Sabha, Tamer
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Lauren Siegel <
Tuesday, February 3, 2026 1 :34 PM
Sabha, Tamer; Jomsky, Mark; McCloy, Lindsey Paige; Airitam, Derrick Legislative Committee, Zone O Letter from EAC
EAC - Final Zone O Memorandum to City Council.pdf
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Hi Mark,
I just wanted to make sure the EAC Zone O Letter was part of the packet and posted for the Legislative Committee today, as it is agendized. I don't see it but maybe I am missing something. It is attached as well.
Thanks,
Lauren
Lauren Siegel
MS Sustainable Development and Resource Management
Pasadena Environmental Advisory Commissioner
MEMORANDUM
From: Pasadena Environmental Advisory Commission
Date: October 25, 2025
To: Members of the Pasadena City Council and Municipal Services Committee Subject: Zone 0 Recommendation
Executive Summary
The Pasadena Environmental Advisory Commission (EAC) recommends the following distinctions to the proposed State regulations, based on research conducted by the City of Los Angeles Forestry Commission:
1. Allow flexibility for the Pasadena Fire Department and its inspectors to implement fire severity zones based on Local conditions.
2. Exempt all well-maintained vegetation and trees from mandatory removal, and establish an appeal process.
3. Recommend regionally appropriate vegetation management practices that preserve and restore native species, prioritize fire-adapted natives where appropriate, and emphasize maintenance and irrigation.
4. Explicitly exempt locally protected native trees and shrubs from all new regulations.
5. Explicitly exempt well-maintained historic gardens and heritage trees.
6. Prohibit the use of artificial turf within defensible space areas, as artificial turf generates extreme heat and emits toxic fumes when ignited, posing health risks to first responders.
Background
On June 23, the Pasadena City Council adopted Fire Hazard Severity Zone maps that empowerthe Pasadena Fire Departmentto mitigate wildfire risks while maintaining ecological health. The maps establish zones with increasing levels of protection and spacing requirements to prevent wind-driven fires from spreading between buildings, as seenduringthe Eaton Fire on January?.
The California Board of Forestry now proposes adding a new "Zone O," which would prohibit nearly all trees, shrubs, lawns, ground vegetation, and artificial turf within five feet of any structure, with limited exceptions. This shifts the focus from an "ember-resistant zone" to a "non-combustible zone," a change that has generated significant concern. The statewide regulation would override local ordinances and fail to account for local vegetation, housing density, and wind conditions.
Public and Regional Response
The Board of Forestry has held statewide hearings on Zone 0, including a September 1 8 meeting at the Pasadena Civic Auditorium where hundreds of residents expressed concern following the Eaton Fire. Commissioners from the EAC have attended these sessions and consulted with fire prevention and sustainability experts, including Nurit Katz of UCLA, to evaluate the scientific basis of the proposal.
On October 7, the Los Angeles City Council, supported by the Los Angeles Fire Department and Los Angeles Urban Forest Advisory Committee (UFAC), voted unanimously to oppose Zone 0, citing the loss of local control and negative impacts on urban canopy, heat mitigation, and environmental health. On October 21, the Ventura County Board of Supervisors also unanimously opposed the proposal, urging restoration of local control and funding for regionally adaptable implementation.
Pasadena EAC Position
The EAC recommends that the Pasadena City Council take a similar position opposing the proposed Zone 0 regulation and maintaining local control underthe Pasadena Fire Department to preserve well-managed trees and vegetation and uphold existing local ordinances.
Key Impacts of Zone 0
Loss of Natural Protections: Trees reduce wind, capture embers, retain soil moisture, and stabilize hillsides which are critical protections against post-fire erosion, landslides and drought.
Loss of Tree Canopy and Increased Heat: Removing all vegetation within five feet of structures would significantly reduce Pasadena's tree canopy, increase temperatures, energy use, and urban heat island effects.
Environmental Justice Impacts: Low-income neighborhoods with smaller lots and closely spaced buildings would be disproportionately affected by increased heat and reduced shade.
Loss of Biodiversity and Habitat: Vegetation removal would diminish biodiversity and wildlife habitat, weakening ecological resilience.
Scientific Evidence: Research from the LA UFAC shows structure separation—not vegetation separation—is the key factor in preventing structure-to-structure wildfire spread.
Heritage and Identity: Pasadena's "Tree City" status and its historic landscapes, including the Tournament of Roses, La Casita Del Arroyo, and the Gamble House, would be at risk.
