BILL ANALYSIS                                                                                                                                                                                                    



                                                                  SB 1207
                                                                  Page  1

          Date of Hearing:  June 28, 2010

                       ASSEMBLY COMMITTEE ON NATURAL RESOURCES
                                Wesley Chesbro, Chair
                    SB 1207 (Kehoe) - As Amended:  March 24, 2010

           SENATE VOTE  :  23-11
           
          SUBJECT  :  General plan:  safety element:  fire hazard impacts.
           
          SUMMARY  :  Requires a local government located in areas at risk  
          of wildfire to consider, by January 1, 2015, specified wildfire  
          hazard and risks in its review of the safety element of its  
          General Plan.  Requires the Office of Planning and Research  
          (OPR) to update a fire planning report and propose changes to  
          California Environmental Quality Act (CEQA) guidelines  
          pertaining to fire risks.

           EXISTING LAW  :

          1)Requires the Board of Forestry and Fire Protection (Board) to  
            identify all lands, or state responsibility areas (SRAs) where  
            the state has the primary financial responsibility for  
            preventing and suppressing fires.  Fire prevention and  
            suppression in areas not classified as SRAs are the  
            responsibility of local agencies or the federal government.   
            The board is required to map SRAs every five years.

          2)Requires California Department of Forestry and Fire Protection  
            (CDF) to classify and update or reclassify, if necessary, SRAs  
            into fire hazard severity zones for the purposes of fire  
            prevention and suppression.  Within local responsibility  
            areas, CDF must identify "very high fire hazard severity  
            [VHFHS] zones."  Both zones must be based on factors including  
            fuel loading, slope, and fire weather.

          3)Pursuant to CEQA, requires lead agencies to prepare an EIR for  
            a discretionary project if an initial study shows that it may  
            have a significant effect on the environment.   Requires OPR  
            to prepare guidelines to implement CEQA and to recommend  
            changes to the guidelines, and the Natural Resources Agency  
            (NRA) to certify and adopt these changes at least once every  
            two years.

          4)Requires local governments to adopt a general plan that  








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            includes, among other things, a safety element.  Prior to the  
            adoption or amendment of this element, a local government with  
            SRAs or a VHFHS zone must submit a draft element to the Board  
            and local fire agencies for review and comment.

           THIS BILL  :

          1)Requires OPR, on or before January 1, 2012, to update its  
            "Fire Hazard Planning" document.

          2)Requires, prior to January 1, 2015, and thereafter upon each  
            revision of a housing element, a safety element to be reviewed  
            and updated as needed to address the fire risks on SRA lands  
            and land classified as VHFHS zones.  This review must consider  
            information the "Fire Hazard Planning" document and include  
            all of the following:

             a)   Information regarding fire hazards, including, but not  
               limited to fire hazard severity zone maps, historical data  
               on wildfires, and information about wildfire hazard areas  
               that may be available from the United States Geological  
               Survey.

             b)   General location and distribution of existing and  
               planned development in VHFHS zones, including structures,  
               roads, utilities, and essential public facilities.

             c)   Local, state, and federal agencies responsible for fire  
               protection, including special districts and local offices  
               of emergency services.

             d)   Goals, policies, and objectives for the protection of  
               the community from the unreasonable risk of wildfire,  
               including, but not limited to, all of the following:

               i)     Avoiding or minimizing the unreasonable risks of  
                 wildfire to new development.

               ii)    Identifying construction design or methods,  
                 including fire resistive construction materials, fuels  
                 management methods, or other methods, to minimize damage  
                 if new development is located in a state responsibility  
                 area or in a VHFHS zone.

               iii)   Locating, when feasible, new essential public  








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                 facilities outside of high fire risk areas, or  
                 identifying construction methods or other methods to  
                 minimize damage if these facilities are located in a SRA  
                 or VHFHS zone.

               iv)    Working cooperatively with public agencies with  
                 responsibility for fire protection.

             e)   Establish a set of feasible implementation measures  
               designed to carry out the above goals, policies, and  
               objectives.

          3)Directs OPR, in cooperation with CDF, on or after January 1,  
            2011, at the time of the next review of the CEQA guidelines to  
            prepare, develop, and transmit to NRA recommended changes to  
            the guidelines regarding fire hazard impacts.  NRA must  
            certify and adopt the recommended changes or amendments.

           FISCAL EFFECT  :  According to the Senate Appropriations  
          Committee, $50,000 to OPR to update CEQA guidelines, and $65,000  
          to CDF to assist OPR.

           COMMENTS  :  According to the author's office, given the  
          devastating wildfires the state has recently experienced, the  
          significant increase in development in the wildfire-urban  
          interface, and the doubling of fire risk over the next several  
          decades projected by climate change scientists, "It is in the  
          state's best interest to ensure that cities and counties do all  
          they can to engage in comprehensive and consistent fire  
          prevention and fire protection planning as early in the local  
          land use planning process as possible for projects in SRAs and  
          [VHFHS] zones."

