Investigation of Policies Regarding Fire Hazards in Environmentally Sensitive Areas

R1

The Santa Cruz County Fire Districts and the Office of Emergency Preparedness should complete the Habitat Conservation Project. Response: Aptos/La Selva Fire Protection District This recommendation will not be implemented because the requirement for a Habitat Conservation Plan to allow for fire-safe vegetation management for existing residences is unreasonable. At the time of construction of these homes, the fire protection standards were required to be maintained as a condition of development, and those conditions are still applicable. Recently developed and more restrictive environmental standards are driving the increased restrictions on private property. As these restrictions are put in place, the expectation is that fire protection clearances will somehow be changed in light of findings in a Habitat Conservation Plan. Fundamentally, the need for clearance of flammable vegetation around structures has not changed for many years and is not expected to change in the future. The existence of structures and roads in areas of critical fire hazard suggests that the impact has already occurred. Requiring a Habitat Conservation Plan will not change the need for the removal of flammable vegetation around homes and along roadsides if these are to be safe. Furthermore, requiring that a Habitat Conservation Plan be completed by the County’s fire districts would cause an expenditure of public funds to produce a plan that will not have a material effect on the requirements for flammable vegetation management. The time and money expended on such an analysis will simply divert resources from what should be the true work effort reducing the potential of life-threatening conflagration in the wildland/urban interface areas of the county. If a plan is to be completed, it should be completed by those agencies with enforcement authority for the environmental regulations, much like the fire protection agencies work with property owners to develop fire safety vegetation management plans. Response: Aromas Tri-County Fire District DISAGREES If a plan is to be completed, it should be completed by those agencies with enforcement authority for the environmental regulations, much like the fire protection agencies work with property owners to develop fire safety vegetation management plans. Response: Ben Lomond Fire Protection District This recommendation will not be implemented because the requirement for a Habitat Conservation Plan to allow for fire-safe vegetation management for existing residences is Investigation of Policies Regarding Fire Hazard - 27 unreasonable. At the time of construction of these homes, the fire protection standards were required to be maintained as a condition of development, and those conditions are still applicable. Recently developed and more restrictive environmental standards are driving the increased restrictions on private property. As these restrictions are put in place, the expectation is that fire protection clearances will somehow be changed in light of findings in a Habitat Conservation Plan. Fundamentally, the need for clearance of flammable vegetation around structures has not changed for many years and is not expected to change in the future. The existence of structures and roads in areas of critical fire hazard suggests that the impact has already occurred. Requiring a Habitat Conservation Plan will not change the need for the removal of flammable vegetation around homes and along roadsides if these are to be safe. Furthermore, requiring that a Habitat Conservation Plan be completed by the County’s fire district would cause an expenditure of public funds to produce a plan that will not have a material effect on the requirements for flammable vegetation management. The time and money expended on such an analysis will simply divert resources from what should be the true work effort reducing the potential of life-threatening conflagration in the wildland/urban interface areas of the county. If a plan is to be completed, it should be completed by those agencies with enforcement authority for the environmental regulations, much like the fire protection agencies work with property owners to develop fire safety vegetation management plans. Response: Boulder Creek Fire Protection District This recommendation will not be implemented because the requirement for a Habitat Conservation Plan to allow for fire-safe vegetation management for existing residences is unreasonable. At the time of construction of these homes, the fire protection standards were required to be maintained as a condition of development, and those conditions are still applicable. Recently developed and more restrictive environmental standards are driving the increased restrictions on private property. As these restrictions are put in place, the expectation is that fire protection clearances will somehow be changed in light of findings in a Habitat Conservation Plan. Fundamentally, the need for clearance of flammable vegetation around structures has not changed for many years and is not expected to change in the future. The existence of structures and roads in areas of critical fire hazard suggests that the impact has already occurred. Requiring a Habitat Conservation Plan will not change the need for the removal of flammable vegetation around homes and along roadsides if these are to be safe. Also, requiring that a Habitat Conservation Plan be completed by the County’s fire districts would cause an expenditure of public funds to produce a plan that will not have a material effect on the requirements for flammable vegetation management. The time and money expended on such an analysis will simply divert resources from what should -28 Investigations of Policies Regarding Fire Hazard be the true work effort reducing the potential of life-threatening conflagration in the wild land/urban interface areas of the county. If a plan is to be completed, it should be completed by those agencies with enforcement authority for the environmental regulations, much like the fire protection agencies work with property owners to develop fire safety vegetation management plans. Response: Branciforte Fire Protection District This recommendation will not be implemented because it is not warranted or is unreasonable. If a plan is to be completed, it should be completed by those agencies with enforcement authority for the environmental regulations, much like the fire protection agencies work with property owners to develop fire safety vegetation management plans. Response: Central Fire Protection District This recommendation will not be implemented because the requirement for a Habitat Conservation Plan to allow for fire-safe vegetation management for existing residences is unreasonable. At the time of construction of these homes, the fire protection standards were required to be maintained as a condition of development, and those conditions are still applicable. Recently developed and more restrictive environmental standards are driving the increased restrictions on private property. As these restrictions are put in place, the expectation is that fire protection clearances will somehow be changed in light of findings in a Habitat