Proposed Addendum to The Laguna Beach
Fuel Modification Treatment Protocol:
Targeted Herbicide Application Limited to Orange County California Native Plant Society Emergent Invasive Plant Species Background
As part of the Coastal Development Permit (CDP) process for fuel modification activities, the City of Laguna Beach must prepare and maintain a treatment protocol that outlines approved vegetation management methods. This protocol serves as the operational framework for compliance with the California Coastal Act, CEQA, and all applicable regulatory requirements.
Per the certified protocol for hand-treated Fuel Modification Zones, targeted herbicide application is expressly authorized as a regulated method for controlling invasive plant species. Such applications are subject to defined performance standards, weather limitations, licensing requirements, and oversight by certified Pest Control Advisors and licensed applicators.
At its January 9, 2024 meeting, the City Council directed staff to implement a two-year trial period during which herbicide would not be used within Fuel Modification Zones. In response, staff transitioned exclusively to mechanical treatment methods, such as mowing and trimming. Eighteen months into the trial, staff have determined that the program continues to meet its fire safety objectives.
Accordingly, staff proposes to extend the mechanical-only treatment program with a limited exception for EIPS-listed species through this addendum to the certified protocol. Under the revised approach, the City will continue to treat invasive plant species not listed on the Orange County California Native Plant Society’s Emergent Invasive Plant Species (EIPS) list using mechanical methods. Herbicide application will be reserved only for invasive species identified on the EIPS list, which includes plants classified as having the potential to be ecologically aggressive and to be an immediate and significant threat to habitat integrity. These species are treated as ecological contagions, warranting swift intervention, with the goal of complete eradication before the species can become established and spread.
This addendum represents a reduction in herbicide use compared to the certified protocol. Because it narrows the scope of authorized treatment practices, the City has determined that this amendment does not trigger recertification under CEQA or require a new Coastal Development Permit. The revised approach reflects the City’s commitment to wildfire risk reduction, habitat protection, and responsiveness to community concerns regarding herbicide use.
Staff supports continuation of the mechanical treatment program and will continue to evaluate its effectiveness in controlling invasive species not listed on the EIPS list. If the program trends towards not meeting its fire safety objectives or becomes cost prohibitive, staff will return to the City Council for further direction through a public meeting.
Control Mandates
1. Reduction of Fire Behavior Potential
DRAFT Addendum to the Laguna Beach Fuel Modification Treatment Protocol: Targeted Herbicide Application Limited to Orange County California Native Plant Society Emergent Invasive Plant Species
Fuel modification treatment shall achieve an average 75% reduction in potential wildfire fireline intensity, as measured by flame length and rate of spread. In general, a 50% reduction in fuel loading and continuity will meet this objective (see Fuel Modification Impacts to Potential Fire Behavior – A Case Study for the City of Laguna Beach, Rohde, 2017; Catastrophic Wildfire Assessment – City of Laguna Beach, Franklin, 2013). Fuel treatments must disrupt the continuity and trajectory of wildfire spread.
2. Habitat Protection via Targeted Invasive Species Control The program shall also protect native habitat by removing invasive plant species listed on the Orange County California Native Plant Society’s EIPS list. These species have the potential to displace native vegetation, alter soil conditions, elevate fire risk, and/or degrade habitat quality.
Primary treatment shall rely on manual or mechanical removal. Herbicide may be used only when alternative methods fail to achieve 100% control. When used, herbicide must be species-specific, narrowly applied, and carefully managed to avoid harm to native species or ecological functions.
Invasive species removal shall align with long-term habitat recovery objectives, including passive recolonization or active restoration as necessary. Adaptive management and monitoring will guide treatment efficacy and future maintenance decisions to ensure the program benefits high- and very-high-value habitat areas.
Standards for Targeted Herbicide Application
Herbicide shall only be used to control plant species listed on the EIPS list. Targeted application methods are limited to:
• Targeted foliar application using backpack sprayers with focused nozzles on individual plants or dense patches.
• Cut-stump treatment, where herbicide is applied directly to the freshly cut surfaces of shrubs or trees.
• Wick or dauber application, in which herbicide is directly wiped onto plant tissue.
Herbicide must only be used for the complete eradication of EIPS-listed species. The EIPS list, incorporated by reference in Appendix 1, is subject to change based on evolving science, regional monitoring, or regulatory guidance.
All applications must comply with the following:
• A licensed Pest Control Advisor (PCA) must issue a written recommendation prior to application.
DRAFT Addendum to the Laguna Beach Fuel Modification Treatment Protocol: Targeted Herbicide Application Limited to Orange County California Native Plant Society Emergent Invasive Plant Species
• A Qualified Applicator (QAL), certified by the California Department of Pesticide Regulation, must supervise the application.
• All personnel engaged in herbicide application or handling are required to complete Pesticide Handler SafetyTraining as mandated by the California Department of Pesticide Regulation annually.
• Only products registered for use in California may be applied, and only in accordance with EPA labeling, site-specific recommendations, and applicable laws.
