STAFF REPORT
Meeting Date:
April 28, 2026
STUDY SESSION
1 SUBJECT: POLICY CONSIDERATIONS FOR DEVELOPMENT IN THE VERY HIGH FIRE
HAZARD SEVERITY ZONE
RECOMMENDATION: It is recommended that the City Council:
1. Provide policy direction regarding development within the Very High Fire Hazard Severity Zone and direct staff to return at a future Council meeting with a proposed policy and ordinance documents to carry out the City Council’s direction; and
2. Determine that the action is not a project under the California Environmental Quality Act (CEQA) pursuant to CEQA Guidelines Section 15378, as the action consists of receiving information and providing policy direction and does not authorize any physical change to the environment.
SUMMARY OF THE MATTER
Staff is seeking policy direction regarding development within the Very High Fire Hazard Severity Zone (“VHFHSZ”). Based on the direction received, staff will return at a future Council meeting with the appropriate policy and ordinance documents for City Council review and adoption.
DISCUSSION
The recent Palisades and Eaton Fires highlight the risks faced by many communities throughout Southern California and serve as a reminder of the importance of regularly evaluating and updating the City’s policies to anticipate and mitigate potential risks. Doing so helps ensure the City is planning proactively, remaining prepared, and adapting to current trends and best practices. Approximately 87% of the City falls within the VHFHSZ, as defined by the California Department of Forestry and Fire Protection (CAL FIRE), which is the highest wildfire risk classification.1 While much of this land area coincides with the City’s surrounding open space “green belt,” approximately 65% of the City’s buildable property is within the VHFHSZ. In light of this fact, and recognizing the dynamic and evolving risks that wildfires present to our community, staff has evaluated the City’s existing policies and regulations and identified opportunities for improvement.
Staff has organized its analysis and recommendations into four key areas: Legal, Planning, Fire, and Public Works.
Legal
Current Process. Under the City’s Municipal Code, the City adopts the 2025 California Fire Code, including Chapters 1-80 and Appendix Chapter 4, and Appendices B, BB, C, CC, D, H, and K, by reference with certain local amendments. (See LBMC Section 15.01.010.) Accordingly, a development application must comply with the Fire Code or, if not, request an Alternative Materials and Methods (AM&M), which is considered by the fire official and approved if it can be demonstrated that the AM&M is as effective in 1 The City’s interactive GIS map viewer can be accessed through the following web link. To view the extent of the VHFHSZ within the City, click “Layers” in the left-hand window pane, expand the menu for “Fire” by clicking the plus icon to the left, and click the “Fire Hazard Severity Zones” checkbox.
https://gis.lagunabeachcity.net/Html5Viewer/index.html?viewer=LagunaBeachPublicGIS
POLICY CONSIDERATIONS FOR DEVELOPMENT IN THE VERY HIGH FIRE HAZARD
SEVERITY ZONE
April 28, 2026
addressing fire risks as the Fire Code requirement. As a local amendment, under the City’s Municipal Code, the City requires a certain fire protection plan when developing in the VHFHSZ. (See LBMC Section
14.70.045.) Below are the City’s requirements for a fire protection plan, which requires compliance with the 2019 City of Laguna Beach Fire Department Landscape/Fuel Modification Standards and Maintenance Program document (Attachment 1):
SECTION 602—FIRE PROTECTION PLANS
602.1 General.
The code official is authorized to require the owner or owner’s authorized agent to provide a fire protection plan. The fire protection plan shall be prepared to determine the acceptability of fire protection and life safety measures designed to mitigate wildfire hazards presented for the property under consideration.
The fire protection plan shall be prepared by a registered design professional, qualified landscape architect, qualified fire safety specialist or similar specialist acceptable to the code official and shall analyze the wildfire risk of the building, project, premises or region to recommend necessary changes.
The code official is authorized to require a preliminary fire protection plan prior to the submission of a final fire protection plan.
602.2 Contents
The Fire Protection Plan shall contain the requirements set forth in the 2019 City of Laguna Beach Fire Department Landscape/Fuel Modification Standards and Maintenance Program document as amended from time to time by City Council and pursuant to Resolutions 89.104, 1640, and 1641.
