into unintended ‘ember catchers.’” That outcome is exactly what we should want to avoid. The Physics of Plant Ignition. Don’t be scared off by the word “physics” – this is fun stuff. To listen to the acolytes of defensible space, all trees and shrubs are evil propagators of flames and a menace to our homes, lives and fortunes. If fire is in the neighborhood, trees and shrubs will burst into flame. This hyperbole is unscientific, and in an urban context essentially backwards. True, some plants can ignite fairly easily, and our attention should be directed to them, and not to all plants. Often the easy igniters are easy because they harbor lots of dead wood, not because their green parts just burst into flame. Take for example the semi-popular use of juniper groundcover; considered maintenance-free, as a result it’s likely to be about half dead wood. Maybe more. So be careful how you think about green plants and fire. Most green plants aren’t easy to get burning. Before a green plant ignites, it must go through physical and chemical processes to make ignition possible. That takes time. And lots of interesting things happen along the way. Any kid who builds campfires learns a simple fact: wet and green wood doesn’t ignite, but dead and dry will make a nice blaze. This lesson applies also to wildfire, and seems contrary to fire establishment allegations about plant flammability that are cited as justification for defensible space and zone zero vegetation removal. For well-hydrated green vegetation to ignite a number of steps intermediate from ignition exposure to ignition must take place. Understanding these helps explain why vegetation may be fire-protective rather than dangerous. When well-hydrated living plants, shrubs or trees are exposed to a high heat source, the moisture in them must be driven off before they can ignite. That happens by evaporation of the plant’s water content. This evaporation cools the surrounding area (think “swamp coolers”), and that lowers the plant’s flammability. Cooling the surroundings in zone 0, for example, not only lowers flammability of zone 0 plants that lie between an ignition source and the protected building but also lowers the heat impact of the ignition source on the protected building. In many cases, the plant’s moisture is sufficient to prevent the plant’s ignition. But even if the plant does eventually ignite, its residual moisture may still limit how hot it burns (like our campfire example if after the blaze is going you toss on some green wood). Green well-maintained plants can slow the spread of fires by serving as heat sinks, absorbing energy, and blocking embers. These facts about ignition physics are ignored and undercut by the proposed state vegetation removal regulations. Controversy. LA has just experienced two of the most devastating fires in recent history, and its fire department is widely regarded as having expended heroic efforts. Given this recent trauma, and the political tendency to use trauma as a weapon for extreme actions, I find it telling that LA’s fire department has joined the chorus of criticism of the proposed state fire regulations. This fact is well worth noting when considering what to do in San Luis Obispo. Wildfires turning into urban fires is a familiar recent pattern in Southern California. If ever there were a place you’d expect fire safety measures to be welcomed, this is it. Yet, because media there aren’t ignoring the new rules,5 people are fairly well informed and popular opposition is already apparent (and just wait till people are informed what they’re supposed to do). The LA Times recently had a wrap-up article on the controversy that’s loaded with interesting links.6 In LA, the public is hearing from people with great knowledge about fires – people who can contradict the proposed state edicts with authority. People like US Geological Survey fire ecologist Jon Keeley who observes that fires change when they move from chaparral to neighborhoods. “The bottom line is the winds far outweigh the [plant] fuel in terms of fire 5 Unlike here where our news desert leaves probably 95% of your constituents ignorant of what you’re considering. 6 https://www.latimes.com/lifestyle/story/2025-09-15/proposed-zone-zero-rules-would-remove-all-plants-within- five-feet-homes-fire-areas spread . . . When you have these winds it makes [plant] fuels less relevant. And the [plant] fuels are definitely not relevant once it gets into the urban environment, because the primary fuels are the homes.” (emphasis added) So if plant fuels are irrelevant in the urban environment, how does it make any sense to uproot thousands of SLO’s trees and shrubs and make us remove our flower, vegetable and fruit gardens? This clearcut mentality doesn’t make us safer. A remarkable critique of the proposed state regulations has been prepared within LA city hall jointly by the city’s Community Forestry Advisory Committee and the fire department.7 This document is intended to inform city council actions on fire regulations. The report includes much that mirrors my own critique as expressed to this point, but it makes one notable overall damning observation: “The state’s proposed regulations impose a one-size- fits-all solution on an enormous state with vast differences. Many of the underlying case studies, graphics, and demonstration projects used in devising the rules were based on conditions more commonly found in forested areas in Northern California.” It urges regulations to “recognize the geographic and structural differences between Northern and Southern California. In Southern California, particularly in Los Angeles County, many homes are situated in densely populated neighborhoods with limited setbacks” that moot proposed plant-based rules. Instead of one-size-fits-all state mandates, the LA document urges “flexibility