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August 26, 2026
The Honorable Monique Limón The Honorable Robert Rivas Senate President pro Tempore Assembly Speaker
California State Senate California State Assembly
1021 O Street, Suite 8518 1021 O Street, Suite 8330 Sacramento, CA 95814 Sacramento, CA 95814
RE: Opposition to Forthcoming Wildfire Liability Reform Package that Would Limit Public Agency Recovery
Dear Senate Pro Tem Limon and Assembly Speaker Rivas,
On behalf of the League of California Cities (Cal Cities), the California State Association of Counties (CSAC), the Rural County Representatives of California (RCRC), and the undersigned local elected officials, cities and counties, we are calling on you to reject efforts to limit public agency recovery when private electric utilities cause wildfires, as proposed in the Governor’s wildfire liability reform package, prompted by the SB 254 Report.
This proposal will wrongly shift costs to taxpayers and force devastating consequences on public agencies and wildfire victims already struggling to rebuild their communities.
The proposal relies on the false hopes that public property, infrastructure and emergency response costs can be recovered from FEMA or insurance. Limiting public agency recovery will only shift costs to taxpayers and leave public agencies financially stranded – or even worse, bankrupt. We strongly oppose the following reforms and urge the Legislature to reject them outright from being included in any wildfire package that will advance this legislative session.
1. Limiting Public Property and Infrastructure Damages Imperils Public Agencies Tasked with Rebuilding their Communities
The proposal will have negligent private electric utilities pay just pennies on the dollar to rebuild critical infrastructure and public facilities that are destroyed. Limiting such costs to the mere depreciated value of the public facility or infrastructure will impact the rebuilding of:
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• Public facilities and buildings
• Water, sewer, roads, communication, and traffic signal infrastructure • Parks, schools, libraries, and fire stations
When a private electric utility causes a wildfire, they are required to fully compensate for property damage. Public agencies cannot rebuild damaged infrastructure on recovery dollars that only cover the depreciated value of an asset. Rebuilding public facilities and infrastructure is not a luxury - it is an essential public service for homeowners, businesses, and communities to return home.
2. Limiting Recovery for Emergency Response and Mutual Aid Forces Public Agencies to Absorb Costs and Increase Financial Risk, Waiting Years For FEMA Reimbursement While Communities Struggle to Recover
The proposal prevents public agencies from recovering emergency response and mutual aid costs from the very private electric utilities who cause these devastating wildfires and inappropriately suggest FEMA as the solution. Limiting emergency response cost recovery will be catastrophic for small jurisdictions and fracture our mutual aid system upon which the state and communities rely on. There is a federal obligation to pursue negligent parties per the Stafford Act. This will create ambiguity when negligent parties must meet that requirement and will jeopardize federal reimbursement. FEMA has strict rules on recoverability, and some events aren’t even eligible for FEMA reimbursement. Since FEMA is a reimbursement model, funds must be spent upfront.
Interpretations in FEMA change from Administration to Administration, creating uncertainty whether future relief will even be available for these incidents.
3. Eliminating Property Tax Losses Leaves Communities Financially Stranded Schools, cities, counties, and special districts rely on property taxes to fund basic needs in our communities. The proposal will financially strand public agencies by eliminating the ability to bring claims for lost property taxes. This has tremendous consequences for essential public services, including fire, police, social services programs, drinking water, public infrastructure, and drastically risks school closure.
There is no evidence in the SB 254 Report to suggest that public agency claims are unreasonable or unjustified. Public agency damages amounted to merely 4% of the total wildfire claims that utilities paid from 2017 to 2024. Public infrastructure, lost tax revenue, emergency response, and mutual aid are necessary and critical for local governments to function while struggling to rebuild their communities. If public agencies cannot recover costs from negligent private electric utilities, local taxpayers will pay more instead. The very survivors whose community burned will foot the bill which is NOT an equitable approach to socializing wildfire risk.
We respectfully request the Legislature to protect public infrastructure, safeguard emergency response and our mutual aid system, and protect taxpayers from this private electric utility bailout – and to reject the Governor’s proposal to limit public agency recovery when such utilities cause wildfires.