Conservation Plan. Fundamentally, the need for clearance of flammable vegetation around structures has not changed for many years and is not expected to change in the future. The existence of structures and roads in areas of critical fire hazard suggests that the impact has already occurred. Requiring a Habitat Conservation Plan will not change the need for the removal of flammable vegetation around homes and along roadsides if these are to be safe. Furthermore, requiring that a Habitat Conservation Plan be completed by the County’s fire districts would cause an expenditure of public funds to produce a plan that will not have a material effect on the requirements for flammable vegetation management. The time and money expended on such an analysis will simply divert resources from what should be the true work effort reducing the potential of life-threatening conflagration in the wildland/urban interface areas of the county. If a plan is to be completed, it should be completed by those agencies with enforcement authority for the environmental regulations, much like the fire protection agencies work with property owners to develop fire safety vegetation management plans. Response: Felton Fire Protection District Investigation of Policies Regarding Fire Hazard - 29 This recommendation will not be implemented because the requirement for a Habitat Conservation Plan to allow for fire-safe vegetation management for existing residences is unreasonable. At the time of construction of these homes, the fire protection standards were required to be maintained as a condition of development, and those conditions are still applicable. Recently developed and more restrictive environmental standards are driving the increased restrictions on private property. As these restrictions are put in place, the expectation is that fire protection clearances will somehow be changed in light of findings in a Habitat Conservation Plan. Fundamentally, the need for clearance of flammable vegetation around structures has not changed for many years and is not expected to change in the future. The existence of structures and roads in areas of critical fire hazard suggests that the impact has already occurred. Requiring a Habitat Conservation Plan will not change the need for the removal of flammable vegetation around homes and along roadsides if these are to be safe. Furthermore, requiring that the County’s fire districts complete a Habitat Conservation Plan would cause an expenditure of public funds to produce a plan that will not have a material effect on the requirements for flammable vegetation management. The time and money expended on such an analysis will simply divert resources from what should be the true work effort reducing the potential of life-threatening conflagration in the wildland/urban interface areas of the county. If a plan is to be completed, it should be completed by those agencies with enforcement authority for the environmental regulations, much like the fire protection agencies work with property owners to develop fire safety vegetation management plans. Response: Pajaro Valley Fire District Station This recommendation will not be implemented because it is unreasonable. The propounded purpose of the HCP is to identify and reconcile potentially incompatible environmental and fire safety clearance regulations. While the PVFD supports protecting the environment in Santa Cruz County, it does not have any interest in compromising the current fire safety laws. As such, there is an inherent conflict of interest if PVFD participates in preparing a countywide plan that proposes lessened defensible space requirements due to environmental concerns.12 While the conflict makes PVFD a stakeholder in the process, and to that extent PVFD would like to be consulted, it would be wholly inappropriate and unreasonable for PVFD to be a party to creating a plan that may undermine its ability to enforce currently mandated fire safety laws. Response: Santa Cruz Fire Department This recommendation will not be implemented because the City is not involved in an HCP project with the County. As noted above, the City is developing its own HCP. Moreover, the City of Santa Cruz Fire Department, Planning Department, and Resource Ecologist are already conducting a coordinated review of areas within the City where high fire hazard and environmental issues coincide. The City’s General Plan update process will also involve a review of these aspects. Two examples of current projects on City property -30 Investigations of Policies Regarding Fire Hazard which use this approach are the DeLaveaga Park demonstration project and a fuel modification and vegetation reduction plan for Meder Canyon. Response: Scotts Valley Fire Protection District This recommendation will not be implemented because it is unreasonable. In the spirit of cooperation with other government agencies, the Scotts Valley Fire Protection District has already participated in discussions regarding Habitat Conservation Plan preparation. However we have not taken an active role since that is not our area of primary responsibility or expertise. If a plan is to be completed, it should be completed by the agencies with enforcement authority for the environmental regulations, much like the fire protection agencies work with property owners to develop fire safety vegetation management plans. Fundamentally, the need for clearance of flammable vegetation around structures has not changed for many years and is not expected to change in the future. The requirement for a Habitat Conservation Plan to allow for fire-safe vegetation management for existing residences is, in itself, unreasonable. At the time of construction of these homes, the fire protection standards were required to be maintained as a condition of development, and those conditions are still applicable. Recently developed and more restrictive environmental standards are driving the increased restrictions on private property. As these restrictions are put in place, the expectation is that fire protection clearances will somehow be changed in light of findings in a Habitat Conservation Plan. Although the Scotts Valley Fire Protection District does not wish to create additional negative impact on the environment, the existence of structures and roads in areas of critical fire hazard suggests that the impact has already occurred. Requiring a Habitat Conservation Plan will not change the need for the removal of flammable vegetation around homes and along roadsides if these are to be safe. Furthermore, requiring that a Habitat Conservation Plan be completed by the county’s fire districts would cause an expenditure of public funds to produce a plan that will not have a material effect on the requirements for flammable vegetation management. The time and money expended on such an analysis will simply divert resources from what should be the true work effort: reducing the potential of life-threatening conflagration in the wildland/urban interface areas of the county. Response: UC at Santa Cruz Fire Department Investigation of Policies Regarding Fire Hazard - 31 This recommendation will not be implemented because the requirement for a Habitat Conservation Plan to allow for fire-safe vegetation management for