Sabha, Tamer
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From: Bridget Lawlor <
cityclerk
Tuesday, February 3, 2026 3:48 PM
Iraheta, Alba; Jomsky, Mark; Robles, Sandra; Sabha, Tamer; McMillan, Acquanette (Netta); Soo, Christine
FW: Zone Zero
ZoneZero_PH.pdf
Sent: Tuesday, February 3, 2026 3:47:32 PM (UTC-08:00) Pacific Time (US & Canada) To: cityclerk <[email protected]>
Subject: Zone Zero
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Please see our attached letter.
Best,
Bridget
PASADENA
HER IT AGE
PRESERVATION / ADVOCACY j EDUCATION
Bridget Lawlor, Ph.D.
Executive Director
160 N. Oakland Avenue Pasadena, CA 91101
www.pasadenaheritage.org
PASADENA
HERITAGE
PRESERVATION | ADVOCACY | EDUCATION
I (S NORTH OAKt.AND AVENUE
PASADENA. CALIFORNIA »1 )CII-!714
t> 41&.44! .4333 F S2S.44 1.2917
WWW.rASADENAHERITAGE.ORG
Dear Members of the Legislative Committee,
Pasadena Heritage shares the Legislature's commitment to protecting lives and communitiesfrom wildfire risk, particularly in the wake of recent devastating fires across California. We writeto express concern about the pending implementation of Zone Zero legislation as it is currentlyproposed, and to urge a more nuanced, science-based approach that reflects the realities of firebehavior in urban and historic communities such as Pasadena and Altadena.
Zone Zero was developed in response to catastrophic wildland fires, including the Tubbs Fire(2017) and the Paradise Fire (2018). However, its current framework relies on assumptions aboutfire spread that do not consistently align with conditions in built, suburban, and urbanneighborhoods. Increasingly, research and on-the-ground experience show that fires in thesesettings are largely structure- and ember-driven rather than vegetation-driven. As articulated byAltadena Green through public education efforts and community discussions, treating developedneighborhoods as if they were wildlands overlooks critical differences in ignition sources, fuel loads, and fire dynamics.
Evidence from the January 2025 Baton Fire in Altadena underscores the need for this distinction.Aerial imagery demonstrates that healthy, well-maintained trees and vegetation often survivedwhile adjacent structures burned. Large, high-moisture trees, including oaks, pines, and deodarcedars, frequently resisted ignition and likely reduced fire intensity by acting as windbreaksagainst ember showers. In many instances, vegetation that did burn appears to have been ignitedby nearby buildings, which bum hotter and provide significantly greater fuel loads thanlandscaping. Notably, many homes that had already removed surrounding vegetation still burned.
Pasadena Heritage supports common-sense fire safety measures, including the removal ofcombustible debris such as dead leaves and pine needles from yards and gutters, as well as themaintenance of defensible space. However, consistent with the position advanced by AltadenaGreen and other fire-ecology advocates, healthy, well-watered vegetation presents far less riskthan is often assumed and provides substantial protective and environmental benefits. Firemitigation policies should therefore prioritize strategies that directly address how fires spread inurban settings, including ember-resistant venting, fire-resistant roofing, non-combustible siding,double-pane windows, and targeted home hardening measures.
The widespread removal of vegetation adjacent to buildings would also create cascadingenvironmental and public health impacts. Loss of tree canopy and plantings, particularly thosethat shade walls and windows, would intensify urban heat islands, increase reliance on energy-intensive air conditioning, degrade air quality, and heighten flood risk through reduced waterabsorption and soil stabilization. These impacts would fall most heavily on communities already facing disproportionate climate burdens, undermining goals of environmental equity and climate resilience.
Zone Zero, as currently drafted, also conflicts with existing environmental standards, including CALGreen shade requirements for schools, and runs counter to broader climate adaptation strategies that recognize trees as essential infrastructure. Mature urban trees play a critical role in cooling neighborhoods, improving air quality, supporting biodiversity, and strengthening community resilience in the face of climate change.
Pasadena Heritage does not oppose defensible space requirements in principle. Rather, we urge an approach that reflects local conditions, scientific evidence, and the unique characteristics of mature, developed communities. Presently, the Board of Forestry has options within the proposed regulation that would better achieve these goals. Option 4 for vegetation and Option 2 for trees would provide meaningful defensible space while preserving the character, environmental benefits, and climate resilience of historic urban neighborhoods. Hydration and maintenance are essential components of risk reduction, and local knowledge and control are more appropriate than a blanket statewide standard.
The devastating fires of recent years demand thoughtful, evidence-based responses that protect lives while strengthening ecological and community resilience. Pasadena Heritage respectfully urges policymakers to advance fire mitigation strategies that align with climate adaptation principles, prioritize home hardening in urban areas, and recognize trees and healthy landscapes as essential components of safe, livable communities.
Thank you for your time and thoughtful consideration of this important issue.
Respectfully,
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Bridget Lawlor, Ph.D.
Executive Director
Pasadena Heritage