Sincerely,
Melissa Sparks-Kranz John Kennedy
Legislative Advocate Senior Policy Advocate
League of California Cities Rural County Representatives of California
Jordan Wells
Legislative Advocate
California State Association of Counties
And on behalf of the following cities, counties and local elected officials:
City of Arcata
City of Artesia
City of Atascadero
City of Albany
City of Agoura Hills
City of Azusa
Alameda County
Town of Apple Valley
City of Benicia
City of Bellflower
City of Buena Park
City of Beverly Hills
City of Big Bear Lake
City of Brea
Calaveras County
Contra Costa County
City of Camarillo
City of Coachella
City of Claremont
City of Colton
City of Clearlake
City of Corona
City of Cloverdale
City of Daly City
City of Del Mar
City of Diamond Bar
City of Downey
City of Danville
City of El Cerrito
City of Emeryville
El Dorado County
City of Fremont
Fresno County
City of Glendora
City of Greenfield
Town of Goleta
City of Hayward
City of Half Moon Bay
City of Hemet
City of Hesperia
City of Highland
City of Irvine
City of Jackson
Kern County
Lake County
City of La Mirada
City of La Verne
City of Lake Elsinore
City of Lakeport
City of Lake Forest
City of Lakewood
City of Lomita
City of Los Alamitos
City of Livermore
Lassen County
City of Manteca
City of Maywood
Marin County
Mariposa County
Mendocino County
Monterey County
Modoc County
Mono County
City of Monrovia
City of Morgan Hill
City of Mission Viejo
City of Napa
City of Norwalk
Napa County
Nevada County
City of Oakland
City of Oceanside
City of Orinda
City of Palm Desert
City of Petaluma
City of Poway
City of Point Arena
Placer County
City of Pleasanton
City of Rosemead
City of Rancho Palos Verdes
Redwood City
City of Rio Dell
City of Riverside
City of Rolling Hills
City of Rolling Hills Estates
City of San Fernando
City of San Jose
City of San Marcos
City of Santa Cruz
City of Santee
City of Salinas
City of Seal Beach
City of Santa Rosa
City of Sierra Madre
City of Stanton
City of Sunnyvale
City of Santa Monica
City of Santa Barbara
C
ity of Solana Beach
City of San Luis Obispo
City of Santa Paula
City of Saratoga
Santa Cruz County
Santa Barbara County
San Bernardino County
Santa Clara County
San Joaquin County
San Mateo County
San Luis Obispo County
Sonoma County
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Stanislaus County
Sutter County
Sacramento County
Tehama County
City of Temecula
City of Torrance
City of Thousand Oaks
City of Tracy
City of Tustin
City of Vacaville
City of Visalia
City of Vista
City of Walnut
City of Walnut Creek
City of Weed
City of West Hollywood
City of Whittier
City of Willits
City of Yreka
Yolo County
Yuba County
Marin County Council of
Mayors and Councilmembers
Orange County Fire Authority
Sonoma County Mayor’s and
Councilmembers’ Association
Ventura Council of Governments
Supervisor Anne Contrell, Napa County
Mayor Brett Taylor, City of Visalia
Mayor Bill Powers, City of Portola
Mayor Betsy Smegal Andersen, City of Piedmont
Vice Mayor Conna McCarthy, City of Piedmont
Mayor Dr. Cynthia Gonzalez, City of Cudahy
Mayor Carlos Juarez, City of Santa Paula
Mayor David Tennessen, City of Camarillo
Councilmember Debby Stegura, City of Rolling Hills Estates Councilmember Dorothy Pemberton, City of Downey
Councilmember David McGowan, City of Palos Verdes Estates Councilmember Evan Branning, City of Livermore
Mayor Frank J. Navarro, City of Colton
Supervisor Gary Bradford, Yuba County
Mayor Glenn R. Sylvester, City of Daly City
Councilmember Holly Tillman, City of Clayton
Supervisor Jake Withrow, Glenn County
Supervisor Jill Cox, Trinity County
Supervisor Justin Cummings, Santa Cruz County
Vice Mayor Jaime Patino, City of Union City
Councilmember Jen Long, City of Piedmont
Mayor John Stephens, City of Costa Mesa
Mayor Kevin Wilk, City of Walnut Creek
Supervisor Kim De Serpa, Santa Cruz County
Mayor Kerry Hills, City of Moraga
Councilmember Larry Spicer, City of Monrovia
Councilmember Lorrel Plimier, City of Piedmont
Supervisor Manu Koenig, Santa Cruz County
Supervisor Monica Martinez, Santa Cruz County
Mayor Michael Kemps, City of Palos Verdes Estates
Mayor Mike Hannon, City of Newark
Mayor Pro Tem Dr. Monica Sánchez, City of Pico Rivera
Councilmember Nathan Steele, City of Seal Beach
Councilmember Norma Martínez-Rubin, City of Pinole
Councilmember Pamela Campos, City of San Jose
Mayor Stephanie Hellman, City of Fairfax
Mayor Sylvia Lemus, City of Cotati
Chair of Supervisors Sukhminder S. Dhaliwal, San Joaquin County Vice Mayor Steve “Woody” Culleton, Town of Paradise
Councilmember Tom Ramsey, City of Piedmont
Councilmember Xouhoa Bowen, City of San Leandro
cc: The Honorable Governor Gavin Newsom
Members, California State Senate
Members, California State Assembly