existing residences is unreasonable. At the time of construction of these homes, the fire protection standards were required to be maintained as a condition of development, and those conditions are still applicable. Recently developed and more restrictive environmental standards are driving the increased restrictions on private property. As these restrictions are put in place, the expectation is that fire protection clearances will somehow be changed in light of findings in a Habitat Conservation Plan. Fundamentally, the need for clearance of flammable vegetation around structures has not changed for many years and is not expected to change in the future. The existence of structures and roads in areas of critical fire hazard suggests that the impact has already occurred. Requiring a Habitat Conservation Plan will not change the need for the removal of flammable vegetation around homes and along roadsides if these are to be safe. Furthermore, requiring that a Habitat Conservation Plan be completed by the County’s fire districts would cause an expenditure of public funds to produce a plan that will not have a material effect on the requirements for flammable vegetation management. The time and money expended on such an analysis will simply divert resources from what should be the true work effort reducing the potential of life-threatening conflagration in the wildland/urban interface areas of the county. If a Habitat Conservation Plan is to be completed due to unavoidable obligations established by the Federal Endangered Species Act, it should be completed by those agencies with enforcement authority for the environmental regulations, much like the fire protection agencies work with property owners to develop fire safety vegetation management plans. At the same time, any HCP effort must involve the Fire Districts and any HCP planning requirements must be responsive to Fire District concerns. The HCP must avoid making implementation of fire safety measures unduly difficult and/or costly. With respect to UC Santa Cruz, an HCP is not likely to be needed for fire management purposes because the fire prone areas where vegetation management is needed for fire control purposes currently do not contain Federally protected species. UCSC is preparing an HCP for other specific areas of the campus (not for fire management purposes). If a campus-wide HCP is pursued in the future, fire management considerations would be built into the plan. UCSC is well aware of the substantial costs associated with preparation of a Habitat Conservation Plan. Therefore any decision to pursue an HCP should be made with full understanding of the cost implications of that decision. Take avoidance strategies should be considered as an alternative to preparing an HCP, if feasible. Response: Watsonville Fire Department This recommendation will not be implemented because the requirement for a Habitat Conservation Plan to allow for fire-safe vegetation management for existing residences is unreasonable. At the time of construction of these homes, the fire protection standards -32 Investigations of Policies Regarding Fire Hazard were required to be maintained as a condition of development, and those conditions are still applicable. Recently developed and more restrictive environmental standards are driving the increased restrictions on private property. As these restrictions are put in place, the expectation is that fire protection clearances will somehow be changed in light of findings in a Habitat Conservation Plan. Fundamentally, the need for clearance of flammable vegetation around structures has not changed for many years and is not expected to change in the future. The existence of structures and roads in areas of critical fire hazard suggests that the impact has already occurred. Requiring a Habitat Conservation Plan will not change the need for the removal of flammable vegetation around homes and along roadsides if these are to be safe. Furthermore, requiring that a Habitat Conservation Plan be completed by the County’s fire districts would cause an expenditure of public funds to produce a plan that a plan that will not have a material effect on the requirements for flammable vegetation management. The time and money expended on such an analysis will simply divert resources from what should be the true work effort reducing the potential of life- threatening conflagration in the wildland/urban interface areas of the county. If a plan is to be completed, it should be completed by those agencies with enforcement authority for the environmental regulations, much like the fire protection agencies work with property owners to develop fire safety vegetation management plans. Response: Zayante Fire Protection District The Zayante Fire Protection District does not believe it is within our prevue nor Responsibility to find nor commit limited staff resources to subsidize a County and Federal responsibility. This recommendation will not be implemented because the requirement for a Habitat Conservation Plan to allow for fire-safe vegetation management for existing residences is unreasonable. At the time of construction of these homes, the fire protection standards were required to be maintained as a condition of development, and those conditions are still applicable. Recently developed and more restrictive environmental standards are driving the increased restrictions on private property. As these restrictions are put in place, the expectation is that fire protection clearances will somehow be changed in light of findings in a Habitat Conservation Plan. Fundamentally, the need for clearance of flammable vegetation around structures has not changed for many years and is not expected to change in the future. The existence of structures and roads in areas of critical fire hazard suggests that the impact has already occurred. Requiring a Habitat Conservation Plan will not change the need for the removal of flammable vegetation around homes and along roadsides if these are to be safe. Investigation of Policies Regarding Fire Hazard - 33 Furthermore, requiring that a Habitat Conservation Plan be completed by the County’s fire districts would cause an expenditure of public funds to produce a plan that will not have a material effect on the requirements for flammable vegetation management. The time and money expended on such an analysis will simply divert resources from what should be the true work effort reducing the potential of life-threatening conflagration in the wildland/urban interface areas of the county. If a plan is to be completed, it should be completed by those agencies with enforcement authority for the environmental regulations, much like the fire protection agencies work with property owners to develop fire safety vegetation management plans. Response: Board of Supervisors of the County of Santa Cruz This recommendation is being implemented. The County Office of Emergency Services is the lead agency in coordinating the development of the HCP in collaboration with local fire agencies, the California Department of Forestry, the Santa Cruz County Planning Department, the U.S. Fish and Wildlife Service, the California Department of Fish and Game, the California Native Plant Society, and affected property owners.

