November 2010 v2
MONTEREY COUNTY
COMMUNITY WILDFIRE PROTECTION PLAN
November, 2010
MONTEREY
Monte
M
wwwCOUNTY, CALIFORNIA
rey Fire Safe Council
2221 Garden Road
onterey, CA 93940
831-333-2606
.firesafemonterey.org
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Congressional Direction for the 10-Year Comprehensive Strategy
Conference Report for the Fiscal Year 2001 Interior and Related Agencies
Appropriations Act (Public Law 106-291)
The Secretaries should also work with the Governors on a long-term strategy to deal with the
wildland fire and hazardous fuels situation, as well as needs for habitat restoration and
rehabilitation in the Nation. The managers expect that a collaborative structure, with the States
and local governments as full partners, will be the most efficient and effective way of
implementing a long-term program.
The managers are very concerned that the agencies need to work closely with the affected States,
including Governors, county officials, and other citizens. Successful implementation of this
program will require close collaboration among citizens and governments at all levels. The
managers direct the Secretaries to engage Governors in a collaborative structure to cooperatively
develop a coordinated, National ten-year comprehensive strategy with the States as full partners
in the planning, decision-making, and implementation of the plan.
Key decisions should be made at local levels.
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Preamble
This MCCWPP is an advisory document that was prepared by a committee of the Monterey Fire
Safe Council in collaboration with public agencies pursuant to the Healthy Forests Restoration
Act. The committee comprises citizens (or their representatives) living in at-risk communities,
and the contents of the MCCWPP are opinions of these citizens following the procedures
outlined in The Wildland Fire Leadership Council's handbook, Preparing a Community Wildfire
Protection Plan, A Handbook for Wildland Urban Interface Communities. More specifically,
landscape and fire science discussions, WUI designation, priority of at-risk communities,
regulatory interpretation and other discussions set forth in the MCCWPP are findings and
recommendations by these citizens to help protect their communities from wildfires. Because the
MCCWPP is an advisory document, the MCCWPP does not legally commit any public agency to
a specific course of action or conduct and thus, is not a project subject to CEQA or NEPA. At
least twelve counties in California have signed CWPPs without considering the CWPP as a
project subject to CEQA.
However, if and once grant funding is received from state or federal agencies and prior to work
performed pursuant to this MCCWPP or a local CWPP, or prior to issuance of discretionary
permits or other entitlements by any public agencies to which CEQA or NEPA may apply, the
lead agency must consider whether the proposed activity is a project under CEQA or NEPA. If
the lead agency makes a determination that the proposed activity is a project subject to CEQA or
NEPA, the lead agency must perform environmental review pursuant to CEQA or NEPA.
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TABLE OF CONTENTS
Section Page
1.0 Introduction 1
2.0 MCCWPP Development Process 3
2.1 Federal Agencies 4
2.2 State and Local Agencies 5
2.3 Interested Parties 5
2.4 Funding/Grant Management 7
3.0 Monterey County Planning Area 7
3.1 Site Characteristics 7
3.1.1 Topography 7
3.1.2 Vegetation/Fuels 8
3.1.3 Climate and Weather Conditions 12
3.1.4 Fire History 13
3.1.5 Population and Housing 15
3.1.6 Land Ownership 15
3.1.7 Unique Community Conditions 16
3.1.7.1 Uniformity of Ingress and Egress Safety 16
3.1.7.2 Unique Values and Level of Preparedness 16
3.1.8 Fire Threat 17
3.2 Existing Fire Plans 17
3.2.1 California Department of Forestry and Fire Protection 17
3.2.2 Bureau of Land Management 17
3.2.3 United States Forest Service 19
3.2.4 Pebble Beach Community Services District 19
3.2.5 Other Plans 19
3.3 Regulatory Framework 20
3.3.1 Applicable Federal laws 20
3.3.1.1 Healthy Forests Restoration Act 20
3.3.1.2 Wilderness Acts 21
3.3.1.2.1 Wilderness Act of 1964 21
3.3.1.2.2 The Endangered American Wilderness Act of 1978 22
3.3.1.2.3 The California Wilderness Act of 1984 23
3.3.1.2.4 Los Padres Condor Range and River Protection Act (1992) 24
3.3.1.2.5 Big Sur Wilderness and Conservation Act of 2002 24
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3.3.1.3 Los Padres National Forest Management Plan 25
3.3.1.4 National Environmental Policy Act 26
3.3.1.5 Federal Endangered Species Act 27
3.3.2 Applicable State Laws 28
3.3.2.1 California Constitution 28
3.3.2.2 Division 4 of Public Resources Code — Forests, Forestry and Range
and Forage Lands 28
3.3.2.2.1 Board of Forestry and Fire Protection and Department of Forestry
and Fire Protection 28
3.3.2.2.2 State Responsibility Areas 29
3.3.2.2.3 Title 14 CCR 1299 and Defensible Space Guidelines 29
3.3.2.2.3.1 California Environmental Quality Act Review of 14 CCR 1299 and Guidelines 30
3.3.2.2.4 Public Resources Code Section 4291 31
3.3.2.2.5 Access Roads 31
3.3.2.3 California Coastal Act and Local Coastal Programs 32
3.3.2.3.1 Big Sur Coast Land Use Plan and Implementation Plan 32
3.3.2.3.2 North County Land Use Plan and Implementation Plan 33
3.3.2.3.3 Carmel Area Land Use Plan and Implementation Plan 34
3.3.2.3.4 Del Monte Forest Land Use Plan and Implementation Plan 36
3.3.2.4 California Environmental Quality Act 36
3.3.2.4.1 MCCWPP Not a Project Subject to CEQA 37
3.3.2.4.2 Implementation of MCCWPP 38
3.3.2.5 California Endangered Species Act and Native Plant Protection Act 38
3.3.2.6 Forest Practice Rules and Z'berg-Nejedly Forest Practice Act 39
3.3.2.7 California Smoke Management Guidelines 40
3.3.2.8 California Wilderness Act of 1974 40
3.3.3 Applicable Local Laws, Regulations, and Policies 41
3.3.3.1 Monterey County General Plan 41
3.3.3.2 MBUAPCD Smoke Management Plan 42
4.0 Fuel Reduction Zone Descriptions 43
4.1 Wildland-Urban Interface 43
4.1.1 Introduction 43
4.1.2 Wildland-Urban Interface Discussion 43
4.2 Hazardous Fuel Reduction Zones 46
4.3 Fire Threat Treatment Areas 46
4.3.1 Defensible Space 46
4.3.2 Survivable Space 47
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4.3.3 Mitigation Zones 47
4.3.4 Threat Zones 47
5.0 Fire Fuel Hazard, Threat and Risk 47
5.1 Fire Fuel Hazard 48
5.2 Fire Threat 48
5.2.1 Field Fire Threat Assessment 49
5.3 FRAP Fire Risk 50
5.4 Prioritization of Need for Fuel Reduction Work 50
5.5 Detailed Priority Threat Descriptions 53
5.6 Special Study Areas: FRAP Fire Behavior Modeling 53
6.0 Hazard Reduction 53
6.1 Reduction of Structure Ignitability 54
6.2 Hazardous Fuel Reduction and Fuelbreaks 57
6.2.1 Access Roads 57
6.2.2 Defensible Space Fuel Treatments 58
6.3 Hazardous Fuel Treatments 60
6.3.1 Strategic Firebreaks/Fuelbreaks and Other Treatments 61
6.3.2 Vegetation Thinning 61
6.3.3 Tree Removal 61
6.3.4 Tree and Shrub Pruning 61
6.3.4.1 Vertical Separation 62
6.3.4.2 Horizontal Separation 62
6.3.4.3 Vegetation Grouping 62
6.3.5 Dead/Dying Plant Removal 62
6.3.6 Exotic/Invasive Plant Removal 63
6.3.7 Mowing 63
6.3.8 Chipping and Mastication 63
6.3.9 Grazing 63
6.3.10 Prescribed Burning 63
6.3.11 CAL FIRE Vegetation Management Program 64
6.3.12 Crushing 64
6.3.13 Lopping and Scattering 64
6.3.14 Fireline Explosives 65
6.3.15 Herbicides 65
6.4 Community Fire Safe Prescriptions 65
6.5 Air Quality 66
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7.0 Environmental Benefits 66
7.1 Greenhouse Gases 66
7.2 Use of Biomass 66
8.0 Strategy and Action Plan 67
8.1 Localized Fire Plans and CWPPs 68
8.2 Long Term Maintenance/Monitoring 69
8.3 Public Education and Outreach 70
9.0 Recommendations 71
9.1 Recommendations to the Secretary of Agriculture 72
9.1.1 Maintain the Ventana Fuelbreak (Big Box Firebreak) 72
9.1.2 Maintain the Bixby Mountain Fuelbreak 75
9.1.3 Establish Agreement with CAL FIRE to Defend the Bixby Mountain
Fuelbreak/Firebreak 76
9.1.4 Pre-attack Planning by USFS in Cooperation with CAL FIRE and Local Fire
Departments 76
9.1.5 Letter of Delegation and Expedited Process to Open and/or Construct
Firebreaks Upon Start of Wildfires 77
9.1.6 Support the Santa Lucia Fire Defense System (In Progress) 77
9.1.7 Manage Hazardous Fuels on National Forest System Lands to Protect All
At-Risk Communities 78
9.1.8 Priorities for Fuel Reduction Funding on Private Lands 78
9.1.9 Fund Emergency Ingress and Egress to the Los Padres National Forest 78
9.1.10 Incorporate CWPPs Into the USFS's Fire Management Plan and Pre-attack
Planning 79
9.2 Recommendations to the Secretary of the Interior 79
9.2.1 Maintain Former Fort Ord Fuel Break System 79
9.2.2 Install and Maintain Sierra de Salinas-Gabilan Fuel Reduction Project
and Strategic Fuel Break System 80
9.2.3 Pinnacles National Monument Hazardous Fuel Reduction 80
9.2.4 Prescribed Fire Hazardous Fuel Reduction at Toro Creek and Creekside 80
9.2.5 Manage Hazardous Fuels on BLM Lands to Protect At-Risk Communities 80
9.2.6 Priorities for Fuel Reduction Funding on Private Lands 81
9.2.7 Fund Emergency Ingress and Egress to Lands Administered by BLM 81
9.2.8 Incorporate CWPP's Into BLM's Pre-attack Planning 81
9.3 Recommendation to Congress 81
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9.3.1 Enact Legislation to Enable and Require that Fuelbreaks and Firebreaks be
Maintained, if Fuelbreak/Firebreak Recommendations to the Secretary of
Agriculture are not Implemented Within Three Years 81
9.4 Recommendations to all Federal, State and Local Regulatory Agencies with
Jurisdiction in Monterey County 82
9.4.1 Establish an Annual Goal for Hazardous Fuel Reduction Work in
Monterey County 82
9.4.2 Establishment of Hazardous Fuel Reduction Zones and Approval of
Hazardous Fuel Reduction Work 83
9.4.3 Lead Agency for California Environmental Quality Act Purposes 83
9.4.4 Within HFRZs, Allow and Facilitate Creation of Survivable Space 83
9.4.5 Allow and Facilitate use of Large Burn Piles During Winter Rains
with a Minimum of Regulatory Requirements 84
9.4.6 Consider the Option of Biomass for Use of Woody Debris From Fuel
Mitigation Activities 84
9.4.7 Monterey Fire Safe Council and California Department of Fish and Game
Develop Localized Handouts Describing Species That are Protected by State
and/or Federal Law 84
9.4.8 Reduction of Structural Ignitability 85
9.5 Recommendations to CAL FIRE and Other Fire Authorities Having
Jurisdiction 85
9.5.1 Designate Hazardous Fuel Reduction Zones 85
9.5.2 Support Ready, Set, Go! to Include Those Who May be Trapped by Fire 85
9.5.3 Support Community Emergency Response Teams 86
9.5.4 Support Annual Treatment Goals in Implementation of the CAL FIRE
Range Improvement and Vegetation Management Programs 86
9.5.5 Prioritize CAL FIRE Resources to Support the Recommendations in
this MCCWPP 87
9.6 Recommendations to Monterey County and to Municipalities and
Districts Within Monterey County 87
9.6.1 Include Language to Allow and Facilitate Hazardous Fuel Reduction Work
in all Planning Documents, Ordinances, Rules and Regulations 87
10.0 MCCWPP Agreement 88
11.0 References 90
12.0 Resources 90
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Tables
Table 1 MCCWPP Development Team 3
Table 2 Federal Agencies Involved 4
Table 3 State and Local Agency Representatives 5
Table 4 Interested Parties Involved 5
Table 5 Monterey County Land Cover/Fuels Distribution 11
Table 6 Monterey County Fires in Excess of 10,000 Acres 13
Table 7 Monterey County Housing Density 15
Table 8 Monterey County Land Ownership 16
Table 9 Monterey County Fire Threat 17
Table 10 BLM FMU Characteristics and Objectives in Monterey County 18
Table 11 Monterey County Fuel Hazard Rating 48
Table 12 Monterey County Fire Threat Rating 49
Table 13 Prioritization of Need for Fuel Reduction Work, by Community 50
Table 14 Misapplication Examples During Non-emergency Situations 59
Appendices
Appendix A Glossary of Terms
Appendix B Monterey County Maps
B-1 Monterey County Topography
B-2 Monterey County Vegetation/Fuels Distribution
B-3 Monterey County Fire History
B-4 Monterey County Land Ownership Distribution
B-5 Monterey County Fire Threat Rating
B-6 Monterey County State Responsibility Area
B-7 WUI Zones in Monterey County
B-8 Fire Fuel Hazard Rating
Appendix C Ready, Set, Go!
Appendix D Recommended Fuel Reduction Projects
Appendix E General Guidelines for Creating Defensible Space
Appendix F CEQA Flowchart
Appendix G Forest Practice Rules Checklist
Appendix H Sample Threat Assessment Study Summaries
Appendix I Detailed Priority Threat Descriptions
Appendix J Comments on the 2010 MCCWPP
Appendix K USFS Defensible Fuel Profile Zone Letter
Appendix L Sample Fire Prescription
Appendix M Table of Acronyms
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1.0 Introduction
The Monterey County Community Wildfire Protection Plan (MCCWPP) was developed by the
Monterey Fire Safe Council (MFSC), including the Monterey County Wildfire Working Group
(MC2WG) which is serving as its MCCWPP committee, with input from the California
Department of Forestry and Fire Protection (CAL FIRE), the United States Forest Service
(USFS), the Bureau of Land Management (BLM) and other stakeholders. Other stakeholders
include: community members, forest and rangeland property owners, and local fire agencies
within State Responsibility Area (SRA) and other interested parties, along with wildfire
protection planning consultants from Dudek.
It is recommended that this document serve as an advisory plan to guide wildfire
prevention and preparation activities throughout Monterey County, subject to
compliance with all other applicable local, state and federal laws and regulations.
This MCCWPP makes the connection between Strategic Fuelbreaks, Defensible Space,
Defensible Polygons, and incident management, providing communities and agencies guidance
to wildfire prevention and protection. Recommendations made herein include hazardous fuel
mitigation activities and methods for reducing structural ignitability.
This MCCWPP covers Monterey County, California, and includes such information as:
 Large destructive fires.
 The County's physical characteristics.
 Landscape-scale and watershed-based fire hazard and fire threat assessment work completed
to date.
 Fire hazard risk areas.
 Uniformity of ingress and egress safety.
 Strategic Fuelbreaks.
 Defensible Polygons.
 Hazardous fuel reduction treatments, methods and projects.
 Methods for reducing structural ignitability. (See Section 6.1.)
 Regulatory framework for hazardous fuel reduction projects.
 Methods and preplanned evacuation (e.g., Ready, Set, Go! and "prepare, stay and defend or
leave early" (PSDLE) concepts).
 Wildland-urban interface (WUI) zone boundaries.
The purposes of this MCCWPP are to:
 Provide wildfire planning recommendations at a county wide scale.
 Provide recommendations for hazardous fuel assessment and reduction within the County,
emphasizing WUI zones, to protect lives, structures and infrastructure from wildfire.
 Reduce the potential for wildfire-originated structure ignitions.
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 Reduce wildfire costs and losses.
 Reduce the potential for ignitability of structures and address human activities that may cause
wildfires.
 Reduce the spread of wildfire within WUI zones.
 Provide advice to help implement the national and state fire plans, the 10-Year
Comprehensive Strategy, and the 10-Year Comprehensive Strategy Implementation Plan.
 Present recommended priorities of at-risk communities.
 Help qualify Monterey County communities, agencies, and others for grant funding from a
variety of sources.
 Facilitate efficient use of taxpayer dollars, and mobilize the coordination of community,
private, local, state, and federal agency projects and funding priorities.
 Promote the importance of preparing localized fire plans and community wildfire protection
plans (CWPPs) that address issues each community considers appropriate, which may vary
substantively from the county wide provisions and maps in this MCCWPP, provided such
local fire plans and CWPPs receive all necessary approvals from local, state or federal
agencies.
This MCCWPP recognizes:
 The success of initial attack fire suppression policy.
 That 2 percent of the state's wildfires that escape initial attack are responsible for 90 percent
of wildfire costs and losses.
 That hazardous fuel buildup around structures, infrastructure, roads, highways, watersheds
and areas where there is hazardous fuel accumulation due to past fire suppression practices or
other hazardous conditions brought about by severe weather events, disease, or other
disturbances in Monterey County is a threat to lives, property and the environment due to its
potential for high intensity wildfire.
 That extreme weather events can cause high-intensity uncontrolled wildfire, largely
irrespective of vegetation age or density, though higher hazardous fuel density and steep
topography will increase fire intensity given the same weather conditions.
 That of the factors that affect wildfire behavior and intensity, hazardous fuel is the only
factor humans can control, and during mild weather conditions, hazardous fuel density can
have a greater ability to alter fire spread probabilities than weather.
 That failure to plan for and implement hazardous fuel reduction work to address wildfire
during extreme weather events puts lives, property and the environment at risk.
 That low and moderate intensity fire has a role in maintaining ecosystem balance and
biological resiliency.
 That efforts to reduce large, damaging wildfires are protective of the environment as well as
of lives and property.
This MCCWPP is intended to be a living document with long term community involvement
consistent with requirements of the Healthy Forests Restoration Act (HFRA), including guidance
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established by the Wildland Fire Leadership Council (for example, as described in Preparing a
Community Wildfire Protection Plan, A Handbook for Wildland–Urban Interface Communities).
Appendix A provides a glossary of technical and regulatory terms used in this document.
2.0 MCCWPP Development Process
This section lists the representatives or organizations either involved in the development of the
MCCWPP or who/which provided information for the completion of this MCCWPP. The
organization, roles, and responsibilities are indicated in Table 1 below.
Table 1. MCCWPP Development Team
Organization Roles/Responsibilities
Monterey Fire Safe Council (MFSC) Provides review and guidance for MCCWPP preparation,
prepares sections of the MCCWPP, and is involved with
MCCWPP review team and approval process. Coordinates
community involvement, planning information and
resources web site, web site forms and information, member
input, meeting attendance and coordination. Responsible for
grant administration, documents, forms and grant
management.
Property owners, community members,
stakeholders, forest and rangeland property
owners, and interested parties
Provide community guidance, input, concerns, priorities,
commitment to projects, and collaborative engagement with
agencies and MCCWPP co-operators.
California Department of Forestry and Fire
Protection (CAL FIRE)
Primary fire suppression for SRA lands within the County --
Provides input and expertise on minimum standards, SRA
lands, and hazardous fuel reduction.
Local Fire Districts and Volunteer Fire
Departments
Provide community guidance, input, concerns, priorities,
commitment to projects, and collaborative engagement with
agencies and MCCWPP co-operators.
Bureau of Land Management (BLM) Primary fire suppression for BLM lands within the County -
- Provides input and expertise on MCCWPP preparation,
existing and proposed projects, and hazardous fuel reduction
efforts.
United States Forest Service (USFS) Primary fire suppression for USFS lands within the County -
- Provides input and expertise on MCCWPP preparation,
existing and proposed projects, and hazardous fuel reduction
efforts.
Dudek Wildfire protection planners -- Prepared wildfire hazard
reduction plan, recommendations for hazardous fuel
reduction and structural ignition reduction, initial
development of the MCCWPP with guidance and input from
the MFSC, community risk and value assessment,
development of community protection priorities, and
establishment of hazardous fuels treatment project areas and
methods.
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Organization Roles/Responsibilities
Monterey County Planning Department Identifies regulatory framework for coordinating land use
plans with the MCCWPP.
Monterey County Wildfire Working Group
(MC2WG)
Coordinates preparation of the MCCWPP by gathering and
incorporating agency and community input.
2.1 Federal Agencies
Representatives of the federal agencies in Monterey County are listed in Table 2 below.
Table 2. Federal Agencies Involved
Agency Representative Initial MCCWPP
Intent Letter Sent
Date Invited to
Participate in Agency
Meeting
United States Forest
Service (USFS)
Monterey Ranger District,
Los Padres National Forest
(LPNF)
John Bradford
Sherry A. Tune
May 1, 2006 January 15, 2009
Bureau of Land
Management (BLM)
Hollister Field Office
Michael Chiodini
Rick Cooper
May 1, 2006 January 15, 2009
National Park Service
(NPS)
Albert Faria May 1, 2006 January 15, 2009
United States Fish and
Wildlife Service
(USFWS)
Terry Palmisano May 1, 2006 January 15, 2009
USDA Natural Resources
Conservation Service
(USDA NRCS)
Robert LaFleur May 1, 2006 January 15, 2009
Tribal Governments Louise J. Ramirez May 1, 2006 January 15, 2009
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2.2 State and Local Agencies
Representatives of the state/local agencies that have jurisdictional responsibilities in Monterey
County are listed in Table 3 below.
Table 3. State and Local Agency Representatives
Agency Representative Initial MCCWPP
Intent Letter Sent
Date Invited to
Participate in Agency
Meeting
California Department of Parks
and Recreation (CDPR)
Loren Rex May 1, 2006 January 15, 2009
California Department of Fish
and Game (CDFG)
Chuck Hughes May 1, 2006 January 15, 2009
California Department of
Transportation (Caltrans)
Mike Mendoza May 1, 2006 January 15, 2009
California Highway Patrol,
Monterey
Debbie Hershey May 1, 2006 January 15, 2009
Monterey County Planning
Department
Carl Holm March 1, 2009 March 1, 2009
Monterey Bay Unified Air
Pollution Control District
(MBUAPCD)
Betsy Hibbits or Bob
Nunes
May 1, 2006 January 15, 2009
Monterey County Office of
Emergency Services (OES)
Phil Yenovkian May 1, 2006 January 15, 2009
Monterey County Public Works Ed Muniz May 1, 2006 January 15, 2009
Monterey Peninsula Regional
Parks District
Tim Jensen May 1, 2006 January 15, 2009
American Red Cross, Monterey Sharon Crino May 1, 2006 January 15, 2009
2.3 Interested Parties
Parties from the communities in Monterey County that have shown interest in fire management
or may be interested in this MCCWPP are listed in Table 4 below.
Table 4. Interested Parties Involved
Interested Parties Initial MCCWPP Intent Letter Sent
Fire Safe Councils
Monterey Fire Safe Council
May 1, 2006
Local Landowners/Managers
Big Sur Land Trust
El Sur Ranch
Mason Ranch
May 1, 2006
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Interested Parties Initial MCCWPP Intent Letter Sent
Monterey County Cattlemen's Association
Monterey San Benito Range Improvement
Association
Packard Ranch
Santa Lucia Preserve
Rancho Rico
Environmental Organizations
Monterey Bay Chapter, California Native Plant
Society
The Nature Conservancy
The Sierra Club, Ventana Chapter
May 1, 2006
Local Utility Companies
Pacific Gas & Electric
May 1, 2006
Homeowners Associations
Cachagua-Jamesburg Community Task Force
Carmel Highlands Association
Coast Property Owners Association (CPOA)
Corral de Tierra Homeowners Association
Friends, Artists, and Neighbors of Elkhorn Slough
(FANS)
Laguna Seca Homeowners Association
Lower Carmel River Advisory Committee
Mal Paso Creek Property Association
Prunedale Neighbors Group (PNG)
Prunedale Preservation Alliance (PPA)
Rancho Bolsa Nueva Homeowners Association
Rancho Rio Vista Homeowners Association
Rancho San Clemente Homeowners Association
Rancho Tierra Grande Homeowners Association
San Jerardo Housing Co-op
Sunset West Homeowners Association
Toro Park Homeowners Association
White Oaks Homeowners Association
White Rock Homeowners Association
May 1, 2006
(Not all)
Other Parties
Davey Resource Group
May 1, 2006
As part of preparing this MCCWPP, the MFSC held three separate public meetings where public
comments were taken and incorporated into the MCCWPP. The public meetings were held on
March 24, March 25, and March 26, 2009 in Big Sur at the Big Sur Lodge conference room,
Carmel Valley at the Hidden Valley Facility, and Monterey at the Monterey Fair Grounds,
respectively.
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2.4 Funding/Grant Management
Funding for preparation of a portion of this MCCWPP was made available from a National Fire
Plan grant made possible by federal financial assistance provided to the California Fire Safe
Council from the Bureau of Land Management (BLM). That portion of the project was funded
via WUI Community Rural Fire Assistance, CFDA # 15.228. The grant number was
08BLM0149. The grant period extended from February 2008 to April 2009. Grant management
and reporting are being conducted by the MFSC.
3.0 Monterey County Planning Area
This MCCWPP covers Monterey County, California. Located in central coastal California,
Monterey County encompasses over 2.1 million acres, with a population of approximately
425,960 distributed among 12 cities and unincorporated County areas.1 Monterey County cities
encompass a total of about 38,016 acres or about 1.8 percent of the County's land area. Total
population of Monterey County cities is about 320,000. The remainder of Monterey County's
inhabitants (about 106,000, or 25 percent) live in unincorporated areas. About 1.2 million acres
in Monterey County are forest and rangeland.
In 2006, the MFSC contracted with CAL FIRE's Fire and Resource Assessment Program
(FRAP), Ron Montague, National Fire Wise Coordinator, and Doug Campbell, Fire Behavior
Analyst, to more thoroughly evaluate wildfire threat and risk in Monterey County. While state-
level risk analyses are made publicly available by FRAP, the analysis conducted for Monterey
County fuels distribution, fire threat, and fire risk ratings is more detailed and experience-
specific, with focused results that were instrumental in identifying overall threat to Monterey
County communities. A more detailed discussion of the FRAP fire threat analysis is presented in
Section 3.1.8.
3.1 Site Characteristics
This section presents a discussion of the variables affecting fire behavior and risk assessment for
Monterey County.
3.1.1 Topography
The topography of Monterey County is extremely variable. Within the Salinas Valley, slopes are
relatively flat across the valley floor (0-10 percent). Elevations in this region range from sea
level, where the valley meets the Pacific Ocean in the north, up to nearly 400 feet above mean
sea level (AMSL) in the southern portions of the valley. More significant topographic variation
is found in the eastern and western portions of the County, often characterized by steep slopes,
deeply incised canyons, and narrow valleys. The elevation within Monterey County ranges from
sea level to over 5,800 feet AMSL.2 Slope measurements reach up to 175 percent gradients,
most notably in the Los Padres National Forest (LPNF) located in the western portion of the
County and the Gabilan Range located along the eastern County boundary.3 All maps are
1 County of Monterey 2008.
2 FRAP 2006.
3 FRAP 2006.
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included in Appendix B. Topography for Monterey County is graphically presented on the map
in Appendix B-1.
The regional topographic conditions within Monterey County have considerable effect on
wildland fire behavior, as well as on the ability of firefighters to access and respond to wildfires.
Steep slope and canyon alignments are conducive to channeling, deflecting, concentrating, or
dispersing winds, and creating extremely erratic wildfire conditions, especially during wind-
driven fire events.4
3.1.2 Vegetation/Fuels
The Monterey Fire Safe Council’s findings on the vegetation type and distribution in the County
and the vegetation’s role in affecting fire behavior are based substantially on a special Fire
Threat Assessment conducted in 2006 by CAL FIRE’s Fire Resource Assessment Program
(FRAP) using best available data for Monterey County.
By agreement with the MFSC, the Sierra Club, and the Ventana Wilderness Alliance, a more
detailed review of the scientific basis for these findings will be augmented by a collaboration of
the MFSC/MC2WG Science Review Team and Dr. Scott Stephens. Dr. Stephens will address
scientific knowledge of the fire ecosystem, both ecological impacts of disturbance, and
effectiveness of treatments for each biological community type in Monterey County. The Sierra
Club has agreed to provide funding for Dr. Stephens’ work.
This work should be completed, reviewed, and formally inserted into this Section 3.1.2 to the
MCCWPP no later than April 1, 2011, as part of a subsequent amendment to the MCCWPP.
Vegetation/Fuels
The following is a brief review of the vegetation conditions and fire threat assessment protocol in
Monterey County:
California and Monterey County are fire prone, fire-adapted ecosystems. Protection and
conservation of both human and natural wildland communities from fire threat can be achieved
through maintenance of the fire adapted ecosystem supporting human and natural wildland
community function, resilience, and sustainability over time.
Ecosystems can be managed such that the structure, composition, and function of all elements,
including their frequency, distribution, and natural extinction, may be conserved. Addressing the
science of both fire threat to human communities and threat to ecosystem simultaneously allows
4 Davis, F.W., & Borchert, M.I., 2006. Central Coast Bioregion. In: Sugijara, N.G., Van Wagtendonk, J.W.,
Shaffer, K.E., Fites-Kaufman, J., and Thode, A.E., eds. Fire in California’s ecosystems. University of California
Press, Berkeley, pp. 321-349.
Hanson & Usner 1993. The Natural History of Big Sur. University of California Press, Berkeley, pp. 232-238.
U.S. Department of Agriculture, Forest Service (USDA FS). 2000. "Policy Implications of Large Fire Management:
A Strategic Assessment of Factors Influencing Costs." A Report by the Strategic Overview of Large Fire Costs
Team. Washington, DC: Forest Service, U.S. Department of Agriculture. 43 pp.
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stakeholders, utilizing an adaptive management decision process, to determine priorities and best
treatment methods to be applied.
The Fire Equation
In addition to weather and topography, vegetation (or fuel) plays a major role in affecting fire
behavior and shaping fire hazard potential. Vegetation distribution throughout the county varies
by location and topography, with dramatic differences observed between coastal, valley, and
inland regions.
Frequent presence of low and moderate intensity fire shaped the landscape, the vegetation, and
its ecology. Lightning, Native Americans, and early settlers provided ignition sources before fire
suppression policy interrupted these processes. Prior to 1800, approximately 4.4 million acres
burned annually in California5.
Over the past century, federal land management agencies and others have learned that the active
suppression of fires has resulted in large contiguous areas of hazardous fire fuel beds with large
concentrations of down-dead and ladder fuels that contribute to costly, suppression-resistant,
high heat intensity wildfires, that threaten communities, both human and natural wildland. Over-
crowding, resource depletion, and disease susceptibility due to high vegetation densities (stem
spacing) are some of the effects resulting from long-term fire suppression.