           1)Background  :  SRAs primarily consist of privately owned  
            forestlands, watersheds, and rangelands.  According to the  
            Legislative Analyst's Office (LAO), roughly one-third of the  
            state or 31 million acres is within SRAs.  SRA lands are found  
            in every county expect San Francisco and Sutter Counties.  CDF  
            removes lands from SRA every five years as housing density  
            reaches more than three units per acre.

            CDF's role in SRAs is to prevent and suppress wildland fires.   
            However, CDF is also authorized, but not required, to provide  
            rescue, first aid, and other emergency services if the  
            activity does not require additional funds.  Moreover, it is  








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            the Board's policy to respond to a structure fire if it  
            presents a threat to wildlands.  Even though state law does  
            not require local governments to provide fire protection  
            within SRAs, in practice they have assumed the responsibility  
            for structure protection and basic medical assistance.   
            According to the LAO, about 70 percent of SRAs are covered by  
            some form of local fire protection, funded by property taxes  
            or special assessments.

            In 2006, while a vast majority of incidents CDF responded to  
            in SRAs were non-fire medical emergencies, CDF spent about 75  
            percent of its time fighting wildland fires, 95 percent of  
            which, according to CDF, were caused by humans.  In its  
            analysis of the 2008-09 budget, the LAO found that CDF's  
            budget has increased 150% since 1997-98.  One of the cost  
            drivers is increasing development in the wildland urban  
            interface.  Despite the fact that the total acreage in SRA has  
            remained stable over the last 15 years, the number of housing  
            units in SRA has increased by 15% over this period.  Based on  
            2005 data, the LAO reports there are about 870,000 housing  
            units in SRAs and the trend is upward.

           2)Preventing fires through better planning  : By relying strictly  
            on planning as a means to minimize the hazards of wildfire,  
            this bill takes a different approach than SB 1500 (2008,  
            Kehoe), which prohibited a county from approving development  
            on SRA lands unless it provided sufficient structural fire  
            protection, but is intended to lead to a similar outcome:  
            avoiding and minimizing the impacts of wildfire on life and  
            property.

            Instead, this bill requires a safety element of a General Plan  
            to be reviewed and updated, by January 1, 2015, as needed to  
            consider updated fire planning advice published by OPR and  
            information such as the location of historical fires, existing  
            and planned development in fire hazard zones, and agencies  
            responsible for fire protection.  It relies on a similar  
            planning approach contained in AB 162 (Wolk), Chapter 369,  
            Statutes of 2007, which required more comprehensive flood  
            hazard planning through a three-pronged approach of hazard  
            identification, the development of appropriate goals,  
            policies, and objectives to minimize flood risks, and feasible  
            measures to implement the above.

            Local governments containing SRAs or within a VHFHS zone are  








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            currently required to submit the safety element of their  
            General Plan to the Board and local fire agencies for review  
            and comment (submission deadlines vary but by December 31,  
            2015, all local governments must submit their elements to the  
            Board).  The Board reviews about 20 such elements a year but  
            given resource constraints it can only conduct a cursory  
            review using a standard analytical template.  This review  
            encompasses many of the same issues required by this bill.   
            However, without additional resources, expanding the issues to  
            be included or reviewed in a safety element would undoubtedly  
            further constrain the ability of the Board to conduct  
            meaningful reviews.

           3)Fire hazards may be a significant impact  : CEQA requires lead  
            agencies to prepare an EIR for a discretionary project if an  
            initial study shows that it may have a significant effect on  
            the environment.  The initial study contains questions that  
            help a planner determine the significance of a project's  
            potential impact on the environment, including a project's  
            wildland fire risks to people or structures.  This bill would  
            require OPR, on or after January 1, 2011, to propose  
            additional questions regarding a project's potential fire  
            hazards impacts on SRAs or VHFH severity zones, and directs  
            NRA to adopt these proposed changes as part of the CEQA  
            guidelines.  In doing so, the bill may effectively create a  
            new category or subset of environmental impact, the  
            significance of which may trigger the preparation of an EIR.

           4)Previous legislation  :  Except for the deadlines, this bill is  
            identical to last year's SB 505 (Kehoe), which the Governor  
            vetoed.  In his veto message, the Governor stated:
                
                While I concur that counties must ensure that adequate fire  
               protection is available in an area before approving  
               additional development, I am concerned that this bill will  
               result in additional General Fund costs and create  
               significant cost pressures to maintain State Responsibility  
               Areas and fire hazard severity zone maps.  In addition, I  
               am also concerned with the cost pressures this bill will  
               place upon local governments to implement this measure.

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           








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          American Planning Association of California
          California Fire Chiefs Association
          California Native Plan Society
          California Professional Firefighters
          California State Firefighters' Association
          Fire Districts Association of California
          League of California Cities
          Mountains Recreation and Conservation Authority
          Orange County Professional Firefighters' Association
          Sierra Club California
           
            Opposition 
           
          California State Association of Counties
          County of San Bernardino
          County of Orange Board of Supervisors
          Regional Council of Rural Counties


           Analysis Prepared by  :  Dan Chia / NAT. RES. / (916) 319-2092