R2

The Santa Cruz County Fire Districts, the Office of Emergency Preparedness, and the Environmental Section of the Planning Department should agree upon policy and create written instructions based upon the policy to be given to homeowners by all governmental agencies. Response: Aptos/La Selva Fire Protection District This requires further analysis with an explanation, scope, parameters and a time frame for completion. We believe that a cooperative approach with other government agencies is generally in the public interest, and would be particularly valuable in this instance. The fire protection districts in Santa Cruz County currently have adopted a uniform fire code, which leads to a standard policy approach. The fire safety regulations are very clear and have not changed in a number of years. Written instructions on fire safety practices have been provided to homeowners for years, and we would welcome the opportunity to work with other, allied agencies to incorporate their concerns into those instructions in the interest of fire safety and cooperation. The District has developed fire safety vegetation management plans for specific neighborhoods with the cooperation of property owners based on their unique and individual situations. The U.S. Fish and Wildlife Service, Native Plant Society, County Planning and other agencies have been provided opportunities for review and input in those plans. It should be noted, however, that a “one size fits all” policy in an environmentally diverse county such as Santa Cruz is not feasible. There is a variety of topographic, weather, and vegetation variations that lead to a need for individual review based on specific conditions. -34 Investigations of Policies Regarding Fire Hazard Response: Aromas Tri-County Fire District PARTIALLY AGREES A cooperative approach with other government agencies is generally in the public’s interest. Response: Ben Lomond Fire Protection District This requires further analysis with an explanation, scope, parameters and a time frame for completion. We believe that a cooperative approach with other government agencies is generally in the public interest, and would be particularly valuable in this instance. The fire protection districts in Santa Cruz County currently have adopted a uniform fire code, which leads to a standard policy approach. The fire safety regulations are very clear and have not changed in a number of years. Response: Boulder Creek Fire Protection District This requires further analysis with an explanation, scope, parameters and a time frame for completion. We believe that a cooperative approach with other government agencies is generally in the public interest, and would be particularly valuable in this instance. The fire protection districts in Santa Cruz County currently have adopted a uniform fire code, which leads to a standard policy approach. The fire safety regulations are very clear and have not changed in a number of years. Written instructions on fire safety practices have been provided to homeowners for years, and we would welcome the opportunity to work with other, allied agencies to incorporate their concerns into those instructions in the interest of fire safety and cooperation. The District has developed fire safety vegetation management plans for specific neighborhoods with the cooperation of property owners based on their unique and individual situations. The US Fish and Wildlife Service, Native Plant Society, County Planning and other agencies have been provided opportunities for review and input in those plans. It should be noted, however, that a “one size fits all” policy in an environmentally diverse county such as Santa Cruz is not feasible. There is a variety of topographic, weather, and vegetation variations that lead to a need for individual review based on specific conditions. Response: Branciforte Fire Protection District This requires further analysis with an explanation, scope, parameters and a time frame for completion. We believe that a cooperative approach with other government agencies is generally in the public interest, and would be particularly valuable in this instance. It should be Investigation of Policies Regarding Fire Hazard - 35 noted, however, that a “one size fits all” policy in an environmentally diverse county such as Santa Cruz is not feasible. There are a variety of topographic, weather, and vegetation variations that lead to a need for individual review based on specific conditions. Response: Central Fire Protection District This requires further analysis with an explanation, scope, parameters and a time frame for completion. We believe that a cooperative approach with other government agencies is generally in the public interest, and would be particularly valuable in this instance. The fire protection districts in Santa Cruz County currently have adopted a uniform fire code, which leads to a standard policy approach. The fire safety regulations are very clear and have not changed in a number of years. Written instructions on fire safety practices have been provided to homeowners for years, and we would welcome the opportunity to work with other, allied agencies to incorporate their concerns into those instructions in the interest of fire safety and cooperation. This District does have a weed abatement program that sends initial abatement notices to over 240 homeowners requiring them to abate the hazard. In addition, this District mails fire safety brochures to an additional 1200 residents that reside in the urban interface area. It should be noted, however, that a “one size fits all” policy in an environmentally diverse county such as Santa Cruz is not feasible. There are a variety of topographic, weather, and vegetation variations that lead to a need for individual review based on specific conditions. Response: Felton Fire Protection District This requires further analysis with an explanation, scope, parameters and a time frame for completion. We believe that a cooperative approach with other government agencies is generally in the public interest, and would be particularly valuable in this instance. The fire protection districts in Santa Cruz County currently have adopted a uniform fire code, which leads to a standard policy approach. The fire safety regulations are very clear and have not changed in a number of years. Written instructions on fire safety practices have been provided to homeowners for years, and we would welcome the opportunity to work with other, allied agencies to incorporate their concerns into those instructions in the interest of fire safety and cooperation. The District has developed fire safety vegetation management plans for specific neighborhoods with the cooperation of property owners based on their unique and individual situations. The U.S. Fish and Wildlife Service, Native Plant Society, County Planning and other agencies have been provided opportunities for review and input in -36 Investigations of Policies Regarding Fire Hazard those plans. It should be noted, however, that a “one size fits all” policy in an environmentally diverse county such as Santa Cruz is not feasible. There are a variety of topographic, weather, and vegetation variations that lead to a need for individual review based on specific conditions. Response: Pajaro Valley Fire District Station This recommendation requires further analysis. As discussed above, PVFD does not think it is appropriate to promulgate any policy that lessens its ability to enforce currently mandated fire safety laws. Nonetheless, we believe that a cooperative approach with other government agencies is generally in the public interest, and we would willingly participate in formulating joint instructions to homeowners to ensure uniformity throughout the County. This type of cooperative approach is currently used by the fire districts, which collectively develop written fire safety instructions for homeowners. In that same vein, PVFD would welcome the opportunity to work with other allied agencies to provide instructions to homeowners, as long as those instructions are compatible with current fire and life safety requirements. As requested in the instructions, here are the recommendations for the further analysis: (1) determine what actual conflicts exist between environmental restrictions and state and local laws addressing fire and life safety