Hazardous levels of fire fuels can cause fire intensities to exceed firefighting tactical ability to
contain and control. High intensity fire contributes to long distance spotting of flaming embers.
Structural losses in wildland fires initially occur due to spotting, flying embers and firebrands,
and backing and creeping surface fires. Once a structure is ignited, most structural losses are due
to structure-to-structure ignition; relatively few are destroyed by a flaming fire front.
Fire intensity is a measure of total heat (BTU), which is a function of available fire fuel,
considering the condition of the fuel, the conditions of the fire environment, weather, and
topography. High intensity fire occurs when fire environment conditions come into alignment
and burnable fuel volume is greatest.
Fire intensity is subjectively quantified as low, moderate, and high for given conditions within a
fire regime or ecosystem/bioregion. The most obvious indications of fire intensity are the length
of the flames, the rate of spread, and flame duration. Hazardous fuel reduction is about reducing
fire intensity.
Can a fire safe protocol be developed that identifies Wildland Urban Interface Zones and
Hazardous Fuel Reduction Zones (HFRZ), and supports functioning, resilient, sustainable
communities, both human and natural wildland communities, using an adaptive management
decision process? We have the opportunity to approach the problem as one of a choice between
potentially destructive high intensity wildfire under severe conditions and desirable low and
moderate intensity prescribed fire, or ecosystem-sensitive hazardous fuel reduction based on the
5 Stephens, S.L. et al., Prehistoric fire area and emissions from California’s forests, woodlands, shrublands, and
grasslands, Forest Ecol. Manage. (2007), doi:10.1016/j.foreco.2007.06.005
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principles of fire surrogates; hand crew and mechanical treatments are a safe and economically
viable method of reducing fuel loads to reduce fire threat and maintain ecological function.
In the HFRZ the desired fire intensity is low to moderate, within tactical firefighting capability.
In the Defensible Space Zone, the desirable fire intensity is zero for the protection of citizens and
firefighters. The goal is firefighter and citizen safety, using safe rules of tactical firefighting
engagement, according to the FAHJ.
Fire Threat Assessment is the art and science of predicting fire intensity and threat from fire.
This characterization is then mapped to inform the creation of the boundaries of effective Safety
Zones, Defensible Space, and designation of HFRZ. Effective pre fire, pre-attack planning
identifies existing roads, topography, and strategic fuel breaks as anchor points to “connect the
dots” to firefighter and citizen safety: Safety Zones, Defensible Space Zones, and values
protected.
To determine treatment distances and intensity, each community or project area is analyzed using
a fire threat assessment that proactively performs hypothetical scenarios of potential fire
situations. The rules of safe tactical engagement are applied to delineate and inform the
prioritization and identify the appropriate level of pre fire treatment necessary for effective
mitigation and protection.
The wildland fire service utilizes the “Haul Chart” (see below) as a rule of thumb reference guide
for quickly assessing fire behavior, fire intensity, and fire effects, relative to firefighter safety.
The scales of the Haul Chart are based
on the same science, base codes and
algorithms of the BEHAVE, FARSITE,
and FLAMMAP fire modeling tools
used by FRAP and pre-attack planners.
For a full explanation of fire behavior
and fire spread algorithms, see
Rothermel’s publications on his
mathematical model6 and wildland fire
management. 7
ROS = Rate of Spread in chains per
hour. 1 chain = 66 feet.
Flame Length Color Code:
Blue < 1 foot flame length;
Green < 3 foot flame length;
Tan < 8 foot flame length;
Magenta <15 foot flame length;
Red +15 foot flame length
6 Rothermel, Richard C., 1972. A mathematical model for fire spread predictions in wildland fuels. USDA For.
Serv. Res. Pap. INT-115, 40 p. lntermt. For. and Range Exp. Stn. Ogden, Utah.
7 Rothermel, Richard C., and Charles W. Philpot. 1973. Fire in wildland management: predicting changes in
chaparral flammability. J. For. 71(10):640-643.
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The values represented in the Haul Chart characterize safe direct tactical engagement of
firefighters, correlating to low intensity flame lengths no greater than 4-8 feet high. These are
the safety standards firefighters apply to hazardous fuel reduction and the creation of Defensible
Space and Safety Zones during a conflagration.
CONCLUSIONS:
 This Section 3.1.2 should be completed, reviewed, and formally inserted into this
MCCWPP no later than April 1, 2011.
 Fire Science and Fire Ecology are complementary.
 Utilize an adaptive management decision process.
 More research is needed to investigate comparative fire effects upon the varied landscape
ecosystems of Monterey County.
 Develop environmentally sensitive hazardous fuel reduction protocols and treatments to
reduce high intensity fire potential by reducing potential flame length and duration.
 Refine WUI map for Monterey County. Refine FRAP maps and pertinent data. Refine
mapping and designation of biological communities.
 MCCWPP integration with USFS “FireScape Monterey”.
 “Connect the dots” between Defensible Space and Strategic Fuelbreaks.
Science Review Team Members:
Dr. Scott Stephens Associate Professor of Fire Sciences, UC Berkeley
Jonathan Pangburn Registered Professional Forester, CAL FIRE
Michael Emmett Mal Paso Homeowners’ Association
Joe Rawitzer Monterey-San Benito Range Improvement Association
Wildland Fire Safe Council
Robin Hamelin Battalion Chief, CAL FIRE
Table 5. Monterey County Land Cover/Fuels Distribution*
Fuel Model**
Number
Description Approximate Acreage Percent Cover
1 Grass 662,270 31.3%
5 Light Brush 450,958 21.3%
2 Light Grass/Woodland 312,639 14.8%
8 Hardwood Litter 276,924 13.1%
97 Agriculture 240,714 11.4%
4 Heavy Chaparral 58,945 2.8%
28 Urban 43,525 2.1%
9 Light Conifer Litter 35,039 1.7%
98 Water 15,033 0.7%
10 Heavy Conifer Litter w/ Understory 9,007 0.4%
7 Young Maritime Chaparral 6,209 0.3%
99 Barren 5,698 0.3%
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Fuel Model**
Number
Description Approximate Acreage Percent Cover
30 Maritime Live Oak Forest 95 0.0%
6 Moderate Brush 70 0.0%
Total: 2,117,126 100.0%
*FRAP Monterey Fire Risk Analysis, 2006
** Fuel Model is a rating of vegetation and dead woody material and their volume, type, condition, arrangement,
distribution and location.
3.1.3 Climate and Weather Conditions
Localized weather patterns may vary significantly in different portions of the County as humidity
levels and plant moisture content near the coast can be higher than inland locations due to the
influence of the Pacific Ocean. The northwestern portions of the County adjacent to the Pacific
Ocean exhibit a typical coastal weather pattern with morning low clouds and fog burning off by
midday with maximum temperatures reaching over 80 degrees F. Onshore wind speeds in
excess of 15 miles per hour (mph) are normal. Several miles inland, fog and the marine layer are
typically only nominal factors, and it is not unusual for peak summer temperatures to reach 90 to
100 degrees F. In the southern and eastern (leeward side of the Santa Lucia Mountain Range)
portions of the County, clouds and fog are less prevalent, allowing maximum temperatures to
reach 90 to 100 degrees F with minimum humidities dropping to 10 percent or less (CAL FIRE
2009). Afternoon winds in the Salinas Valley and surrounding terrain may often exceed 15 mph.
Average annual rainfall in Monterey County is approximately 19 inches; however actual annual
rainfall can vary dramatically from one location to another. Fluctuations in wind patterns are
expected due to the influence of topography, although predominant wind direction is northwest
with average speeds between 7 and 10 mph (CAL FIRE 2009).
Joining of marine and land air masses over uneven topography significantly compounds fire
behavior in Monterey County. Erratic fire behavior due to rapidly shifting winds and humidities
under "normal" conditions is common. Fire behavior under rare or extreme fire weather
conditions constitute the greatest threat of destructive uncontrolled wildland fires, and
historically are immune to planned tactical response and aggressive initial attack. During
extreme fire-weather conditions, fuel factors like age, density and moisture content may be
overshadowed by weather factors such as high wind and low humidity.8 Nevertheless, under the
same weather conditions, higher fuel loads in a given vegetation type will generally result in fires
that are more difficult to suppress and have higher heat intensity. Given that humans cannot
control weather, and that fuel density is largely within our control, this MCCWPP emphasizes
hazardous fuel reduction and reduction of structural ignitability as the primary means of
addressing the destructive force of wildfire. However, the importance of weather should not be
ignored. Fire planning and fuel treatments should assume worst case weather conditions, or risk
loss of life and property and harm to the environment in the event of wildfire during extremely
adverse weather conditions.
8 Spatiotemporal Analysis of Controls on Shrubland Fire Regimes: Age Dependency and Fire Hazard, Max Moritz,
Ecology, 2003, volume 84, number 2, p. 359.
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During warmer and drier offshore wind flow regimes, which occur several times each year, wind
patterns shift from onshore northwest to offshore east-northeast in the northern section of the
County, and east-southeast in the southern portions of the County, often with above-average
velocities. These conditions are associated with "Severe Fire Weather" and "Red Flag" fire
warnings.
3.1.4 Fire History
Fire history is an important component in understanding fire frequency, fire type, significant
ignition sources, and vulnerable areas/communities. The topography, vegetation, and climatic
condition associated with Monterey County combine to create a unique situation capable of
supporting large-scale, often damaging wildfires. The history of wildfires in Monterey County is
significant, and is graphically portrayed in Appendix B-3.
Based on historical fire perimeter data (FRAP 2008),9 portions of the County are more
susceptible to wildfires, with some areas having burned up to six times during the recorded fire
history period. Specifically, the western portion of the County within and adjacent to the LPNF
exhibits more frequent fires over the recorded history. Fire size within the County is also
extremely variable, with fire sizes ranging from less than 5 acres to over 100,000 acres.
A number of notable fires have occurred in WUI zones in Monterey County. Fires that occurred
under extreme fire weather or red flag conditions are the Los Laureles Fire (1970), Molera Fire
(1972) and Cherry Canyon Fire (1985). The Morse [Pebble Beach] Fire (1987), Fort Ord Escape
(2003), and the Eucalyptus Fire (2005) occurred under normal Monterey County weather
conditions. The Morse Fire burned about 160 acres, destroying 31 homes in a short period of
time and causing approximately $18,000,000 in damage.
The greatest threat to the WUI in Monterey County occurs under extreme fire weather
conditions. Areas in Monterey County share a similar risk as the Oakland Hills area, where the
Tunnel Fire in 1991 was the most destructive and deadly WUI wildfire in California history: 26
dead and 2,900 homes destroyed in less than five hours.
Notable Monterey County wildfires in the WUI and those in excess of 10,000 acres are presented
in Table 6.
Table 6. Notable Monterey County Fires
Fire Name Year Approximate Acreage Burned
Marble-Cone Fire 1977 173,000
Basin Complex Fire 2008 162,000
Big Sur Fire 1906 150,000
Kirk Fire 1999 86,000
9 Based on polygon GIS data for CAL FIRE and USFS -- fires measuring 10 acres and greater between 1950 and
2007.
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Fire Name Year Approximate Acreage Burned
Indians Fire 2008 76,000
Gorda-Rat Fire 1985 56,000
Unnamed Fire 1924 55,000
Buckeye Fire 1970 42,000
Pine Canyon Fire 1924 42,000
Cherry Fire 1985 41,000
Wild Fire 1996 26,000
Sam Jones Fire 1953 24,000
Casey Fire 1953 21,000
Unnamed Fire 1928 21,000
Tule Canyon 1942 21,000
Reliz Canyon 1942 19,000
Unnamed Fire 1944 18,000
Miller Canyon Fire 1928 18,000
Chalk Fire 2008 16,000
Unnamed Fire 1913 15,000
Rico Fire 2006 15,000
Paloma Fire 1944 14,600
Unnamed Fire 1985 14,000
Devil Fire 1954 13,000
Unnamed Fire 1913 12,000
Fort Ord Escape 2003 1500
Los Laureles 1970 450
Morse (Pebble Beach) 1987 160
The average interval between large wildfires in excess of 10,000 acres burning within Monterey
County is 7.3 years, with intervals as short as 1 year and as long as 16 years. The median
interval between such fires is 7 years. Most recently, three large fires in 2008 (the Basin
Complex Fire, the Indians Fire, and the Chalk Fire) burned over 250,000 acres within Monterey
County combined. The Basin Complex Fire (Basin Fire), the largest of these fires, started on
June 21, 2008, triggered a state of emergency announcement by Governor Schwarzenegger on
June 23, 2008, and ultimately burned over 160,000 acres, destroying 58 structures and causing 9
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injuries, before it was contained on July 27, 2008 (InciWeb 2008). Fire suppression costs for
these fires alone exceeded $200 million.
3.1.5 Population and Housing
The estimated population of Monterey County is 425,960 people within 12 incorporated cities
and unincorporated County lands (County of Monterey 2008). The largest population center is
the City of Salinas, with approximately 150,000 people, followed by unincorporated County
areas that include approximately 106,000 people. Other relatively large cities in the County
include Seaside (approximately 34,000 people), Monterey (approximately 30,000 people), and
Soledad (approximately 28,000 people). The remaining population is spread out among the
remaining eight cities. The County includes approximately 138,000 housing units (US Census
2008).
Table 7. Monterey County Housing Density
Housing Density* Approximate Acreage Percent
One unit per 40 acres, or less 2,019,515 95.4%
One unit per 5 acres to one unit per
20 acres
37,162 1.8%
One unit per acre to one unit per 5
acres
22,131 1.0%
Greater than one unit per acre 38,318 1.8%
Total: 2,117,126 100.0%
* FRAP Monterey Fire Risk Analysis, 2006
3.1.6 Land Ownership
Over 70 percent of the land within Monterey County is privately owned. Other significant
ownership includes the USFS - LPNF (14.3 percent), U.S. Army installations (9.7 percent), and
the Bureau of Land Management (1.9 percent). The current distribution of land ownership
within Monterey County is presented in Table 8. Land ownership distribution for Monterey
County is presented in the Land Ownership map in Appendix B-4.
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Table 8. Monterey County Land Ownership
Ownership Type* Approximate Acreage Percent
Private 1,512,658 71.5%
USFS (LPNF) 302,627 14.3%
US Army (Fort Ord, Presidio, Fort
Hunter Liggett, Camp Roberts)
204,460 9.7%
BLM 40,555 1.9%
California State Parks 26,005 1.2%
City/County Park 22,741 1.1%
CDFG 3,318 0.2%
California State Lands Commission 2,948 0.1%
NPS (Pinnacles National Monument) 1,190 0.1%
US Navy 581 >0.0%
Other Military 43 >0.0%
Total: 2,117,126 100.0%
*FRAP Land Ownership data, 2008
3.1.7 Unique Community Conditions
3.1.7.1 Uniformity of Ingress and Egress Safety
Safety of ingress and egress is not uniform in all areas. It is possible that some communities may
become trapped without the option to evacuate, forcing them to shelter in place and defend
themselves. Examples are Big Sur coast, Palo Colorado, Partington Ridge, Los Burros Road,
Cachagua and White Rock.
3.1.7.2 Unique Values and Level of Preparedness
Certain communities have shown increased interest in higher levels of preparedness and
involvement in protecting their property. The California Constitution provides the following:
All people are by nature free and independent and have inalienable rights. Among these
are enjoying and defending life and liberty, acquiring, possessing, and protecting
property, and pursuing and obtaining safety, happiness, and privacy.
CAL FIRE's policy is Ready, Set, Go! (see Appendix C). While early evacuation is the safest
option, there may be times when homeowners cannot evacuate or choose not to evacuate. It
cannot be overemphasized that creation of defensible/survivable space and the use of firewise
materials and firesafe practices are extremely important for reducing risk in the event a
homeowner cannot, or chooses not to evacuate. An excellent resource for firewise information
can be found at http://firecenter.berkeley.edu/toolkit/homeowners.html.
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3.1.8 Fire Threat
Based on vegetation/fuel distribution, topography, and fire history, fire threat was evaluated for
Monterey County during the 2006 FRAP/MFSC analysis. This analysis characterizes fire threat
as the summation of fire probability (based on fire history) and hazard or expected fire behavior
(based on fuels, weather, topography and on-the-ground fire experience). The FRAP fire threat
analysis rates areas of the County into five separate categories, including little/none, moderate,
high, very-high, or extreme. Table 9 presents fire threat acreages for Monterey County, while
the map in Appendix B-5 graphically presents the distribution of fire threat ratings across the
County. It is important to note that 83.5 percent of Monterey County's land area is categorized
as high, very-high, or extreme fire threat.
Table 9. Monterey County Fire Threat
Fire Threat Rating* Acreage Percent
Little to None 261,698 12.4%
Moderate 87,911 4.2%
High 719,366 34.0%
Very-High 646,759 30.5%
Extreme 401,394 19.0%
Total: 2,117,127 100.0%
* FRAP Monterey Fire Risk Analysis, 2006
3.2 Existing Fire Plans
The following sections describe existing fire management plans prepared by agencies and/or
local districts that affect fuel management activities in Monterey County.
3.2.1 California Department of Forestry and Fire Protection (CAL FIRE)
The 2009 Fire Plan10 prepared by CAL FIRE San Benito – Monterey Unit (BEU) addresses the
goals and objectives set forth in the California Fire Plan, focusing on overall wildfire risk
reduction at a local level (CAL FIRE 2009). The Plan outlines local stakeholders, discusses the
local fire environment, evaluates assets at risk, and identifies priority fuel treatment areas.
The priorities outlined in this MCCWPP are intended for inclusion in future CAL FIRE BEU fire
plan updates.
3.2.2 Bureau of Land Management (BLM)
The BLM Hollister Fire Management Plan (FMP) presents fire management strategies for BLM
land in Monterey County (BLM 2008). It identifies resource values and conditions pertaining to
fire management on BLM land and recommends strategies for wildland fire suppression,
10 Online at: http://cdfdata.fire.ca.gov/fire_er/fpp_planning_plans_details?plan_id=95
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prescribed fire, non-fire hazardous fuels treatment, and community assistance/protection. The
strategies outlined in the BLM FMP are utilized in preparing the annual agency work plan and
associated budgets. Management guidelines in the FMP prioritize public/firefighter safety,
reduction of hazardous fuels, and wildfire risk reduction through prevention, mitigation,
education, and other actions.
The FMP also identifies and describes BLM-specific fire management units (FMU) and provides
target hazardous fuel treatment objectives, treatment types, special conditions, and at-risk
communities/assets associated with each FMU. Table 10 summarizes the BLM FMU
characteristics and management objectives within Monterey County.
Table 10. BLM FMU Characteristics and Objectives in Monterey County
Fire
Management
Unit/ID
BLM
Acreage
Fuel Type/
Fuel Model
Target Rx
Burn
Acreage
Target
Mechanical
Treatment
Acreage
Comments
Fort Ord BLM
Land FMU
CA-190-02
7,253 Maritime
chaparral
Fuel Model 4
500 ac.
(annual);
5,000 ac.
(decadal)
500 ac.
(annual);
5,000 ac.
(decadal)
Former Fort Ord military base.
Habitat Management Plan
(HMP)-covered species present.
Rx burns in 1997, 2003, 2005.
At-risk communities: Del Rey
Oaks, Marina, Salinas, Sand City,
and Seaside.
Sierra de
Salinas,
Williams Hill
FMU
CA-190-09
23,581 California
chaparral
Fuel Model 4
100 ac.
(annual);
1,000 ac.
(decadal)
100 ac.
(annual);
1,000 ac.
(decadal)
Monterey knobcone pine present
in FMU.
At-risk values: oil/gas reserves,
habitat, communication sites,
sensitive plant species.
Parkfield FMU
CA-190-10
5,099 California
chaparral and
grassland
Fuel Model 4
and 1
1,000 ac.
(annual);
5,000 ac.
(decadal)
1,000 ac.
(annual);
5,000 ac.
(decadal)
Rugged terrain in Diablo Range.
At-risk values: oil/gas reserves,
communication site at Charley
Mountain, fire lookout at Smith
Mountain, homes.
Ventana
Contiguous
WSA FMU
CA-190-11
655 California
chaparral
Fuel Model 4
100 ac.
(annual); 500
ac. (decadal)
none Steep terrain, adjacent to LPNF.
At-risk values: City of Carmel,
White Rock gun club adjacent to
the west side of FMU, habitat,
LPNF, Rancho San Clemente and
Santa Lucia Preserve (wildlife
preserve and residential
community), Palo Corona/
Monterey Peninsula Regional
Parks District.
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3.2.3 United States Forest Service (USFS)
The 2008 LPNF Fire Management Plan is a strategic document that addresses the fire
management program and guides fire management activities based on the 2006 Los Padres
National Forest Land Management Plan (LPNF Management Plan). The Monterey Ranger
District, responsible for management of USFS lands in Monterey County, segregates areas of the
National Forest into two primary Fire Management Units (FMU) that are differentiated by
management objectives, fire suppression expectations, and values at risk. The Developed and
General Forest unit (FMU1) encompasses the majority of at-risk communities identified through
the National Fire Plan, which focuses on public and firefighter safety, cost containment, and full
suppression as primary objectives.
Fire prevention planning and management within FMU1 focuses on maintaining defensible
space around structures/improvements, and strategically treating hazardous fuels to interrupt fire
spread and enhance suppression efforts.
The Wilderness, Research, Natural, and Special Interest Areas (FMU2) are generally removed
from developed areas and focus primarily on public and firefighter safety and Minimum Impact
Suppression Tactics (MIST), where applicable.
The USFS prepared the LPNF Management Plan and an associated Environmental Impact
Statement (EIS), and a Record of Decision (ROD) was issued in April 2006. The LPNF
Management Plan includes fire and fuel management planning as discussed further in Section
3.3.1.3.
3.2.4 Pebble Beach Community Services District
The Fire Defense Plan for the Pebble Beach Community Services District (2009 FDP) is
included in the CAL FIRE BEU Fire Plan. The 2009 FDP addresses fire and life safety related
to wildland fires within the Del Monte Forest area of Pebble Beach. The plan addresses
emergency access and hazardous fuel treatment standards for open space areas and undeveloped
vacant parcels. The plan outlines roadside fuel treatment methods, firebreak maintenance
criteria, road and access gate identification standards, environmental protection, and targets fuel
break areas.
3.2.5 Other Plans
In addition to the aforementioned plans dealing with wildland fire issues in Monterey County,
several other plans have been or are in the process of being prepared, including the following:
 Santa Lucia Preserve Fuel Management Plan. Addresses habitat-based fire management
concerns for the Santa Lucia Preserve
 Monterey County Emergency Permit, Sudden Oak Death - Permit for removal of dead
trees infected with SOD in the Palo Colorado Canyon and Big Sur areas of Monterey
County
 Aromas Tri-County FPD Fire Plan
 Big Sur Community Wildfire Protection Plan
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 Cachagua-Jamesburg Community Wildfire Protection Plan
 Carmel Highlands FPD Community Wildfire Protection Plan
 Cypress FPD Community Wildfire Protection Plan
 Mid Coast (Palo Colorado area) Community Wildfire Protection Plan
 Fort Ord
 Pinnacles National Park
 Fort Hunter Liggett
The status of the above plans can be determined by contacting CAL FIRE.
3.3 Regulatory Framework
This section discusses the complex framework of federal, state and local laws and regulations
that relate to hazardous fuel reduction work.
3.3.1 Applicable Federal Laws
3.3.1.1 Healthy Forests Restoration Act
Devastating wildfires in the western United States at the turn of this century resulted in action by
the Western Governors Association in concert with the Secretaries of Agriculture and Interior,
counties, southern governors, and tribes, to address the hazardous fuels problem at a national
level. In 2002, the Western Governors Association agreed on a plan called A Collaborative
Approach for Reducing Wildland Fire Risks to Communities and the Environment: 10-Year
Strategy.
In 2003, Congress enacted the Healthy Forests Restoration Act of 2003 (HFRA). The HFRA
improves the ability of the United States Secretary of Agriculture and Secretary of Interior to
conduct hazardous fuel reduction projects on National Forest System lands and BLM lands, to
protect communities, watersheds, and infrastructure from catastrophic wildfire. The provisions
of the HFRA include the following: (1) a streamlined National Environmental Policy Act
(NEPA) process for hazardous fuel treatments and other activities that would reduce hazardous
fuels on Federal land and, (2) incentives for local communities to prepare Community Wildfire
Protection Plans (CWPP) that prioritize where hazardous fuel reduction should take place on
Federal lands, and where federal fuel reduction funds should be expended on private lands (e.g.,
fuel reduction grants).
This MCCWPP was prepared pursuant to provisions of the HFRA, recognizing that certain large
federal land holdings influence wildfire risk to nearby state, county and private lands, and local
communities. In accordance with section 101 of the HFRA, this MCCWPP: (1) identifies and
prioritizes areas for hazardous fuel reduction treatments and recommends the types and methods
of treatment on federal and non-federal land that will protect at-risk communities, watersheds
and essential infrastructure; and (2) recommends measures to reduce structural ignitability
throughout at-risk communities. Pursuant to section 103 of the HFRA, through the preparation
of this MCCWPP and subsequent community-specific CWPPs, federal fuel reduction funding
priorities on federal and non-federal land should be allocated to protecting those at-risk
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communities described in this MCCWPP and local CWPPs, and to those hazardous fuel
reduction projects recommended priorities in Appendix D.
3.3.1.2 Wilderness Acts
Monterey County contains 290,000 acres of federal and state wilderness designated as the
Ventana Wilderness Area, Silver Peak Wilderness Area and Limekiln State Park Wilderness.
These designated wilderness areas encompass 14% of Monterey County and are located in the
northern Santa Lucia Mountains. Each wilderness area has been the subject of multiple acts of
Congress. Congressional records indicate exceptions were made to wilderness prohibitions so
that these wilderness areas can and will be managed to protect communities and watersheds from
wildfire.
3.3.1.2.1 Wilderness Act of 1964
The Wilderness Act of 1964 (Wilderness Act) states as follows:
In order to assure that an increasing population, accompanied by expanding
settlement and growing mechanization, does not occupy and modify all areas
within the United States and its possessions, leaving no lands designated for
preservation and protection in their natural condition, it is hereby declared to be
the policy of the Congress to secure for the American people of present and future
generations the benefits of an enduring resource of wilderness. Wilderness
areas…shall be administered for the use and enjoyment of the American people in
such matter as will leave them unimpaired for future use as wilderness, and so as
to provide for the protection of these areas, the preservation of their wilderness
character and for the gathering and dissemination of information regarding their
use and enjoyment as wilderness…
Wilderness is defined under Section 2(c) of the Wilderness Action of 1964 as follows:
A wilderness, in contrast with those areas where man and his own works
dominate the landscape, is hereby recognized as an area where the earth and its
community of life are untrammeled by man, where man himself is a visitor who
does not remain. An area of wilderness is further defined to mean in this Act an
area of undeveloped Federal land retaining its primeval character and influence,
without permanent improvements or human habitation, which is protected and
managed so as to preserve its natural conditions and which (1) generally appears
to have been affected primarily by the forces of nature, with the imprint of man's
work substantially unnoticeable; (2) has outstanding opportunities for solitude or
a primitive and unconfined type of recreation; (3) has at least five thousand acres
of land or is of sufficient size as to make practicable its preservation and use in an
unimpaired condition; and (4) may also contain ecological, geological, or other
features of scientific, educational, scenic, or historical value.
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The Wilderness Act of 1964 (Wilderness Act) generally prohibits use of motor vehicles and
motorized equipment within wilderness areas.
However, the Wilderness Act also provides a special provision for "fire, insects and diseases"
and for administration and personal heath and safety emergencies as exceptions to its
prohibitions as follows: 11
Prohibition provisions: commercial enterprise, permanent or temporary roads, mechanical
transports, and structures or installations; exceptions: area administration and personal
health and safety emergencies. Except as specifically provided for in this Act [16 USCS
§§ 1131 et seq.], and subject to existing private rights, there shall be no commercial
enterprise and no permanent road within any wilderness area designated by this Act [16
USCS §§ 1131 et seq.] and, except as necessary to meet minimum requirements for the
administration of the area for the purpose of this Act [16 USCS §§ 1131 et seq.]
(including measures required in emergencies involving the health and safety of persons
within the area), there shall be no temporary road, no use of motor vehicles, motorized
equipment or motorboats, no landing of aircraft, no other form of mechanical transport,
and no structure or installation within any such area. (16 USCS § 1133(c).)
3.3.1.2.2 The Endangered American Wilderness Act of 1978
The Endangered American Wilderness Act of 1978 (Wilderness Act of 1978) builds upon the
above referenced exceptions in the Wilderness Act, applying additional exceptions for fire
presuppression measures and techniques specifically to the Ventana Wilderness to guarantee the
continued viability of watersheds and the continued health and safety of communities. The
Wilderness Act of 1978 reads in pertinent part as follows (emphasis added):12
In order to guarantee the continued viability of the Ventana watershed and to
insure the continued health and safety of the communities serviced by such
watershed, the management plan for the Ventana area to be prepared following
designation as wilderness shall authorize the Forest Service to take whatever
appropriate actions are necessary for fire prevention and watershed protection
including, but not limited to, acceptable fire pre-suppression and fire suppression
measures and techniques. Any special provisions contained in the management
plan for the Ventana Wilderness area shall be incorporated in the planning for the
Los Padres National Forest. …
Specific to forest fires, the report on the Wilderness Act of 1978 by the Senate Committee on
Energy and Natural Resources reads in pertinent part as follows (emphasis added):13
Due to the extreme hazard of forest fires in the Los Padres National Forest, the
committee adopted the special management language for the Santa Lucia and
Ventana Wilderness areas approved by the House authorizing the Forest Service
11 16 USC 1133(d)(1); see, Sierra Club v. Lyng (1987) 663 F.Supp. 556.
12 The Endangered American Wilderness Act of 1974, section 2(d).
13 Senate Report 95-490 on H.R. 3454 (The Endangered American Wilderness Act of 1978), 95th Congress 1st
session October 11, 1977, Senate Committee on Energy and Natural Resources.
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"to take whatever appropriate actions are necessary for fire prevention and
watershed protection included [sic] but not limited to acceptable fire pre-
suppression and fire suppression measures and techniques."
3.3.1.2.3 The California Wilderness Acts of 1984
The California Wilderness Act of 1984 (State Wilderness Act of 1984) signed into law by
President Ronald Reagan on September 28, 1984 adding 2,750 acres to the Ventana Wilderness
Area
Section 103 of the State Wilderness Act of 1984 states in relevant parts as follows:
Within the National Forest wilderness areas designated by this title …as provided
in section 4(b) of the Wilderness Act, the Secretary concerned shall administer
such areas so as to preserve their wilderness character and to devote them to the
public purposes of recreational, scenic, scientific, educational, conservation, and
historical use.