Financial Burden: Removal of trees and vegetation across municipal, residential,and commercial properties would impose significant costs on property owners and the City.
The Pasadena Environmental Advisory Commission urges the City Council to support alocally adaptive approach to wildfire resilience that safeguards public safety whilepreserving Pasadena's ecological and cultural heritage. The proposed statewide "Zone0" regulation imposes a one-size-fits-all standard that overlooks local conditions andproven fire management practices. By maintaining local authority, Pasadena cancontinue applying science-based strategies that reduce fire risk, protect its tree canopy,and uphold the city's identity as a leader in sustainable urban stewardship.
Appendices:
The new Fire Hazard Severity Maps are divided into zones with increasing levels of protection and distance from buildings:
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1.2 Sabha, Tamer
From:
Sent:
To:
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Jessica Richards -^
Tuesday, February 3, 2026 1:35 PM
Sabha, Tamer
EAC letter re Zone Zero for 2/3 legislative meeting
EAC - Final Zone 0 Memorandum to City Council.pdf
You don't often get email fromLearn why this is important WWSiS^S|;ii;B;!3;|;w^ffi^^
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Please distribute this letter written by Pasadena's EAC as well. Thank you, Jessica Richards
MEMORANDUM
From: Pasadena Environmental Advisory Commission
Date: October 25, 2025
To: Members of the Pasadena City Council and Municipal Services Committee Subject: Zone 0 Recommendation
Executive Summary
The Pasadena Environmental Advisory Commission (EAC) recommends the following distinctions to the proposed State regulations, based on research conducted by the City of Los Angeles Forestry Commission:
1. Allow flexibility for the Pasadena Fire Department and its inspectors to implement fire severity zones based on local conditions.
2. Exempt all well-maintained vegetation and trees from mandatory removal, and establish an appeal process.
3. Recommend regionally appropriate vegetation management practices that preserve and restore native species, prioritize fire-adapted natives where appropriate, and emphasize maintenance and irrigation.
4. Explicitly exempt locally protected native trees and shrubs from all new regulations.
5. Explicitly exempt well-maintained historic gardens and heritage trees.
6. Prohibit the use of artificial turf within defensible space areas, as artificial turf generates extreme heat and emits toxic fumes when ignited, posing health risks to first responders.
Background
On June 23, the Pasadena City Council adopted Fire Hazard Severity Zone maps that empower the Pasadena Fire Department to mitigate wildfire risks while maintaining ecological health. The maps establish zones with increasing levels of protection and spacing requirements to prevent wind-driven fires from spreading between buildings, as seenduringthe Eaton Fire on January?.
The California Board of Forestry now proposes adding a new "Zone O," which would prohibit nearly all trees, shrubs, lawns, ground vegetation, and artificial turf within five feet of any structure, with limited exceptions. This shifts the focus from an "ember-resistant zone" to a "non-combustible zone," a change that has generated significant concern. The statewide regulation would override local ordinances and fail to account for local vegetation, housing density, and wind conditions.
Public and Regional Response
The Board of Forestry has held statewide hearings on Zone 0, including a September 1 8 meeting at the Pasadena Civic Auditorium where hundreds of residents expressed concern following the Eaton Fire. Commissioners from the EAC have attended these sessions and consulted with fire prevention and sustainability experts, including Nurit Katz of UCLA, to evaluate the scientific basis of the proposal.
On October 7, the Los Angeles City Council, supported by the Los Angeles Fire Department and Los Angeles Urban Forest Advisory Committee (UFAC), voted unanimously to oppose Zone 0, citing the loss of local control and negative impacts on urban canopy, heat mitigation, and environmental health. On October 21, the Ventura County Board of Supervisors also unanimously opposed the proposal, urging restoration of local control and fundingfor regionally adaptable implementation.
Pasadena EAC Position
The EAC recommends that the Pasadena City Council take a similar position opposing the proposed Zone 0 regulation and maintaining local control underthe Pasadena Fire Department to preserve well-managed trees and vegetation and uphold existing local ordinances.
Key Impacts of Zone 0
Loss of Natural Protections: Trees reduce wind, capture embers, retain soil moisture, and stabilize hillsides which are critical protections against post-fire erosion, landslides and drought.
Loss of Tree Canopy and Increased Heat: Removing all vegetation within five feet of structures would significantly reduce Pasadena's tree canopy, increase temperatures, energy use, and urban heat island effects.
Environmental Justice Impacts: Low-income neighborhoods with smaller lots and closely spaced buildings would be disproportionately affected by increased heat and reduced shade.