Application records must include the chemical used, concentration, method of application, total area treated, weather conditions, and any observed impacts to non-target species. These records shall be included in the City’s annual fuel modification report and submitted to regulatory agencies, as required.
Herbicide Exclusionary Zones
The City of Laguna Beach shall establish and enforce exclusionary zones within fuel modification areas where herbicide prohibited unless authorized under the Exceptions to Exclusionary Zones provision. The following zones shall apply:
1. Trails
A minimum buffer of 30 feet shall be maintained between any herbicide application within a fuel modification zone and the edge of any publicly accessible and legally designated hiking or recreational trail.
2. Schools and Childcare Facilities
A minimum buffer of 100 feet shall be maintained between any herbicide application within a fuel modification zone and the property line of any public or private school or licensed childcare facility.
3. Parks
A minimum buffer of 50 feet shall be maintained between any herbicide application within a fuel modification zone and the boundary of any public park.
4. Streetways
A minimum buffer of 50 feet shall be maintained between any herbicide application within a fuel modification zone and the edge of any public street or right-of-way.
5. Waterway and Streams
A minimum buffer of 50 feet shall be maintained between any herbicide application within a fuel modification zone and the edge of any waterway or stream.
Vegetation management within these areas shall be limited to non-chemical methods, including but not limited to manual removal, mechanical treatment, and grazing.
DRAFT Addendum to the Laguna Beach Fuel Modification Treatment Protocol: Targeted Herbicide Application Limited to Orange County California Native Plant Society Emergent Invasive Plant Species
Contractors and licensed applicators shall be informed of these exclusionary zones prior to initiating work.
Exceptions to Exclusionary Zones
While mechanical treatment will remain the primary method for addressing EIPS-listed species, certain plants may require targeted herbicide application for eradication. In most cases, the Orange County California Native Plant Society provides a treatment protocol to contain newly introduced species. Upon identification of an EIPS-listed species within an exclusionary zone, staff will present a treatment plan for the affected area to the City Council at a publicly noticed meeting and seek authorization to proceed if herbicide is recommended.
Private Property Opt-Out Procedure
Private property owners within or adjacent to a Fuel Modification Zone may formally request exclusion from herbicide application on their property. The City shall honor such requests provided the property owner submits a written opt-out request prior to scheduled treatment.
If the property owner does not maintain invasive species to the City's performance standard, the City reserves the right to initiate weed abatement notice which is subject to regulatory requirements outlined in the Laguna Beach Municipal Code.
Weather Restrictions
Herbicide shall not be applied under the following conditions:
• Wind speeds exceed 10 miles per hour;
• Rainfall is occurring or greater than ½ inch is forecast with a probability exceeding 30 percent chance within 72 hours;
• Soil saturation or runoff conditions exist that could result in surface water transport of the compound.
Public Notice Requirements
Prior to herbicide application, the City shall:
• Post notice on-site at least one week in advance;
• Notify adjacent properties by posting, door hanger, or mailed notice at least one week in advance.
Each notice shall include:
• Proposed date and time of application;
• Name and type of herbicide;
• Brief statement of purpose;
• Contact information for the City representative overseeing the application.
Documentation and Reporting
Each herbicide application shall be recorded in a treatment log, including:
• Date, time, and location;
DRAFT Addendum to the Laguna Beach Fuel Modification Treatment Protocol: Targeted Herbicide Application Limited to Orange County California Native Plant Society Emergent Invasive Plant Species
• Name and concentration of herbicide;
• Name and license number of the applicator;
• Application method;
• Weather conditions;
• Observations on effectiveness and off-target impacts.
These records shall be submitted as part of the City’s annual fuel modification report to regulatory agencies, as required.
DRAFT Addendum to the Laguna Beach Fuel Modification Treatment Protocol: Targeted Herbicide Application Limited to Orange County California Native Plant Society Emergent Invasive Plant Species
Appendix 1 –
Orange County California Native Plant Society Emergent Invasive Plant Species List Low score = greater invasive threat
This is current as of August 12, 2025, and is subject to change. A current list will be posted on the City’s website as changes occur.
Scientific Name Common Name Score
Brassica fruticulosa Mediterranean cabbage 1.21
Galenia pubescens Coastal galenia 1.31
Cenchrus longispinus Mat sandbur 1.64
Osteospermum
calendulaceum
Stinking Roger 1.64
Cenchrus echinatus Southern sandbur 1.71
Elymus ponticus Tall wheat grass 1.79
Volutaria tubuliflora North African knapweed 1.86
Chrysanthemoides
monilifera
Bitou bush 2.00
Hypericum canariense Canary Island St. John's wort 2.36 Senecio angustifolius Bitterbos 2.36
Centaurea diluta Spotted knapweed 2.50
Parthenium hysterophorus Santa Maria feverfew 2.57
Dipogon lignosus Okie bean 2.64
Centaurea solstitialis Yellow starthistle 2.71
Rubus armeniacus Himalayan blackberry 3.00
Euphorbia terracina Geralton carnation weed 3.07