Section 103(b)(2) of this Act referenced the following exception in the Wilderness Act for the
control of fire:14
As provided in subsection 4(d)(l) of the Wilderness Act, the Secretary concerned
may take such measures as are necessary in the control of fire, insects, and
diseases, subject to such conditions as he deems desirable. (Section 103(b)(2)).
Specific to addressing the threat of fire, the report by the House Committee on Interior and
Insular Affairs on the Wilderness Act of 1984 reads in pertinent part as follows (emphasis
added):15
Fire management—Due to the arid climate, high seasonal temperatures and
buildup of fuel that exists in so many California roadless areas, especially in
Southern California, fire management is a key concern. … Not only does the
threat of wildfire pose a danger to public safety, but uncontrolled fires can also
cause severe damage to watersheds, water quality and other beneficial wilderness
values.
To address this concern in the [Wilderness Act of 1984], the Committee reiterated
the fire provisions of Section 4(d)(1) of the Wilderness Act. … As the Committee
stressed … this provision is intended to grant the Forest Service with the means of
utilizing such measures or tools as it deems "necessary" and "desirable" in the
control of [sic] pre-suppression of fire in wilderness areas. In some instances, the
Forest Service has exercised this broad authority [for] fire roads, fuel breaks or
other management. … The major point to be made however, is that the
Wilderness Act permits the Forest Service to utilize measures necessary to control
14 16 USC 1133.
15 House Report 98-40 on H.R. 1437 (P.L. 98-425), 98th Congress 1st session, March 18, 1983, House Committee
on Interior and Insular Affairs.
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wildfire, or the threat of fire, in wilderness areas. Obviously, such measures
should, to the maximum extent practicable, be implemented consistent with
maintaining the wilderness character of areas, while at the same time protecting
the public health and safety and protecting private property located immediately
adjacent to wilderness areas.
3.3.1.2.4 Los Padres Condor Range and River Protection Act (1992)
The Los Padres Condor Range and River Protection Act of 1992 (Los Padres Act of 1992) was
signed into law by President George H. W. Bush on June 19, 1992 adding 38,000 acres to the
Ventana Wilderness Area and creating the 14,500 acre Silver Peak Wilderness Area.
Section 1 of the Los Padres Act of 1992 states as follows:
The Congress finds that --- (1) areas of undeveloped national Forest System lands
within the Los Padres National Forest have outstanding natural characteristics
which will, if properly preserved, contribute as an enduring resource of
wilderness for the benefit of the American people; and (2) it is in the national
interest that certain of these areas be designated as components of the National
Wilderness Preservation System and Wild and Scenic River System or reserved
from mineral entry in order to preserve such areas and their specific multiple
values for watershed preservation, wildlife habitat protection, scenic and historic
preservation, scientific research, educational use, primitive recreation, solitude,
physical and mental challenge, and inspiration for the benefit of all of the
American people of present and future generations.
In the Act, Congress sets forth the following exceptions to the Wilderness Act prohibitions
which allow for fire pre-suppression measures within wilderness in order to protect watersheds
and communities. Section 3(b) of the Los Padres Act of 1992 reads as follows (emphasis
added):
FIRE PREVENTION AND WATERSHED PROTECTION —In order to
guarantee the continued viability of the watersheds of the wilderness areas
designated by this Act and to ensure the continued health and safety of the
communities serviced by such watersheds, the Secretary of Agriculture may take
such measures as are necessary for fire prevention and watershed protection
including, but not limited to, acceptable fire pre-suppression and fire suppression
measures and techniques.
3.3.1.2.5 Big Sur Wilderness and Conservation Act of 2002
The Big Sur Wilderness and Conservation Act of 2002 (Wilderness Act of 2002) expanded the
Ventana Wilderness and the Silver Peak Wilderness. Congress provided exceptions to
wilderness prohibitions to allow for fire pre-suppression measures and techniques. Section 4 of
the Wilderness Act of 2002 reads as follows (emphasis added):
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SEC. 4. WILDERNESS FIRE MANAGEMENT.
(a) REVISION OF MANAGEMENT PLANS.—The Secretary of Agriculture
shall, by not later than 1 year after the date of the enactment of this Act, amend
the management plans that apply to each of the Ventana Wilderness and the Silver
Peak Wilderness, respectively, to authorize the Forest Supervisor of the Los
Padres National Forest to take whatever appropriate actions in such wilderness
areas are necessary for fire prevention and watershed protection consistent with
wilderness values, including best management practices for fire pre-suppression
and fire suppression measures and techniques.
(b) INCORPORATION INTO FOREST PLANNING.—Any special provisions
contained in the management plan for the Ventana Wilderness and Silver Peak
Wilderness pursuant to subsection (a) shall be incorporated into the management
plan for the Los Padres National Forest.
3.3.1.3 Los Padres National Forest Management Plan (LPNF Management Plan)
Consistent with the Wilderness Act of 1978 and the Wilderness Act of 2002, the USFS prepared
the LPNF Management Plan. An EIS and a ROD was adopted for the LPNF Management Plan
in April 2006. The ROD includes the following language to describe the overall intent of the
plan:
[W]e will be doing fuels work in the Wildland/Urban Interface (WUI) Defense
and Threat zones for community protection. In these areas, the emphasis is on
vegetation treatments that are expected to create conditions allowing fire fighters
to work safely in the area. Wildlife habitat requirements are still an emphasis.
However, to be absolutely clear, the protection of human life and property is our
highest priority. While we do the work in the WUI Defense and Threat zones, we
will try to maintain habitat in a condition that will support the species that live
there, but we will meet the criteria for community defense. If there is a trade-off,
human life and property will be the priority.16
The LPNF Management Plan describes the WUI and WUI zones as follows:
There are extensive areas within and adjacent to the national forests of southern
California meeting the definition of Wildland/Urban Interface (WUI) as described
in the Healthy Forests Restoration Act of 2003. WUI (as defined by the Act) is a
variable width … as defined in individual community fire protection plans. This
forest plan further identifies a direct protection zone (WUI Defense Zone) and an
indirect protection zone (WUI Threat Zone) that fall within the broader definition
of WUI. A WUI Defense Zone is the area directly adjoining structures and
evacuation routes that is converted to a less-flammable state to increase defensible
space and firefighter safety. The WUI Threat Zone is an additional strip of
vegetation modified to reduce flame heights and radiant heat. The Threat Zone
generally extends approximately 1 1/4 miles out from the Defense Zone
16 Record of Decision, Los Padres National Forest Land Management Plan, page 11
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boundary. Yet, actual extents of Threat Zones are based on fire history, local fuel
conditions, weather, topography, existing and proposed fuel treatments, and
natural barriers to fire and community protection plans, and therefore could
extend well beyond the 1 1/4 mile. The two zones together are designed to make
most structures more defendable.17
The EIS for the LPNF Management Plan analyzed impacts well beyond the 1 1/4 mile distance
for WUI Threat Zone18 The LPNF Management Plan includes fire and fuel management
planning. Forest Goal 1.2 discusses community protection through vegetation treatment in the
WUI and strategically located fuelbreaks and associated burns. The LPNF Management Plan
also states that existing fuelbreaks are to be maintained using prescribed fire, fireline explosives,
grazing, herbicide or mechanical methods.19
3.3.1.4 National Environmental Policy Act (NEPA)
The purpose of the NEPA is to declare a national policy that will encourage productive and
enjoyable harmony between man and his environment; to promote efforts which will prevent or
eliminate damage to the environment and biosphere, and stimulate the health and welfare of
man; to enrich the understanding of the ecological systems and natural resources important to the
Nation; and to establish a Council of Environmental Quality.20
Any proposed hazardous fuel treatment projects on federal land or requiring federal discretionary
approval will require compliance with NEPA. Hazardous fuel reduction treatments on non-
federal land that do not use federal funding and do not require federal discretionary approval
generally do not require NEPA review. If NEPA review applies, projects implementing a
hazardous fuel reduction recommendation in a CWPP on Federal land, that is within a WUI, or
within 1.5 miles of an at-risk community, are afforded expedited NEPA review under the HFRA.
Further environmental review under NEPA may be required by the USFS prior to the USFS’s
implementation of individual projects in the LPNF Management Plan.
Moreover, hazardous fuel reduction treatments recommended for USFS and BLM land in a
CWPP must be considered in the NEPA analysis by the USFS or BLM as an alternative to the
agency's proposed project. As provided by the HFRA, if a federal fuel reduction project is
within a WUI, but more than 1.5 miles from the at-risk community's boundary, only one
alternative other than the proposed project is required to be considered.21 If the hazardous fuel
reduction project is within 1.5 miles of the boundary of the at-risk community, an alternative to
the proposed project is not required to be considered, unless the proposed agency action does not
implement the recommendations in an adopted CWPP "for the same general location and basic
17 Appendix K, Guidelines for Development and Maintenance of WUI Defense and Threat Zones, page 81 in Part
3, Design Criteria for Southern California National Forests, of the Land Management Plan [for the Los Padres
National Forest, 2005].
18 Final Environmental Impact Statement, Volume 1, Land Management Plan [for the Southern California National
Forests], page 315.
19 Page 22, Los Padres National Forest Land Management Plan, Part 2, Los Padres National Forest Strategy.
20 42 USC 4321
21 Note that without this provision, 2 or more alternatives must be considered, one of which must be a "no action"
alternative.
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method of treatments", in which case the recommendations in the CWPP should be evaluated as
an alternative to the proposed agency action in accordance with HFRA.22 This streamlined
NEPA process does not apply to certain hazardous fuel reduction treatments within wilderness
areas. The USFS prepared the LPNF Management Plan and an associated EIS, and a ROD was
issued in April 2006. The key community protection factors in the ROD for the LPNF
Management Plan are stated in the ROD as follows:23
 Emphasizes the protection of lives and property;
 Includes the flexibility to adjust WUIs according to CWPPs; and
 Retains access.
The LPNF Management Plan also discusses the maintenance of existing fuelbreaks using
prescribed fire, fireline explosives, grazing, herbicides or mechanical methods. Herbicide use
may delay need for mechanical treatment, especially when there is a diminished workforce. The
Departments of Agriculture and Interior enacted categorical exclusions to NEPA for hazardous
fuel reduction activities and rehabilitation activities for lands and infrastructure impacted by fires
or fire suppression.24 The categorical exclusions are limited to (1) those activities identified
through a collaborative framework as described in the 10-Year Comprehensive Strategy
Implementation Plan; (2) fuel reduction activities that are within a WUI, or, if outside the WUI,
in Condition Classes 2 or 3 in Fire Regime Groups I, II, or III; (3) hazardous fuels reduction
activities using fire, limited to 4,500 acres; (4) mechanical hazardous fuels reduction activities,
limited to 1,000 acres; (5) fuel reduction and rehabilitation activities that are not in wilderness
areas or where they would impair the suitability of wilderness study areas for preservation as
wilderness; and (6) fire rehabilitation activities of not more than 4,200 acres. At the time of this
writing (September 2010), certain categorical exclusions were under legal challenges.
3.3.1.5 Federal Endangered Species Act (ESA)
The purposes of the ESA are to provide a means whereby the ecosystems upon which
endangered and threatened species depend may be conserved; to provide a program for the
conservation of such endangered and threatened species; and to take such steps as may be
appropriate and practicable pursuant to various international treaties and conventions.25
Section 7 of the ESA requires federal agencies, such as the U.S. Fish & Wildlife Service
(USFWS), to ensure that any action authorized, funded or carried out by them is not likely to
jeopardize the continued existence of listed species or modify their critical habitat. Section 9 of
the ESA provides that it is unlawful for any person subject to the jurisdiction of the United States
to take, possess, deliver or sell any species that has been listed as threatened or endangered
pursuant to the ESA.26
22 Title 16 USC 6514(d).
23 Record of Decision, Los Padres National Forest Land Management Plan, page 5.
24 Federal Register, Vol. 68, No. 108, June 5, 2003.
25 16 USC 1531 (a) & (b).
26 16 USC 1538. The term "take" means to, "harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or
collect, or to attempt to engage in any such conduct." (16 USC 1532(19).)
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In accordance with the ESA, hazardous fuel reduction activities proposed in this MCCWPP must
avoid a taking of federally listed threatened or endangered species, or, if a take cannot be
avoided, the take must be authorized pursuant to the ESA. The USFWS has the authority to
allow the take of threatened or endangered species or impacts to their critical habitat incidental to
fire prevention/protection activities.27
3.3.2 Applicable State Laws
3.3.2.1 California Constitution
Article 1, Section 1 of the California Constitution reads as follows:
All people are by nature free and independent and have inalienable rights.
Among these are enjoying and defending life and liberty, acquiring, possessing,
and protecting property, and pursuing and obtaining safety, happiness, and
privacy.
While no rights are absolute, fundamental rights such as the rights to defend life, protect
property, and pursue and obtain safety, may be infringed only to the minimum extent necessary
to promote a compelling government interest.
3.3.2.2 Division 4 of California Public Resources Code (PRC) – Forests,
Forestry and Range and Forage Lands
3.3.2.2.1 Board of Forestry and Fire Protection and Department of Forestry and
Fire Protection (CAL FIRE)
The Board of Forestry and Fire Protection (Board of Forestry) is a government-appointed body
within CAL FIRE. The Board of Forestry is responsible for developing the general forest policy
of the state, for determining the guidance policies of CAL FIRE, and for representing the state's
interest in federal forestland in California. Together, the Board of Forestry and CAL FIRE work
to carry out the California Legislature's mandate to protect and enhance the state's unique forest
and wildland resources.
The Board of Forestry is charged with protecting the forest resources of all the wildland areas of
California that are not under federal jurisdiction. These resources include: major commercial
and non-commercial stands of timber, areas reserved for parks and recreation, the woodland and
brush-range watersheds, and all such lands in private and state ownership that contribute to
California's forest resource wealth.28
Under California Public Resources Code (PRC) section 4111, the Board of Forestry has the
authority to "make and enforce such regulations as are necessary and proper for the organization,
27 For example, a memorandum of understanding (MOU) was executed by and between USFWS, the California
Department of Fish and Game (CDFG), CAL FIRE and other fire agencies and districts for hazardous fuel reduction
activities in San Diego County.
28 http://www.bof.fire.ca.gov/about_the_board/
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maintenance, government, and direction of the fire protective system for the prevention and
suppression of forest fires."
3.3.2.2.2 State Responsibility Areas (SRA)
PRC section 4102 defines the term "State Responsibility Areas" (SRAs) as "the areas of the state
in which the financial responsibility of preventing and suppressing fires has been determined by
[CAL-FIRE] ... to be primarily the responsibility of the state." (Emphasis added.)
Lands in SRAs include:
1. Lands covered wholly or in part by forests or by trees producing or capable of producing
forest products.
2. Lands covered wholly or in part by timber, brush, undergrowth, or grass, whether of
commercial value or not, which protect the soil from excessive erosion, retard runoff of
water or accelerate water percolation, if such lands are sources of water which are
available for irrigation or for domestic or industrial use.
3. Lands in areas which are principally used or useful for range or forage purposes, which
are contiguous to the lands described in subdivisions (a) and (b) Division 4 of the PRC,
Forests, Forestry and Range and Forage Lands, which contains statutes related to fuel
reduction on certain land.29
The map in Appendix B-6 shows that most of Monterey County is within SRA.
3.3.2.2.3 Title 14 CCR 1299 and Defensible Space Guidelines
In 2006, the Board of Forestry promulgated a regulation to implement the defensible space
provisions of PRC section 4291. The regulation was codified in Title 14, section 1299 of the
California Code of Regulations (14 CCR 1299).
14 CCR 1299(b) provides the following specific mandatory language: "Any vegetation fuels
identified as a fire hazard by the fire inspection official of the authority having jurisdiction shall
be removed or modified provided it is required by subsection (a)(1) & (a)(2)."
Subsections (a)(1) and (a)(2) state as follows:
(a) A person that owns, leases, controls, operates, or maintains a building or
structure in, upon, or adjoining any mountainous area, forest-covered lands,
brush-covered lands, grass-covered lands, or any land that is covered with
flammable material, and is within State Responsibility Area, shall do the
following:
(1) Within 30 feet from each building or structure, maintain a firebreak by
removing and clearing away all flammable vegetation and other combustible
growth pursuant to PRC § 4291(a). Single specimens of trees or other
29 PRC section 4126.
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vegetation may be retained provided they are well-spaced, well-pruned, and
create a condition that avoids spread of fire to other vegetation or to a building
or structure.
(2) Within the 30 feet to 100 feet zone (Reduced Fuel Zone) from each building
or structure (or to the property line, whichever is nearer to the structure),
provide a fuelbreak by disrupting the vertical and/or horizontal continuity of
flammable and combustible vegetation with the goal of reducing fire intensity,
inhibiting fire in the crowns of trees, reducing the rate of fire spread, and
providing a safer environment for firefighters to suppress wildfire pursuant to
PRC § 4291(b).
Subsection (c) broadens and adds flexibility to CAL FIRE's authority by stating the following:
Within the intent of the regulations, the fire inspection official of the authority
having jurisdiction may approve alternative practices which provide for the same
practical effects as the stated guidelines.
The creation of defensible space is a requirement subject to penalties if property owners do not
comply with the mandatory requirement.
14 CCR 1299(c) also references a guidance document for implementation of this regulation,
which is entitled, General Guidelines for Creating Defensible Space (Guidelines), as published
by the Board of Forestry by resolution adopted on February 8, 2006. The Guidelines provide
criteria intended to instruct individuals and fire officials on acceptable ways to comply with
14 CCR 1299, and are incorporated into section 14 CCR 1299 by reference. See Appendix E for
the Guidelines.
3.3.2.2.3.1 California Environmental Quality Act (CEQA) Review of 14 CCR 1299
and Guidelines
The Board of Forestry considered adoption of 14 CCR 1299 and its associated Guidelines a
"project" subject to CEQA (Project), and the scope of the CEQA review was the Project's
ultimate effect on the environment. Generally, CEQA defines the term "project" as an activity
carried out, supported by, or authorized by a public agency, "which may cause either a direct
physical change in the environment, or a reasonably foreseeable indirect physical change in the
environment. ..."30 CEQA is discussed further in Section 3.3.2.4 of this MCCWPP.
At the time of the Board of Forestry's adoption of the Guidelines on February 8, 2006, the Board
of Forestry deliberated on the issue of CEQA and concluded that the Class 4 categorical
exemption applied and that the Project "is consistent with the CEQA statutory exemption under
section 21080(b)(4) specifying that actions [are] necessary to prevent or mitigate an
emergency."31
30 PRC section 21065; 14 CCR 15378(a).
31 Item 9 of Meeting Minutes.
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3.3.2.2.4 Public Resources Code Section 4291 (PRC 4291)
PRC 4291 requires that any person who owns, leases, controls, operates, or maintains a building
or structure in, upon, or adjoining a mountainous area, forest-covered lands, brush-covered lands,
grass-covered lands, or land that is covered with flammable material, shall maintain defensible
space of 100 feet from each side and from the front and rear of the structure, or as further
provided in PRC 4291, but not beyond the property line unless allowed by state law, local
ordinance, or regulation, and with the consent of the adjacent landowner.
The statute provides that the amount of fuel modification necessary shall take into account the
flammability of the structure as affected by building material, building standards, location, and
type of vegetation.
PRC 4291 provides that a distance greater than 100 feet may be required by state law, local
ordinance, rule, or regulation, with limitations on requiring fuel modification beyond the
property line, including consent by the adjacent landowner.
PRC 4291 also provides that an insurance company that insures an occupied dwelling or
occupied structure may require a greater distance if a fire expert, designated by the Director of
Forestry and Fire Protection, provides findings that such hazardous fuel reduction is necessary to
significantly reduce the risk of transmission of flame or heat sufficient to ignite the structure, and
there is no other feasible mitigation measure possible to reduce the risk of ignition or spread of
wildfire to the structure. The greater distance may not be beyond the property line unless
allowed by state law, local ordinance, rule, or regulation. The statute also requires other
hazardous fuel reduction measures, such as a minimum distance of 10 feet between trees and the
outlet of a chimney or stovepipe.
PRC 4291 further provides that the Director of Forestry and Fire Protection may authorize
removal of vegetation that is not consistent with the standards of PRC 4291.
PRC section 4291.1 describes the penalties for PRC 4291 violations. Penalties range from a fine
of not less than $100, to not less than $500, depending upon the number of violations during a
five year period. PRC section 4291.1 also provides that under certain conditions, CAL FIRE
may contract to have hazardous fuel reduction work done and bill the person convicted of the
violation for the cost of the work.
3.3.2.2.5 Access Roads
Under 14 CCR 1273, all road and street networks, whether public or private (unless exempt),
must provide safe access for emergency equipment and civilian evacuation concurrently. There
are roads that do not meet this standard and cannot feasibly be upgraded. Fuel reduction along
access roads is a necessary maintenance activity in order to provide safe access for fire
equipment and resident evacuation during fires. Emergency access is part of defensible space.32
32 The Guidelines adopted to implement PRC 4291 define Defensible Space to include emergency vehicle access;
"Defensible space: … The area is characterized by the establishment and maintenance of emergency vehicle access.
…" (General Guidelines for Creating Defensible Space, 2006, page 3.)
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3.3.2.3 California Coastal Act (CCA) and Local Coastal Programs
The California Coastal Commission (CCC) was established temporarily by voter initiative in
1972 (Proposition 20) and later made permanent by the Legislature through adoption of the
California Coastal Act (CCA). The CCA serves as a comprehensive planning and regulatory
program to manage conservation and development within the California coastal zone.
The California Coastal Commission (CCC), in partnership with coastal cities and counties, plans
and regulates the use of land in the coastal zone. The California Coastal Act (CCA) provides
that land uses that meet its definition of "development"33 require a coastal development permit
(CDP) from either the CCC or the local government that has been delegated permitting
authority.34 As relevant here, the term "development" in the CCA includes the following
definition: "Development" means… the removal or harvesting of major vegetation …35
(Emphasis added.)
Monterey County has been delegated CDP permitting authority through the adoption and
certification of Local Coastal Programs (LCP). However, the CCC retains appellate authority.
The need for a CDP is reviewed against the policies of the certified LCP. Monterey County has
divided its portion of the coastal zone into four separate coastal planning areas: (1) Big Sur, (2)
North County, (3) Carmel, and (4) Del Monte Forest. Each coastal planning area has its own
coastal land use plan and coastal implementation plan. When adopted and certified, these coastal
plans underwent environmental review that was the functional equivalent of CEQA, and CEQA
review was therefore not required.36 The following sections discuss policies related to fire
prevention and protection in these four coastal land use plans, which are in certified LCPs.
3.3.2.3.1 Big Sur Coast Land Use Plan (Big Sur LUP) and Implementation Plan
(Big Sur CIP)
The Big Sur LUP recognizes that the entire Big Sur area is "subject to fire hazard to life,
property, vegetation, and wildlife."37 The Big Sur LUP cautions, "Fire danger is ever present in
summer and can be extremely hazardous for residents."38
In addition to numerous policies for new development in the Big Sur LUP, the plan provides the
following broad policy to support fire protection agencies:
Monterey County should support and assist the efforts of the various fire
protection agencies and districts to identify and minimize fire safety hazards to
the public. (Big Sur LUP Policy 3.7.3.C.5.)
33 PRC section 30106 for the CCA's definition of development.
34 PRC sections 30106, 30101.5 and 30600(a).
35 PRC section 30106
36 The CCC obtained certification from the Secretary of Resources that its regulatory program is the functional
equivalent of CEQA in 1979, and the LCP approval process has been exempt from EIR requirements ever since.
Santa Barbara County Flower and Nursery Growers Association, Inc. v. County of Santa Barbara, (2004) 121
Cal.App.4th 864; Title 14 CCR section 15251, subdivision (f); Title 14 CCR section 15265.
37 Page 40, Big Sur LUP.
38 Page 6, Big Sur LUP
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As stated in Section 3.3.2.3, the term "development" in the CCA includes the removal or
harvesting of major vegetation. Big Sur LUP Policy 5.4.2.13 states as follows (emphasis added):
A coastal development permit must be obtained for the removal of trees and other
major vegetation. However, in the Big Sur Coast area, the following will not be
considered as removal of major vegetation:
a. Removal of non-native or planted trees, except where this would result [in]
the exposure of structures in the critical viewshed;
b. Removal of hazardous trees which pose an imminent danger to life or
property, or threaten contagion of nearby forested areas, subject to verification
by the County or California Department of Forestry;
c. Thinning of small (less than 12" diameter) or dead trees from density [sic]
forested areas, especially as needed to reduce unsafe fuel accumulations
adjacent to existing occupied buildings; and,
d. Prescribed burning, crushing, lopping or other methods of brush clearing
which do not materially disturb underlying soils.
The Big Sur CIP mimics the language of Policy 5.4.2.13 in its Forest Resources Development
Standards (Big Sur CIP section 20.145.060.) The Big Sur CIP's Forest Resources Development
Standards provide development standards for the protection and maintenance of Big Sur's forest
resources. Section 20.145.060 of the Forest Resources Development Standards states as follows:
"A coastal development permit must be obtained for the removal of trees and other major
vegetation with the following exceptions…." (Emphasis added.) The same subsections (a
through d) provided in Policy 5.4.2.13 of the Big Sur LUP follows that sentence.39
3.3.2.3.2 North County Land Use Plan (North County LUP) and Implementation
Plan (North County CIP)
The North County LUP recognizes the high dangers of wildland fires in North County. It states,
"Wildland fires are a danger to lives and property, and continued residential development in
North County increases the risk of fire."40 The North County LUP acknowledges that "most of
North County has a moderate to high fire potential because of its vegetation or 'heavy' fuel
loading."41
To address the heavy fuel loads in North County, North County LUP Policy 2.3.3.A.2 provides
the following:
A fuel reduction program should be developed for North County's oak woodland
and chaparral to reduce the potential risk of wildfires, to maintain the vigor of
plant communities, and to maintain the diversity and value of habitat areas.
39 To the extent the language in the CIP fails to implement the language in the LUP, the language in the LUP
controls.
40 Page 50, North County LUP.
41 Page 50, North County LUP.
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Controlled burning should be strictly limited and managed in maritime chaparral
areas.
Policy 2.8.3.C.5 of the North County LUP states the following to maintain fire access in North
County:
Roads serving residential development in high fire hazard areas shall be adequate
to serve emergency equipment.
Finally, Policy 2.8.3.C.7 provides the following broad provision to support fire agencies and
districts in North County:
Monterey County should support the efforts of the various fire protection agencies
and districts to identify and minimize fire safety hazards to the public.
North County CIP Policy 20.144.050.A.1 states the following:
A coastal development permit must be obtained for the removal of trees and other
major vegetation with the following exceptions:
a. Removal of non-native or planted trees, except where this would be ridgeline
tree removal as per Section 20.144.050.D.8 or where the trees are considered
to be of significant or landmark status, as defined in Section 20.144.050.D.1;
b. Removal of hazardous trees which pose an immediate danger to life or
structures;
c. Removal of native trees less than 12" diameter when measured at breast
height, or removal of oak trees less than 6" in diameter measured 2 feet above
the ground, or removal of marine trees less than 6" in diameter measured at
breast height; and prescribed burning, crushing, lopping, or other methods of
clearing brush which do not materially disturb underlying soils.
3.3.2.3.3 Carmel Area Land Use Plan (Carmel LUP) and Implementation Plan
(Carmel CIP)
The Carmel LUP recognizes the high risk of damage to life and property from fires in the
unincorporated areas of Carmel as follows: "Poor roads and limited accessibility in areas of
rugged terrain such as steep mountain slopes and canyons increase the response time for
firefighting equipment and may hinder escape. The risk of damage to life and property,
therefore, is more severe and fire control more difficult."42
In addition to numerous policies set forth for new development, the Carmel LUP Policy 2.7.4.5
provides the following broad policy to support the fire protection agencies and districts in the
Carmel area:
42 Page 54 Carmel LUP.
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Monterey County should support and assist the efforts of the various fire
protection agencies and districts to identify and minimize fire safety hazards to
the public.
Moreover, the following General Policy 2.5.3.9 of the Carmel LUP addresses hazardous fuel
reduction activity in the Carmel area:
Fuel hazard reduction and prescribed burning shall be considered acceptable
management techniques for forested areas in private or public ownership where
such action will enhance the vigor of the forest habitat or will reduce hazardous
fuel loads.
Recommended Action 2.3.5.7 in the Carmel LUP recommends the following activities to reduce
fuel loads in certain areas of unincorporated Carmel:
To reduce accumulated fuel loads, maintain the health and vigor of the pine and
cypress forests, facilitate reproduction of the Gwen and Monterey cypress, and
reduce the spread of Monterey pine into certain areas such as Northern Coastal
Prairie, the State Department of Parks and Recreation should develop a fuel
hazard reduction and prescribed burning program. Such a program should not be
executed, however, until it is proven practical and prudent. In the meantime, the
California Department of Parks and Recreation should give serious consideration
to contracting for manual removal of fuel-hazardous materials.
Carmel CIP Policy 20.146.060.A.1 provides the following:
A coastal development permit must be obtained for the removal of trees and other
major vegetation with the following exceptions:
a. Removal of non-native or planted trees, except where this would result in the
exposure of structures in the critical view shed area; where defined as habitat;
where previously protected by coastal permit or forest management plan or
scenic/conservation easement;
b. Removal of hazardous trees which pose an immediate danger to life or
structures;
c. Thinning of small (less than 12" in diameter) or dead trees from densely
forested areas, especially as needed to reduce unsafe fuel accumulations
adjacent to existing occupied buildings;
d. Prescribed burning, crushing, lopping or other methods of brush clearing
which do not materially disturb underlying soils.
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3.3.2.3.4 Del Monte Forest Land Use Plan (Del Monte LUP) and Implementation
Plan (Del Monte CIP)
The Del Monte LUP recognizes the high fire hazards in the Del Monte Forest as follows: "Most
forested areas of the Del Monte Forest are considered high fire hazard areas…"43 The plan also
warns, "Land uses and development in areas of geologic, flood, and fire hazard shall be carefully
regulated through the best available planning practices in order to minimize risks to life and
property, or damage to the environment.
Policy 48 of the Del Monte LUP acknowledges the PRC 4291 requirement and states as follows:
The fire hazard policies contained in the Safety Element of the Monterey County
General Plan and the clearance requirements of the State Forest and Fire Law
(Section 4291 of the Public Resources Code) shall be regularly and consistently
applied.
Del Monte CIP Policy 20.147.050.A.1 states as follows:
A coastal development permit must be obtained for the removal of trees and other
major vegetation with the following exceptions:
a. Removal of non-native or planted trees, except where this would result in the
exposure of structures in the critical viewshed area; where defined as habitat;
where previously protected by coastal permit or forest management plan or
scenic/conservation easement;
b. Removal of hazardous trees which pose an immediate danger to life or
structures or where a diseased tree is determined by a qualified professional
forester to represent a severe and serious infection hazard to the rest of the
forest; and
c. Except for Monterey Cypress in its indigenous range, thinning of small (less
than 12" in diameter) or dead trees from densely forested areas, especially as
needed to reduce unsafe fuel accumulations adjacent to existing occupied
buildings; and
d. Prescribed burning, crushing, lopping or other methods of brush clearing
which do not materially disturb underlying soils.