requirements, (2) determine the legal hierarchy of these conflicts, (3) assess whether a single set of instructions can be implemented on a countywide basis or whether a case-by-case review is preferable, and (4) decide upon the parameters and scope of any joint instructions. This further analysis could be conducted upon agreement of all the fire districts, the Office of Emergency Services, and the environmental section of the planning department, but it may prove more efficient and beneficial to wait until the G.I.S. layers (discussed in the response to finding #8) have been completed. Response: Santa Cruz Fire Department The City of Santa Cruz will need to conduct further analysis of any broad-based policy and instructions developed for suburban and rural areas to see if their implementation will complement or be in conflict with our efforts within the City. Response: Scotts Valley Fire Protection District This recommendation has not yet been implemented, but should be implemented. The time frame is unknown pending completion of the Habitat Conservation Plan. The District believes a cooperative approach with other government agencies is generally in the public interest, and would be particularly valuable in this instance. To do so will first require the Habitat Conservation Plan be completed, after which the Fire Districts could participate in the development of the instructions along with the environmental agencies. Investigation of Policies Regarding Fire Hazard - 37 The fire protection districts in Santa Cruz County currently employ a standard fire code, which leads to a standard policy approach. The fire safety regulations are very clear and have not changed in a number of years. Written instructions on fire safety practices have been provided to homeowners for years, and the District would welcome the opportunity to now work with other, allied agencies to incorporate their concerns into those instructions in the interest of fire safety and cooperation. The District has developed fire safety vegetation management plans for specific neighborhoods with the cooperation of property owners based on their unique and individual situations. The US Fish and Wildlife Service, Native Plant Society, County Planning and other agencies have been provided opportunities for review and input in those plans. It should be noted, however, that a “one size fits all” policy in an environmentally diverse county such as Santa Cruz is not feasible. There are a variety of topographic, weather and vegetation variations that lead to a need for individual review based on specific conditions. Response: UC at Santa Cruz Fire Department This requires further analysis with an explanation, scope, parameters and a time frame for completion. We believe that a cooperative approach with other government agencies is generally in the public interest, and would be particularly valuable in this instance. The fire protection districts in Santa Cruz County currently have adopted a uniform fire code, which leads to a standard policy approach. The fire safety regulations are very clear and have not changed in a number of years. Written instructions on fire safety practices have been provided to homeowners for years, and we would welcome the opportunity to work with other, allied agencies to incorporate their concerns into those instructions in the interest of fire safety and cooperation. The District has developed fire safety vegetation management plans for specific neighborhoods with the cooperation of property owners based on their unique and individual situations. The U.S. Fish and Wildlife Service, Native Plant Society, County Planning and other agencies have been provided opportunities for review and input in those plans. It should be noted, however, that a “one size fits all” policy in an environmentally diverse county such as Santa Cruz is not feasible. There is a variety of topographic, weather, and vegetation variations that lead to a need for individual review based on specific conditions. Response: Watsonville Fire Department This requires further analysis with an explanation, scope, parameters and a time frame for completion. -38 Investigations of Policies Regarding Fire Hazard We believe that a cooperative approach with other government agencies is generally in the public interest, and would be particularly valuable in this instance. The fire protection districts in Santa Cruz County currently have adopted a uniform fire code, which leads to a standard policy approach. The fire safety regulations are very clear and have not changed in a number of years. Written instructions on fire safety practices have been provided to homeowners for years, and we would welcome the opportunity to work with other, allied agencies to incorporate their concerns into those instructions in the interest of fire safety and cooperation. The District has developed fire safety vegetation management plans for specific neighborhoods with the cooperation of property owners based on their unique and individual situations. The U.S. Fish and Wildlife Services, Native Plant Society, County Planning and other agencies have been provided opportunities for review and input in those plans. It should be noted, however, that a “one size fits all” policy in an environmentally diverse county such as Santa Cruz is not feasible. There are a variety of topographic, weather, and vegetation variations that lead to a need for individual review based on specific conditions. Response: Zayante Fire Protection District This requires further analysis with an explanation, scope, parameters and a time frame for completion. We believe that a cooperative approach with other government agencies is generally in the public interest, and would be particularly valuable in this instance. The fire protection districts in Santa Cruz County currently have adopted a uniform fire code, which leads to a standard policy approach. The fire safety regulations are very clear and have not changed in a number of years. Written instructions on fire safety practices have been provided to homeowners for years, and we would welcome the opportunity to work with other, allied agencies to incorporate their concerns into those instructions in the interest of fire safety and cooperation. It should be noted, however, that a “one size fits all” policy in an environmentally diverse county such as Santa Cruz is not feasible. There are a variety of topographic, weather, and vegetation variations that lead to a need for individual review based on specific conditions. Response: Board of Supervisors of the County of Santa Cruz This recommendation is being implemented. The County agrees that clear direction should be given to property owners involved in vegetation management projects. Currently, local fire agencies, U.S. Fish and Wildlife Services, and local resource specialists collaborate to develop best practices for individual vegetation management projects pending the completion of the HCP and federal approval of the overall vegetation management program. Ultimately, the best management practices developed Investigation of Policies Regarding Fire Hazard - 39 in the HCP process and as included in the U.S. Fish and Wildlife permit for fuel reduction projects will determine the policies and practices to be followed by property owners under the direction of local fire agencies. Once these policies have been determined, consistent written instructions can be provided to homeowner.

R3