Loss of Biodiversity and Habitat: Vegetation removal would diminish biodiversity and wildlife habitat, weakening ecological resilience.
•
•
Scientific Evidence: Research from the LA UFAC shows structure separation—not vegetation separation—is the key factor in preventing structure-to-structure wildfire spread.
Heritage and Identity: Pasadena's "Tree City" status and its historic landscapes, including the Tournament of Roses, La Casita Del Arroyo, and the Gamble House, would be at risk.
Financial Burden: Removal of trees and vegetation across municipal, residential, and commercial properties would impose significant costs on property owners and the City.
The Pasadena Environmental Advisory Commission urges the City Council to support a locally adaptive approach to wildfire resilience that safeguards public safety while preserving Pasadena's ecological and cultural heritage. The proposed statewide "Zone 0" regulation imposes a one-size-fits-all standard that overlooks local conditions and proven fire management practices. By maintaining local authority, Pasadena can continue applying science-based strategies that reduce fire risk, protect its tree canopy, and uphold the city's identity as a leader in sustainable urban stewardship.
Appendices:
The new Fire Hazard Severity Maps are divided into zones with increasing levels of protection and distance from buildings:
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Exterior Siding
Year Built
Flame Length
Ember Deposited
Roof Construction
Vent Screen
VSD
Window Pane
Eaves
+0.96
+0.78
+0.67
+0,46
+0.46
+0.45
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Sabha, Tamer
From:
Sent:
To:
Subject:
Attachments:
Jessica Richards
Tuesday, February 3, 2026 1:33 PM
Sabha, Tamer
Legislative committee written comment 2/3 Zone Zero - please distribute Pasadena-Altadena-ZZ-coalition-letter-final_signed-logos adds.pdf You don't often get email frorr,Learn why this is important [,ills ] CAUTION: This email was delivered from the Internet. Do not click links or open attachments unless you know the content is safe. Report phish using the Phish Alert Button. For more information about the Phish Alert Button view article "KB0011474" on the DolT portal.
Thank you for taking up this critical issue. Yes, we want to mitigate fire risk and we need to follow independent research to guide those policies.
The Board of Forestry is poised to handover more powerto the private insurance industry that is already wrecking havoc on the Lives of Californians. I am hoping you will stand up for the residents of Pasadena.
The Board strongly favors the insurance industry Grafted option 1 for plants requiring all vegetation be removed in the area immediately around one's home and replace it with gravel, concrete, pavers, etc. 10 potted plants in 5 gallon or less noncombustible pots with plants less than 18" tail and separated by a distance of at least 1 8" and kept away from doors, vents and windows. So what do the relevant, independent experts say about this?
Each week, Nurit Katz, Director of Sustainability for UCLA hosts a call featuring a diverse array of experts from across the state. I have been listening to these calls. After months and dozens of experts sharing research and testimony what is clear is that the most stringent Option 1 is not supported by the experts.
In fact, it is unanimous. So why then would the Broad of Forestry ignore California's own expertise, independent, double-peer reviewed science? I'LL leave that for you to ponder but I'LL mention that on a recent call Sasha Renee Perez shared the insurance lobby is the most powerful in Sacramento. They argue these regulations are necessary but provide no assurance that homeowners will be insured if they rip out all vegetation (the estimated cost is over $1 5k per home). These draconian regulations, if enacted, will make homes in the very high risk fire severity zone hotter, drier, destabilize hillside slopes, decrease habitat, and increase energy costs. The insurance industry is scapegoating plants and creating a justification to deny claims and drop coverage if a single potted plant is out of place. Research shows other factors such as home hardening and proximity to the next structure are the most significant risk factors.
I implore you, like Los Angeles and Glendale, to codify Option 4 for plants allowing for healthy vegetation but removing the most risky components and Option 2 for trees to protect our iconic urban canopy while pruning away from chimneys. These options are consistent with what I've heard from dozens of experts and reduce risk by removing the agreed upon and research-backed factors such as wood piles and attached wood fences.
Thankyou.
Jessica Richards
P.S. I'm attaching a coalition letter signed by six community associations regarding Zone Zero please distribute as well to the committee.
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LINDA VISTA / ANNANDAS.E ASSOCIATION
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HERITAGE
PRESERVATION ! ADVOCACY I EDUCATION
4 December 2025
State Board of Forestry and Fire Protection
715P Street, 10th Floor
Sacramento, California
Re: Zone 0 Regulation
Dear Chair and Members,
Our neighborhood organizations represent thousands of Pasadena and Altadena households living in residential neighborhoods designated as Very High Fire Hazard Severity Zones and allied neighborhoods who strongly oppose the blanket removal of healthy, maintained, and hydrated vegetation within five feet of structures.