3.3.2.4 California Environmental Quality Act (CEQA)
The purpose of CEQA is to maintain a quality environment for the people of this state; provide a
high-quality environment that at all times is healthful and pleasing to the senses and intellect of
man; understand the relationship between the maintenance of high-quality ecological systems
and the general welfare of the people of the state, including their enjoyment of the natural
resources of the state; understand that the capacity of the environment is limited, and that the
government of the state must take immediate steps to identify any critical thresholds for the
health and safety of the people of the state and take all coordinated actions necessary to prevent
43 Page 30, Del Monte LUP.
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such thresholds being reached; and regulate activities of private individuals, corporations, and
public agencies which are found to affect the quality of the environment so that major
consideration is given to preventing environmental damage, while providing a decent home and
satisfying living environment for every Californian.44
A public agency must comply with CEQA when the agency undertakes an activity defined by
CEQA as a "project." PRC section 21065 defines a "project" subject to CEQA as follows:
"Project" means an activity which may cause either a direct physical change in the
environment, or a reasonably foreseeable indirect physical change in the
environment, and which is any of the following:
(a) An activity directly undertaken by any public agency.
(b) An activity undertaken by a person which is supported, in whole or in part,
through contracts, grants, subsidies, loans, or other forms of assistance from one
or more public agencies.
(c) An activity that involves the issuance to a person of a lease, permit, license,
certificate, or other entitlement for use by one or more public agencies.
If the activity does not meet the definition of a "project" above, CEQA does not apply and
CEQA analysis is not required. Even if the activity qualifies as a project, CEQA analysis may
not be required if it is statutorily exempt or categorically exempt. For example, PRC section
21080(b)(4) and 14 CCR 15269(c) provide a statutory exemption for specific actions necessary
to prevent or mitigate an emergency.
Class 4 categorical exemption, i.e., minor alteration to land, consists of minor public or private
alterations in the condition of land, water, and/or vegetation. As relevant to fuel mitigation
activities, subsection (I) of Class 4 states as follows:
Fuel management activities within 30 feet of structures to reduce the volume of
flammable vegetation, provided that the activities will not result in the taking of
endangered, rare, or threatened plant or animal species or significant erosion and
sedimentation of surface waters. This exemption shall apply to fuel management
activities within 100 feet of a structure if the public agency having fire protection
responsibility for the area has determined that 100 feet of fuel clearance is
required due to extra hazardous fire conditions.
3.3.2.4.1 MCCWPP Not a Project Subject to CEQA
This MCCWPP is an advisory document subject to compliance with all other applicable local,
state and federal laws, and comprises recommendations by the community to various
governmental agencies. The MCCWPP does not legally commit any agency to a specific course
of action or conduct, including by the act of signing the MCCWPP. The MCCWPP is not a
project subject to CEQA or NEPA. However, if any agency adopts a regulation or ordinance, or
makes a discretionary decision to implement an action recommended in the MCCWPP that has
44 PRC section 21000.
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the potential to cause a significant adverse impact on the environment, such discretionary action
might be considered a project subject to CEQA or NEPA, and an environmental analysis of that
proposed action may be required, unless one of the factors discussed in Section 3.3.2.4.2 below
applies.
3.3.2.4.2 Implementation of MCCWPP
Implementation of vegetation management activities recommended in this MCCWPP might be a
project subject to CEQA as shown in the Flowchart included as Appendix F, unless:
 An environmental review has already been completed that can be relied upon by an
agency or agencies,
 A statutory or categorical exemption applies to the activity, or,
 The project does not involve any discretionary approval by a public agency, does not
involve public funding, and will not be carried out by a public agency.
3.3.2.5 California Endangered Species Act (CESA) and Native Plant Protection
Act (NPPA)
The California Endangered Species Act (CESA)45 generally parallels the main provisions of the
federal Endangered Species Act and is administered by the California Department of Fish and
Game (CDFG). A lead agency is required to consult with CDFG if any action it undertakes is
likely to jeopardize the continued existence of any endangered or threatened species. CESA
section 2080 of the State Fish and Game Code states:
No person shall import into this state, export out of this state, or take, possess,
purchase, or sell within this state, any species, or any part or product thereof, that
the commission determines to be an endangered species or a threatened species,
or attempt any of those acts, except as otherwise provided in this chapter [or] the
Native Plant Protection Act.
The California Native Plant Protection Act (NPPA) was "enacted to preserve, protect and
enhance endangered or rare native plants of this state." The NPPA authorizes the California Fish
and Game Commission to designate species of native plants as endangered or rare. The NPPA
provides:
No person shall import into this state, or take, possess, or sell within this state,
except as incident to the possession or sale of the real property on which the plant
is growing, any native plant, or any part or product thereof, that the commission
determines to be an endangered native plant or rare native plant, except as
otherwise provided in this chapter.
45 Fish & Game Code section 2050, et seq.
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The NPPA grants authority to the Commission to adopt regulations governing the take of any
endangered or rare native plants.46 The NPPA includes provisions that provide exclusions from
the NPPA regulation.
Section 1912 of the Fish and Game Code states that the provisions of this chapter "shall not be
applicable to emergency work necessary to protect life or property."47 The NPPA also states:
[T]he provisions of this chapter are not intended and shall not be construed as
authorizing any public agency to mandate, prescribe, or otherwise regulate
management practices, including [among others] … clearing of land for … fire
control measures."48 (Emphasis added.)
Under the provisions of Fish and Game Code sections 1912 and 1913, emergency work and land
clearing for fire control measures are excluded from NPPA regulation. As applicable to the
interpretation of provisions in the CESA, Attorney General's Published Opinion No. 98-10549
states the following with regard to section 2080 of the CESA:50
We thus conclude in answer to the … question that a landowner may destroy a
plant on his property that is listed as threatened or endangered under CESA when
… (7) incidental to specified emergency projects, or (8) incidental to … the
clearing of certain property under the provisions of NPPA.
3.3.2.6 Forest Practice Rules and Z'berg-Nejedly Forest Practice Act
The Z'berg-Nejedly Forest Practice Act of 1973 (Forest Practice Act)51 was enacted to create and
maintain an effective and comprehensive system of regulation and use of all timberlands.
Extensive regulations have been promulgated to implement the Forest Practice Act, the
California Forest Practice Rules (Rules).52
CAL FIRE is responsible for administering the Rules on all non-federal timberland. The Rules
apply regardless of zoning and include lands inside city limits. The removal of California native
"commercial" timber species from forested lots, areas of pending new construction, and from
around existing structures may be regulated by the Rules. Appendix G contains a checklist
46 California Fish & Game Code §1907(a).
47 Section 1912 includes the following notification requirement: "[N]otification by the person or agency
performing such emergency work shall be made to the department within 14 days of the commencement of such
work."
48 California Fish and Game Code §1913(a).
49 81 Ops. Cal. Atty. Gen. 222.
50 Fish and Game Code section 2080 reads, "No person shall import into this state, export out of this state, or take,
possess, purchase, or sell within this state, any species, or any part or product thereof, that the commission
determines to be an endangered species or a threatened species, or attempt any of those acts, except as otherwise
provided in this chapter, the Native Plant Protection Act (Chapter 10 (commencing with Section 1900) of this code),
or the California Desert Native Plants Act (Division 23 (commencing with Section 80001) of the Food and
Agricultural Code)." (Emphasis Added.)
51 PRC section 4511 et seq (to 4628)
52 14 CCR 895 et seq (to 1115.3).
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prepared by CAL FIRE for the purpose of helping individuals decide if the Rules will apply to a
tree-removal activity.
3.3.2.7 California Smoke Management Guidelines
The California Air Resources Board (CARB) promulgated regulations, the Smoke Management
Guidelines, on March 23, 2000.53 The Smoke Management Guidelines apply to prescribed and
agricultural burns, and required each air district in the state to develop a Smoke Management
Program for their region by July 1, 2001. The regulation also established the overall framework
each air district was to follow in developing the program for their area. The requirements of the
Smoke Management for the North Central Coast Air Basin, which includes Monterey, Santa
Cruz and San Benito Counties, are outlined in the Monterey Bay Unified Air Pollution Control
District's (MBUAPCD) Rule 438, Open Outdoor Fires.
3.3.2.8 California Wilderness Act of 1974
The California Wilderness Act of 1974 states as follows:
In order to assure that an increasing population, accompanied by expanding
settlement and growing mechanization, does not occupy and modify all areas on
state-owned lands within California, leaving no areas designated for preservation
and protection in their natural condition, it is hereby declared to be the policy of
the State of California to secure for present and future generations the benefits of
an enduring resource of wilderness.
A California wilderness preservation system to be composed of state-owned areas was
established through the State Wilderness Act of 1974 and was designated by the Legislature as
"wilderness areas" or “state wildernesses”. Relevant parts of section 5093.33 of the State
Wilderness Act describes the wilderness areas and state wildernesses areas administered for the
use and enjoyment of the people in such manner as will leave them unimpaired for future use and
enjoyment as wilderness, provide for the protection of such areas, preserve their wilderness
character, and provide for the gathering and dissemination of information regarding their use and
enjoyment as wilderness. No state-owned areas shall be designated as "wilderness areas" except
as provided for in this chapter or by subsequent legislative enactment.
A wilderness area, in contrast to those areas where man and his own works dominate the
landscape, is hereby recognized as an area where the earth and its community of life are
untrammeled by man, where man himself is a visitor who does not remain. A wilderness area is
further defined to mean an area of relatively undeveloped state-owned land which has retained its
primeval character and influence or has been substantially restored to a near natural appearance,
without permanent improvements or human habitation, other than semi-improved campgrounds
and primitive latrines, and which is protected and managed so as to preserve its natural
conditions and which:
(1) Appears generally to have been affected primarily by the forces of nature, with the
imprint of man's work substantially unnoticeable.
53 17 CCR 80100 et seq.
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(2) Has outstanding opportunities for solitude or a primitive and unconfined type of
recreation.
(3) Has at least 5,000 acres of land, either by itself or in combination with contiguous
areas possessing wilderness characteristics, or is of sufficient size as to make practicable
its preservation and use in an unimpaired condition.
(4) May also contain ecological, geological, or other features of scientific, educational,
scenic, or historical value.
Assembly Bill 2945 was signed into law by Governor Arnold Schwarzenegger on September 30,
2008 amending the California Wilderness Act to create the 413 acre Limekiln State Park
Wilderness.
3.3.3 Applicable Local Laws, Regulations, and Policies
3.3.3.1 2010 Monterey County General Plan
Monterey County’s 2010 General Plan recognizes the high risk of fire in Monterey County, and
the need to minimize that risk. The 2010 General Plan states as follows:
Monterey County experiences a variety of types of fires: wildland, structural, and
chemical. Over half of the land area in Monterey County is mountainous and
covered with highly combustible vegetation. Wildland fires are part of the
ecosystem that are both a beneficial and destructive force. Monterey County has
some older communities (Chualar, Spreckels, San Lucas, Bradley, North County,
and Carmel Valley Village) where structural failure could occur as a result of out-
dated electrical or mechanical conditions. In addition to wildland and structural
fires, Monterey County is subject to fire hazards from oil and natural gas fields,
gasoline storage wells and flammable chemicals.
The California Department of Forestry and Fire Protection (CAL FIRE) is
charged with Wildland fire protection for much of Monterey County. CAL FIRE
provides wildland fire protection to 1.3 million acres of State Responsibility Area
(SRA) from seven fire stations and one conservation camp located in Monterey
County. In addition to the CAL FIRE equipment located within Monterey County,
there are two air tankers, an aerial command aircraft and a helicopter located in
adjacent San Benito County. The state funded fire equipment located in Monterey
County is sufficient to meet the stated CAL FIRE goal of controlling 95% of SRA
wild fires in the first burning period.
Older buildings that do not have adequate fire protection devices pose a high fire
hazard risk. Structural fire protection in the county (Local Responsibility Area or
LRA) is the responsibility of local government and is provided by various fire
protection districts and special districts, of which five have contracts with CAL
FIRE to manage and staff their departments. Pebble Beach Community Services
District, Cypress Fire Protection District, Carmel Highlands Fire Protection
District, Aromas Tri-County Fire Protection District, and South Monterey County
Fire Protection District all contract with CAL FIRE.
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To assure that the County is prepared to anticipate, respond and recover from fire emergencies,
Monterey County adopted Policy S-5.1, which states as follows:
The County shall participate in developing emergency plans that provide
preparation for, as well as a coordinated and effective response to, emergency and
disaster events. Plans include, but are not limited to, a multi-jurisdictional Local
Hazard Mitigation Plan (LHMP) and Community Wildfire Protection Plans
(CWPPs).
This MCCWPP was drafted in anticipation of and pursuant to the above policy.
3.3.3.2 MBUAPCD Smoke Management Program (SMP) 54
As required in 17 CCR 80100 to 80330, the MBUAPCD’s Smoke Management Program (SMP)
requires that burn managers obtain a smoke management permit from the District for certain
types of burns. Not all types of burns require a District permit. For example, "back yard" and
agricultural burning activities do not trigger the permit requirement.
The permit is obtained through District Rule 438 - Open Outdoor Fires, which also requires that
burn projects be registered annually, have a smoke management plan and be conducted on
permissive burn days with District authorization. Collectively, the requirements of Rule 438,
including the permit and project specific smoke management plan, fulfill the requirements of the
MBUAPCD’s SMP.
The MBUAPCD adopted Rule 438 in 2003, in consultation with the Open Burn Task Force,
which was a group of local, state and federal fire officials, as well as private and governmental
land managers. Rule 438 allows and permits landowners and agencies to conduct landscape
scale prescribed burning for the purposes of hazardous fuel reduction and habitat and range
improvement. The MBUAPCD plans to begin revising Rule 438 in 2009, which will allow for
input related to this MCCWPP from the reconvened Open Burn Task Force.
The MBUAPCD recognizes the need to reduce the accumulation of hazardous fuels in our area
in order to reduce the threat of catastrophic wildfires, which history demonstrates can seriously
impact the air quality of the entire region. Through the MBUAPCD's SMP, which encourages
good smoke management practices, the MBUAPCD will work collaboratively with landowners
and fire and land management agencies to reduce the wildfire threat while protecting air
quality. The MBUAPCD also encourages the use of alternative practices whenever practical,
such as chipping, mechanical removal, mowing, composting or recycling.
District Rule 402 provides that nuisance may apply to burn projects. Rule 402 basically means
that no one can create a public nuisance with smoke from their fire.
Environmental review for impacts from burn projects permitted through the MBUAPCD’s SMP
is addressed in the MBUAPCD’s Program EIR for the SMP entitled, Monterey Bay Unified Air
Pollution Control District Proposed Smoke Management Program, State Clearing House
# 200112114. The Program EIR was approved by the MBUAPCD Board on May 15, 2002.
54 This section incorporates comments from MBUAPCD staff.
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4.0 Fuel Reduction Zone Descriptions
This section recommends zones where hazardous fuel reduction work should take place. Section
5 discusses the framework used to assess fire threat. Section 6 discusses recommended
hazardous fuel reduction treatments within various zones based upon the fire threat assessment.
4.1 Wildland-Urban Interface
4.1.1 Introduction
The wildlands of Monterey County are fire dependent, a living landscape that has evolved with
fire over time, sometimes referred to as a "firescape." Native Americans of the Central Coast lit
fires as a management tool. Early explorers report numerous smoke columns across the
Monterey County landscape as their ships sailed the central coast. Today, you can see the
residual effects of traditional use of fire management in the burn-hollowed redwoods, sycamores,
and great oaks throughout the county.
Historical fire suppression policy is contributing to an ever increasing wildfire threat to
communities and the environment due to hazardous fuels accumulation. On balance, current fire
suppression policy is beneficial, however, resulting hazardous fuels accumulation must be
addressed.Pre-suppression strategic fire defense planning identifies and characterizes fire threat,
and helps communities prioritize hazardous fire fuel reduction activities.
4.1.2 Wildland-Urban Interface (WUI) Discussion
In general, a WUI is that area where hazardous fuel reduction work should be performed to
protect communities, infrastructure and watersheds from wildfire. The WUI zone may extend a
variable distance from structures and infrastructure, taking into account such factors as
topography, fire fuels, weather, and fire history. Many communities will extend the WUI to the
surrounding watershed ridge breaks (i.e., firesheds), which are usually consistent with historical
or anticipated fire suppression control points (e.g., firebreaks and/or fuelbreaks).
The HFRA empowers at-risk communities with the ability to determine where the boundaries for
their WUI zones will be by showing where the WUI zone is in a CWPP.55 The California Fire
Alliance recommends that CWPPs designate a "generous WUI," noting that certain benefits of
the HFRA are lost for areas that are not included in WUI.56
The HFRA aims to protect more than structures. The HFRA also aims to protect rangelands,
infrastructure (e.g., water systems, power transmission and communications systems),
watersheds and other assets.57 To build flexibility into CWPPs, it is important to extend WUI to
include these assets that may benefit from reduction of hazardous fuels.
55 "WILDLAND-URBAN INTERFACE.—The term 'wildland-urban interface' means—
(A) an area within or adjacent to an at-risk community that is identified in recommendations to the Secretary in a
community wildfire protection plan …" (HFRA section 101(16)(A).)
56 CWPP Enhancement Guidance – Lessons Learned!, California Fire Alliance.
57 Title 16 USC 6501.
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For example, it is reported that the Los Padres Dam on the Carmel River lost about 700 acre-feet
of its 2,500 acre-foot holding capacity during the winter following the Marble Cone Fire of
1977,58 due in part to the severity of the fire from high fuel loads.59 Monterey County relies on
reservoirs in the Salinas River basin to supply water to support the county's agriculture industry,
which sustains about 40 percent of the County's economy. Reservoirs are essential infrastructure
for the communities they serve. Through benefits provided by the HFRA, watersheds, which
supply reservoirs, may be protected against the production of high levels of silt runoff that can
result from high intensity wildfires and reduce reservoir capacity.
Much of the County's rangelands are used for grazing cattle and other livestock, which also
contributes to the well being of communities in the County. Though the term wildland-urban
interface brings to mind the fringes of densely populated urban areas, Congress defined at-risk
communities to be broadly inclusive,60 to provide flexibility for receiving the maximum benefits
of the HFRA.61
This MCCWPP describes and refers to hazardous fire fuel treatment areas as Hazardous Fuel
Reduction Zones, Defensible Space, Survivable Space, Mitigation Zones and Threat Zones,
which are generally within the WUI zone.
It is important to each community at risk from wildfires that it be named as an at-risk community
or community at-risk in a CWPP, and that its community and WUI zone boundaries be set where
they will help protect the community from wildfire. This is especially true for at-risk
communities near land managed by the USFS and BLM. For example, the HFRA provides that
if a hazardous fuel reduction project proposed on Federal land is inside a WUI zone and within 1
½ miles of the boundary of an at-risk community, NEPA review for the project need not consider
any alternative but the project.62 Moreover, if a CWPP describes a hazardous fuel reduction
project that is inside a WUI zone and within 1 ½ miles of an at-risk community, and a proposed
agency action does not implement the recommendations in the CWPP with regard to the general
location and basic method of fuel treatments, the agency is required to evaluate the
recommendations in the CWPP as an alternative to the agency's proposed action when doing its
58 Fall 2008 Stage-Volume Relationship for Los Padres Reservoir, Carmel River, California, 2009.
59 Sequential Changes in Bed Habitat Conditions in the Upper Carmel River Following the Marble-Cone Fire of
August, 1977, 1981.
60 Title 16 USC 6511(1).
61 The Ventana Chapter of the Sierra Club submitted comments on the January 2010 MCCWPP stating that the
WUI boundary was overextended. The chapter alleged that a WUI definition it found that was published in the
Federal Register in 2001 is "federal law" and implied that the definition was the legal definition for WUI that must
be applied when developing CWPPs. However, the referenced definition was an initial definition, was not published
as a rule or proposed rule, is not found in any federal statute or regulation, and was not used by Congress when it
passed the HFRA in 2003. The definition for WUI used for developing this MCCWPP is the definition in the
HFRA, and is the lawful definition for WUI to be used when developing CWPPs. Other CWPPs have used the
HFRA's WUI definition to extend a "generous" WUI to maximize the benefits available through the HFRA. (See,
for example the Santa Cruz County CWPP, which extends WUI throughout most of the County’s non-urban areas.)
Were the initial definition to be applied, the landscape scale protection of watersheds, rangeland and infrastructure
contemplated by the HFRA would be frustrated, as flexibility would be lost as to where benefits of the HFRA might
be applied.
62 Title 16 USC 6514(d)(2).
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NEPA review for the project.63 It is therefore appropriate for this MCCWPP to recommend at-
risk communities, and to map recommended WUI zone boundaries for Monterey County. The
WUI boundaries recommended in this MCCWPP are identified pursuant to the provisions of the
HFRA. They fully encompass at-risk communities, watersheds, forests and rangelands across
the landscape; are broadly inclusive to allow for flexibility; and may be refined or redefined in
local CWPPs. The recommended priority of at-risk communities for reduction of hazardous
fuels within the WUI is discussed in Section 5.4.
Notwithstanding the area of WUI that this MCCWPP identifies in recommendations to the
Secretaries of Agriculture and Interior (Secretaries), specific locations where reduction of
hazardous fuels are recommended are generally limited to those listed in Appendix D and those
recommended in Section 9.
To address concerns about unintended consequences of the area of WUI identified, it is
important to emphasize that this WUI is designated pursuant to the HFRA in the context of
hazardous fuel reduction to protect communities and infrastructure and "enhance efforts to
protect watersheds and address threats to forest and rangeland health, including catastrophic
wildfire, across the landscape."64 More specifically, the recommended activities within the WUI
are listed below:
 Fuel mitigation work around ingress/egress/emergency roads;
 Fuel mitigation work around structures;
 Reduction of structural ignitability;
 Maintenance of strategic fuelbreaks; and
 Fuel mitigation work to protect infrastructure and watersheds.
It is important to note that the WUI designation should not be used for purposes of expediting or
encouraging development, removing trees and other vegetation for unrelated purposes, or for any
other purpose that is not contemplated by the HFRA. The WUI identified to the Secretaries in
recommendations in this MCCWPP should have no application but the purposes of the HFRA.
Subject to the priority of at-risk communities recommended to the Secretaries in Section 5.4, the
WUI zones, shown on the map in Appendix B-7, are areas within the County where hazardous
fuel reduction and reduction of structural ignitability activities may occur. The WUI map is low
resolution and may require a higher resolution map to further refine the WUI boundary.
Additional refinement may occur in the local CWPPs, or in areas where local CWPPs are not
prepared, the WUI may be refined in the scope of work description.
Such activities within the WUI include: Strategic Fuelbreaks; Safety Zones; Defensible
Polygons; shaded fuelbreaks; strategically placed landscape area treatments (SPLATS/SPOTS);
building construction or modifications that improve the structure's ability to withstand a wildfire,
survivable space around structures, prescribed fire, and other treatments. These activities may
need to be conducted to reduce hazardous fuel, structure ignition potential and threats to wildlife
habitat, while providing for increased citizen and firefighter safety.
63 HFRA section 104(d)(3) (Title 16 USC 6514(d)(3)).
64 HFRA, 16 USC 6501(3).
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4.2 Hazardous Fuel Reduction Zones
A Hazardous Fuel Reduction Zone (HFRZ) is an area designated by the Fire Authority Having
Jurisdiction (FAHJ), based upon the FAHJ's experience, knowledge and anticipated fire
behavior, as containing hazardous fuel that presents a potential threat to lives, communities,
structures, infrastructure, access roads, and/or watersheds in the event of wildfire. HFRZs may
also include areas where fuelbreaks, firebreaks and other treatments may be needed to protect
such areas from wildfires originating outside the area. HFRZs may vary in size, and are
independent from, though may include, Defensible Space, Mitigation Zones and Threat Zones.
The concept of HFRZs is specific to the Monterey County area, and was developed to help focus
on locations where hazardous fuel reduction work is most needed, as determined by the FAHJ.
The intent is that HFRZs identify areas where hazardous fuels present a potential threat to lives,
communities, structures, infrastructure, access roads, and/or watersheds in the event of wildfire,
especially under extreme adverse fire-weather conditions. In such areas, large quantities of
hazardous fuels may need to be reduced to help protect communities and infrastructure from
wildfire. One of the goals within HFRZs is to restore such areas to a fuel density that, in the
judgment of the FAHJ, approximates the fuel density the area would have if fire suppression had
not been practiced in the area, and to protect any remaining hazardous fuel from ignition. Due to
the extensive time that can be required to reduce hazardous fuel accumulations, and the short
time it can take for a wildfire to start and progress to catastrophic proportions, removal, disposal
and continued maintenance of hazardous fuels on an ongoing basis is recommended.
The FAHJ may also provide oversight for new construction and may require certain building
construction to improve the structure's ability to withstand a wildfire.
It is intended that any of the treatments in Section 6 may be applied in HFRZs, provided they can
be applied safely. The following list activities recommended within the HFRZ:
 Fuel mitigation work around ingress/egress/emergency roads;
 Fuel mitigation work around structures;
 Reduction of structural ignitability;
 Maintenance of strategic fuelbreaks; and
 Fuel mitigation work to protect infrastructure and watersheds.
4.3 Fire Threat Treatment Areas
Within the WUI zone, this MCCWPP identifies four fire threat treatment areas: Defensible
Space, Survivable Space, Mitigation Zones and Threat Zones.
4.3.1 Defensible Space
Defensible Space includes the area within the perimeter of a parcel (or beyond if permission is
obtained from the adjacent landowner(s)) where basic wildfire protection practices are
implemented, providing a key point of defense from an approaching wildfire or escaping
structure fire. The area is characterized by the establishment and maintenance of emergency
vehicle access, emergency water reserves, street names and building identification, structure
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defense measures to reduce the likelihood of structure ignition, and fuel modification measures.
Defensible Space is intended to protect lives and property and to ensure the safety of those
defending the area from wildfire. Defensible Space implies that tactical resources will be
available to defend assets during a wildfire.
4.3.2 Survivable Space
Survivable Space includes structure defense measures to reduce the likelihood of structure
ignition and the area around a structure where fuels have been modified to provide a high
likelihood, under the site's conditions (e.g., vegetation type, construction materials and terrain),
that the structure (and people if present) will survive in the event of a wildfire, under
extraordinarily adverse weather conditions, without the presence of firefighters or others
defending the structure. Survivable Space applies where there is potential that tactical resources
will not be available to defend assets during a wildfire.
4.3.3 Mitigation Zones
Mitigation Zones are strategically prioritized target areas within the Threat Zone where
hazardous fuel reduction activity will be of high value to protect life, property, and the
environment, and to support safe tactical suppression capability. The Mitigation Zone includes
and extends from the Defensible/Survivable Space to distances determined by considering such
anticipated factors as fuel, topography, weather, fire history, flame length, firebrand spotting and
tactical suppression capability. Hazardous fuel reduction work in Mitigation Zones may serve to
mitigate the fire threat exacerbated by years of fire suppression and/or regulations that
discourage vegetation removal.
4.3.4 Threat Zones
Threat Zones extend out from Defensible/Survivable Space to major landscape/watershed
features such as roads, rivers, or ridges. Threat Zones generally extend to the boundary of the
WUI, and may include strategic fuelbreaks and/or other treatments placed in coordination with
major watershed features, and with the Mitigation Zones and Defensible Space, creating anchor
points for wildfire suppression. Areas entirely surrounded by such fuelbreaks, other treatments
or watershed features are known as Defensible Polygons. Hazardous fuel treatments in the
Threat Zone will often be prescribed fire, prescribed grazing (wildlife, livestock) and fuelbreaks.
5.0 Fire Fuel Hazard, Threat, and Risk
In 2006, the MFSC contracted with CAL FIRE's FRAP and a fire threat assessment team
consisting of local fire chiefs and experienced fire veterans to evaluate wildfire threat and risk in
Monterey County, and to field validate the FRAP computer-based assessment models on a site-
specific basis.
This section presents a summary of the 2006 FRAP analyses including the fire hazard, threat,
and risk assessment protocol for Monterey County, and the prioritization of threats to at-risk
communities. There is concern that the 2006 FRAP analyses understated fire risk and threat. A
new 2010 FRAP analysis is under development by CAL FIRE which should provide updated
maps based on new data, science, and technology.
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Fire fuel hazard is a rating of vegetation and dead woody material and their volume, type,
condition, arrangement, distribution and location (i.e., Fuel Model), and topography.
Fire threat is a rating that combines fire fuel hazard, fire history and weather conditions.
Fire risk is a rating that combines fire threat plus the value of assets that would be threatened in
the event of wildfire.
5.1 Fire Fuel Hazard
Fire fuel hazards were evaluated in the 2006 FRAP Monterey Fire Risk Analysis. Fire fuel
hazard was analyzed based on such factors as the Fuel Model and topography. Fire fuel hazard
analysis utilized updated county wide vegetation maps, aerial photography and terrain modeling
in combination with field validation and air review. The refined vegetation/fuels data for
Monterey County was then analyzed and the resulting data was used to classify fire fuel hazard
rating. (Appendix B-8)
Table 11 presents fire fuel hazard rating acreages for Monterey County.
Table 11. Monterey County Fire Fuel Hazard Rating
Fire Fuel Hazard Rating* Acreage Percent
Little to None 261,455 12.3%
Moderate 410,187 19.4%
High 960,478 45.4%
Very-High 485,007 22.9%
Total: 2,117,127 100.0%
* FRAP Monterey Fire Risk Analysis, 2006
5.2 Fire Threat
Fire threat was evaluated for Monterey County during the 2006 FRAP analysis based on fire
hazard, weather, and fire history. This analysis characterizes fire threat as the combination of
fire probability (based on fire history) and hazard or expected fire behavior (based on fuels,
weather, and topography and on-the-ground fire experience). The FRAP fire threat analysis rates
areas of the County into five separate categories, including little/none, moderate, high, very-high,
or extreme. According to the 2006 FRAP analysis, 83.5 percent of Monterey County lies within
a high, very-high, or extreme fire threat area.
Assessment of fire threat assists in prioritization of hazardous fuel reduction projects. The fire
threat assessment informs strategic management decisions. A cooperative approach to
community wildfire protection with local input can then be accomplished. Table 12 presents fire
threat acreages for Monterey County, while the map in Appendix B-5 graphically presents the
distribution of fire threat ratings across the County.
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Table 12. Monterey County Fire Threat Rating
Fire Threat Rating* Acreage Percent
Little to None 261,698 12.4%
Moderate 87,911 4.2%
High 719,366 34.0%
Very-High 646,759 30.5%
Extreme 401,394 19.0%
Total: 2,117,127 100.0%
(FRAP, 2006.)