The Santa Cruz County Fire Districts should create stiffer penalties for homeowners who do not comply with fire clearance regulations. Response: Aptos/La Selva Fire Protection District This recommendation will not be implemented because it is not warranted or is unreasonable. Better coordination and a more focused abatement program would have a more positive outcome than would the issuance of citations. Clear concise direction would be the preferred means of obtaining compliance. Further, in recent years, the insurance industry, (a stakeholder) has taken steps to also reduce its losses from wildfire through property inspections and in some cases have dropped insured properties because of previous fire history, location of property, etc. It has been our experience, that most homeowners generally want to comply with fire safety regulations in an effort to protect their families and property, and have cooperated with our staff in that regard. The real issue is the imposition of new environmental regulations on existing properties that are in conflict with existing fire safety regulations without guidance as to how to comply. Property owners are caught in a regulatory cross fire trying to maintain fire safety under the weight of new environmental regulations. What is needed is technical advice on how to appropriately comply with the regulations without sacrificing fire safety. Increasing penalty fees will not have a material effect on this issue and will only further frustrate homeowners Response: Aromas Tri-County Fire District DISAGREES Prosecution for violations is sometimes the only remedy, but the District has found that education and information have a more positive outcome for compliance. Most homeowners want to comply with fire safety regulations. Response: Ben Lomond Fire Protection District This recommendation will not be implemented because it is not warranted or is unreasonable. Better coordination and more focused abatement program would have a more positive outcome that would the issuance of citations. Clear concise direction would be preferred means of obtaining compliance. Further, in recent years, the insurance industry, (a stakeholder) has taken steps to also reduce its losses from wildfire through property inspections and in some cases have dropped insured properties because of previous fire history, location of property, etc. It has been our experience that most homeowners -40 Investigations of Policies Regarding Fire Hazard generally want to comply with fire safety regulations in an effort to protect their families and property, and have cooperated with our staff in the regard. The real issue is the imposition of new environmental regulations on existing properties that are in conflict with existing fire safety regulations without guidance as how to comply. Property owners are caught in a regulatory cross fire trying to maintain fire safety under the weight of new environmental regulations. What is needed is technical advice on how to appropriately comply with the regulations without sacrificing fire safety. Increasing penalty fees will not have a material effect on this issue and will only further frustrate homeowners. Response: Boulder Creek Fire Protection District This recommendation will not be implemented because it is not warranted or is unreasonable. Better coordination and a more focused abatement program would have a more positive outcome than would the issuance of citations. Clear, concise direction would be the preferred means of obtaining compliance. In recent years, the insurance industry, (a stakeholder) has taken steps to also reduce its losses from wildfire through property inspections and in some cases have dropped insured properties because of previous fire history, location of property, etc. It has been our experience, that most homeowners generally want to comply with fire safety regulations in an effort to protect their families and property, and have cooperated with our staff in that regard. The real issue is the imposition of new environmental regulations on existing properties that are in conflict with existing fire safety regulations without guidance as to how to comply. Property owners are caught in a regulatory cross fire trying to maintain fire safety under the weight of new environmental regulations. What is needed is technical advice on how to appropriately comply with the regulations without sacrificing fire safety. Increasing penalty fees will not have a material effect on this issue and will only further frustrate homeowners Response: Branciforte Fire Protection District This recommendation will not be implemented because it is not warranted or is unreasonable. Better coordination and a more focused abatement program would have a more positive outcome than would the issuance of citations. Clear concise direction would be the preferred means of obtaining compliance. What is needed is technical advice on how to appropriately comply with the regulations without sacrificing fire safety. Increasing penalty fees will not have a material effect on this issue and will only further frustrate homeowners. Response: Central Fire Protection District This recommendation will not be implemented because it is not warranted or is unreasonable. Investigation of Policies Regarding Fire Hazard - 41 Better coordination and a more focused abatement program would have a more positive outcome than would the issuance of citations. Clear concise direction would be the preferred means of obtaining compliance. Further, in recent years, the insurance industry (a stakeholder), has taken steps to also reduce its losses from wildfire through property inspections and in some cases have dropped insured properties because of previous fire history, location of property, etc. It has been our experience that most homeowners generally want to comply with fire safety regulations in an effort to protect their families and property, and have cooperated with our staff in that regard. The real issue is the imposition of new environmental regulations on existing properties that are in conflict with existing fire safety regulations without guidance as to how to comply. Property owners are caught in a regulatory cross fire trying to maintain fire safety under the weight of new environmental regulations. What is needed is technical advice on how to appropriately comply with the regulations without sacrificing fire safety. Increasing penalty fees will not have a material effect on this issue and will only further frustrate homeowners. Response: Felton Fire Protection District This recommendation will not be implemented because it is not warranted or is unreasonable. Better coordination and a more focused abatement program would have a more positive outcome than would the issuance of citations. Clear concise direction would be the preferred means of obtaining compliance. Further, in recent years, the insurance industry, (a stakeholder) has taken steps to also reduce its losses from wildfire through property inspections and in some cases have dropped insured properties because of previous fire history, location of property, etc. It has been our experience most homeowners generally want to comply with fire safety regulations in an effort to protect their families and property, and have cooperated with our staff in that regard. The real issue is the imposition of new environmental regulations on existing properties that are in conflict with existing fire safety regulations without guidance as to how to comply. Property owners are caught in a regulatory cross fire trying to maintain fire safety under the weight of new environmental regulations. What is needed is technical advice on how to appropriately comply with the regulations without sacrificing fire safety. Increasing penalty fees will not have a material effect on this issue and will only further frustrate homeowners. Response: Pajaro Valley Fire District Station This recommendation will not be implemented because it is not warranted. Creating stiffer penalties is not likely to motivate homeowners who fail to comply with fire clearance regulations. PVFD believes that most homeowners who do not comply, fail to do so because they are not aware of the existing laws and/or hazards, or they are confused by the seemingly conflicting directions they get from public officials with regard -42 Investigations of Policies Regarding Fire Hazard to vegetation clearance. Admittedly, there are those property owners who will blatantly disregard any attempt by a government official to regulate the owner’s private property. But even for these people, better solutions exist. Increasing enforcement capabilities and public education efforts would better solve the problem. Additionally, a countywide weed-abatement program modeled after other successful programs in neighboring counties may prove useful, as would tracking the current insurance industry movement towards conducting its own property inspections prior to renewing insurance policies in rural areas. Together, these could lay the foundation for a county ordinance that allowed a fire official to report the hazard directly to the insurance company. This type of ordinance amendment would prove far more effective than increasing the fine for what is currently classified as a