and common sense.” “There is a risk of letting fear and ‘the need to do something’ override science-based decision making. Policymakers should resist the impulse to impose inappropriate models.” That conclusion prefaces the LA document’s list of recommendations to the city council. The list is well-worth reading, and though I don’t agree with all its recommendations, it is a thoughtful effort. One final point from the report: it will cost homeowners a lot to comply with what the board of forestry proposes – an average of $13,000 according to the report just for vegetation removal and zone 0 fence modifications. Does our city really think such costs, on top of emotional and physical losses, for measures that can be shown to be unnecessary for fire safety, will be swallowed without rebellion? If you have doubts, look at what’s happening in Oregon where similar state-wide mandates were implemented in the name of fire safety. The populace have become so restive that a bipartisan coalition of Oregon legislators is moving to revoke state fire maps that impose “costly home hardening measures and strict defensible space mandates” that go along with them. One state senator said, "Repealing the fire maps and associated government overreach 7 https://cityclerk.lacity.org/onlinedocs/2010/10-2468-S2_misc_9-8-25.pdf cannot wait. Oregonians have lost too much of their lives and resources worrying about this issue already. Many of them fear they will not be able to continue living in their houses.” The same can be said about SLO if your regulations and “enforcement” go too far. If your goal is to impose unreasonable requirements on a neighborhood like mine, where the “very high fire hazard” classification itself is nonsense, you’ll be inviting vehement opposition to the entire effort. If your goal is actually fire safety, developing measures that are reasonable and have community buy-in is a better road to voluntary non-coercive compliance. Conclusion. It’s worth concluding that the criticism of the state measures isn’t confined to fire scientists, LA city committees, the press, and nutcases like me. Even the bean counters at the renowned California Legislative Analyst’s Office have doubts based on the lack of science behind requirements being promoted. At the time Friedman’s legislation was in the making, the LAO advised “The research literature has not yet provided clear information on the cost-effectiveness of maintaining defensible space compared to other risk-reduction activities, or on the cost-effectiveness of different programs designed to improve defensible space compliance.” “This lack of information,” concludes the LAO, “makes it difficult to determine which specific steps, if any, state or local agencies should undertake.” What to Do? • I’ll repeat the words with which I began: go slowly and gently. Simply adopting whatever the board of forestry and Newsom dictate will open a world of trouble. There’s no need for that. • There must be flexibility since no two properties are the same, no two sets of vegetation of equal safety or hazard. • There must be room for meaningful appeal of any enforcement orders, at no cost to the appellant. (As much as anything, this cost-free appeal will work as a check on unreasonable enforcements.) • There must be honest acknowledgement that a plant free zone 0 is not politically acceptable and is not good fire ignition science. Any city zone 0 regulations must reflect this. • Whatever is done must support city climate action goals; following proposed state mandates will undercut climate action goals. • Whatever is done must support city affordable housing goals; imposing huge costs on homeowners does the opposite. • Whatever is done must support biodiversity. It is unclear, for example, if defensible space requirements will be applied to riparian areas; if they are, they will decimate biodiversity including songbirds, fish and amphibians to mention only the top of the riparian food chain. • The city should get consultation on plant-related fire safety and biodiversity from independent sources, from persons with expertise and disposition likely to result in open disagreement with proposed state measures. Only by getting conflicting input can the council make good decisions. • Whatever is done must support urban comfort (visual, sonic, thermal, safety) above all else. Obliterating these qualities in the name of promoting dubious “safety measures” is not acceptable. • The city must plant thousands of new trees, for beauty, comfort and fire safety. • Enforcement must be gentle and non-obtrusive. Talk of traipsing through our yards or using drones to invade private space is offensive and such municipal acts are unacceptable. Enforcement actions must be reasonable for specific circumstances, not procrustean. • A too draconian program will have major costs for SLOcity due to inspection and enforcement. The LA document estimates LA city annual costs of about $2 million to implement state proposals, money better spent on more effective fire safety measures. • There must be a relaxed enforcement approach. One doesn’t have to go all in police-state style to achieve fire safety. Your ultimate goal should be voluntary citizen implementation of demonstrated fire protective measures rather than shoving an arbitrary one-size-fits-all list of questionable measures down constituents’ throats. (At the time of Friedman’s bill, the state LAO noted: “While state and local agencies are authorized to enforce defensible space regulations, there generally is no requirement that they conduct enforcement or that homeowner compliance be verified, such as through inspections.” That’s interesting. I’ve been unable to verify whether that’s current law.) • Going slow, and developing reasoned and reasonable non-draconian fire regulations is the best path. Richard Schmidt