5.2.1 Field Fire Threat Assessment
The field fire threat assessment was used to provide on-the-ground site-specific validation of the
2006 FRAP fire threat analysis. This threat assessment process characterizes the wildfire
environment to inform prioritization decisions for the community and agencies. Consideration
of fire threat helps effectively locate Safety Zones, Strategic Fuelbreaks and fuel reduction buffer
zones, and determine minimum fuel break widths, and extent of hazardous fuel reduction
required to help ensure citizen and firefighter safety.
To complement the FRAP analysis, the fire threat assessment team provided field verification of
threat, including identification of:
 Factors of fire behavior change (fuels, slope, topography, weather).
 Fire behavior decision points [predetermined locations (i.e. proximity to structures,
change in slope, etc.) or set of meteorological thresholds that may require a change in
tactics to deal with changing conditions (location or weather)].
 Fire severity alignment scenarios (situations in which the slope, fuels, and/or weather
align to create an increase in fire activity and subsequent fire severity and possibly fire
intensity).
 Direction of fire spread (influenced by prevailing winds, topography, and fuels).
 Tactical suppression thresholds of control (identification of potential wildfire control
lines or anchor points, such as ridges, roads, and drainages).
 Fire history (the number and geographic extent of previous fires in a given area).
 Tactical fire suppression capacity (level of firefighting resources available).
Examples of fire defense plans are the Pebble Beach Fire Defense Plan, and the
BLM/Department of Defense (DOD) Fire Defense Plan for Fort Ord. See Appendix I for a map
with proposed BLM fuel treatment areas on former Fort Ord.
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5.3 FRAP Fire Risk
Fire risk is a rating that combines fire threat plus the value of assets that would be threatened in
the event of wildfire. An objective of the FRAP fire risk analysis for Monterey County was to
analyze data to be used for pre-suppression fire planning purposes. The data can be used to
identify treatment areas and potential measures to mitigate wildfire risk, and develop products
that can be used in community outreach. The methodology employed by FRAP in this process
included geographic information systems (GIS) based field, air, and infrared imagery analysis to
refine fire fuels data throughout the county and develop fire fuel hazard rating, fire threat, and
fire risk data for analysis and presentation purposes.
The risk analysis performed by FRAP included an assessment of risk to ecosystems, risk to soils,
and risk to communities.
5.4 Prioritization of Need for Fuel Reduction Work
Table 13 provides recommended prioritization of areas within Monterey County where wildfire
hazardous fuel reduction work may be needed. The communities listed qualify as at-risk
communities pursuant to the HFRA and/or communities at-risk as listed by the California Fire
Alliance, as indicated in the table. The communities in Table 13 may be characterized as being
at risk of harm from wildfire.
Table 13. Prioritization of Need for Fuel Reduction Work, by Community
Community or
Area at Risk
See Note
A
See Note
B
See Note
C
Fuel
Hazard
Risk of
Wildfire
Occurrence
Structural
Ignitability
Overall
Priority
Aromas X High Medium Medium High
Big Sur X X X High High High High
Bryson-Hesperia X High High High High
Cachagua-
Jamesburg
X High Medium High High
California State
University
Monterey Bay
X High Medium High High
Carmel X Medium Low High High
Carmel Highlands X X High Medium High High
Carmel Valley
(also includes
Jamesburg -
Cachagua)
X X X High Medium High High
Carmel Valley
Village
X X X High Medium High High
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Community or
Area at Risk
See Note
A
See Note
B
See Note
C
Fuel
Hazard
Risk of
Wildfire
Occurrence
Structural
Ignitability
Overall
Priority
Castroville *** Low Low Medium Low
Chualar Canyon *** High High High High
Corral de Tierra *** High High High High
Del Monte Forest/
Pebble Beach
X X High Medium High High
Del Rey Oaks X X High Medium High High
Elkhorn X Medium Medium Medium Medium
Former Fort Ord X X High Medium High High
Fort Hunter
Liggett
X High High High High
Gabilan Range X High High Medium High
Gonzales X Low Low Low Low
Greenfield X X Low Low Low Low
Highway 68
Corridor
*** High High High High
Jack's Peak *** High Medium High High
King City X X Medium Medium Medium Medium
Las Lomas X Medium Medium Medium Medium
Las Palmas/
Indian Springs
X High High Medium High
Lucia X X High High High High
Manzanita Park *** High High High High
Marina X X Low Medium Medium Medium
Monterey X X Medium Medium High High
Pacific Grove X X Medium Low High High
Pajaro X Medium Medium Medium Medium
Palo Colorado ** X ** High High High High
Pine Canyon
(North)
X Medium High Medium Medium
Pine Canyon
(South)
X High High Medium High
Pinnacles
National
X X High Medium Low High
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Community or
Area at Risk
See Note
A
See Note
B
See Note
C
Fuel
Hazard
Risk of
Wildfire
Occurrence
Structural
Ignitability
Overall
Priority
Monument
Prunedale X High Medium Medium High
Rancho San
Carlos
X High Medium High High
Rancho San
Clemente
X High Medium High High
Reliz Canyon X High High Medium High
Rural Northern
Monterey County
*** High Medium High High
Rural Southern
Monterey County
*** High Medium High High
Salinas X X Medium Medium Medium Low
San Antonio Lake X High High High High
Sand City X X Low Low Medium Low
Santa Lucia
Preserve
X High High Low High
Seaside X X Low Medium High High
Sierra de Salinas X High High Medium High
Soledad X Low Low Low Low
Toro County Park *** Medium High Medium Medium
Toro Park Estates *** High Medium High High
White Rock X High High High High
Note A - These communities meet the definition of an at-risk community in the HFRA (i.e., they are on the list
published in the Federal Register; are at risk of wildfire; and are within or adjacent to Federal land), per 16 USC
6511(A)(i).
Note B - These communities meet the definition of an at-risk community in the HFRA (i.e., a group of homes and
other structures with basic infrastructure and services (such as utilities and collectively maintained transportation
routes), that are at risk of wildfire, and are within or adjacent to Federal land, per 16 USC 6511(A)(ii).
Note C - These communities are listed as a community at-risk on the list maintained by the California Fire Alliance.
** Palo Colorado is within the Big Sur at-risk community and the Big Sur community at-risk.
*** These communities should consider applying to the California Fire Alliance for listing as a community at-risk.
See http://www.cafirealliance.org/communities_at_risk/communities_at_risk_addtolist.
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5.5 Detailed Priority Threat Descriptions
Recommended prioritization of communities for hazardous fuel reduction work is provided in
Table 13 above. Certain areas, listed in alphabetical order below, are described in more detail in
Appendix I.
 Bryson-Hesperia
 Fort Ord
 Highway 68 Corridor
 North County
 Palo Colorado
 Pine Canyon (South)
 Santa Lucia Fire Defense System
 Sierra de Salinas-Gabilan Fuel Reduction Project and Strategic Fuel Break System
 Tularcitos Ridge
 White Rock
5.6 Special Study Areas: FRAP Fire Behavior Modeling
Three representative areas within Monterey County were selected for special study by FRAP:
Fort Ord, Carmel Valley, and the North County. Fire behavior modeling was conducted by
FRAP utilizing the refined topography and fuels data, and refined local 3D wind modeling data
obtained from the Monterey Naval Postgraduate School Meteorology Section. Employing
FlamMap and FARSITE computer models, simulations were conducted for each area.65 Two
ignition scenarios and two weather scenarios (moderate and severe) were evaluated to assess fire
behavior potential.
The study summarizes (1) the FRAP findings for each area, based on modeling results, and (2)
the field validation performed by the fire threat assessment team.
(See Appendix H)
6.0 Hazard Reduction
Hazard reduction includes the following:
 Reduction of structure ignitability
 Hazardous fuel reduction and fuelbreaks
 Defensible space (PRC 4291)
 Fuel treatments
 Community fire safe prescriptions
65 http://www.fs.fed.us/psw/topics/fire_science/craft/craft/Resources/Fire_models_tools.htm
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6.1 Reduction of Structure Ignitability
Current California Fire and Building Codes and Monterey County amendments to those Codes
provide for strict fire safe construction for new construction in State Responsibility Areas
(SRAs). SRAs encompass essentially most of the sloped areas of the County that are not
federally owned. Examples of the requirements under the Codes are Class A rated roofing
materials, boxed eaves, special venting devises, boxed deck, fire resistant siding and residential
sprinklers. Reducing structural ignitability is an effective way of reducing structure losses in the
event of wildfire. In cooperation with CAL FIRE, the Monterey Fire Safe Council supports and
promotes firewise activities by (1) educating citizens on ways to reduce structural ignitability
and (2) seeking funding to support the use of fire resistant building materials and other strategies
to reduce the impact of human activities on wildfires.
Threat to structures by a burning wildfire is a progressive process. Typically, the first threat is
from ashes cast in front of a fire by winds or the fire convection column. In some cases, ashes
may retain enough heat and/or flame that secondary ignitions are possible. Next, embers and
firebrands are blown in front of an advancing fire. These have more surface area and mass than
ashes and consequently more heat, and are often a cause of ignition of structures and vegetation,
sometimes far in advance of the wildfire front. Finally, the wildfire flame front and associated
radiant heat can expose combustible material, including vegetation and structures, to sufficient
heat to cause ignition.
Studies reveal that the exposure of a structure to a wildland flame front is usually less than six
minutes. The majority of structure losses from wildland fire occur not from the flaming fire
front but from burning embers and firebrands. Anywhere a flying bee can go, a burning ember
can go.
Preventing structure ignition requires addressing each of these causes of ignition, as any one
source can lead to loss of the structure if ignition is initiated.
To prevent structure ignition caused by ashes, embers and firebrands, roof materials should be
Class A rated, such as Class A composition shingles, clay tiles or cement tiles. Heat can be
conducted through metal coverings and ignite wood or other combustible materials behind it, so
metal roof coverings (and siding) should be backed with materials that will result in a system
with a Class A rating.
Rain gutters, roof valleys, clerestories, and other areas that may collect combustible debris such
as leaves and pine needles should be kept clean. Follow CAL FIRE's Guidelines (see Section
6.2.1 and Appendix E), including removing vegetation and combustible materials to mineral soil
within 30 feet of structures so flammable materials cannot be ignited by embers and transfer fire
to the structure. Openings for underfloor vents and roof and soffit vents should be covered with
wire mesh, and should be completely blocked if a wildfire is approaching. Combustible
materials such as firewood and patio furniture should be kept away from structures so they
cannot transfer fire to structures if they are ignited.
Radiant heat can pass through windows and ignite curtains, papers and other combustible
materials inside structures. To prevent ignition inside structures from radiant heat, combustible
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materials should be moved away from windows if a wildfire is approaching. It is recommended
that CAL FIRE's Guidelines be followed to reduce vegetation density around structures, which
should reduce fire intensity and radiant heat during a wildfire.
Various other measures may help reduce the likelihood of structure ignition during a wildfire.
For example, decks and balconies can be conduits for fire to ignite a residential structure. By
boxing in the undersides of decks and balconies, especially with fire resistant materials, the
chances of ignition are reduced. A relatively recent development includes aluminized fiberglass
fabric used to "wrap" a house with reflective fire-resistant fabric, much like when a house is
wrapped for termite control. Water gels are available that can be sprayed on structures as a fire
approaches (though effectiveness is time-limited due to evaporation). These methods require
preparation well before wildfire approaches, including purchasing special materials and
equipment to have them ready to use and learning how to use them. There is no assurance these
measures will prevent a structure from igniting, but they will likely increase the odds of structure
survival.
New building code provisions for wildland areas are generally required for new construction.
Owners of existing structures should consider voluntarily using wildland construction materials
when maintaining buildings. For example, if windows are being replaced, the property owner
could consider replacing them with tempered glass, which may help avoid window breakage
during a wildfire. Windows broken by the heat from an approaching fire can provide a path for
the fire to enter a structure. Owners of structures may consider purchasing and pre-fitting fire
resistant material to place over the outside of windows when there is a threat from approaching
fire, to help prevent windows from transmitting radiant heat, and to help avoid breakage and
window openings from becoming a path for fire to enter structures. A brochure on fire safe
structures is available at http://anrcatalog.ucdavis.edu/pdf/8393.pdf.
Maintaining defensible/survivable space around structures is an effective means of reducing
structure ignitability by reducing the opportunity for ignition. Removal of vegetation
overgrowth in the WUI reduces overall wildfire intensity, thus, reducing the energy in the
convection column and lowering its potential for transporting ashes, embers and firebrands over
distance, and reducing radiant heat and potential for direct flame impingement, which lower
structure ignition potential.
It is recommended that grant funding be sought for the following measures to help reduce
structural ignitability:
 To assist owners who want to replace existing ignitable materials on structures with fire
resistant materials.
 To develop educational materials to inform owners how to protect their residences
through actions such as cleaning rain gutters, roof valleys and clerestories; the
importance of maintaining defensible/survival space around structures; and the
importance in the event of fire, of covering vent openings, clearing flammable material
from on and under decks and moving wood piles.
 To form a defensible space/Firewise Program in neighborhoods throughout Monterey
County.
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To summarize, individuals and community members can reduce structural ignitability throughout
Monterey County by implementing defensible space/Firewise Programs to include the
following: 66
 Assess risk/structure ignitability.
 Consider fire resistant exterior siding and roofing materials.
 Maintain defensible space around structures.
 Clean roofs and gutters annually.
 Develop a community phone tree in case of a fire emergency.
 Develop agreements with the County to use the reverse 911 system.
 Remove ladder fuels.
 Clean and screen chimney.
 Maintain green grass and fire resistant plants (or bare earth as discussed above) within 30
feet of house.
 Move all flammable materials at least 30 feet from buildings and structures.
 Remove dead, dying, or diseased shrubs trees, dried grass, fallen branches and dried
leaves around the defensible space of structure.
 Attach a hose that can reach to all parts of the house.
Where it is necessary to maintain a survival space, the following activities may be taken:
 Clean roof surfaces and gutters of pine needles, leaves, branches, etc., to reduce
flammable materials.
 Remove portions of any tree extending within 10 feet of the flue opening of any stove or
chimney.
 Maintain a screen constructed of non-flammable material over flue opening of every
chimney or stovepipe. Mesh openings of the screen should not exceed ½ inch.
 Remove branches from trees to height of 15 feet.
 Create a fuelbreak around the structure.
 Dispose of stove or fireplace ashes and charcoal briquettes only after soaking them in a
metal pail of water.
 Store gasoline in an approved safety can away from occupied buildings.
 Garden hose should be connected to outlet.
66 In a July 13, 2010 comment letter to the January 2010 MCCWPP, the Ventana Chapter of the Sierra Club
provided various excerpts from approved CWPPs that include discussions of methods for reducing structural
ignitability. The discussions in the July 13, 2010 comment letter are reflected below, and some of the discussions
below are duplicative of those above.
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 Have fire tools handy such as: ladder long enough to reach the roof, shovel, rake and
bucket for water.
6.2 Hazardous Fuel Reduction and Fuelbreaks
Hazardous fuel reduction work may be performed by private property owners, contractors and/or
public agencies, subject to compliance with all applicable local, state and federal laws. Funding
may be from private sources, grants, agency budgets or a combination of these.
A strategic watershed/fireshed approach is advocated by this MCCWPP to protect communities,
infrastructure and watersheds, as promoted by the HFRA. Utilization of historic and existing
roads, firebreaks (during a fire) and fuelbreaks is recommended as top priority. Strategic
coordination and connection of firebreaks and fuelbreaks is key to protecting communities. This
MCCWPP recommends, as a priority, the long term maintenance and restoration of existing and
historic Strategic Fuelbreaks in state responsibility areas and on federal land. It is recommended
that CAL FIRE, fire districts, volunteer fire departments, the DOD, BLM, National Park Service
(NPS), and USFS cooperate with each other and communities to establish and maintain a
network of Strategic Fuelbreaks to protect at-risk communities from wildfire.
6.2.1 Access Roads
In a July 13, 2010 comment letter to the January 2010 MCCWPP, the Ventana Chapter of the
Sierra Club provided various references67 that include discussions of fire access and escape
routes. The discussions in the July 13, 2010 comment letter are reflected below.
Roads are an essential part of any fire and fuels management plan, providing the principal access
to the communities, homes and wild places in the watershed. Additionally, roads may offer a
defensible space from which firefighters can conduct direct attack on wildfires and also provide
strategic locations for roadside shaded fuelbreaks. Roadside shaded fuelbreaks provide not only
defensible space for firefighters, but also a safe escape route for residents in the event of a
wildfire.
Roadside protection should occur within a corridor that extends up to 100 feet out from either
side of the road. This treatment is designed to protect evacuation routes for community residents
and provide safety for firefighters entering a community to provide protection in the event of a
wildfire. Brush and shrubs that have spacing 3 times the height of the residual plants should be
removed immediately adjacent to the road to keep flames from directly impinging the roadway.
Spacing between trees should be at least 20 feet between crowns of residual trees, with an
average crown base height [distance from the ground to the base of the leaf (needle) crown] of at
least 20 feet. Trees immediately adjacent to the road should be few. Flame lengths should be
less than 2 feet if there is enough fuel reduction to keep flames from traveling directly across the
roadway.
The MFSC generally supports the Sierra Club position, and would add that under extraordinary
conditions fuel treatments along roads may need to extend beyond 100 feet given conditions such
67 Keswick CWPP – Fire Access and Escape Routes; Lexington Hills CWPP – Fire Access and Escape Routes;
Fallen Leaf – Fire Access and Escape Routes.
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as terrain, vegetation type and potential weather conditions. The MFSC also notes that trees that
may fall on a road and block it during a wildfire should be removed or trimmed to avoid the
potential for this hazard.
6.2.2 Defensible Space Fuel Treatments
Maintaining properties with appropriate defensible space is a key factor to protecting lives and
property. Any of the fuel treatments in Section 6.3 have the potential to be used to create
defensible space when they can be used safely.
PRC 4291 and related regulations require certain hazardous fuel reduction measures, and
encourage others. The goal is to create "Defensible Space" to enable safe defense of structures
during a wildfire, and to provide for such related needs as emergency vehicle access and safe
evacuation routes. As discussed previously, detailed information on defensible space is found in
the Guidelines, published by CAL FIRE.68 The Guidelines are incorporated by reference into 14
CCR 1299, which was developed to implement PRC 4291. The Guidelines should be reviewed
by all landowners to which PRC 4291 applies.69
The Guidelines provide both general and specific defensible space fuel reduction guidance.
Important general concepts are expressed in the following Guideline excerpts:
While individual property owners are not required to clear beyond 100 feet,
groups of property owners are encouraged to extend clearances beyond the 100
foot requirement in order to create community-wide defensible spaces.
Properties with greater fire hazards will require more clearing. Clearing
requirements will be greater for those lands with steeper terrain, larger and denser
fuels, fuels that are highly volatile, and in locations subject to frequent fires.
More specifically, the Guidelines outline two distinct zones: from a structure outward to 30 feet
and from 30 to 100 feet from structures (Reduced Fuel Zone). It is important to note that these
distances are generally the maximum area that is required to be maintained by the statute, but are
based upon flat ground and moderate vegetation fuel loads. Required fuel reduction work over
substantially greater distances is desirable where terrain and vegetation type vary from this norm.
PRC 4291 provides conditions under which a greater distance may be required by an insurance
company, when approved by a fire expert approved by the Director of CAL FIRE, or when
required by local rule or regulation; however, such voluntary fuel reduction work may require
separate permits and must comply with all local, state and federal laws.
The Guidelines are included in Appendix E. See the Guidelines for more detail on fuel reduction
requirements for defensible space, and for detailed information on various treatments for
different vegetation types and terrain.
68 Online at: http://www.fire.ca.gov/cdfbofdb/pdfs/4291finalguidelines2_23_06.pdf
69 PRC 4291 applies to every "person who owns, leases, controls, operates, or maintains a building or structure in,
upon, or adjoining a mountainous area, forest-covered lands, brush-covered lands, grass-covered lands, or land that
is covered with flammable material."
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Defensible space fuel reduction should be conducted throughout the year in order to avoid the
accumulation of hazardous fuels over time. It should include fuel reduction for emergency
access as well as around structures, infrastructure, roads, and watersheds.
Consistent with the Guidelines and PRC 4291, this MCCWPP recommends that responsible
parties who reduce fuel for defensible space comply with all applicable federal, state or local
environmental protection laws and other laws, and obtain permits when required. Such laws
include, but are not limited to, those that protect threatened and endangered species, water
quality, air quality, and cultural/archeological resources. For example, trees removed for
hazardous fuel reduction that are used for commercial purposes require permits from CAL FIRE.
See Appendix G, Forest Practice Rules Checklist that can help you determine when such a
permit from CAL FIRE is required. Contact your local fire or planning agency officials to
ensure compliance.
PRC 4291 and the Guidelines state in part that:
 Responsible parties shall "Maintain defensible space of 100 feet from each side and from
the front and rear of the structure..." or as further provided in PRC 4291, but not beyond
the property line unless allowed by state law, local ordinance, or regulation, and with the
consent of the adjacent landowner.
 A greater distance may be required by state or local laws or by an insurance company
with approval by the FAHJ.
 Groups of property owners are encouraged to extend clearances beyond the 100-foot
requirement in order to create community-wide defensible spaces and escape routes.
The recommendations in this MCCWPP encourage prudent hazardous fuel reduction work to
protect people as well as the environment. To help those responsible for complying with PRC
4291 properly apply the recommendations in this plan, Table 14 is provided to show examples of
inappropriate hazardous fuel reduction work that would be inconsistent with federal, state or
local environmental protections or other laws.
Table 14. Misapplication Examples During Non-emergency Situations
Actor / Entity Misapplication of PRC 4291 and
the Guidelines
Comments
1 Property/Parcel Owner Removes all 60 oak trees (five
greater than 10 inches in
diameter) on a non-coastal half
acre building site without a
removal permit.
Such moonscape removal of
trees would violate current
county ordinance.
2 Home Owner Along property boundary,
owner removes fuel including
cutting down tree with roosting
condor pair, without prior
approval from appropriate State
or Federal agency.
Violates state and/or federal
Endangered Species Act(s).
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Actor / Entity Misapplication of PRC 4291 and
the Guidelines
Comments
3 Property Owner Creates 200-foot radius bare-
earth clearing around existing
structure on flat terrain, and
there is no requirement to do
so.
Structure and conditions do
not warrant such excessive
defensible space.
4 Ranch Owner Bulldozes a firebreak in a creek
bottom.
Violates riparian protection
regulations, such as the Fish
and Game Code.
5 Private Water Purveyor Without permit, a purveyor
grades, excavates, and installs
60,000-gallon underground
water tank in area with known
protected plant species.
Violates County building,
health, safety, and
environmental regulations.
6 Subdivision Housing
Project Owner
Builds line of small sheds 200-
feet apart for 800-feet, then
clears 60-foot wide swath
through fuel to provide
improved view of valley for the
houses being built.
Given that the intent was to
improve the view, this is a
misuse of defensible space
requirements.
7 USFS or BLM Bulldozes a new road in a
wilderness area under the guise
of constructing a fuelbreak.
Violates the Wilderness Act.
6.3 Hazardous Fuel Treatments
In addition to defensible space treatments, other hazardous fuel treatment projects described
below should be considered to reduce overall wildfire threat to communities, infrastructure,
rangelands, watersheds and other assets. Such projects must comply with all applicable local,
state or federal laws, and may occur on private or public land under state or federal jurisdiction
and would be used to act as a buffer between communities and/or assets and wildland fuels.
Hazardous fuel treatments may include treatments such as the following, but not by way of
limitation:
 Fuelbreaks or other treatments intended to modify fire behavior and spread by altering
fuel beds in a linear alignment, typically situated along roads, rivers and ridgetops, and
may include retained trees (e.g., shaded fuelbreaks).
 Roadside fuel treatments, intended to reduce the likelihood of ignition along roadways
and to maintain emergency ingress and egress capabilities during wildfires.
 Area treatments, intended to modify fire behavior by treating hazardous fuels over large
areas in strategic locations or historic fire corridors; typically conducted in large expanses
of federal or private land (e.g., strategically placed landscape area treatments).
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 Prescribed burning, intended to reduce hazardous fuel loads in key locations and reduce
overall wildfire intensity and negative smoke impacts while considering vegetation type
characteristics and disturbance regimes.
The following hazardous fuel treatment prescriptions are recommended to reduce vegetation fuel
in treatment areas. Within the recommended WUI zones, the goal is to reduce
understory/surface fuel flame length to under four feet around access roads, structures,
infrastructure, and watersheds.
6.3.1 Strategic Fuelbreaks and Other Treatments
It is recommended that strategic fuelbreaks and other treatments be established and maintained
throughout the County, where indicated in this MCCWPP or local CWPPs, or where determined
to be appropriate by the FAHJ including, but not limited to, existing and historic fire
containment lines. Fuelbreaks and other treatments should incorporate adjacent buffers in which
wildfire fuels are modified in such manner and for such distance as will ensure a high probability
the fuelbreak or other treatment will be effective under adverse weather conditions and permit
effective tactical suppression actions.
6.3.2 Vegetation Thinning
Thinning of vegetation involves an overall reduction of woody biomass to break up horizontally
and vertically continuous fuels. Site specific conditions and fire threat potential should dictate
thinning percentages and distance in relation to structures, emergency access routes, and other
assets. Factors such as topography and vegetation type may also be considered.
6.3.3 Tree Removal
Removal of trees should focus primarily on removing dead and dying trees. However, in areas
with hazardous fuels, live tree removal may be necessary to improve vegetation spacing and
reduce overall fuel continuity. Where trees require removal, root systems should generally be
left intact where needed to maintain slope stability. In such cases, annual treatment of stump
growth or re-sprouting may be needed to maintain reduced fuel load volumes.
Along access roads, spacing between trees should be at least 20 feet between crowns of residual
trees, with an average crown base height (distance from the ground to the base of the leaf
[needle] crown) of at least 20 feet. Trees immediately adjacent to the road should be few.70
Trees that may fall on a road and block it during a wildfire should be removed or trimmed to
avoid the potential for this hazard.
6.3.4 Tree and Shrub Pruning
Trees or large tree-form shrubs (reaching four feet or taller at maturity) that are to be retained in
defensible space should be trimmed or pruned to reduce both vertical and horizontal fuel
continuity. Pruning should eventually attain at least 8 foot (16 foot preferable where attainable)
70 July 13, 2010 comment letter to the January 2010 MCCWPP from the Ventana Chapter of the Sierra Club.
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vertical clearance from the highest slope point within the canopy, yet should not exceed 50
percent reduction of live crown (canopy).
Along access roads, brush and shrubs that have spacing 3 times the height of the residual plants
should be removed immediately adjacent to the road to keep flames from directly impinging the
roadway. Flame lengths should be less than 2 feet if there is enough fuel reduction to keep
flames from traveling directly across the roadway.71
6.3.4.1 Vertical Separation
At a minimum, pruning of vegetation off the ground should provide vertical clearance that
measures three times the height of the understory vegetation or ten feet, whichever is higher (see
CAL FIRE's Guidelines for more details). Pruning tree limbs up to 16 feet or more may be
desirable in some terrain and vegetation types. Vertical separation serves to minimize the
potential for a ground fire to transition to a crown fire. This process will remove ladder fuels and
reduce the potential for fire spread from lower shrubs to higher trees and structures.
6.3.4.2 Horizontal Separation
Pruning of vegetation should result in horizontal clearance that measures three times the height
of the plant material height or 20 feet, whichever is greater. Horizontal separation of 40 feet or
more may be desirable, depending upon slopes and vegetation types. Horizontal separation
serves to minimize fire spread from plant to plant and from plant to structure. In defensible
space, an alternative to crown separation is to use the Guidelines' option 4b, which provides for
retaining a closed canopy while removing surface fuels/understory and lower branches from
trees.
6.3.4.3 Vegetation Grouping
Maintaining groups of shrubs is recommended to provide a mosaic pattern in the landscape.
However, shrub groups should be separated from other shrub groups according to the horizontal
separation criteria discussed above.
6.3.5 Dead/Dying Plant Removal
Removal of dead and dying plant material from the WUI will help reduce low fuel moisture
biomass and highly flammable fine fire fuels. This practice should also be conducted in
combination with vegetation thinning efforts and may help reach or completely satisfy thinning
objectives in some areas.
71 See previous footnote.
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6.3.6 Exotic/Invasive Plant Removal
Removal of non-native and invasive plants from the WUI will help reduce the presence of
undesirable species and enhance thinning efforts aimed at reducing overall biomass levels.
Typical undesirable exotic species may include, but are not limited to:
 Palm trees (various species)
 Eucalyptus trees (Eucalyptus spp.)
 Pepper trees (Schinus spp.)
 Fennel (Foeniculum vulgare)
 Mustard (Brassica spp.)
 French broom (Genista monspessulana)
 Poison hemlock (Conium maculatum)
 Thistle (various species)
 Harding grass (Phalaris aquatica)
 Jubata grass (Cortaderia jubata)
 Pampas grass (Cortaderia selbana)
 Cape ivy (Delairea odorata)
6.3.7 Mowing
Mowing of grasses and exotic weeds should be conducted to maintain grass heights at four
inches or lower. Focus should be primarily on invasive weed prevention, suppression and
monitoring, and properly timed and implemented grassland management (e.g. mowing, grazing)
that promotes the establishment of less volatile native perennial grasses. Mowing should be
performed before 10 AM during the dry season to reduce the chance of starting a fire from
sparks caused by the mowing equipment.
6.3.8 Chipping and Mastication
Chipping/mastication and spreading of existing dead biomass or biomass from hazardous fuel
reduction efforts may be an effective method of hazardous fuel reduction and weed suppression.
However, chip or mulch depth should generally not exceed six inches.
6.3.9 Grazing
Livestock (including goats) have proven to be an effective method for reducing hazardous fuel
volumes in WUI areas.
6.3.10 Prescribed Burning
Preplanned controlled burning is currently conducted by private landowners throughout
Monterey County, by CAL FIRE as a function of the state Vegetation Management Program
(VMP), and on land administered by the BLM, DOD, and USFS.
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Burning under desirable conditions restores fire to the ecosystem and is normally one of the most
cost effective methods for strategically reducing hazardous fuels by 50 to 80 percent. Rangeland
property owners and stakeholders have identified the goal of accomplishing 20,000 acres of
landscape-scale prescribed fire projects on private property in State Responsibility Areas
annually in Monterey County. Large-scale prescribed burning is conducted by private
landowners under permit and with the cooperation of the Monterey Bay Unified Air Pollution
Control District (MBUAPCD), CAL FIRE, USFS, BLM, and various local fire agencies.
Landowners may also contract with CAL FIRE to perform burns under the statewide Vegetation
Management Program. For more information about obtaining a Smoke Management Permit,
visit www.mbuapcd.org and under "Programs," click on "Smoke Management."
Preplanned burning under low and moderate wildfire hazard conditions is the preferred
alternative to unplanned wildfire events occurring under severe fire weather conditions. The
Monterey San Benito Range Improvement Association Wildland Fire Safe Council72 actively
assists landowners and cooperating agencies in the coordination of prioritized projects.