misdemeanor. Because the penalties already in place are not used due to a lack of qualified enforcement personnel and because there are more effective solutions, we believe that this recommendation is unwarranted. Response: Santa Cruz Fire Department The City of Santa Cruz will not implement this recommendation, as it uses the County Court bail schedule for violations. The City would rather gain compliance and improve the overall community fire safety by engineering, enforcement, and education. Response: Scotts Valley Fire Protection District This recommendation will not be implemented because it is not warranted. The Scotts Valley Fire Protection District has not had a need to impose a fine for lack of compliance with fire clearance regulations for over twenty years. Homeowners generally want to comply with fire safety regulations in an effort to protect their families and properties and have cooperated with our staff in that regard. The real issue is the imposition of new environmental regulations on existing properties that are in conflict with existing fire safety regulations without guidance as to how to comply. Property owners are caught in a regulatory cross fire trying to maintain fire safety under the weight of new environmental regulations. What is needed is technical advice on how to appropriately comply with the regulations without sacrificing fire safety. Increasing penalty fees will not have a material effect on this issue and will only further frustrate homeowners. Response: UC at Santa Cruz Fire Department This recommendation will not be implemented because it is not warranted or is unreasonable. Investigation of Policies Regarding Fire Hazard - 43 Better coordination and a more focused abatement program would have a more positive outcome than would the issuance of citations. Clear concise direction would be the preferred means of obtaining compliance. Further, in recent years, the insurance industry, (a stakeholder) has taken steps to also reduce its losses from wildfire through property inspections and in some cases have dropped insured properties because of previous fire history, location of property, etc. It has been our experience that most homeowners generally want to comply with fire safety regulations in an effort to protect their families and property, and have cooperated with our staff in that regard. The real issue is the imposition of new environmental regulations on existing properties that are in conflict with existing fire safety regulations without guidance as to how to comply. Property owners are caught in a regulatory cross fire trying to maintain fire safety under the weight of new environmental regulations. What is needed is technical advice on how to appropriately comply with the regulations without sacrificing fire safety. Increasing penalty fees will not have a material effect on this issue and will only further frustrate homeowners. Response: Watsonville Fire Department This recommendation will not be implemented because it is not warranted or is unreasonable. Better coordination and a more focused abatement program would have a more positive outcome than would the issuance of citations. Clear concise direction would be the preferred means of obtaining compliance. Further, in recent years, the insurance industry, (a stakeholder) has taken steps to also reduce its losses from wildfire through property inspections and in some cases have dropped insured properties because of previous fire history, location of property, etc. It has been experienced, that most homeowners generally want to comply with fire safety regulations in an effort to protect their families and property, and have cooperated with our staff in that regard. The real issue is the imposition of new environmental regulations on existing properties that are in conflict with existing fire safety regulations without guidance as to how to comply. Property owners are caught in a regulatory cross fire trying to maintain fire safety under the weight of new environmental regulation. What is needed is technical advice on how to appropriately comply with the regulations without sacrificing fire safety. Increasing penalty fees will not have a material effect on this issue and will only further frustrate homeowners. Response: Zayante Fire Protection District This recommendation will not be implemented because it is not warranted or is ineffective. Better coordination and a more focused abatement program would have a more positive outcome than would the issuance of citations. Clear concise direction would be the -44 Investigations of Policies Regarding Fire Hazard preferred means of obtaining compliance. Further, in recent years, the insurance industry, (a stakeholder) has taken steps to also reduce its losses from wildfire through property inspections and in some cases have dropped insured properties because of previous fire history, location of property, etc. It has been our experience, that most homeowners generally want to complywith fire safety regulations in an effort to protect their families and property, and have cooperated with our staff in that regard. The real issue is the imposition of new environmental regulations on existing properties that are in conflict with existing fire safety regulations without guidance as to how to comply. Property owners are caught in a regulatory cross fire trying to maintain fire safety under the weight of new environmental regulations. What is needed is technical advice on how to appropriately comply with the regulations without sacrificing fire safety. Increasing penalty fees will not have a material effect on this issue and will only further frustrate homeowners

R4

The Santa Cruz County Fire Districts should reestablish a fire safety committee based on the San Mateo County model. Response: Aptos/La Selva Fire Protection District This requires further analysis with an explanation, scope, parameters and a time frame for completion. The issue of fire protection in the wild land urban interface is a significant issue in Santa Cruz County and should remain in the forefront of concerns. However, due to demographics, some thought should be given to forming sub-committees for a given geographical area, rather than a countywide council. An example for a county wide Fire Safe Council would be the make up of the Fire Department Advisory Commission. All stakeholders would be represented, the demographics and geographic differences can be expressed, and all interests (stakeholders) would have an equal representation. Further exploration should be given to find other Fire Safe Councils to find a model that better represents the challenges and uniqueness of Santa Cruz County. Response: Aromas Tri-County Fire District AGREES Response: Ben Lomond Fire Protection District This requires further analysis with an explanation, scope, parameters and a time frame for completion. The issue of fire protection in the wildland urban interface is a significant issue in Santa Cruz County and should remain in the forefront of concerns; however, due to demographics, some thought should be given to forming sub-committees for a given geographical area, rather than a countywide council. Investigation of Policies Regarding Fire Hazard - 45 An example for a countywide Fire Safe Council would be the make up of the Fire Department Advisory Commission. All stakeholders would be represented, the demographics and geographic differences can be expressed, and all interests (stakeholders) would have an equal representation. Further exploration should be given to find other Fire Safe Councils to find a model that better represents the challenges and uniqueness of Santa Cruz County. Response: Boulder Creek Fire Protection District This requires further analysis with an explanation, scope, parameters and a time frame for completion. The issue of fire protection in the wild land urban interface is a significant issue in Santa Cruz County and should remain in the forefront of concerns. However, due to demographics, some thought should be given to forming sub-committees for a given geographical area, rather than a county wide council. An example for a countywide Fire Safe Council would be the make up of the Fire Department Advisory Commission. All stakeholders would be represented, the demographics and geographic differences can be expressed, and all interests (stakeholders) would