Future Consideration. The City Council may consider amendments by City Council resolution to amend 2019 City of Laguna Beach Fire Department Landscape/Fuel Modification Standards and Maintenance Program document to address its policy. The City Council may also consider imposing conditions of approval on an ad hoc basis (per project) or by legislative action (ordinance with general applicability) to require land dedications to construct public improvements or traffic safety, subject to findings. Indeed, a city is authorized, as relevant here, to (1) impose a land dedication3 requirement to construct public improvements, including but not limited to, sidewalk and sewer improvements; and (2) impose a land dedication4 requirement as a condition of approval of a specific housing development project for traffic safety features, if the city makes a finding, specific to the housing development project and supported by substantial evidence, that the land dedication requirement is necessary to preserve the health, safety, and 3 “Land dedication” means a physical exaction of property for public use without compensation, whether imposed on an ad hoc or legislative basis, that is charged by a local agency to the applicant in connection with approval of a development project for the purpose of defraying all or a portion of the cost of public facilities related to the development project. (Gov. Code Section 66005.1(d)(2).) 4 Same definition as above.
POLICY CONSIDERATIONS FOR DEVELOPMENT IN THE VERY HIGH FIRE HAZARD
SEVERITY ZONE
April 28, 2026
welfare of the public, including pedestrians, cyclists, and children.7 In analyzing conditions of approval, whether imposed on an ad hoc basis or legislative basis, a city must consider the nexus and rough proportionality of the condition. First, permit conditions must have an “essential nexus” to the city’s landuse interest. The nexus requirement ensures that the city is acting to further its stated purpose and not leveraging its permitting authority to exact private property without paying for it. Second, permit conditions must have “rough proportionality” to the development’s impact on the land-use interest. A permit condition that requires a landowner to give up more than is necessary to mitigate harms resulting from new development has the same potential for abuse as a condition that is unrelated to that purpose. Additionally, among other actions, the City Council may consider changes to existing City policies established through the Planning Division of the Community Development Department, Fire Department, and Public Works Department, as discussed in more detail below.
Planning
The City of Laguna Beach is largely built out. As a result, the vast majority of development consists of infill redevelopment, remodels, and additions to existing structures, with a much smaller amount involving the development of vacant parcels. In both cases, the zoning entitlement review process is the City’s opportunity to ensure that development is constructed in compliance with current local and state regulations and is consistent with best safety practices. While additional reviews for Fire Code compliance will occur during the building permit application process that follows the zoning entitlement, many requirements are checked and confirmed during the zoning process, particularly those that are fundamental to site planning, such as firefighter path-of-travel requirements around the perimeter of structures and when applicable, fire apparatus access requirements.
While many aspects of a project are reviewed as part of the entitlement process, fire access and safety remain among the most critical considerations. Because development patterns throughout the City evolved organically and are often irregular, project sites have historically been evaluated on a case-by-case basis.
By contrast, in many surrounding communities characterized by tract development, life safety issues can often be addressed more comprehensively at the master planning level. Laguna Beach also consists of many small and distinct neighborhoods, each with its own development history shaped by the period in which it was generally built and by its particular physical setting . Those conditions vary considerably across the city, including differences in topography, roadway design, and neighborhood layout. In staff’s view, this process requires some updating to better address the cumulative fire safety impacts associated with development throughout the City.
For example, it is not uncommon for a project, such as a single-family home, to request AM&M’s, which allow project modifications that differ from standard fire safety code requirements while still ensuring the safety of the property. When considered individually, staff is often able to support these requests because the alternative fire protection measures provided are equally effective.
However, staff’s concern, and the reason policy direction is being requested, is that this approach has led to a “patchwork” of fire mitigation measures that, while providing project-specific safety benefits, do not 7 Gov. Code Section 66005.1(c)(2).
POLICY CONSIDERATIONS FOR DEVELOPMENT IN THE VERY HIGH FIRE HAZARD
SEVERITY ZONE
April 28, 2026
address the City’s broader fire protection needs on a citywide basis. For this reason, staff recommends shifting away from the use of AM&Ms except in very limited and unique circumstances, and instead establishing a more prescriptive and objective set of fire safety criteria.