We appreciate the opportunity to provide formal comment on the California Board of Forestry and Fire Protection's proposed regulations for the "Zone 0" ember-resistant zone within five feet of structures in fire-prone areas.
We strongly support the State's goal of enhancing community wildfire resilience. However, we urge the Board to adopt an approach that allows flexibility for local jurisdictions and reflects regional differences unique to Southern California's urban Wildland-Urban Interface (WUI).
We strongly urge that the Board adopt Vegetation Option 4 and Tree Option 2 as presented in the October 23, 2025 draft rule package.
Vegetation Option 4 - Well-Maintained Plants Allowed
Option 4 provides the appropriate balance between safety and ecological stewardship. This approach allows potted and in-ground vegetation that is well-maintained and hydrated while prohibiting dead or combustible materials, such as dry weeds or wood mulches.
This method aligns with science-based research (Escobedo et al, 2025) showing that plant health and moisture content—not the mere presence of greenery—are key predictors of fire spread.
Healthy vegetation can also provide cooling benefits, erosion control, and protection against wind-driven embers, which are especially relevant in Pasadena's and Altadena's hillside communities.
1 Tree Option 2 - Well-Maintained Trees with Clearances Tree Option 2 provides a reasonable standard that maintains appropriate clearance from chimneys and roofs while recognizing the importance of trees in urban areas. Trees play a critical role in heat mitigation, erosion control, air quality, and the provision of habitat. Our community supports this approach as it maintains safety without imposing unnecessary removals that could harm biodiversity or conflict with local tree ordinances.
Preserve Local Authority within the Local Responsibility Area (LRA) We also strongly urge the Board to allow local control within LRAs, consistent with the "alternatives" language included in the draft rule.
Local discretion ensures that defensible space policies are effective, enforceable, and compatible with existing municipal codes, environmental protections, historic preservation ordinances and community expectations.
If the Boards finds that a single set of regulations is desired, then the least restrictive options (options 4 and 2) are advisable to prevent ecologically and financially costly regulatory overreach.
Financial burden and Insurability
Many homes were only recently added to Very High Fire Hazard Severity Zones. Zone 0 imposes costly, unfunded mandates on residents and local governments. Risk of mandatory clearances, fines and liens presented by these regulations are a burden to local municipalities and homeowners.
These regulations, while framed as boosting insurability, do not guarantee coverage. After thousands of dollars ($13,000 average cited by BOF) are spent to comply, there is no assurance that insurance carriers will provide coverage. These regulations will increase insurance challenges for homeowners who will face additional, costly hurdles to potentially gain coverage.
The challenges related to insurance coverage in California are very real and complex but should be navigated through separate legislation.
Conclusion
As residents in the Very High Risk Fire Severity Zones and adjacent areas, we share the goal of wildfire risk reduction through home hardening, vegetation management, and community education. We respectfully request that the Board of Forestry:
1. Adopt Vegetation Option 4 and Tree Option 2 as part of the final Zone 0 rule; and
2. Preserve local control and flexibility for LRA jurisdictions to apply tailored compliance approaches through local fire departments.
3. Ensure any further regulations or guidelines shall have full, statewide representation.
Only having a northern California technical advisor minimizes the significant differences of Southern California neighborhoods and further discounts the geographic, and 2 environmental differences across our great state. A technical advisory committee that is representative of the whole state with scientists from more than one county is essential to developing a comprehensive and well-crafted policy to address the challenges we face.
We urge the Board to prioritize scientific integrity and local consultation over speed, ensuring that regulatory deadlines do not override the call for a more thoughtful, locally informed approach. Additionally, passage ofAB 1455 must not impose a rushed implementation with costly consequences.
Thank you for considering our feedback on this critical matter. We appreciate the Board's continued collaboration with local municipalities and local fire agencies in developing practical, balanced, science-informed defensible space regulations that improve safety while protecting the environment.
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Annette Yasin
President, Bungalow Heaven Neighborhood Association
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Jonathan Langager
Chair, Garfield Heights Neighborhood Association
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Michael D. Bicay, Ph.D.
President, AltadenaWILD Inc.
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Eric Kern
President, LVAA Linda Vista/Annandale Association
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David Quigg
President, San Rafeal Hills
'Bridget Law lor
Bridget Lawlor, Ph.D.
Executive Director, Pasadena Heritage
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