BILL ANALYSIS                                                                                                                                                                                                              1










                  SENATE COMMITTEE ON NATURAL RESOURCES AND WILDLIFE
                                           

                             Senator Sheila Kuehl, Chair
                              2003-2004 Regular Session

               BILL NO:       SB 1369
               AUTHOR:   Kuehl
               AMENDED:       March 22, 2004
               FISCAL:        Yes            HEARING DATE:March 23, 2004
               URGENCY:       No        CONSULTANT:Bill Craven
               SUBJECT:       Fire protection; relating to fire protection

               Summary:       This bill extends the requirements for a  
               firebreak around houses located in very high fire hazard  
               severity zones from 30 to 100 feet, extends the firebreak  
               requirement for homes in state responsibility areas from 30  
               to 100 feet, allows liens to be placed on property in state  
               responsibility areas if these clearances are not achieved,  
               allows, property insurance companies, in the context of a  
               contract with landowners, to require greater distances for  
               certain homes, and requires the owners of new and re-built  
               homes to self-certify to their insurance company as to  
               their compliance with state and local building codes.

               Existing Law: For homes state responsibility areas, Public  
               Resources Code Section 4291 requires a firebreak of 30 feet  
               around structures. Government Code Section 51182 requires a  
               firebreak of 30 feet around such homes in local  
               responsibility areas. Insurance companies do not have the  
               flexibility under existing law to increase these distances  
               when necessary, nor is there an existing requirement that  
               new and rebuilt homes located in "very high fire hazard  
               severity zones" must comply with building codes.
          
               "Very high fire hazard severity zones" are designated by  
               the California Department of Forestry and Fire Protection  
               director and are updated approximately every 5 years. Fire  
               suppression in local responsibility areas is typically a  
               matter for local fire agencies, although CDF frequently  











               responds to such fires as a matter of mutual aid. Local  
               jurisdictions are required to adopt these designations by  
               ordinance. They are allowed to show that certain areas  
               should be added or excluded from the zones designated by  
               the director. Transferors of real estate in such zones are  
               required to disclose this designation to buyers. 

               State responsibility areas are also divided by the director  
               into various hazard severity zones. These are lands for  
               which the state has the primary responsibility for  
               non-structural fire suppression.  Local agencies frequently  
               respond to fires in these areas. Historically, these lands  
               have been forestlands, chapparal, or grasslands. However,  
               population densities on many such lands are rapidly  
               increasing. Updates to designations of these lands by the  
               Board of Forestry also occur every five years. 

               The Public Resources Code and Government Code have similar  
               requirements for vegetation management. Both have a 30 foot  
               minimum clearance requirement around houses. For properties  
               in state responsibility areas, the director may increase  
               that distance to 100 feet because of extra-hazardous  
               conditions. Both codes exempt specimen trees, ornamental  
               shrubbery, and other plantings that do not pose a fire risk  
               to structures. 

               Additionally, both codes require removal of tree limbs that  
               hang above chimneys, require screens over chimneys, and  
               exempt structures that are constructed with nonflammable  
               materials. 

               Both codes are subject to criminal enforcement as  
               infractions, and third violations are misdemeanors.  
               Additionally, the Government Code (local responsibility  
               area lands) allows for local governments to undertake the  
               necessary vegetation removal and to impose a lien on the  
               property if a landowner fails to comply. There are no  
               similar provisions for lands in the state responsibility  
               areas. 

               Last year, AB 1216 (Vargas) required the State Fire Marshal  
               to propose building standards to strengthen fire protection  
               standards for attached components (including porches and  











               balconies) of homes and openings (including vents and  
               windows) into homes. These new building standards are to  
               apply to homes in very high fire hazard severity zones in  
               both state and local responsibility areas. AB 1216 also  
               defined the "urban-wildland interface" and requires the new  
               building codes to apply to homes in  the interface zone as  
               well. The interface is defined as the communities  
               designated at-risk from wildfire in a 2001 report from the  
               department. The State Fire Marshal is to make its  
               recommendations about building code improvement by 2005. It  
               will then be up to the State Building Code Commission to  
               determine whether to adopt those recommendations.

               Proposed Law: This bill:
               (1) Establishes identical firebreak criteria of 100 feet  
               for homes in state responsibility areas as well as those in  
               local responsibility areas when the homes are in very high  
               fire hazard severity zones. 