This shift in approach would help ensure that, as projects are incrementally developed over time, the City can achieve a framework for broader improvements, such as roadway widening to improve fire access.
Additional information regarding these access requirements is provided under the Fire and Public Works sections below.
Should the Council wish to move forward with some or all of staff’s policy recommendations, it will be important to establish clear triggers for when the new standards would apply. For example, staff does not recommend applying these requirements to minor improvements or additions, as it is important for community members to be able to maintain and reinvest in their homes. However, when a property undergoes what is defined as a major remodel, involving more than 50 percent demolition or more than 50 percent expansion,9 or when a new home is constructed, staff recommends that those circumstances trigger the Fire and Public Works standards outlined below.
Fire
Staff recommends establishing prescriptive access standards that do not allow for flexibility or modification through Alternative Means and Methods, including requirements for roadway width, maximum grades, and the provision of adequate turnarounds. These elements are fundamental to ensuring reliable emergency access and evacuation capabilities and are therefore not well-suited for case-by-case adjustments.
Maintaining consistent, objective standards for these critical access components is essential to establishing a baseline level of fire and life safety throughout the community. While flexibility may be appropriate for certain design elements, access-related requirements should not include the same flexibility as they directly impact emergency response times, firefighter safety, and the ability of residents to evacuate during a wildfire event. As such, deviations from these standards can introduce cumulative risks when considered across the broader development pattern of the City.
By applying uniform requirements moving forward, the City can incrementally improve its overall emergency access network as properties are redeveloped over time. This approach ensures that individual projects contribute to a more cohesive and resilient system, rather than perpetuating inconsistent conditions that may compromise public safety during emergency situations.
To improve community-wide wildfire resilience and ensure safe, reliable emergency response, the Fire Department recommends enforcing objective, prescriptive access and operational standards for development within the VHFHSZ, consistent with the 2025 California Fire Code Appendix D. 9 Refer to the Major Remodel Interpretation handout for the methodologies used to determine when a project reaches the threshold of a major remodel. The handout can be accessed through the following web link. https://www.lagunabeachcity.net/home/showpublisheddocument/23171/638901125715200000
POLICY CONSIDERATIONS FOR DEVELOPMENT IN THE VERY HIGH FIRE HAZARD
SEVERITY ZONE
April 28, 2026
Fire Apparatus Access Road Width
Minimum 20-foot unobstructed width shall be maintained at all times. Width shall be continuous along the entire access route with no reductions or pinch points. No deviations recommended: width reductions restrict fire apparatus access, limit staging capability, and create conflicts with civilian evacuation. Further, cumulative reductions degrade system-wide access.
Roadway Grade (Slope)
Maximum roadway grade shall not exceed 10 percent.
Grade shall be consistent with smooth transitions.
No deviations recommended: increased grades reduce apparatus performance, braking ability, and safety, especially when combined with other constraints.
Turning Radius / Apparatus Maneuvering
Access roads shall support fire apparatus turning movements without multi-point maneuvers. Turning geometry shall be demonstrated through a turning analysis. No deviations recommended: multi-point turning delays response and creates operational conflicts.
Dead-End Roads and Turnarounds (CFC Appendix D §D103.1) Dead-end roads over 150 feet shall provide an approved turnaround. Cul-de-sac: Minimum 96-foot diameter.
Hammerhead (T-turn): Minimum 120-feet.
T-Turn: Minimum 60-foot legs.
Turnarounds must allow the apparatus to exit without reversing greater than 150 feet without meandering (obstructions).
No deviations recommended: non-compliant turnarounds increase entrapment risk and delay emergency response.
Engine Staging and Operational Positioning
• A compliant fire apparatus staging location shall be provided on an approved access road. • Staging areas shall be located on a relatively flat surface to allow safe apparatus positioning, stabilization, and hose deployment.
• Staging shall provide direct and reasonable access to the structure, without requiring firefighters to traverse excessive horizontal distances or steep slopes. • Site design shall ensure firefighters are not required to repeatedly travel up and down steep terrain to transport hose packs, tools, or rescue equipment.