See Appendix L for a sample fire prescription for safe controlled burns in chaparral.
Depending on site conditions, piling and burning is a form of prescribed fire that can be more
feasible and cost effective than chipping or hauling material to landfills. Project location and
setting determines which approach is the most environmentally friendly and effective alternative.
Piling and burning can generally be safely conducted during the winter rainy season.
6.3.11 CAL FIRE Vegetation Management Program
The CAL FIRE VMP provides a means for landowners to contract with CAL FIRE for
hazardous fuel reduction and prescribed burn projects. Under contract with CAL FIRE,
landowners share the costs of regulatory compliance, preparation, and treatment according to the
public vs private benefit. Statewide, CAL FIRE is authorized to treat up to 180,000 acres
annually under the VMP. The cooperative and coordinated utilization of the CAL FIRE VMP is
important to the success of this MCCWPP.
6.3.12 Crushing
Crushing breaks and presses brush and/or slash on or into the ground surface. This occurs when
equipment drives over slash. This method involves the use of heavy ground-based equipment
that crushes slash to a depth not exceeding two feet. The closer crushed material is to the forest
floor, the quicker decomposition occurs and the less chance of fire reaching the above canopy
layers.
6.3.13 Lopping and Scattering
Lopping is the cutting of limbs, branches, treetops, small diameter trees, or other woody plant
residue into lengths so that the remaining slash will lie close to the ground. Scattering is the
spreading of lopped slash evenly over the ground so that the remaining slash will lie no more
than three (3) feet off the ground. This method is suited to areas with lower brush and/or slash
72 Contact via email at: wildland_fsc@yahoo.com
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accumulations and is effective for such accumulations in meeting height requirements,
facilitating use of the treated area by humans and animals, improving aesthetics, and distributing
material more uniformly and closer to the ground for faster decomposition. Lopping is also
useful as preparation for piling and burning, especially in areas with higher fuel density where
scattering would contribute to wildfire hazard (e.g., see Section 6.3.10).
6.3.14 Fireline Explosives
Fireline explosives are linear explosive charges placed and detonated in lengths of up to a half
mile or more to create a fireline through surface and ground fuels. The explosive component is
typically a water gel compounded to reduce flame generation to avoid igniting a fire. Fireline
explosives may be advantageous in locations where mechanized equipment cannot be used to
construct firelines. Four people using fireline explosives can construct fireline as fast as 25 to 40
people with handtools.73 Less specialized explosive charges may be advantageous to drop trees
that are too hazardous for sawyers to cut, such as snags and those with widowmakers. Dropping
partially rotted standing Sudden Oak Death killed Tanoaks is an example of when such use of
explosives may be beneficial.
6.3.15 Herbicides
Herbicides are chemicals that have been developed to control or kill specific groups of plant
species. Three primary types of herbicide exist: foliar active, soil active, and those that are both
foliar and soil active. Herbicides that are foliar active enter the plant through the leaves and
occasionally the stem. Soil active herbicides are taken up through the roots of the plant.
Herbicides are most effective when used in accordance with a sound prescription. A single
treatment provides long-term reduction of hazardous live fuels and changes in species
composition, but the effect on total live and dead fuels is not immediate.74 Herbicides can be
used as an effective tool for managing vegetation and forest health. Herbicides can have
detrimental effects on water quality and lethal effects on non-target organisms. Therefore, they
should be used consistent with the instructions under which their use was approved by the
Environmental Protection Agency, and with an appreciation of their potential for harm if
misused.
6.4 Community Fire Safe Prescriptions
Community Fire Safe Prescriptions are envisioned to be site-specific fuel treatments and fire
behavior parameters within the Defensible Space, Mitigation Zones, Threat Zones and HFRZs to
reduce the risk of wildfire within and near a community. These treatments and parameters may
be developed for some locations on a site-specific basis, to prevent the spread of wildfire to more
wildland or structures, and to prevent the spread of a structure fire to neighboring structures or
the wildland.
73 Wenger, Karl. Forestry Handbook: Second Edition, John Wiley & Sons, 1984. Page 222.
74 University of Florida. Fuel Reduction Options for Landowners at the Wildland-Urban Interface, Technical Paper
for Master of Forest Resources & Conservation.
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6.5 Air Quality
As discussed in Section 3.3.3.2, the MBUAPCD works closely with communities, landowners,
agencies and the MFSC to allow burning of hazardous fire fuels consistent with air quality goals.
The MBUAPCD may require a permit for burning within the District.75 Contact the MBUAPCD
to determine if a permit is required. For large project burns, the MBUAPCD cooperates with
agencies, landowners, the CARB meteorology section, and fire weather forecasters to seek burn
conditions that will be conducive to successful smoke dispersion and minimal impacts to
communities.
Requirements for efficient pile burning procedures are available from the MBUAPCD.
7.0 Environmental Benefits
7.1 Greenhouse Gases
Globally, fires are a significant contributor of carbon dioxide and other greenhouse gases in the
atmosphere. While burning vegetation is carbon neutral, high intensity fires due to hazardous
fuel accumulation may result in more vegetation burning than would burn if lower fuel loads
were present, contributing more carbon dioxide to the atmosphere than would generally occur
with lower fuel loads present. Researchers found that large scale fires contributed to most of the
year-to-year changes in atmospheric carbon dioxide totals during the period from 1997 to 2001.76
Fires were found to account for approximately one-fifth of the total global emissions of carbon
dioxide.77 Fuel reduction and fire suppression efforts will need to occur expeditiously or greater
amounts of carbon will be released by large higher intensity wildfires, further exacerbating the
global warming problem.
7.2 Use of Biomass
Where practical, use of biomass woody debris resulting from hazardous fuel mitigation efforts is
supported by this MCCWPP. Biomass is plant matter, which can be used for purposes such as
generating electricity or producing heat. Wood biomass includes wood chips, wood pellets and
other low-grade wood wastes. In areas where the location of biomass sources and of biomass
utilization make transportation of biomass practical, biomass may offer many benefits including
those listed below:
75 See the following web page for a summary of when permits are required (when in doubt, contact the
MBUAPCD):
http://www.mbuapcd.org/~mbuapcd/index.php?option=com_content&view=article&id=56&catid=21&Itemid=80#S
tandards1
76 University of Maryland University College(2004) El Nino Fires Released Clouds of Greenhouse Gases.
77 Levine, Joel S.; Cofer, Wesley R., III. 2000. Boreal forest fire emissions and the chemistry of the atmosphere. In:
Kasischke, Eric S.; Stocks, Brian J., eds. Fire, climate change, and carbon cycling in the boreal forest. Ecological
Studies Vol. 138. New York: Springer-Verlag: 31-48.
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 Biomass energy is good for the environment. Biomass energy systems help keep forests
healthy by providing a market for low-grade “cull” wood, which removal improves the
well-being of the forest.
 Biomass fuel is a local product. Dollars spent on biomass fuel stay in the regional
economy, creating jobs.
 Biomass is easy to use and has high energy content. Wood pellets or wood chips are a
clean-burning, high energy, carbon neutral renewable fuel that is convenient to use and
requires less storage space than other biomass fuels.
8.0 Strategy and Action Plan
It is recommended that this document serve as an advisory document to assist in the development
of fire safe activities and policies throughout Monterey County, subject to the issuance of all
necessary permits and compliance all local, state and federal laws.
This MCCWPP makes the connection between Strategic Fuelbreaks, Defensible Space,
Defensible Polygons, and the incident management, providing communities and agencies a
cooperative guidance to wildfire protection.
This MCCWPP provides a general framework for coordinated interagency multi-jurisdictional
strategic community wildfire protection planning for Monterey County.
Government agencies and private landowners responsible for managing the vegetation in and
near the recommended at-risk communities within Monterey County will be invited to submit
hazardous fuel reduction projects that provide communities wildfire protection and reduce risk.
The Recommended Hazardous Fuel Reduction Projects table in Appendix D presents a list of
hazardous fuel reduction projects currently recommended. Whether the projects will actually be
initiated or conducted depends upon such factors as continued availability of leaders/organizers,
availability of funding, continued interest by landowners, and potential changes to existing
conditions before projects are funded and started, and issuance of all necessary permits and
compliance with all local, state and federal laws.
The MFSC, along with local communities, intends to assess hazardous fuel reduction progress
annually and invite agencies, landowners, and involved citizens to submit projects that provide
community, watershed and infrastructure protection. Project identification and implementation
are an on-going processes and the table in Appendix D may be updated by the MFSC as needed.
This MCCWPP is a living document and has been created to allow for ongoing management,
updates, and community input intended for reducing the severity of wildland fires and reducing
the vulnerability of assets to wildland fires in Monterey County. The following sections discuss
long term management objectives intended to promote fire safe communities and the overall
reduction of wildfire costs and losses in Monterey County.
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8.1 Localized Fire Plans and CWPPs
This MCCWPP provides wildfire planning recommendations and information at a county wide
scale. The preparation of localized fire plans and CWPPs at the community or neighborhood
scale are recommended and supported. This document is intended to provide a guide for
communities or neighborhoods to develop localized fire plans and CWPPs. However, local areas
may rely on this MCCWPP for the purpose of seeking grant funds to perform hazardous fuel
reduction work without the need for a local CWPP. Such work would need to comply with the
requirements of all applicable local, state and federal laws, including environmental protection
laws, as well as with all requirements of the grant agreement, including development of specific
details on the scope of work. It is the intention of this MCCWPP that local CWPPs should have
priority and authority over the county-level recommendations included in this MCCWPP, subject
to all local, state and federal laws. Pursuant to the HFRA, a local CWPP must be agreed to by
the local fire department(s), CAL FIRE and the applicable local government (city or the County
of Monterey). Local CWPPs may identify site-specific constraints, fuels treatment options,
specific vegetation prescriptions, at-risk community boundaries and refined or redefined WUI
boundaries, emergency preparedness and other issues important to community wildfire safety,
and accordingly, may deviate from the MCCWPP.
When developing local CWPPs, one should bear in mind that in some locations, coordination of
large strategic firebreaks and fuelbreaks is important to the protection of multiple communities.
Those drafting local CWPPs should consider the needs of other communities and communicate
with them before deciding on such treatments. Fire does not recognize political boundaries, so
those working to protect communities must interact and cooperate with other communities in
order to be effective.
It is anticipated that the findings, projects, and recommendations included in the localized fire
plans and CWPPs will be integrated into this MCCWPP during routine maintenance and updates
of the document. Currently, localized fire plans or CWPPs are being considered for the areas of
Big Sur, Palo Colorado, Cachagua, Pebble Beach, Carmel Highlands and Carmel Valley.
The following recommendations are intended to provide guidance for the preparation of
localized fire plans and CWPPs. Localized fire plans and CWPPs should be prepared as
provided in the HFRA, including within the context of the collaborative agreements and the
guidance of the Wildland Fire Leadership Council, which calls for collaboration between a broad
spectrum of affected parties, and may provide the following information:
 Define or redefine WUI boundaries for the community based on factors such as local
topography, fuel types and densities, the desire to protect watersheds, property
lines/ownerships, location of historic fuelbreaks and proximity to federal land, all as
desirable to promote hazardous fuel reduction to protect the community from wildfires.
 Define or redefine the boundaries for the community.
 Identify and define a description of essential infrastructure such as roads, water supply
systems, and power or communication structures, including an estimate of its value. The
HFRA provides that CWPPs should make recommendations for hazardous fuel reduction
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treatments on federal land and non-federal land to protect such infrastructure from
damage by wildfire.
 Requests for hazardous fuel reduction work on land managed by the USFS and/or the
BLM.
 Prioritize locations where fuel reduction grants should be made to fund projects on
private land.
 Collaborate with Monterey County and the incorporated cities within the County, when
required, and other agencies to facilitate and streamline hazardous fuel mitigation work
described herein.
 Implement measures to reduce structural ignitability.
 Identify additional stakeholders or at-risk communities not included in this MCCWPP.
 Include in the decision-making process affected individuals including residents and
private property owners in the community, CAL FIRE and the FAHJ (e.g. local fire
district, volunteer fire department, city fire department, etc.) and the local government
(city or Monterey County). The USFS, BLM, environmental groups, and other
stakeholders should be consulted during the drafting process.
 Identify and address site-specific environmental regulations and necessary permitting
requirements.
 Identify and address hazardous fuel treatment prescriptions, funding sources, and
monitoring protocols.
 Identify opportunities for additional public education and safety training.
 Identify local evacuation routes and safe zones, and involve law enforcement officials
responsible for emergency evacuation and implementation of Ready, Set, Go! and
PSDLE78 concepts in the planning process.
 Include tribal contact information and provision for notifying tribal representatives in the
event ancestral remains are uncovered.
8.2 Long Term Maintenance/Monitoring
Long term maintenance and monitoring of hazardous fuel reduction efforts within Monterey
County is important to maintaining reduced hazardous fuel loads in critical threat areas and
identifying new or additional projects necessary for reducing overall wildfire risk to
communities. The following actions by the MFSC are intended to reduce community wildfire
risk:
 It is recommended that the FAHJ conduct annual monitoring of treated areas.
Maintenance of hazardous fuels is recommended for access roads, structures,
infrastructure, and watersheds within the WUI and can typically be completed at a cost
less than that for the initial effort. Monitoring efforts can identify areas in need of
additional hazardous fuel reduction treatments.
78 Example at www.ruralfire.qld.gov.au/Bushfire_Safety/Safety_in_Rural_Areas/Planning_and_Survival.html
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 Long term maintenance of the MCCWPP is essential. Maintaining the MCCWPP
document is critical to tracking completed projects and on-going hazardous fuel reduction
efforts, and most importantly, to address and define new priority areas and associated
hazardous fuel reduction projects. A two to three year review/edit cycle is recommended.
 Collaboration with Monterey County and the incorporated cities in the County (when
required) and other agencies is important for facilitating and expediting hazardous fuel
mitigation work described herein. To facilitate collaboration, it is recommended that
Monterey County authorize a position to be the primary contact for fire related and
hazardous fuel mitigation related activities, such as a Forester for Monterey County
residing within the MFSC.
 The Recommended Hazardous Fuel Reduction Projects included in Appendix D of this
MCCWPP shall be updated at least annually by the MFSC. Input from those in an at-risk
community (including interested individuals and the local fire authority) shall be given
the highest priority for informing such updates for their community. The MFSC shall
consider requests from project proponents to update Appendix D in a timely manner.
Note that Appendix D may be updated without requiring resigning by signatories to this
MCCWPP.
8.3 Public Education and Outreach
Public outreach and education is an important component in community fire preparedness
efforts. The MFSC sponsors ongoing fire prevention and public education programs county
wide and supports and promotes firewise activities by educating its citizens in ways to reduce
structure ignitability. The following MFSC actions are intended to support the wildfire hazard
reduction goals of this MCCWPP by incorporating community education, wildfire readiness, and
preparedness:
 Maintain the MFSC website as a portal for public information regarding hazardous fuel
reduction efforts throughout the County and advice on reduction of structural ignitability.
 Post the MCCWPP, updates, and specific project descriptions on the MFSC website.
 Provide a list of local fuel reduction contractors and consultants on the MFSC website.
 Develop printed educational materials for distribution in the at-risk communities.
 Conduct public outreach/education in communities where fuel reduction projects are
proposed prior to initiation of work.
 Develop strategic partnerships and funding opportunities with local industry to support
hazardous fuel reduction and firewise demonstration projects.
 Organize site visits to recently burned areas (e.g., one-year, three-year, ten-year post fire),
and contrast with old burns.
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9.0 Recommendations
In order to mitigate impending catastrophic fires, the recommendations below should be
accomplished with all deliberate speed.
The measures recommended in this MCCWPP to protect lives, property and the environment, are
intended to facilitate hazardous fuel reduction work in Monterey County, subject to the issuance
of all necessary permits and compliance with all local, state and federal laws.
Note on the Collaborative Process Used to Develop the MCCWPP, Including the
Recommendations
A CWPP, as defined under HFRA, is a plan that is, "developed within the context of the
collaborative agreements and the guidance established by the Wildland Fire Leadership
Council."79 The Wildland Fire Leadership Council provides a handbook, Preparing a
Community Wildfire Protection Plan, A Handbook for Wildland-Urban Interface Communities,
(Handbook) that outlines the process to be used to develop a CWPP.80
The MCCWPP was developed using the Handbook as a guide, and accordingly, the development
process was an open and collaborative process. This MCCWPP was written over the course of
years. Table 4 lists organizations that were sent letters of intent to develop the MCCWPP, and
invited to participate. Some groups that were not included in the original notice were added as
the MFSC became aware of their interest.
Participants in this process included fire professionals, concerned citizens, and representatives
from various organizations including homeowners associations and conservation groups.
During this collaborative process, the working draft was placed on the Internet in an on-line
document collaboration application (Acrobat Buzzword), and invitations to participate and enter
comments were sent out to a lengthy email list of interested parties, thus affording interested
parties an opportunity to collaborate using this convenient and accessible interface.
The January 2010 MCCWPP, which was signed by 18 agencies including CAL FIRE; the
Monterey County Fire Chiefs Association and local fire districts, departments and volunteer fire
brigades; USFS; BLM; the Presidio of Monterey/Fort Ord; and the California Department of
Parks and Recreation, contained recommendations to amend local, state and federal laws and
regulations to expedite fuel mitigation and fire preparedness efforts, to better protect lives,
property and the environment.
However, after the January MCCWPP was finalized and signed by these 18 agencies, comments
on the January 2010 MCCWPP were received from various environmental groups. In the spirit
of collaboration and in response to these comments, the MFSC removed from the MCCWPP,
among other things, recommendations to amend various environmental laws that in the opinion
of the MFSC are needed to better protect lives, property and the environment. Letters from
various organizations commenting on the January 2010 MCCWPP are included in Appendix J.
79 Title 16 USC 6511(c)(A).
80 Download the handbook at http://www.forestsandrangelands.gov/communities/documents/cwpphandbook.pdf
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The MFSC prepared a letter in response to these comments from these organizations, which is
also included in Appendix J.
In response to those comments, the September 2010 MCCWPP was revised to address them.
However, during Monterey County’s review of the September 2010 MCCWPP, Monterey
County and various environmental organizations requested additional changes to the document.
The MFSC amended the September 2010 MCCWPP to respond to the additional comments,
which are also included in Appendix J, resulting in the November 2010 MCCWPP. The
November 2010 MCCWPP was further amended to this version 2 (v2), after Monterey County
again deferred signing the MCCWPP.
9.1 Recommendations to the Secretary of Agriculture
Pursuant to sections 101(3)(B), 103, 104 and 105 of the HFRA,81 this MCCWPP recommends
the following to the Secretary of Agriculture:
9.1.1 Maintain the Ventana Fuelbreak (Big Box Firebreak)
Background: The Ventana Fuelbreak (formerly the Big Box Firebreak), which generally
surrounds much of the Monterey District of the LPNF, protects the following at-risk
communities from fires originating in the LPNF, and protects the LPNF from fires originating in
the following at-risk communities:
 Arroyo Seco
 Big Sur
 Big Sur, South Coast
 Bryson-Hesperia
 Cachagua
 Carmel Highlands
 Carmel Valley
 Carmel Valley Village
 Indians
 Jamesburg
 Lockwood
 Palo Colorado
 Pine Canyon (south)
 Rancho San Carlos
 Rancho San Clemente
 Reliz Canyon
 San Antonio Lake
 Tassajara
 White Rock
81 16 USC 6511(3)(B)), 6511(16)(A), 6513 & 6514.
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The image below shows the Basin Fire burning toward Carmel Valley in 2008. The Basin Fire
was stopped on the north at the Big Box/Ventana Firebreak. Most of the northern portion of the
Big Box/Ventana Firebreak (near Carmel Valley) is in the Ventana Wilderness. The photo was
taken from the Los Tulares area in Carmel Valley, looking generally southward, on or about July
15, 2008. The fog in the foreground is over the valley floor.
Recommendation: Reduce the risk to communities by maintaining the Ventana Fuelbreak,
and treatment on both sides of it in a condition and for such distance that will ensure a high
probability the fuelbreak or other treatment will be effective under adverse weather conditions
and permit effective tactical suppression actions. The fuelbreak should serve to allow firefighters
to work safely in the area; to change fire direction; to drop fire to the ground; and to stop the
spread of wildfire under adverse fire conditions. The width of treatment should be determined
utilizing such factors as fuel loads, topography, predominant winds, values at risk and fire
behavior modeling. To the extent the Ventana Fuelbreak and the treatments on both sides of it
are on non-federal land, this recommendation should be construed as recommending that federal
funds be made available for their maintenance (e.g., through grants). The location of the
Ventana Fuelbreak is shown on the map in Appendix B-7 by the line representing the Big Box
Firebreak.
Rationale: The Big Box Firebreak was used to protect at-risk communities surrounding the
LPNF from the 178,000 acre Marble Cone Fire in 1977, the 86,000 acre Kirk Complex Fire in
1999, and the 163,000 acre Basin Fire and 81,000 acre Indians Fire in 2008.
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The Basin Fire burned on the west side of an 8 mile segment of the western portion of the Big
Box Firebreak, consuming 26 homes and 32 other structures in the Big Sur at-risk community,
and threatening approximately 300 homes in the Palo Colorado at-risk community. Maintaining
and defending the Ventana Fuelbreak and treatments on both sides of it will reduce the threat of
harm to firefighters and to the communities surrounding the Los Padres National Forest. As
noted in Section 3.3.1.2., "Due to the extreme hazard of fires in the Los Padres National Forest"
Congress has provided special management language for wilderness areas in the Los Padres
National Forest, including allowing pre-suppression measures such as those recommended in this
MCCWPP.82
The recommendation to maintain the Ventana Fuelbreak and its side-treatments before fire starts
is to help ensure they can be used effectively and safely without delay to stop the spread of fire,
to protect lives, property and the environment. However, it is important to note that a fire,
whether natural or human-caused could occur outside fuelbreaks/firebreak, which would make
the fuelbreaks/firebreaks ineffective for slowing or stopping fires.
Note 1: Firebreak vs. Fuelbreak – Comments on the January 2010 MCCWPP included
concerns over the use of the term, "firebreak" instead of the term "fuelbreak". In an attempt to
reach consensus, this November 2010 MCCWPP deleted the recommendation to maintain
“firebreak” in its recommendations. The USFS and BLM have stated that as a matter of policy,
the agencies can only maintain strategic fuelbreaks, and not firebreaks. These agencies state that
firebreaks are, instead, opened and/or created during a wildfire. This MCCWPP recommends
measures to allow mechanized equipment into wilderness areas, when necessary, to open and/or
construct firebreaks and fight wildfire without any procedural delays.
Note 2: Use of Fuelbreaks – Fuelbreaks typically contain vegetation, though at reduced
volume. Fuelbreaks are generally maintained over substantially wider distance than firebreaks,
depending upon such factors as topography and vegetation type and density. Due to their
vegetation, fuelbreaks must be properly designed and maintained for such distance as will ensure
a high probability the fuelbreak or other treatment will be effective under adverse weather
conditions and permit effective tactical suppression action.
Fuelbreaks may be improved with heavy equipment to be firebreaks during fires, if time allows
and resources are available. During catastrophic events like the 2008 Lightning Siege in
California, which started over 2,000 fires statewide83 including the Basin Fire, availability of
resources can be problematic.
Note 3: Wilderness Expansion – The Ventana Wilderness was created in 1969
encompassing approximately 98,000 acres.84 The 1968 report from the Secretary of Agriculture
to President Johnson on the proposed Ventana Wilderness states, "The boundary of this proposed
Wilderness is very important and has been intentionally established wherever possible to allow
the construction of peripheral fuelbreaks, and fire control access. Approximately 70 percent of
82 Section 3.3.1.2.2, quoting Senate Report 95-490 on H.R. 3454 (The Endangered American Wilderness Act of
1978), 95th Congress 1st session October 11, 1977, Senate Committee on Energy and Natural Resources.
83 http://www.fire.ca.gov/index_incidents_overview.php
84 Public law 91-58, August 18, 1969.
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the boundary of this area would be located 250 feet below the crest of the ridge to permit the
machine construction of effective fuelbreaks."85
The boundary of the Ventana Wilderness has been expanded four times, and now encompasses
over 236,000 acres. In 2002, wilderness boundaries in the Monterey Ranger District of the
LPNF were expanded in twelve areas, in some locations to within 30 to 100 feet of roads. Some
of the roads serve as escape routes in event of fire and some double as firebreaks. In at least one
location, wilderness was expanded over the Big Box Firebreak.
Because of past procedural delays in obtaining authorization for using mechanized equipment in
wilderness, and to help avoid such procedural delays in the future, this MCCWPP makes
recommendations for additional training and communication, and expedited procedures, for
improving and/or creating firebreaks without procedural delay once wildfire has started.
Note 4: Sierra Club’s Expert’s Support for Maintaining Existing Firebreaks – As
part of the comments to the January 2010 MCCWPP,86 the Ventana Chapter of the Sierra Club
included as an exhibit, an opinion memo by Dr. Scott Stephens, Associate Professor of Fire
Science at the University of California, Berkeley. Mr. Stephens stated in his memo the
following: "The CWPP specifies where existing fire and fuel breaks are located throughout the
county (Pg 72, 73 & 74). Since these are already installed maintaining them into the future
makes sense. They can act as anchor points for fire suppression operations and safety areas for
fire fighters." As acknowledged by Dr. Stephens, the existing Big Box Firebreak should be
maintained, before fire starts, and treatments should be provided on each side to help ensure the
firebreak can be safely manned and effectively used during wildfires.
9.1.2 Maintain the Bixby Mountain Fuelbreak
Recommendation: Reduce the risk to communities by maintaining the Bixby Mountain
Fuelbreak, and treatments on both sides of it in a condition and for such distance as will ensure a
high probability the fuelbreak or other treatment will be effective under adverse weather
conditions and permit effective tactical suppression actions. The fuebreak should result in a high
probability that the fuelbreak will serve to allow firefighters to work safely in the area; to change
fire direction and spread; to drop fire to the ground; and to stop the spread of wildfire under
adverse fire conditions. The width of treatment should be determined utilizing such factors as
fuel loads, topography, predominant winds, values at risk and fire behavior modeling. To the
extent the Bixby Mountain Fuelbreak or its side-treatments are on non-federal land, this
recommendation should be construed as recommending that federal funds be made available for
their maintenance (e.g., through grants). The location of the Bixby Mountain Fuelbreak is shown
on the map in Appendix B-7 as the Bixby Mountain Firebreak.
Rationale: The Bixby Mountain Firebreak protected the Palo Colorado at-risk community
from the Basin Fire in 2008. This community contains almost half the residential population in
the greater Big Sur at-risk community. Much of the land on which the Bixby Mountain
85 90th Congress, 2d Session, House Document No, 292, Part 9.
86 July 13, 2010 Letter to Monterey Fire Safe Council from Lippe GaffneyWagner LLP.
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Firebreak is located is currently in private ownership, and some of the land is owned by the
USFS.
The Bixby Mountain Fuelbreak is the "backup" firebreak referred to in the rationale for Section
9.1.1, which was successfully used to stop the Basin Fire from burning into the greater Palo
Colorado area. The Bixby Mountain Firebreak is strategically critical for wildfires burning north
from the Los Padres National Forest southeast of Bixby Mountain. Recommendation 9.1.1
would restore the Bixby Mountain Fuelbreak to its historic role as a backup/secondary fuelbreak.
For additional explanation, see the rationale discussion for the Ventana Fuelbreak above.
However, it is important to note that a fire, whether natural or human-caused could occur outside
fuelbreaks/firebreaks, which would make the fuelbreaks/firebreaks ineffective for slowing or
stopping fires.
9.1.3 Establish Agreement with CAL FIRE to Defend the Bixby Mountain
Fuelbreak/Firebreak
Recommendation: To the extent the Bixby Mountain Fuelbreak is on Federal land, establish
agreements for CAL FIRE to defend the Bixby Mountain Fuelbreak during wildfires in a manner
consistent with CAL FIRE's fire suppression policies.
Rationale: The USFS and CAL FIRE differ in their policies regarding defense of firebreaks
and fuelbreaks that protect rural communities from wildfire. As noted above, the Bixby
Mountain Firebreak is currently located primarily on private land, which is SRA over which
CAL FIRE currently has jurisdiction. During the Basin Complex Fire, CAL FIRE successfully
improved and defended the Bixby Mountain Firebreak, protecting hundreds of homes in the
Bixby, Palo Colorado, Rocky Creek and Garrapata watersheds. Given that CAL FIRE has
successfully defended the Bixby Mountain Firebreak, defense of the fuelbreak should be
contracted out to CAL FIRE should the USFS acquire or own lands on which the fuelbreak is
located, and the agreement should specify that defense of the fuelbreak will be consistent with
CAL FIRE's suppression policies.
9.1.4 Pre-attack Planning by USFS in Cooperation with CAL FIRE and Local Fire
Departments
Recommendation: It is recommended that the USFS prepare, and update as needed, a pre-
attack plan that identifies the Ventana (Big Box) Firebreak and the Bixby Mountain Firebreak as
critical strategic firebreaks. The Pre-attack plan needs to address the urgency and procedures for
obtaining approvals to improving the firebreaks when a wildfire threatens communities at risk. It
is further recommended that the pre-attack plan be prepared and updated in cooperation with
local communities, CAL FIRE, and local fire departments responsible for wildfire suppression
and/or structure protection in communities that may be impacted by wildfires originating in the
Monterey Ranger District of the LPNF. It is also recommended that copies of the pre-attack plan
and its updates be provided to CAL FIRE and to such local fire departments upon completion, in
order that they may have them in their possession before fires start. The pre-attack plan should
also be provided to Monterey County for incorporation into the County's Emergency Operational
Plan.
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Rationale: Pre-attack planning can be used to avoid delays improving firebreaks that are
critical to protecting communities from wildfires that originate in the LPNF. See the Fire
Frequency Map at Appendix B-3 for a graphical indication that most major wildfires in
Monterey County start in the LPNF. Because of past procedural delays in obtaining
authorization for using mechanized equipment in wilderness, and because of the potential for
rapid spread of wildfires in the LPNF under severe fire conditions, and because incident
commanders from outside the area may not be familiar with local conditions, it is important to
prepare documentation in advance of wildfires that will avoid procedural delays improving
critical firebreaks once a wildfire has started.
9.1.5 Letter of Delegation and Expedited Process to Open and/or Construct
Firebreaks Upon Start of Wildfires
Recommendation: It is recommended that the USFS ensure that all fire management
personnel while managing a wildfire will understand the process for requesting authorization to
use mechanized equipment in wilderness to avoid any procedural delays. This process should be
conveyed to the initial attack Incident Commander and Incident Command Team through a letter
of delegation. It is further recommended that to the extent existing procedures have potential to
delay the use of motorized equipment in wilderness during wildfires, the USFS should alter or
supplement existing procedures to implement an expedited process to ensure that mechanized
equipment can be used in wilderness in the Monterey Ranger District of the LPNF during
wildfires, without procedural delay.