               (2) Allows property insurance carriers to require more  
               expansive firebreaks based on conditions facing its  
               prospective policyholder. 

               (3) Requires the owner of new construction and owners who  
               are re-building structures damaged in very high fire hazard  
               severity zones to self-certify to their insurance carriers  
               that the construction complies with all applicable state  
               and local building standards, including those that will be  
               developed pursuant to AB 1215 (Vargas). 

               (4) Creates a parallel process to that which already exists  
               in local responsibility areas for the state to impose liens  
               on property where the owner fails to comply with the  
               firebreak requirements.
               
               Arguments in Support: CDF Firefighters support the bill  
               because of the extended firebreaks in very high fire  
               severity zones. That organization also believes that the  
               bill reflects a sensible approach to fire science and the  
               "practical, real world responsibility of responding to an  
               alarm." 

               Sierra Club and the Planning and Conservation League  











               support the firebreak and the building code provisions of  
               the bill. They contend that the firebreak language will  
               assist homeowners in protecting their homes and that  
               building code compliance "is one of the most important  
               actions that can be taken to avoid loss of property during  
               a fire."

               Arguments in Opposition: None received.
               
               Comments: Benjamin Franklin reportedly said that the  
               definition of insanity is doing the same thing over and  
               over and expecting a different result. So it is with 40  
               years of scientific reports about defensible zones around  
               homes in wildlands. We've been taught over and over that  
               these houses are in areas in which cyclic burning is part  
               of the natural order. Fires are to California as tornadoes  
               are to Kansas. We know that we should use fire-resistant  
               construction methods and building materials. We know we  
               should concentrate development in existing urbanized areas  
               in order not to interfere too dramatically with the natural  
               fire regimen in wildland areas. But instead, we continue to  
               build homes in areas in which there is little or no defense  
               against fires and constantly subdivide larger and unbroken  
               tracts of wildlands. 

               As a result of the most recent series of fires in Southern  
               California, the author is convinced that homes and other  
               structures in the state's regions that are vulnerable to  
               wildfire should have their ability strengthened to  
               withstand future wildfires. Various reports commissioned by  
               the state and scientific analyses of fire behavior have  
               identified the lack of enforceable firebreak legislation in  
               California as a major contributing cause to the spread of  
               wildfire. The recommendations of these reports, many of  
               which are collected on the CDF website, have never been  
               fully implemented. Recommendations about extending  
               firebreaks are scattered throughout these reports. The 100  
               foot limit represents the best available science from the  
               United States Forest Service. "My research results indicate  
               that the big flames of high intensity wildland fires do not  
               directly ignite homes at separation distances beyond 100  
               feet." (Cohen,  Thoughts on the Wildland-Urban Interface  
               Problem  , 2003). 












               Although arson caused several of the recent fires, the fact  
               remains that fires in southern California, regardless of  
               cause, will continue to target houses so long as those  
               houses are vulnerable. Houses and other buildings are a  
               fuel source for wildfire. This bill is an attempt to reduce  
               the vulnerability of those houses and thereby to enhance  
               public safety. 

               It is also important to acknowledge the role of the  
               insurance industry in coping with the risk of wildfires and  
               property losses in California. It is obvious that the  
               exposure of the industry to fire-related losses will  
               decrease if it is able to make case-by-case determinations  
               that minimum firebreak clearances are inadequate for homes  
               in particularly dense forestland or on particularly steep  
               slopes. Fire scientists concur that the type of vegetation  
               and the slope of the land are two of the most salient  
               factors to control if homes are to be better protected. 

               Compliance with building codes, including the  
               recommendations of the state fire marshal pursuant to AB  
               1216,  will also help ensure that new and re-built  
               structures are as safe as possible for the occupants and  
               will be designed and constructed with materials that  
               decrease the exposure of the insurance industry to  
               fire-related losses. The approach in the bill relies on  
               owner self-certification, and not a mandate to local  
               governments or the insurance industry. Those who wish to  
               build homes in high fire hazard severity zones need to  
               provide their insurance company with a certificate from the  
               relevant local government agency that the proposed home  
               will comply with applicable state and local building codes.  


               SUPPORT: 
               CDF Firefighters
               Sierra Club California (co-sponsor)
               Planning and Conservation League (co-sponsor) 

               OPPOSITION: >
               None received