• The distance between the fire apparatus and the structure shall be close enough to allow efficient deployment of equipment and sustained operations without excessive physical strain on personnel. • Staging locations shall allow apparatus to:
o Fully position without blocking access routes
o Deploy hose lines directly
POLICY CONSIDERATIONS FOR DEVELOPMENT IN THE VERY HIGH FIRE HAZARD
SEVERITY ZONE
April 28, 2026
o Exit the site without multi-point maneuvers
• No deviations recommended:
inadequate or improperly located staging areas increase response time, reduce operational effectiveness, and create unsafe working conditions. Requiring firefighters to operate over steep terrain or excessive distances leads to fatigue prior to fire attack, delays suppression efforts, and reduces overall incident effectiveness. These conditions present a direct life-safety risk to both firefighters and occupants.
Hose Pull and Firefighter Access
Maximum hose pull distance shall not exceed 150 feet. Access paths must be all-weather, non-combustible, and of adequate width and slope. No deviations recommended: extended distances delay suppression and increase firefighter fatigue.
Conclusion
These requirements function as an integrated system. Modifications to any single component creates cascading impacts on emergency response and evacuation. For this reason, staff does not recommend the use of Alternative Means and Methods for these core access features.
Public Works
The City’s streets and rights-of-way play a critical role in providing fire access to properties throughout the City, as well as evacuation routes for residents. Given the importance of maintaining a safe and functional circulation system to the greatest extent feasible within a largely built-out community, staff recommends that when a project involves a major remodel or the construction of a new home, the roadway adjacent to the property, and/or the roadway providing the most immediate access to the property that is under the applicant’s control, be improved to City standards, be developed to facilitate future expansion within the right of way, and/or dedicate right of ways for future improvements. This approach is intended to ensure that, over time, cumulative street frontage improvements associated with individual projects can be consolidated into coordinated roadway widening and safety improvement efforts.
It is also the City’s current practice to issue Revocable Encroachment Permits (REPs), which allow limited improvements within the public right-of-way. In light of the need to take a more cumulative and long-term approach to roadway safety and to preserve opportunities for future widening projects, staff recommends that future REPs be limited to landscaping only. In addition, in the case of major remodels, if a property contains an existing REP, any improvements within the right-of-way beyond incidental landscaping should be removed as part of the project.
The City’s standard roadway width for a hillside local street is 20’ per Public Works Standard Plan 101.
Below is a depiction of what the standard roadway section should look like:
POLICY CONSIDERATIONS FOR DEVELOPMENT IN THE VERY HIGH FIRE HAZARD
SEVERITY ZONE
April 28, 2026
In several cases, the existing roadway limits the feasibility for a single property to construct a fully standard roadway in front of their property. For example, it may not be feasible to construct sidewalk, curb, and gutter in front of a single property if it does not exist on the rest of the street; however, it is recommended that in all cases the roadway be widened to provide the minimum 10’ of paved roadway from the centerline to the property. It is recommended that applicants be conditioned to dedicate right of way in cases where the right of way is less than 20’ from the centerline to the property line.
FINANCIAL ANALYSIS
The recommended action has no financial impact to the budget.
ENVIRONMENTAL ANALYSIS
The recommended action consists of receiving information and providing policy direction and does not authorize any physical change to the environment and therefore does not constitute a “project” within the meaning of the California Environmental Quality Act. (Public Resources Code Section 21065; 14 CCR Section 15378.). Any future action to adopt a policy, rule, or regulation will include compliance with CEQA.
POLICY CONSIDERATIONS FOR DEVELOPMENT IN THE VERY HIGH FIRE HAZARD
SEVERITY ZONE
April 28, 2026
ATTACHMENTS
1. 2019 Landscape/Fuel Modification Standards and Maintenance Program (Pgs. 9-32) Submitted By: Matthew Schneider Approved: Gavin Curran, for Matthew Schneider, Director of
Community Development
Dave Kiff, City Manager
Report Prepared By: Coordinated With:
Matthew Schneider, Director of Community
Development
Anthony Viera, Deputy Director of Community
Development
Jane Abzug, Assistant City Attorney
Robert Montaghami, Fire Marshal
Thomas Perez, City Engineer
Gabe Linares, Deputy Director of Community
Development