Rationale: Use of motorized equipment in wilderness is generally restricted until after a fire
has started. Even after a wildfire is burning delays obtaining authorization to use motorized
equipment in wilderness have been known to occur. To avoid procedural delays obtaining
authorization to use motorized equipment in wilderness during wildfires, the USFS should
implement procedures to ensure that all fire management personnel understand the process for
requesting authorization to use mechanized equipment in wilderness, or if needed to avoid
potential for such delays, USFS should alter or supplement existing procedures to implement an
expedited authorization process.
9.1.6 Support the Santa Lucia Fire Defense System (In Progress)
Background: The Santa Lucia Fire Defense System (in progress), including but not limited to
the Ventana Fuelbreak, is a network of interconnecting fire lines and fuelbreaks that protects at-
risk communities from fires originating in the LPNF (including those at-risk communities not
protected by the Ventana and Bixby Mountain Fuelbreaks), and protects the LPNF from fires
originating in at-risk communities. Development of the Santa Lucia Fire Defense System
(SLFDS) is supported by private landowners adjacent to LPNF and BLM threat areas. Initial
work was started on the SLFDS as part of the USFS FireScape Monterey (in progress), and the
BLM Sierra de Salinas-Gabilan Fuel Reduction Project and Strategic Fuel Break System.
Recommendation: Support funding for installation and maintenance of fuelbreaks and fuel
reduction buffer zones on Federal and non-federal lands within the SLFDS.
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Rationale: New and existing firebreaks and fuelbreaks in the area proposed to be encompassed
by the SLFDS were used to protect at-risk communities surrounding the LPNF from the 163,000
acre Basin Fire and 81,000 acre Indians Fire in 2008. The Ventana Fuelbreak will be part of the
SLFDS.
For additional explanation, see the rationale discussion for the Ventana Fuelbreak, above.
However, it is important to note that a fire, whether natural or human-caused could occur outside
fuelbreaks/firebreak, which would make the fuelbreaks/firebreaks ineffective for slowing or
stopping fires.
9.1.7 Manage Hazardous Fuels on National Forest System Lands to Protect All
At-Risk Communities
Recommendation: Manage vegetation on National Forest System lands in Monterey County
to protect all at-risk communities named in this MCCWPP. Recommended activities include
modifying hazardous fuels and installing and maintaining effective fuelbreaks, SPLATS and fuel
reduction buffer zones in a manner that will result in a high probability that wildfires originating
on National Forest System lands can be kept from spreading to at-risk communities under
extreme conditions.
Rationale: Though much of the LPNF burned over in the recent Basin, Indians and Chalk fires,
much of the burned over areas still have dead vegetation that is capable of reburning. The risk of
wildfire and danger to communities is therefore not eliminated on much of this Federal land.
Moreover, given the favorable environmental conditions, vegetation will rapidly regrow, and the
problem of overgrowth must be addressed.
9.1.8 Priorities for Hazardous Fuel Reduction Funding on Private Lands
Recommendation: Award grants and allocate other federal funding through the Department
of Agriculture for hazardous fuel reduction work on private lands and lands owned by state and
local government in Monterey County in accordance with the priorities of this MCCWPP in
Table 13 and Appendix D, subject to compliance with all local, state and federal laws.
Rationale: Pursuant to the HFRA, one purpose of a CWPP is to prioritize hazardous fuel
reduction projects to protect at-risk communities. The prioritization of hazardous fuel reduction
projects in this MCCWPP is based upon community priorities, state of the art fire modeling
analysis (e.g., FRAP fire threat analysis), on-the-ground fire threat assessment, and the expert
opinion of fire professionals familiar with Monterey County's WUI areas.
9.1.9 Fund Emergency Ingress and Egress to the Los Padres National Forest
(LPNF)
Recommendation: Fund fuel reduction work along roads that provide emergency ingress and
egress to the LPNF and to at-risk communities near the LPNF.
Rationale: Access to the LPNF during a wildfire is critical to USFS firefighting operations.
Where such access roads also provide emergency ingress and egress for at-risk communities, the
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added benefit of protecting lives and property in at-risk communities justifies a high priority for
fuel reduction work along such roads.
9.1.10 Incorporate CWPPs Into the USFS's Fire Management Plan and Pre-
attack Planning
Recommendation: Incorporate the maps and community pre-attack strategic fire defense
planning that may be prepared pursuant to this MCCWPP and local CWPPs into the USFS
incident management team's planning processes. Maps that are prepared should include
firebreaks and fuelbreaks, evacuation plans, Safety Zones, and WUI and at-risk community
boundaries, as provided in CWPPs.
Rationale: This recommendation would promote effective support of, and communication and
engagement with, communities that may be affected by wildfires originating on Federal land,
and avoid unnecessary displacement and disharmony among residents. The intent is to provide
for a full range of strategic and tactical options to manage wildland fires to accomplish resource
and protection objectives. This is in keeping with the 1995/2001 Federal Fire Policy and
Guidance for Implementation of Federal Wildland Fire Management Policy (February 13,
2009).87
9.2 Recommendations to the Secretary of the Interior
Pursuant to sections 101(3)(B), 103, 104 and 105 of the HFRA,88 this MCCWPP recommends
the following in this Section 9.2 to the Secretary of the Interior:
9.2.1 Maintain Former Fort Ord Fuelbreak System
Recommendation: Maintain existing Strategic Fuelbreaks and Defensible Polygons, as well
as existing roads and trails in the former Fort Ord Fuelbreak System. Provide for young seral
stage buffer zones at BLM borderlands adjacent to developed areas.
 Coordinate with existing and future communities adjacent to BLM borders to reduce
hazardous fuel loads through fuel treatments that involve a public/private commitment to
reduce fire hazards along WUI areas.
 Develop workforce and interagency prescribed fire skills at Fort Ord.
 Support firewise principles on parcels that will be developed adjacent to current and
future BLM lands at Fort Ord.
Rationale: BLM Borderlands at Fort Ord lie directly adjacent to communities at-risk.
According to the Habitat Conservation Plan (HCP), a range of seral stages will be
managed, including older age stands of chaparral and sage adjacent to at-risk communities and
identified as high fire threat.
87 See, http://www.nifc.gov/policies/guidance/GIFWFMP.pdf
88 16 USC 6511(3)(B)), 6511(16)(A), 6513 & 6514.
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9.2.2 Install and Maintain Sierra de Salinas-Gabilan Fuel Reduction Project and
Strategic Fuel Break System
Recommendation: Install and maintain strategic fuelbreaks, reduced fuel buffer zones and
defensible polygons as well as roads and trails in the Sierra de Salinas-Gabilan Fuel Reduction
Project and Strategic Fuelbreak System.
Rationale: The Sierra de Salinas-Gabilan Fuel Reduction Project and Strategic Fuel Break
System lie in the upland watershed of the Salinas River. With heavy rains following a high
intensity wildfire event, post-fire erosion can be catastrophic to the downstream communities
and the Salinas Valley’s agricultural crops, including world class vineyards. For example, the
2008 fires caused significant damage to many of Monterey County’s premium wines from smoke
taint.
9.2.3 Pinnacles National Monument Hazardous Fuel Reduction
Recommendation: At Pinnacles National Monument, support cooperative Sierra de Salinas-
Gabilan Fuel Reduction Project and Strategic Fuel Break System to include memorandums of
understanding and cooperative agreements between NPS and landowners.
Rationale: See rationale in Section 9.2.2 above.
9.2.4 Prescribed Hazardous Fuel Reduction at Toro Creek and Creekside
Recommendation: Support prescribed hazardous fuel reduction at Toro Creek and Creekside
BLM Borderlands (Highway 68) in coordination with adjacent landowners and Salinas Rural
Fire District.
Rationale: Should conditions in these areas preclude mechanical treatment, prescribed fire is
the preferred alternative.
9.2.5 Manage Hazardous Fuels on BLM Lands to Protect At-Risk Communities
Recommendation: Manage hazardous fuels on lands administered by the BLM in Monterey
County to protect all at-risk communities recommended in this MCCWPP that may be threatened
by wildfires originating on such lands. Recommended activities include modifying hazardous
fuels and installing and maintaining fuelbreaks, shaded fuelbreaks, SPLATS and fuel reduction
buffer zones in a manner that will result in a high probability that wildfires originating on lands
administered by BLM will not spread to at-risk communities under extraordinarily adverse
conditions.
Rationale: Wildfire danger exists on lands that are administered by the BLM in Monterey
County. The problem of hazardous fuels will need to be addressed to protect adjacent at-risk
communities.
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9.2.6 Priorities for Fuel Reduction Funding on Private Lands
Recommendation: Award grants and allocate other federal funding through the Department
of Interior related to hazardous fuel reduction work on private lands and lands owned by state
and local government in Monterey County in accordance with the priorities in Table 13 and
Appendix D, subject to issuance of all necessary permits and compliance with all local, state and
federal laws.
Rationale: Pursuant to the HFRA, one purpose of a CWPP is to prioritize hazardous fuel
reduction projects to protect at-risk communities. The prioritization of hazardous fuel reduction
projects recommended in this MCCWPP is based upon community priorities, FRAP analysis, on-
the-ground fire threat assessment, and the expert opinion of fire professionals familiar with
Monterey County's WUI areas.
9.2.7 Fund Emergency Ingress and Egress to Lands Administered by BLM
Recommendation: Fund fuel reduction work along roads that provide emergency ingress and
egress to lands administered by BLM in Monterey County, and to at-risk communities that may
be threatened by wildfires originating on such lands, in order that such roads may be used during
a wildfire.
Rationale: Access to lands administered by BLM during a wildfire is critical to firefighting
operations. Where such access roads also provide emergency ingress and egress for at-risk
communities, the added benefit of protecting lives and property in at-risk communities justifies a
high priority for fuel reduction work along such roads.
9.2.8 Incorporate CWPPs Into BLM's Pre-attack Planning
Recommendation: Incorporate the maps and community pre-attack strategic fire defense
planning that may be prepared pursuant to this MCCWPP and local CWPPs into the incident
management team's planning process. Essential maps that may be prepared include those
showing firebreaks and fuelbreaks, evacuation plans, Safety Zones, those showing boundaries of
communities at-risk and those showing WUI boundaries, as provided in CWPPs.
Rationale: This recommendation would promote effective support of, and communication and
engagement with, communities that may be affected by wildfires originating on Federal land,
and avoid unnecessary displacement and disharmony among residents.
9.3 Recommendation to Congress
9.3.1 Enact Legislation to Enable and Require that Fuelbreaks be Maintained, if
Fuelbreak Recommendations to the Secretary of Agriculture are not Implemented
Within Three Years
Recommendation: Should the fuelbreaks and side-treatments described in Sections 9.1.1 and
9.1.2 not be installed, maintained and defended as recommended, within three years from the
date this MCCWPP is signed by the signatories required by the HFRA, it is recommended that
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Congress enact legislation to clearly enable and require the recommendations in Sections 9.1.1
and 9.1.2.
Rationale: Though Congressional documents, for decades, have repeatedly stated that the
USFS is free to use whatever presuppression methods and techniques it finds are necessary to
manage wildfire fuels to protect communities near California's wilderness areas, and the Ventana
Wilderness and Silver Peak Wilderness areas in particular,89 little or no such preparation has
taken place. When wildfires come, communities remain vulnerable, with their survival
depending almost entirely on the weather and the location of random lightning strikes or human-
caused ignition.
After fire starts, bulldozers, hydraulic excavators, trucks, chainsaws, and other motorized
equipment must be approved for use in areas designated as wilderness. Obtaining such approval
can be delayed as fire spreads.90 Once approval is obtained motorized equipment is used in a
race to reopen overgrown firebreaks and fuelbreaks. However, depending on the weather and
where lightning strikes, there is no assurance that work can be done in time. This scenario plays
out every 10 to 20 years in the Monterey Ranger District of the LPNF (e.g., Marble Cone Fire
(1977), Kirk Fire (1999), Basin Fire (2008)).
9.4 Recommendations to all Federal, State and Local Regulatory Agencies with
Jurisdiction in Monterey County
This MCCWPP makes the following recommendations to all federal, state and local regulatory
agencies with jurisdiction in Monterey County, subject to compliance with all local, state and
federal laws.
9.4.1 Establish an Annual Goal for Hazardous Fuel Reduction Work in Monterey
County
Recommendation: An annual acreage goal for hazardous fuel reduction work in areas where
such fuel presents a potential threat to lives, structures, infrastructure, access roads or watersheds
in Monterey County should be established by agreement among fire organizations such as CAL
FIRE, the Monterey County Fire Chiefs Association and the MFSC, for the purpose of restoring
vegetation density and ecosystem fire resiliency to a state that approximates the condition an area
would likely have (in the judgment of the FAHJ) had fire suppression not been practiced in the
area.
Rationale: Hazardous fuels in certain areas of Monterey County present a potential threat to
lives, communities, structures, infrastructure, access roads, and watersheds in the event of
wildfire. Significant portions of Monterey County are rated by CAL FIRE's FRAP program as
high, very-high or extreme threat from wildfire. Without an annual goal for performance of
hazardous fuel reduction work in these certain areas that present a potential threat to lives,
89 See Section 3.3.1.2 in this MCCWPP, Wilderness Acts, for acts of Congress and Congressional reports related to
wilderness areas in Monterey County.
90 Reference: Chief Hutchinson’s statement at September 21, 2010 Board of Supervisors Hearing. Other fire
professionals who worked on the Basin Fire have reported that delays of several days occurred before approval for
use of heavy equipment could be obtained for some areas.
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communities, structures, infrastructure, access roads, and watersheds in the event of wildfire, it is
not possible to gauge whether the hazardous fuel problem is being adequately addressed.
9.4.2 Establishment of Hazardous Fuel Reduction Zones (HFRZ) and Approval
of Hazardous Fuel Reduction Work
Recommendation: It is recommended that the FAHJ be empowered to designate particular
areas within its jurisdiction where hazardous fuel presents a potential threat to lives,
communities, structures, infrastructure, access roads, and watersheds in the event of wildfire, as
HFRZ. It is also recommended that the FAHJ be empowered to approve hazardous fuel
reduction work that requires regulatory oversight.
Rationale: The FAHJs are the recognized experts at wildfire prevention, suppression and fuels
management, and under state law, enforce compliance with hazardous fuel reduction
requirements. Moreover, FAHJs bear the added burden of fire suppression in SRAs. Given that
HFRZs are intended to mitigate hazardous fuel conditions, and that hazardous fuels in certain
areas of Monterey County present a potential threat to lives, communities, structures,
infrastructure, access roads, and watersheds in the event of wildfire, FAHJs are the appropriate
agencies to designate HFRZs and to approve fuel reduction work within them.
9.4.3 Lead Agency for California Environmental Quality Act (CEQA) Purposes
Recommendation: For all hazardous fuel reduction work to which CEQA is applicable, this
MCCWPP recommends that CAL FIRE be the lead agency for CEQA purposes for fuel
reduction work on private land in SRA in Monterey County.
Rationale: CAL FIRE is recognized as the expert at wildfire prevention, suppression and fuels
management, and under state law enforces compliance with hazardous fuel reduction
requirements.91 Vast portions of Monterey County contain hazardous fuels, which could result
in catastrophic high-intensity wildfire. Such areas are in need of hazardous fuel treatment at the
earliest opportunity to protect lives, property and the environment. CAL FIRE is best positioned
to analyze the impacts from treatment alternatives related to hazardous fuel reduction work, and
to do so with minimum cost and delay. Environmental analysis for the USFS FireScape
Monterey may be used by CAL FIRE as the functional equivalent for such CEQA analysis to the
extent permitted by law.
9.4.4 Within HFRZs, Allow and Facilitate Creation of Survivable Space
Recommendation: For structures within HFRZs, creation of survivable space should be
allowed and facilitated as a means of encouraging early evacuation in the event of wildfire, and
reducing risk to firefighting personnel and others.
Rationale: Survivable space is an effective means of protecting lives and property, and should
be allowed and facilitated. Due to conditions such as high hazardous fuel content, steep terrain,
poor access roads or potential for overwhelming scale of wildfire, it is likely that for some
91 CAL FIRE is currently the lead agency for fuel reduction undertaken pursuant to PRC 4291 and related
regulations, within the SRA.
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structures in certain locations, firefighting professionals will not be present to defend assets from
wildfire. Landowners who have been allowed to prepare survivable space are more likely to
evacuate early if they know their structure has a good chance of survival without anyone present
defending it. Moreover, survivable space provides potential refuge for those caught by
unexpected change in fire conditions.
9.4.5 Allow and Facilitate use of Large Burn Piles During Winter Rains with a
Minimum of Regulatory Requirements
Recommendation: This MCCWPP recommends that the MBUAPCD allow and facilitate use
of large burn piles during winter rains to dispose of piled vegetation debris.
Rationale: Large quantities of vegetation and deadwood must be disposed of in Monterey
County at low cost. The quantity and remote location of hazardous fuels can make it impractical
to transport the material to landfills or to chip it. Large burn piles are an efficient means of
disposing of vegetation cuttings and deadwood. The MBUAPCD should facilitate a process to
allow landowners to use pile burning as a safe means of material disposal. Proper disposal of
vegetation overgrowth and deadwood is key to the success of the hazardous fuel reduction work
recommended in this MCCWPP, and safe burning of large piles is an appropriate means of
disposal.
9.4.6 Consider the Option of Biomass for Use of Woody Debris From Fuel
Mitigation Activities
Recommendation: This MCCWPP recommends that all relevant agencies consider the option
of biomass for use of woody debris resulting from hazardous fuel reduction effort, where such
use is practical and would help facilitate fuel reduction activities. The agencies should evaluate
technological options that may be available to make vegetation a practical renewable energy
source.
Rationale: Biomass is commonly plant matter grown to generate electricity or produce heat.
Wood biomass includes wood chips, wood pellets and other low-grade wood wastes. Biomass
has many benefits, which are described in Section 7.2. The following summarizes these benefits:
(1) biomass energy is good for the environment – biomass energy systems help keep forests
healthy by providing a market for low-grade "cull" wood, whose removal improves the well-
being of forests and woodlands; (2) dollars spent on biomass fuel stay in the regional economy,
creating jobs; and (3) wood pellets or wood chips are a clean-burning, high energy renewable
fuel that is convenient to use.
9.4.7 Monterey Fire Safe Council and California Department of Fish and Game
Develop Localized Handouts Describing Species That are Protected by State
and/or Federal Law
Recommendation: It is recommended that the Monterey Fire Safe Council (MFSC) and the
California Department of Fish and Game (CDFG) work together to prepare localized handouts,
containing descriptions and photos of species that are protected by state and/or federal law, to
inform those performing hazardous fuel work to avoid the take of listed species.
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Rationale: Species that are listed as threatened or endangered pursuant to state or federal law
generally must be avoided and cannot be taken. The MFSC and CDFG should work together to
develop localized handouts describing and illustrating protected species in order that the public
can be informed about which species to avoid while performing hazardous fuel reduction work.
The handouts should be localized to each fire district or area of responsibility, and made
available through local fire departments and districts, and should focus on only those protected
species that may be found in the applicable area.
9.4.8 Reduction of Structural Ignitability
Recommendation: This MCCWPP recommends that the MFSC coordinate a Countywide
Fire Education Program. The purpose of this program is to educate community members on
methods of reducing structural ignitability through (1) training courses; (2) educational
brochures and flyers; and (3) voluntary home inspection program. Grant funding could be used
to encourage voluntary participation by homeowners to implement Firewise tasks. The purpose
of the education program is to show the homeowners what they can do around their own property
to prevent a wildfire from igniting their home. The education program should cover use of
Firewise landscaping; use of Firewise roof and other construction materials; methods for
maintaining a structure to help prevent ignition; and preparation of a family disaster plan
including information on how to create a survival space.
Rationale: Community education is a key component of a successful fire prevention program.
Through community education, awareness is raised and the public becomes engaged in the
solution. Community-wide commitment to hazardous fuels reduction and reduction of structural
ignitability is essential to establishing an effective fire prevention strategy. Educating
community members about Firewise technique is critical to preventing fires that may otherwise
result in loss of lives, property, and the environment.
9.5 Recommendations to CAL FIRE and Other Fire Authorities Having
Jurisdiction (FAHJ)
9.5.1 Designate Hazardous Fuel Reduction Zones (HFRZs)
Recommendation: CAL FIRE and other FAHJs should designate HFRZs in areas where
hazardous fuel presents a potential threat to lives, communities, structures, infrastructure, access
roads, and/or watersheds in the event of wildfire.
Rationale: This MCCWPP relies on the designation of HFRZs to identify areas that present a
potential threat to lives, communities, structures, infrastructure, access roads, and/or watersheds
in the event of wildfire. If HFRZs are not designated, lives, property and the environment may
continue to be put at risk.
9.5.2 Support Ready, Set, Go! to Include Those Who May be Trapped by Fire
Recommendation: Support Ready, Set, Go! while acknowledging that in some locations
individuals may be trapped by fire and/or be unable to evacuate, and that some individuals may
elect to follow the concept of PSDLE.
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Rationale: Ready, Set, Go! guidelines require community readiness and preparation for
trapped-by-fire, evacuation-not-possible incidents as stated in the Ready, Set, Go! vision
statement:
Residents of communities take personal responsibility for living in the Wildland
Urban Interface (WUI), possesses knowledge and skills to effectively prepare
their home for survival when wildfire is threatening, evacuate early and safely
when ordered, and, if trapped, practice learned skills to survive the wildfire.
9.5.3 Support Community Emergency Response Teams (CERT)
Recommendation: Support implementation of Community Emergency Response Team
(CERT) training and integrate CERT with Coordinated Emergency Response Plans throughout
Monterey County.
Rationale: This recommendation is to prepare and integrate citizen's actions with county-wide
emergency and disaster preparation.
9.5.4 Support Annual Treatment Goals in the CAL FIRE Range Improvement
and Vegetation Management Programs (VMP)
Recommendation: Proactively support safe landscape scale fire hazard reduction burning.
Prioritize assignment of CAL FIRE, local government, and other agency resources to support
strategic hazardous fuel reduction, Range Improvement, and VMP projects in Monterey County.
Prioritize future projects proposed as part of this MCCWPP implementation process with a goal
of treating 20,000 acres annually.
CAL FIRE should acknowledge and proactively support Range Improvement and VMP projects
with fire safety standby personnel and equipment in accordance with the provisions of PRC
sections 449192 and 4480.93 Both sections provide authority for meeting goals of this MCCWPP.
92 PRC section 4491 states as follows: "Cooperation by the department, as provided in this article, with any person
desiring to use prescribed burning as a means of converting brush-covered lands into forage lands, which has as its
objective prevention of high intensity wildland fires, watershed management, range improvement, vegetation
management, forest improvement, wildlife habitat improvement, and maintenance of air quality, or any combination
thereof, is declared to be for a public purpose. This article shall be administered by the director or, if responsibility
therefor is delegated by the director, by the chief of a county fire department in a county contracting with the
department pursuant to the provisions of Section 4129. In furtherance of the provisions of this article, the department
shall provide advisory service to applicants for permits as to precautions to be taken by the applicant to prevent
damage to the property of others by reason of the prescribed burning, and shall provide standby fire protection, to
such extent as personnel, fire crews, and firefighting equipment are available.
93 PRC section 4480 states as follows: "In any area of the state where there are substantially more requests for
prescribed burning operations or other hazardous fuel reduction pursuant to this article than can be conducted
directly by the department in a single fiscal year, the director may, with the approval of the Director of Finance,
enter into an agreement with private consultants or contractors or with other public agencies for furnishing all or a
part of the state's share of the responsibility for planning the operation, preparing the site, and conducting the
prescribed burning or other hazardous fuel reduction. The private consultant or contractor or other public agency,
and the work assignments of its employees, shall be supervised by the fire boss when conducting prescribed burning
operations, or designated officer of the department when conducting other hazardous fuel reduction, as provided in
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Rationale: One purpose of a CWPP is to coordinate agency efforts and landowner initiative
with funding sources to accomplish the goals of the CWPP through effective utilization of
resources. Interagency cooperation, community support, and landowner initiative are necessary
for achieving the objectives of this MCCWPP, which include prescribed fire goals of 20,000
acres treated annually within the County.
PRC sections 4491 and 4480 authorize CAL FIRE to cooperate with and support landowners and
other agencies in the implementation of hazardous fuel reduction projects.
9.5.5 Prioritize CAL FIRE Resources to Support the Recommendations in this
MCCWPP
Recommendation: CAL FIRE should prioritize Unit resources to emphasize strategic pre-fire
mitigation and pre-attack activities, and integrate this MCCWPP and community strategic pre-
attack fire defense and evacuation plans into the Unit Workplan and incident management team's
planning process.
Rationale: Community priorities and Unit priorities need to be synchronized to allow for
effective pre-fire planning.
9.6 Recommendations to Monterey County and to Municipalities and Districts
Within Monterey County
9.6.1 Include Language to Allow and Facilitate Hazardous Fuel Reduction Work
in all Planning Documents, Ordinances, Rules and Regulations
Recommendation: This MCCWPP recommends that Monterey County and all municipalities
and districts with jurisdiction in Monterey County include in planning documents, ordinances,
rules, regulations and department policies, language to allow and facilitate hazardous fuel
reduction work wherever it would advance protecting lives, property or the environment.
Rationale: The source of the police power that justifies the existence of local and regional
government entities is the protection of public health and safety. Various well intentioned
planning policies, ordinances, rules and regulations can have the consequence of adding costs,
delays and limitations that discourage or preclude hazardous fuel reduction work where it is
needed to protect lives, property or the environment. In order to allow and facilitate hazardous
fuel reduction work, it is critical that all plans, ordinances, rules and regulations include
allowances for hazardous fuel reduction work to facilitate such work with the least amount of
regulatory hindrance permissible under state and federal law. It is important to understand that
the intent is to restore areas with hazardous fuels to an approximation of the fuel loads they
would have had fire suppression not been practiced in the area, as determined by the FAHJ.
subdivision (c) of Section 4476. No agreement may be entered into pursuant to this section unless the director
determines that it will enable the prescribed burning operation to be conducted at a cost equal to, or less than, the
cost that would otherwise be incurred by the state."
Monterey County Commu
November 2010 v2
C O
10.0 MCCWPP Agreement
This MCCWPP is a voluntary guideline prepared primarily by various citizen groups with
collaborative input from government agencies at the federal, state and local level. It is
comprised of a statement of existing conditions and laws, and recommends solutions to
individuals and to various government agencies and legislators. This MCCWPP does not legally
commit any agency to a specific course of action or conduct, including by the act of signing the
MCCWPP.
In the spirit of collaboration encouraged by the Healthy Forests Restoration Act of 2003, the
following entities mutually agree with the contents of this Monterey County Community
Wildfire Protection Plan:
State Agency Responsible for Forestry
________________________________
Richard C. Hutchinson Jr., Unit/Fire Chief
San Benito-Monterey Unit, CAL FIRE
Local Fire Chie
Michael Urquide
Richard C. Hutch
Chris Orman
Michael Urquide
Martha Karstens
Cheryl Goetz
Roderic McMaha
Jack Riso
C O P Y
C O P Y
C O P Ynity
P Y
fs
s Monterey County Fire Chiefs Association
ins
s
n
C O P YWildfire Pro
C
on Jr.
C
CCAromas Tri-County FPD, Carmel Highlands
FPD, Pebble Beach CSD Fire Department,
Cypress FPD, South Monterey County FPD
North County Fire Protection DistrictO P Ytection Plan 88
O P Y
O P Y
Carmel Valley FPD,
Monterey County Regional Fire District
Big Sur Volunteer Fire Brigade
Mid Coast Fire Brigade
Cachagua FPD
Presidio of Monterey/Fort OrdO P Y
C O P Y
Local Government
_______________________________________
Simon Salinas, Chair
Monterey County Board of Supervisors
Other Agencies and Groups
The following signatories are not required, but are included to express the spirit of collaboration
in which this MCCWPP was developed:
______________________________ ______________________________
Sherry A. Tune, District Ranger Rick Cooper, Hollister District
USFS, Monterey Ranger District, LPNF Bureau of Land Management
______________________________ ______________________________
Mathew L. Fuzie, District Superintendent Kelly Erin O'Brien, President
Monterey District, California Monterey Fire Safe Council
Department of Parks & Recreation
C O P Y
C O P Y C O P YMonterey Co
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11.0 References
Bureau of Land Management (BLM) 2008. Bureau of Land Management, Hollister Field Office.
Fire Management Plan 2008.
CAL FIRE 2009. California Department of Forestry and Fire Protection, San Benito – Monterey
Unit: 2009 Fire Plan.
County of Monterey 2008. County of Monterey FactFinder. Online at:
http://www.co.monterey.ca.us/factfinder/pdf/2008FactFinder.pdf
Fire and Resource Assessment Program (FRAP) 2008. GIS data, online at:
http://frap.cdf.ca.gov/
Fire and Resource Assessment Program (FRAP) 2006. Monterey Fire Risk Analysis, Report to
Monterey Fire Safe Council, Contract No. 8CA03405. 6 June 2006.
Fire in California Ecosystems, Sugihara/Wagtendonk/Shaffer/Fites-Kaufman/Thode
www.ucpress.edu
InciWeb: Incident Information System. 2008. Online at: http://www.inciweb.org/
Los Padres National Forest (LPNF) 2008. Fire Management Plan.
Monterey County 2007. Draft 2007 Monterey County General Plan. Online at:
http://www.co.monterey.ca.us/planning/gpu/draftNov2007/default.htm
Spatiotemporal Analysis of Controls on Shrubland Fire Regimes: Age Dependency and Fire
Hazard, Moritz, 2003, Ecology, Vol. 84, No. 2, pg. 360.
As part of the CAL FIRE 2005 Fire Plan, Pebble Beach Community Service District (PBCSD)
2005. Fire Defense Plan for Pebble Beach.
12.0 Resources
Bureau of Land Management, Hollister Field Office
http://www.blm.gov/ca/st/en/fo/hollister.html
California Department of Forestry and Fire Protection (CAL FIRE)
http://www.fire.ca.gov/
http://www.fire.ca.gov/communications/communications_firesafety_100feet.php
http://www.fire.ca.gov/communications/downloads/fact_sheets/Checklist.pdf
California Fire Alliance
http://www.cafirealliance.org/
Fire and Resource Assessment Program (FRAP)
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http://frap.cdf.ca.gov/
The Firesafe Council
http://www.firesafecouncil.org/
FIREWISE Communities
http://www.firewise.org/
United States Forest Service, Los Padres National Forest
http://www.fs.fed.us/r5/lospadres/
Monterey County Community Wildfire Protection Plan
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APPENDIX A
Glossary of Terms
Monterey County Community Wildfire Protection Plan Glossary
November 2010 v2 1
APPENDIX A – Glossary of Terms
At-Risk Community – Means as defined in the Healthy Forests Restoration Act of 2003 (HRFA),
namely:
An area –
(A) that is comprised of –
(i) an interface community as defined in the notice entitled "Wildland Urban Interface
Communities Within the Vicinity of Federal Lands That Are at High Risk From
Wildfire" issued by the Secretary of Agriculture and the Secretary of the Interior in
accordance with title IV of the Department of the Interior and Related Agencies
Appropriations Act, 2001 (114 Stat. 1009) (66 Fed. Reg. 753, January 4, 2001); or
(ii) a group of homes and other structures with basic infrastructure and services (such as
utilities and collectively maintained transportation routes) within or adjacent to Federal
land;
(B) in which conditions are conducive to a large-scale wildland fire disturbance event; and
(C) for which a significant threat to human life or property exists as a result of a wildland fire
disturbance event.
