Sabha, Tamer
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Harvey-Williams, Brenda
Monday, March 2, 2026 5:29 PM
Jomsky, Mark; Martinez, Ruben
Sabha, Tamer
FW: Pasadena Beautiful weighs in on Zone Zero
PBF position on Zone Zero.pdf
hli Ruben, please include this with public comment forthe April Leg. Policy meeting.
Thanks,
Brenda E. Harvey-WUliams
Assistant City Manager
626-744-3718
[email protected]
CALIFORNIA • WWW.CITYOFPASADENA.NET
From: Sara Edwards-
Sent: Monday, March 2, 2026 4:07 PM
To: Harvey-Williams, Brenda <[email protected]> Subject: Pasadena Beautiful weighs in on Zone Zero
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Attention office of the City Manager:
Attached is our position paper on Zone Zero. Please read. We will be at the Legislative meeting Tuesday March 3.
Regards,
Sara Edwards
PBF President
Sara Edwards
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Tresideut - - Sara£(ftvards
Vice President - - Susan Osen
Secretary - - Patticia Lyon &
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Truasujer •— Jo]m Paer
Past Pj'esident
Oses King
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ChuAI.iviTigstooe
Tree Program Chan-
Emina Dsa-atgy
Susteuiabili^- Chair
JoanAarestad
Board ufDirwtora
Atidiea Atanay
Robin Bwks
IIilaiy Ciark
Bettt Cooper
Dr.JeffClian
Brooke Larson t?ark>ck
rrJsullaOibbs
Kellty Holnies
CliRMdra King
Donna Lee
Vicki Lhfingstoi'E
Tricia Mad.aren
Mjehael Meeker
Suzi Miller
Kstherine Solaini
Dr. Stepbeii Tlurntun
Gahrisla Yariv
AdvSscfy Buurd
Martyfl Beimont
Max Breroian
George Brunxter
Nadme Danz
William Koelsch
AiidreaNagata
Gordon Padlgian
Caroi TJiomson
Betsey Tyler
Ten Weeks
Polly ^Tieaton
"Protecting Our Trees
ss
March 3, 2026
The Honorable Victor Gordo and Members of the City Council Pasadena City Council
Qrty of Pasadena
lOON.GarfieldAve.
Pasadena, CA 91101
Re: Stone Zero Implementation
Dear Mayor Gordo and Council Members:
As you taiow, the Pasadena Beautiful R)undaltion has long championed the protertion and expanaon erf trees and green space throughout our cfty. We have valued the opportunity to work ator^side many of you, as weH asour dedic^^ Parks and Recr^tton staff, to strer^then and sustain Pasadena's urtoan canopy, tn keeping with our mis^on, we wrfte to express serious concerns regardirg the pending implementation of the proposed Zone Zero legislation as it is currently drafted.
We tuUy stwe the GBy's GonMffBtm^* to yxcSef^Q lives and neighborhoods from wildfire risk. The devastating fires of January 2(]fi5, urtifch (testeoyed ttousands cf tMMnes and ctasned niuftipte (wes, underscore the urgency of thoughtful and effwtive fire prevention poltey. Public safety must remain paramount.
However, as currently written, the proposed Zone Zero standards are overly restrictive and risk uni'ntendecf consequences for Pa^dena's urban forest. Research on fire behavior in readCTtial areas consistently shows that structure ignition and winct-driven embers are the primary drivers of home toss, rather than weB-mainteuned vegetation. Polteies that focus narrowly on vegetation remowl, wittout equal emphasis on structure hardenirg and ember reastaree, may fail to address the rrost significant ri^<s.
Pasadena Beautiful respectfully urges the Council to consider IOCEU amerdments that reflect both fire science and Pasadena's unique urban charactor- We support practical, evidence-based fire safety measures, including:
Removal ot dead or highly combu^ibte veg^aUon
Routine diearirq of debris from yards, foots, and gutters-• printed on recycled paper
75 S. Grand Aveoue • Pasadena, CaJifomia 9i 105
Telephone; 626-795-9704 • Website; www.pasadenabeautifiil.oiig (t
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Pieaident - - Sara EAvards
Vice President -- SIISBB Osen
Secretary - - Patricia Lyon &
Joyce McGilvray
Tteasurer-- Jolin Paer
Past President
Grcg King
Noniinating
Brad Hanson
ExOfficioAtLaa-ge
Chvck l.wingstooe
Tree Program Chair
Eraina Darakjy
SisstainabitAy C'hair
JoanAarested
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Andrea Alanay
Robin Banks
IIilary Clark
Bette Cooper
DrJeffC'Aaa
Brooke Larson <5ark>ck
PrJseillaGibbs
Kdley liolraes
Chandra King
Donnal.ee
Vicld LivingslfMit!