have an equal representation. Further exploration should be given to find other Fire Safe Councils to find a model that better represents the challenges and uniqueness of Santa Cruz County. Response: Branciforte Fire Protection District Further exploration should be given to find other Fire Safe Councils to find a model that better represents the challenges and uniqueness of Santa Cruz County. This requires further analysis with an explanation, scope, parameters and a time frame for completion. Response: Central Fire Protection District This requires further analysis with an explanation, scope, parameters and a time frame for completion. The issue of fire protection in the wildland urban interface is a significant issue in Santa Cruz County and should remain in the forefront of concerns; however, due to demographics, some thought should be given to forming sub-committees for a given geographical area, rather than a countywide council. An example for a county-wide Fire Safe Council would be the make up of the Fire Department Advisory Commission. All stakeholders would be represented, the demographics and geographic differences can be expressed, and all interests (stakeholders) would have an equal representation. Further exploration should be given to find other Fire Safe Councils to find a model that better represents the challenges and uniqueness of Santa Cruz County. -46 Investigations of Policies Regarding Fire Hazard Response: Felton Fire Protection District This requires further analysis with an explanation, scope, parameters and a time frame for completion. The issue of fire protection in the wildland urban interface is a significant issue in Santa Cruz County and should remain in the forefront of concerns; however, due to demographics, some thought should be given to forming sub-committees for a given geographical area, rather than a countywide council. An example for countywide Fire Safe Council would be the make up of the Fire Department Advisory Commission. All stakeholders would be represented, the demographics and geographic differences can be expressed, and all interests (stakeholders) would have an equal representation. Further exploration should be given to find other Fire Safe Councils to find a model that better represents the challenges and uniqueness of Santa Cruz County. Response: Pajaro Valley Fire District Station This recommendation requires further analysis. Fire protection in the wildland-urban interface is a significant issue in Santa Cruz County. Re-establishing the Fire Safe Council would ensure that the issue remains at the forefront, but modeling it after the San Mateo County Fire Council has already proved ineffectual. Instead, some thought should be given to creating a different model designed to address the challenging and unique demographic, topographic, and political diversities within Santa Cruz County. For example, the new Fire Safe Council could be modeled after the County Fire Department Advisory Commission, or it could be regionally based instead of county-based. These are just a couple of ideas that could be explored, although they do not begin reflect the myriad of options that may be available. Further research is definitely warranted. As requested in the instructions, here are the recommendations for the further analysis: (1) find or create an appropriate model for a Fire Safe Council that would be effective within this County, (2) determine the scope and parameters of the new council, (3) develop a start-up timeline for the council. Preliminary action could be taken by the Fire Chief’s Association of Santa Cruz County to appoint a team to create a workable model. This could be completed Response: Santa Cruz Fire Department The recommendation has not yet been implemented, but will be implemented in the future, as the City of Santa Cruz was a participant in the previous fire safety council and recognizes the value of this cooperative effort. However, the re-establishment of this committee will require better leadership, management, and support from the parent (or hosting) agency (CDF) if it is to be successful. Investigation of Policies Regarding Fire Hazard - 47 Response: Scotts Valley Fire Protection District This recommendation has not yet been implemented, but will be implemented in the future. We estimate the time required would be about one year. While the San Mateo County model is considered good, there are other models, including a California State model that should be considered as part of this process so that the best approach for Santa Cruz County can be determined. We also feel that the best approach would be to take an advisory approach rather than a regulatory approach to avoid the types of conflict that cause the prior effort to become ineffective. Response: UC at Santa Cruz Fire Department This requires further analysis with an explanation, scope, parameters and a time frame for completion. The issue of fire protection in the wildland urban interface is a significant issue in Santa Cruz County and should remain in the forefront of concerns; however, due to demographics, some thought should be given to forming sub-committees for a given geographical area, rather than a countywide council. An example for a county-wide Fire Safe Council would be the make up of the Fire Department Advisory Commission. All stakeholders would be represented, the demographics and geographic differences can be expressed, and all interests (stakeholders) would have an equal representation. Further exploration should be given to find other Fire Safe Councils to find a model that better represents the challenges and uniqueness of Santa Cruz County. Response: Watsonville Fire Department This requires further analysis with an explanation, scope, parameters and a time frame for completion. The issue of fire protection in the wildland urban interface is a significant issue in Santa Cruz County and should remain in the forefront of concerns; however, due to demographics, some thought should be given to forming sub-committees for a given geographical area, rather than a countywide council. An example for a county-wide Fire Safe Council would be the make up of the Fire Department Advisory Commission. All stakeholders would be represented, the demographics and geographic differences can be expressed, and all interests (stakeholders) would have an equal representation. Further exploration should be given to find other Fire Safe Councils to find a model that better represents the challenges and uniqueness of Santa Cruz County. -48 Investigations of Policies Regarding Fire Hazard Response: Zayante Fire Protection District This requires further analysis with an explanation, scope, parameters and a time frame for completion. The issue of fire protection in the wild land urban interface is a significant issue in Santa Cruz County and should remain in the forefront of concerns. However, due to demographics, some thought should be given to forming sub-committees for a given geographical area, rather than a countywide council. Further exploration should be given to find other Fire Safe Councils to find a model that better represents the challenges and uniqueness of Santa Cruz County. _______________________________________________ 1 Information obtained from Santa Cruz County Fire Dispatch Records. California’s I-Zone – Urban/Wildland Fire Prevention and Mitigation, Chapter 13, State of California (1996). Id. at Chapters 8 and 13; Fire Safe Guides for Residential Development in California, State of California (1993). Information obtained from Karen Terrill, public affairs information officer, CDF Sacramento 5 See Santa Cruz County Code § 16.52 et. seq. Information obtained from the California Department of Forestry and Fire Protection Vegetation Management Program Coordinator for Santa Cruz and San Mateo counties. Information obtained from the Office of Emergency Services Administrator and the California Department of Forestry and Fire Protection Pre-Fire Engineer for Santa Cruz and San Mateo counties. Information obtained from California Department of Forestry and Fire Protection Peace Officer assigned to Santa Cruz County. Cal. Pub. Res. Code § 4291.1. Santa Cruz County Code 7.92.310; see also Santa Cruz County Bail Schedule. Santa Cruz County Code §§ 1.12, 1.14, 7.92.300 et seq. See e.g., Pub. Res. Code § 4291, Cal. Fire Code § 1103.2.4 and §16 of