Tricia Madsrw
Michael Meeker
SuziMiBer
Katheriiie Solaini
Dr. Stephen Tbomton
GabrielaYariv
Afiviscr}' Baarf
Uartyn Belmont
Max Breiman
George Bnmider
Nadme Danz
Wiffiam Koelsch
ABdrea Nagata
Gordon Pashgiail
Carol Thomson
Bstse}' Tyler
Ten Weeks
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•EJiminatton of flammable materials such as dry weeds and comtxisttote muteh nesr stnx^jres
Realistto, d^ensible space standa'ds Bidt prtoritize
maintenaree over wholesate veg^ation and tree removal
We also encourage alignment with the more balanced regulatory anMoadies umjer corBktCTatton t^ tt Bcwd <rf For^try. In particular, ojMtoi^ th^ aBow RMT weU-maintained, hyctrated wgst^ion uriTile requiring the removal of combustible debris represent a reasonable perth forward. Ttese approaches maintain safety standards—swh as aw)ropriate clearance from roofs and chimn^s—wNle recognizing the altica! rote that mature trees f<ay in urbai environments.
Healthy trees provide shade, reduce extreme heat. improve air quality, manage stormwater, and contribute significantly to neightxirhood charadter and propaly values. In a city increasingly wjner^ble to rising temperatures, preserving canopy cover is not merely aesthetic— it is a public heafth and climate resilience ^rat^y.
Fire prevention and tree preservation are not mutually exclusive goals.
With careful drafting and science-based standards, Pasadena can protect residents from wildfire risk while safeguardir^ the environmental and communtty beneftts that cteflne our city.
Pasadena Beautiful respectfutly urges the Coundl to advance fire prevention policies that recognisse trees and healthy landscapes as essential components of safe, resilient, and liveable communities.
Thank you for your time and thoughtful consideration of this important mertSw.
Re^*eGuuity^ r~^^\
Sara EQwards
Pt^fetWt
Pasa^ei^ Brartffd Rxjixlatton
printed on recycled paper
75 S. Grand Avenue • Pasadeiia, California 9i 105
Telephone: 626-795-9704 * Website: www.pasadenabeautiful.orgf- Sabha, Tamer
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Jessica Richards
Monday, April 6, 2026 9:13 AM
Harvey-Williams, Brenda; cityclerk; Sabha, Tamer
Legislative committee written comment 4/7 Zone Zero - please distribute Pasadena-Altadena-ZZ-coalition-letter-final_signed-logos adds.pdf; EAC - Final Zone 0 Memorandum to City Council.pdf
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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 power to 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 enforceable and consistent with what I've heard from dozens of experts and reduce risk by removing the agreed upon and research-backed factors such as dead vegetation, wood piles and attached wood fences.
Thankyou.
Jessica Richards,
Vice President of Bungalow Heaven Neighborhood Association and Urban Forestry Advisory Commissioner
(Writing in my personal capacity)
P.S. I'm attaching a coalition letter signed by six community associations regarding Zone Zero as well as the EAC'd advisory letter please distribute as well to the committee. eun'yaipw
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IM'illaUUS Wilw*1NEIGHBORHOODS ASSOCIATIONmm
I.'INDA VISTA / ANNANDALE ASSOCIATION
PASADENA
HERT A G E
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 - WelI-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-lVIaintained 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 B OF) 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 mshed 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 Lawlor
Bridget Lawlor, Ph.D.
Executive Director, Pasadena Heritage
3 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. Prohibitthe 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 seen during the Eaton Fire on January 7.
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 Baton Fire. Commissioners from the EAC have attended these sessions and consulted with fire prevention and sustainabitity 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 andfundingfor 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 under the 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 tots 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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Pasadena
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SHAP aggregation results characterizing the contribution of features for the entire (stacked) WUI data from five fires. SSD is short for Structure Seperation Defense. VSD is short for Vegetation Seperation Defense
Stacked WUt data
SSD
Exterior Siding
Year Built
Flame Length
Ember Deposited
Roof Construction
Vent Screen
VSD
Window Pane
Eaves
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