(See the definition for "Community At-Risk," below.)
Building – Any structure used or intended for supporting or sheltering any use or occupancy.
(NFPA, NFPA 1144, 2002, p. 4.)
Combustible – Any material that, in the form in which it is used and under the conditions
anticipated, will ignite and burn or will add appreciable heat to an ambient fire. (NFPA, NFPA
1144, 2002, p. 5.)
Community At-Risk – A community that is listed as a community at-risk on the list maintained
by the California Fire Alliance (see,
www.cafirealliance.org/communities_at_risk/communities_at_risk_list). A community at-risk
differs from an at-risk community in that a community at-risk is not required to be near land
managed by the United States Forest Service (USFS) or the Bureau of Land Management (BLM)
("With California's extensive urban [sic] Wildland-Urban Interface situation, the list of
communities extends beyond just those adjacent to Federal lands." see,
www.cafirealliance.org/communities_at_risk/.)
(See the definition for "At-Risk Community," above.)
Community Fire Safe Prescriptions – Community Fire Safe Prescriptions are envisioned to be
site-specific fuel treatments and parameters within the Defensible Space, Mitigation Zones,
Threat Zones and HFRZs to reduce the risk of wildfire within and near a community. These
treatments and parameters may be developed for some locations on a site-specific basis, to
prevent the spread of wildfire to more wildland or structures, and to prevent the spread of a
structure fire to neighboring structures or the wildland.
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Community Wildfire Protection Plan (CWPP) – A plan for an at-risk community that—
(A) is developed within the context of the collaborative agreements and the guidance established
by the Wildland Fire Leadership Council and agreed to by the applicable local government, local
fire department, and State agency responsible for forest management, in consultation with
interested parties and the Federal land management agencies managing land in the vicinity of the
at-risk community;
(B) identifies and prioritizes areas for hazardous fuel reduction treatments and recommends the
types and methods of treatment on Federal and non-federal land that will protect 1 or more at-
risk communities and essential infrastructure; and
(C) recommends measures to reduce structural ignitability throughout the at-risk community.
(Source: HFRA.)
The process of developing a CWPP can help communities clarify and refine their priorities for
the protection of life, property, and critical infrastructure in the wildland-urban interface (WUI).
The language in the HFRA provides maximum flexibility for communities to determine the
substance and detail of their plans and the procedures they use to develop them. (Source:
Preparing a Community Wildfire Protection Plan, March 2004.)
Condition Class – Describes fire-related risk to ecosystems and relates current expected
wildfires to their historic frequency and effects. Condition class ranks are defined as the relative
risk of losing key components that define an ecosystem. Higher ranked areas present greater risk
to ecosystem health. Condition class is a measure of the expected response of ecosystems to fire
given current vegetation type and structure that often is far different from that historically
present.
Condition Class Departure from
natural
regimes
Vegetation
composition,
structure,
fuels
Fire behavior,
severity,
pattern
Disturbance
agents, native
species,
hydrologic
functions
Increased
smoke
production
Condition Class 1
(Little to None*)
None,
minimal
Similar Similar Within natural
range of variation
Low
Condition Class 2
(Moderate*)
Moderate Moderately
altered
Uncharacteristic Outside historical
range of variation
Moderate
Condition Class 3
(High and Very-
High*)
High Significantly
different
Highly
uncharacteristic
Substantially
outside historical
range of variation
High
(Source: CAL FIRE FRAP 2003 Forest and Range Assessment, p. 98)
* These terms are CAL FIRE equivalents of fire fuel hazard rating to the pertinent condition class.
Coordinated Emergency Response Plans – The Monterey County Office of Emergency Services
(OES) is responsible for initiating and coordinating disaster and emergency preparation,
response, recovery, and mitigation operations within Monterey County. OES develops and
maintains various emergency plans, including coordinated emergency response plans for certain
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November 2010 v2 3
geographical threat areas (e.g., Big Sur). These plans are intended to enhance inter-jurisdictional
coordination by maintaining agreements with local, state and federal agencies to provide
coordinated emergency response.
Defensible Polygon – An area surrounded by firebreaks, fuelbreaks, shaded fuelbreaks or similar
means of controlling the spread of fire, such that there is an increased probability that wildfire
may be stopped from passing in or out of the area, and danger to those working to control the fire
is reduced.
Defensible Space – Defensibe Space includes the area within the perimeter of a parcel (or
beyond if permission is obtained from the adjacent landowner(s)) where basic wildfire protection
practices are implemented, providing the key point of defense from an approaching wildfire or
escaping structure fire. The area is characterized by the establishment and maintenance of
emergency vehicle access, emergency water reserves, street names and building identification,
structure defense measures to reduce the likelihood of structure ignition, and fuel modification
measures. Defensible space intended to protect lives and property and to ensure the safety of
those defending the area from wildfire. Defensible Space implies that tactical resources will be
available to defend assets during a wildfire. (See the definition for "survivable space," below.)
Disaster – Disaster is characterized by the scope of an emergency. An emergency becomes a
disaster when it exceeds the capability of the local resources to manage it. Disasters often result
in great damage, loss, or destruction. (Greene, R.W., Confronting Catastrophe, ESRI Press,
2002, p. 110.)
Dudek – An environmental consulting firm headquartered in Encinitas, California.
Emergency – A situation that calls for immediate action to avoid serious harm to the public
peace, health, safety, or general welfare. (California Government Code section 11342.545.)
Evacuation/Escape Route – A route away from dangerous areas of a fire; should be preplanned.
(FIREWISE Communities, 2009, http://www.firewisewiki.org/main/index.php/Escape_Route.)
Federal land – means:
Land of the National Forest System (as defined in section 1609 (a) of [title 16 United
States Code]) administered by the Secretary of Agriculture, acting through the Chief
of the Forest Service; and
Public lands (as defined in section 1702 of title 43), the surface of which is
administered by the Secretary of the Interior, acting through the Director of the
Bureau of Land Management.
(HFRA, Title 16 United States Code (USC) section 6502.)
Fire Authority Having Jurisdiction (FAHJ) – The organization, office, or individual
responsible for approving equipment, materials, an installation, or a procedure. (NFPA, NFPA
1144, 2002, p. 4.)
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Fire Behavior – The manner in which a fire reacts to the influences of fuel, weather, and
topography. (FIREWISE Communities, 2009,
http://www.firewisewiki.org/main/index.php/Fire_behavior.)
Fire Frequency – A broad measure of the rate of fire occurrence in a particular area. For
historical analyses, fire frequency is often expressed using the fire return interval calculation.
(CDF FRAP 2003 Forest and Range Assessment, p. A-12.)
Fire Hazard – A fuel complex, defined by volume, type, condition, arrangement, and location
that determine the degree of ease of ignition and of resistance to control. (FIREWISE
Communities, 2009, http://www.firewisewiki.org/main/index.php/Fire_hazard.)
Fire Protection – All measures taken to reduce the burden of fire on the quality of life. Fire
protection includes, but is not limited to, fire prevention, fire suppression, built-in fire protection
systems, and other such measures discussed in the planning and building codes. (NFPA, NFPA
1141, 1998, p. 4.)
Fire Regime – A measure of the general pattern of fire frequency and severity typical to a
particular area or type of landscape. The regime can include other metrics of the fire, including
seasonality and typical fire size, as well as a measure of the pattern of variability in
characteristics. (CDF FRAP 2003 Forest and Range Assessment, p. A-12.)
Fire Threat – The combination of two factors: 1) fire frequency, or the likelihood of a given area
burning, and 2) potential fire behavior (hazard). Components include surface fuels, topography,
fire history, and weather conditions. (Source: CDF FRAP 2003 Forest and Range Assessment, p.
A-12, http://frap.cdf.ca.gov/assessment2003/.)
Fire Threat Assessment – Provides field verification of threat, including identification of:
 Factors of fire behavior change
 Fire behavior decision points
 Fire severity alignment scenarios
 Direction of fire spread
 Tactical suppression thresholds of control
 Fire history
 Tactical fire suppression capacity
Determinations of fire threat are based upon anticipated fire flame length, rate of spread, fire
intensity, fire front duration or residence time, and fire brand ember spotting distances under a
range of weather scenarios.
Fire Weather – Weather conditions that influence fire starts, fire behavior or fire suppression.
(FIREWISE Communities, 2009, http://www.firewisewiki.org/main/index.php/Fire_weather.)
Firebreak – A natural or constructed barrier used to stop or check fires that may occur, or to
provide a control line from which to work. (FIREWISE Communities, 2009,
http://www.firewisewiki.org/main/index.php/Firebreak.) A firebreak is at least 10 feet wide,
 Monterey County Community Wildfire Protection Plan                                                                                                                  Glossary  
November 2010 v2 5
frequently 20 to 30 feet wide, and contains no vegetation or other combustible matter.  (The Use 
of Fuelbreaks in Landscape Fire Management, 1998, James K. Agee et al.) 
Fuelbreak  –  A natural or manmade change in fuel characteristics which affects fire behavior so 
that fires burning into them can be more readily controlled.  (National Wildfire Coordinating 
Group (NWCG), Glossary of Wildland Fire Terminology.) 
Fuels – All combustible material within the WUI or intermix, including vegetation and 
structures.  (FIREWISE Communities, 2009,  
http://www.firewisewiki.org/main/index.php/Fuels.) 
Fuel Loading – The volume of fuel in a given area generally expressed in tons per acre. 
(FIREWISE Communities, 2009, http://www.firewisewiki.org/main/index.php/Fuel_loading.) 
Fuel Models – Description of the types of vegetative combustible material, for example: 
• Light Fuels – grasses, forbs 
• Medium Fuels – short light brush and small trees 
• Heavy Fuels – tall dense brush, timber and hardwoods 
• Slash Fuels – logs, chunks, bark, branches, stumps, and broken understory trees and 
brush. 
Fuel Modification – Any manipulation or removal of fuels to reduce fire intensity, rate of 
spread, and/or the likelihood of ignition or the resistance to fire control. (FIREWISE 
Communities, 2009, http://www.firewisewiki.org/main/index.php/Fuel_modification.) 
Fuel Reduction Buffer Zone – The term refers to the Strategic Placement of Treatments 
(SPOTS) within the Mitigation Zone or the Threat Zone.  This zone is an area where a younger 
age class (or earlier seral class) is maintained in a strategic location to reduce the risk of fire 
spread to adjacent lands, such as residential areas. 
Geographic Information Systems (GIS) – The combination of skilled persons, spatial and 
descriptive data, analytic methods, and computer software and hardware – all organized to 
automate, manage, and deliver information though geographic presentation (i.e., maps). (Zeiler, 
M., Modeling Our World, ESRI Press, 1999, p. 46.)  
Ground Fuels – All combustible materials such as grass, duff, loose surface litter, tree or shrub 
roots, rotting wood, leaves, peat or sawdust that typically support combustion. (FIREWISE 
Communities, 2009, http://www.firewisewiki.org/main/index.php/Ground_fuels.)   
Hazard – Refers generally to physical characteristics that may cause an emergency.  Earthquake 
faults, flood zones, and highly flammable brush fields are all examples of hazards. (Greene, 
R.W., Confronting Catastrophe, ESRI Press, 2002, p. 110.)  Also see Fire Hazard. 
 
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Hazardous Fuel – Combustible material that accumulates in the forest or other wildlands and is
concentrated on the ground surface as surface fuel or just above the ground surface as ladder
fuel, or in the tree canopy as crown fuel.
Hazardous Fuel Reduction Zone (HFRZ) – An area designated by the FAHJ, based upon the
FAHJ's experience and knowledge, as containing hazardous fuel that presents a potential threat
to lives, communities, structures, infrastructure, access roads, and/or watersheds in the event of
wildfire. HFRZs may also include areas where fuelbreaks, firebreaks and other treatments may
be needed to protect such areas from wildfires originating outside the area. HFRZs may vary in
size, and are independent from, though may include, Defensible Space, Mitigation Zones and
Threat Zones.
Hazardous Vegetation Overgrowth –Vegetation growth that, in the judgment of the FAHJ,
exceeds the vegetation density that would exist in the area had fire suppression not been
practiced or had proper fuels mitigation measures been accomplished, which in the judgment of
the FAHJ, presents a threat of increased probability of ignition or high intensity wildfire.
Healthy Forests Restoration Act of 2003 (HFRA) – Gives incentives for communities to engage
in comprehensive forest planning and prioritization. This legislation includes statutory
incentives for the USFS and the BLM to give consideration to the priorities of local communities
as they develop and implement forest management and hazardous fuel reduction priorities. The
Act emphasizes the need for federal agencies to work collaboratively with communities in
developing hazardous fuel reduction projects, and it places priority on treatment areas identified
by communities themselves in a CWPP. (Source: Preparing a Community Wildfire Protection
Plan. March, 2004.)
Hydrophobic – Repels water, as with soils that repel water after a high heat intensity wildfire. A
thin layer of soil at or below the mineral soil surface can become hydrophobic after intense
heating. The hydrophobic layer is the result of a waxy substance that is derived from plant
material burned during a hot fire. This waxy substance penetrates the soil as a gas and solidifies
after cooling, forming a waxy coating around soil particles. The layer appears similar to non-
hydrophobic layers. (After the Fires: Hydrophobic Soils, Randy Brookes, University of Idaho
Cooperative Extension Series, http://www.cnr.uidaho.edu/extforest/F5.pdf.)
Intermix – An area where improved property and wildland fuels meet with no clearly defined
boundary. (NFPA, NFPA 1144, 2002, p. 5.)
Ladder Fuels – Fuels that provide vertical continuity allowing fire to carry from surface fuels
into the crowns of trees or shrubs with relative ease. (FIREWISE Communities, 2009,
http://www.firewisewiki.org/main/index.php/Ladder_fuels.)
Mitigation – Action that moderates the severity of a fire or risk. (NFPA, NFPA 1144, 2002, p.
5.)
Mitigation Zone – Mitigation Zones are strategically prioritized target areas within the Threat
Zone where fire fuel reduction activity will be of high value to protect life, property, and the
environment, and to support safe tactical suppression capability.
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National Fire Protection Association (NFPA) – An international nonprofit organization,
established in 1896, to reduce the worldwide burden of fire and other hazards on the quality of
life by providing and advocating consensus codes and standards, research, training, and
education. (NFPA, 2009,
http://www.nfpa.org/categoryList.asp?categoryID=143&URL=About%20Us.)
NFPA-1144 Standard for Protection of Life and Property from Wildfire (NFPA 1144) –
Standard developed by the NFPA to be used to provide minimum planning, construction,
maintenance, education, and management elements for the protection of life, property, and other
values that could be threatened by wildland fire. The standard shall be used to provide minimum
requirements to parties responsible for fire protection, land use planning, property development,
property maintenance, and others responsible for or interested in improving fire and life safety in
areas where wildland fire could threaten lives, property, and other values. (NFPA, NFPA 1144,
2002, p. 4.)
Nitrogen Fixer – Plants whose roots are colonized by certain bacteria that extract nitrogen from
the air and convert or "fix" it into a form required for their growth. When the bacteria are done
with this nitrogen, it becomes available to the plant itself. An example of a nitrogen fixer is
clover. (http://landscaping.about.com/cs/lazylandscaping/g/nitrogenfixer.htm.)
Noncombustible – Any material that, in the form in which it is used and under the conditions
anticipated will not ignite and burn, nor will add appreciable heat to an ambient fire. (NFPA,
NFPA 1144, 2002, p. 5.)
Overstory – That portion of the trees in a forest that forms the upper or uppermost layer.
(FIREWISE Communities, 2009, http://www.firewisewiki.org/main/index.php/Overstory.)
Risk – The potential or likelihood of an emergency to occur. For example, the risk of damage to
a structure from wildfire is high if it is built upon, or adjacent to, a highly flammable brush field
or other area deemed to have a high fire threat. (Greene, R.W., Confronting Catastrophe, ESRI
Press, 2002, p. 110.)
Safety Zone – An area cleared of flammable materials used for escape in the event the line is
outflanked or in case a spot fire causes fuels outside the control line to render the line unsafe. In
firing operations, crews progress so as to maintain a Safety Zone close at hand allowing the fuels
inside the control line to be consumed before going ahead. Safety Zones may also be
constructed as integral parts of fuelbreaks; they are greatly enlarged areas which can be used
with relative safety by firefighters and their equipment in the event of blowup in the vicinity.
(National Wildfire Coordinating Group, 2009, http://www.nwcg.gov/pms/pubs/glossary/s.htm.)
Shaded Fuelbreak – A reduction in vegetation created by altering surface fuels, increasing the
height to the base of the live crown, and opening the canopy by removing trees. This type of
fuelbreak spans a wide range of understory and overstory prescriptions and methods of creation
through manual, mechanical, and prescribed fire means. (The Use of Fuelbreaks in Landscape
Fire Management, 1998, James K. Agee et al.)
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Slope – The variation of terrain from the horizontal; the number of feet rise or fall per 100 feet
measured horizontally, expressed as a percentage (FIREWISE Communities, 2009,
http://www.firewisewiki.org/main/index.php/Slope). Upward or downward incline or slant
(NFPA, NFPA 1144, 2002, p. 5).
State Responsibility Area (SRA) – The area "in which the financial responsibility of preventing
and suppressing fires is primarily the responsibility of the state" (PRC section 4125). This is
further expanded in PRC sections 4125-4128.136
Strategically Placed Landscape Area Treatments (SPLATS) – Areas of forest thinning designed
to slow the spread of fire. They are placed on the landscape so that a spreading fire does not
have a clear path of untreated fuels from the bottom of the slope to the ridge top. These are to be
designed to burn at lower intensities and slower rates of spread during wildfires than comparable
untreated areas. In the example of a large parking lot with speed bumps, the SPLATs are the
speed bumps that slow down fires. (University of California Sierra Nevada Adaptive
Management Project http://snamp.cnr.berkeley.edu/about/snamp-glossary/.)
Strategic Fuelbreak – See the definition for "fuelbreak," above.
Strategic Placement of Treatments (SPOTS) – See the definition for "strategically place
landscape area treatments," above. SPLATS and SPOTS are synonymous, although SPOTS is
newer and may be the preferred term.
Surface Fuels – Surface fuels include understory plants generally less than 6 feet tall (dead and
alive), the litter layer, downed woody materials, and often brush and midstory tree and shrub
fuels. Surface fuel availability for consumption is determined by moisture content, particle size,
horizontal continuity, compactness, and fuel type (particularly fuels with high volatile
compounds).
Survivable Space – Survivable Space includes structure defense measures to reduce the
likelihood of structure ignition and the area around a structure where vegetation has been
modified to provide a high likelihood, under the site's conditions (e.g., vegetation type,
construction materials and terrain), that the structure (and people if present) will survive in the
event of a wildfire, under extraordinarily adverse weather conditions, without the presence of
firefighters or others defending the structure. Survivable space applies where there is potential
that tactical resources will not be available to defend assets during a wildfire. (See the definition
for "defensible space," above.)
Threat Zone – Threat Zones extend out from Defensible/Survivable Space to major
landscape/watershed features such as roads, rivers, or ridges. Threat Zones generally extend to
the boundary of the WUI, and may include strategic firebreaks and fuelbreaks placed in
coordination with major watershed features, and with the Mitigation Zones and Defensible
Space, creating anchor points for wildfire suppression.
136 Also see, http://frap.cdf.ca.gov/projects/population/sra_definition.html
Monterey County Community Wildfire Protection Plan Glossary
November 2010 v2 9
Understory – Low growing vegetation (herbaceous, brush or reproduction) growing under a
stand of trees. The term also includes that portion of trees in a forest stand below the overstory.
(FIREWISE Communities, 2009, http://www.firewisewiki.org/main/index.php/Understory.)
Water Supply – A source of water for firefighting activities or other purposes. (NFPA, NFPA
1144, 2002, p. 5.)
Wildfire – Any unplanned fire occurring in a wildland or wildland-urban interface area that does
not meet management objectives and thus requires a suppression response. Wildland fire
protection agencies use this term generally to indicate a vegetation fire. Wildfire often replaces
such terms as forest fire, brush fire, range fire, and grass fire.
Wildland – A region with minimal development as evidenced by few structures; transportation
networks may traverse region. Region typically contains natural vegetation and may be used for
recreational or agricultural purposes. (CDF FRAP 2003 Forest and Range Assessment, p. A-17.)
Wildland-Urban Interface (WUI) – For purposes of this MCCWPP, WUI shall mean those areas
designated on the map in Appendix B-7, unless the local CWPP designates different areas as
WUI, in which case the local CWPP shall prevail. In the absence of such mapping, section 101
(16) of the HFRA defines WUI as "(I) an area extending ½ mile from the boundary of an at-risk
community; (II) an area within 1 ½ miles of the boundary of an at-risk community, including any
land that (1) has a sustained steep slope that creates the potential for wildfire behavior
endangering the at-risk community; (2) has a geographic feature that aids in creating an effective
fire break, such as a road or ridge top; or (3) is in condition class 3, as documented by the
Secretary in the project-specific environmental analysis; (III) an area that is adjacent to an
evacuation route for an at-risk community that the Secretary determines, in cooperation with the
at-risk community, requires hazardous fuels reduction to provide safer evacuation from the at-
risk community." A CWPP offers the opportunity to establish a localized definition and
boundary for the wildland-urban interface (HFRA, 16 USC 6511(16); Preparing a Community
Wildfire Protection Plan, 2004.)
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APPENDIX B
Monterey County Maps
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APPENDIX C
Ready, Set, Go!
May 14, 2009
Ready, Set,
Go!
Our vision for the future is that ...
Communities situated in high fire hazard environments are designed,
constructed, retrofitted, managed, and maintained in a manner that may
require little fire suppression assistance during wildfires. Residents these
communities take personal responsibility for living in the Wildland Urban
interface (WUI), possess the knowledge and skills to effectively prepare their
home for survival when wildfire is threatening, evacuate early and safely
when ordered, and if trapped, practice learned skills to survive the wildfire.
Table of Contents
Introduction……………………………………………………………………………………. 1
Background/Problem Statement………………………………………………………….… 2
Program Goals……………………………………………………………………………….. 3
Factors for Success………………………………………………………………………..… 3
Preparation of Structures……………………………………………………………………. 5
Human Understanding and Decision Making ..............................................................6
Contingency Planning ................................................................................................6
Recommended Actions and Desired Results ..............................................................7
Links and Resources .....................................................................................................8
1Introduction
"Changing climate and drought conditions, the build-up of hazardous fuels, and more
homes in fire-prone landscapes are changing how we experience wildfire in America."
International Association of Fire Chiefs, Wildland Fire Policy Committee, 2009.
Local government, like its State and Federal widland fire agency partners, have seen a
dramatic increase in the severity, risks to life, property and the environment and costs
associated with wildland fires over the past decade.
The Ready, Set, Go program is not an original message, it is a new approach at
packaging existing public education to gain active public involvement toward reducing
life and property loss associated with wildland fires. The program is presented in three
steps:
1. READY - Prepare yourself, your family and your property.
2. SET - Monitor fire weather I activity and prepare to evacuate.
3. GO - Leave early when directed to by public safety officials.
A subsequent step is included to educate people how to survive, if trapped by a wildfire.
The Ready, Set, Go program is a collaborative process that is effective in improving
coordination and communication between emergency response agencies and the
community. Spending an adequate amount of time developing the Ready, Set, Go
program in each community can help clarify and refine priorities to protect life, property,
infrastructure, and valued resources.
The Ready, Set, Go program is organized in seven sections:
1. Background / Problem Statement
2. Program Goals
3. Factors for Success
4. Preparation of Structures and People
5. Human Understanding and Decision Making
6. Contingency Planning
7. Recommended Actions and Desired Results
Fire resources are maximized during major fire incidents, particularly during the initial
attack, and the public must become part of the overall strategy provide community
safety. This program is just one option to explore and it can be customized to work in
any community as no one program will work everywhere.
21. Background I Problem Statement
The problem is that there is a higher frequency of wildfires occurring and weather
projections indicate this trend is not changing soon. Research is showing that climate
change is a major contributing factor. Weather combined with the ever growing fuels
management issues; indicate that wildland fires will be part of our future.
The problem is that fires can be more costly to everyone in the Wildland Urban Interface
(WUI) or the areas where homes are intermixed within forests and wildlands. An
increasing number of homes are at risk from wildfire as residential development
continues to encroach on forest and wildland areas.
The problem is that no two wildfires behave in the same manner and, during the past
decade, these wildfires are acting more erratically and the deaths and property losses
are escalating. The residents who choose to stay or get trapped also cause a safety
issue for public safety officials who, with already limited resources, must now try to
effect rescues during these wildfires.
Historically, the fire service has conducted public education efforts to try to get the
public's support in reducing fire losses. This effort began with the Smokey Bear
advertising campaign to prevent wildfires. Now the focus is on getting communities to
become fire-ready. There are several national and local programs that teach these
tenets to create Fire Adaptive Communities. The problem is how to get the public
education message listened to and turned into action by the public.
The fire problem within the WUI areas consists of two primary fuel types:
accumulation of natural and exotic vegetation and the structures and ornamental
landscaping that people create. Natural vegetation reduction or management is a long-
term process that is becoming more difficult due to climate change and environmental
conditions. This effort must continue to help restore our ecosystem and reduce fire
size.
The structure fuel component is created as the population increases within traditional
rural areas of the country. This structure fuel type is now greatly escalating the overall
cost of wildland fires, both in terms of the fire suppression costs and property loss. New
building codes and planning conditions are proving themselves to be effective at
combating losses in new developments-but the existing structures in the WUI remain
the biggest threat and the largest mitigation yield. Our greatest opportunity to reduce the
impacts of wildfire lies in the implementation of "pre-fire activities", i.e., actions that take
place before a wildfire occurs that improve the survivability of people and their homes.
These actions on structural fuels are usually more permanent in nature than the
recurring efforts required on natural fuels.
The problem is people tend to have the expectation that, when they call 911, they will
get a response to fit their needs. With an increase in population that has not had a
corresponding public safety service increase; fire managers may not be able to
realistically meet those public expectations. The public must take personal responsibility
3for the specific hazards associated within their choice of habitation. Government must
also fund public services commensurate with growth.
Over time, there is a growing problem with the number of residents that defy evacuation
orders. Some of these residents are successful in staying and defending their property,
but have limited training or experience and have based their actions on past wildfire
experiences. Some people who have stayed died in the face of a rapidly moving and
destructive wildfire.
Evacuations are a local issue, based upon many factors (incident type, activity, number
of people affected, fire preparedness level, road system, transportation system,
relocation centers, available resources to implement plan, etc.), therefore evacuation
alternatives must be determined locally. Fire and law enforcement incident commanders
must evaluate all contributing factors when creating evacuation plans to achieve the
highest level of public safety while balancing the challenges of a dynamic incident.
The problem is that there needs to be adequate evacuation resources, uniform and
consistent evacuation terminology (refer to FIRESCOPE 2007 Field Operation Guide
420-1), model practices, notification ability and re-entry procedures so residents can re-
enter as early and safely as possible.
2. Program Goals
A. Protect life and property by creating and maintaining Fire Adaptive Communities.
B. Improve evacuation procedures.
C. Improve firefighter and public safety.
D. Encourage personal responsibility toward the overall solution.
E. Acceptance of the strategy to: Prepare your property and yourself
F. leave early, follow evacuation orders and survive.
3. Factors for Success
Fire agencies have been providing public education messages for many years, so one
might ask; "Why is Ready, Set, Go different from past efforts?" The following factors will
be instrumental in gaining program effectiveness:
Collaboration between the public, government and neighbors. In 1997, FEMA
established Project Impact to help communities reduce their disaster tolls by building
partnerships among businesses, agencies, churches, neighborhoods and others. This
effort showed that amazing things can happen when working in close partnerships with
one another by making long-term changes in their disaster profiles. Project Impact
identified common issues that communities face when dealing with tornados and
hurricanes with the thought that, if they modify key factors that contribute to
safety/damage, then the community would be better off when the next disaster occurs.
Project Impact sought to change that culture to make hazard mitigation an integral part
of the community and the people's lives.
Use of science - Home Ignition Zone research. Traditional beliefs that homes were
4ignited by the flaming fire front are being disproved by scientific research studies. Jack
Cohen (USFS Researcher) has done several field tests to determine how homes can be
ignited and the results indicate that ember intrusion is the primary cause of home
ignitions.
Target audience identification. Each fire agency must recognize their target audience to
whom they intend to reach out to. This includes understanding the social, economic and
demographic nature of these communities. Example, a rural community (intermix) may
be more self sufficient than an urban home subdivision (interface) and the
communication message needs to fit the character of the community so the target
audience can readily relate. This applies to printed materials and visual graphics on
videos. Fire agencies should also review the national public survey on how the public
receives our current messages (PIFE study, 2008).
Recognition that government cannot be the answer all the time. The Community
Emergency Response Team (CERT) training began as an offshoot of earthquake
preparedness training. During a major earthquake, studies found that the limited
emergency resources would be prioritized to critical infrastructure targets. This
recognition of priorities also found that the CERT program would focus on neighbor
helping neighbor and that the population needs to accept personal responsibility for
their own preparedness and actions. It meant-that residents had to accept the premise
of: If you choose to live in a hazard area, then you must become more self-sufficient.
Recognizing Long-Lasting Change Takes Time. The emotions-following a disaster are
usually short-lived, recognizing this is paramount in allowing change agents to take
advantage of this opportunity. Change management requires opportunities,
perseverance and focus on the goal. One must be committed to the change being
implemented, not be deterred easily and recognize that true change occurs over time,
not immediately. Commitment builds trust among participants.
Setting Priorities. Stakeholders (public, fire agencies, law enforcement, media, disaster
relief organizations, utility companies and local government) may have a limited budget
and time commitment toward achieving the entire program tenets. Therefore, through
local discussions, these stakeholders should reach consensus on their specific program
priorities that will benefit their community. A phased-in program is better than no
program at all.
Leave Early and Early Return. The public generally trusts public safety officials because
of their training and experience. They should accept evacuation orders and leave early,
but be ready for an early return if possible. Public safety officials will need to have re-
entry plans developed as evacuation orders are issued, but they must assure the
public's safety before re-entry is directed.
Understanding that no programs can be universally applied and there are clear,
understandable messages. Public officials must issue direction based upon the general
population. Specific direction and modifications can occur, but only when there are clear
communications with the affected populace, usually in small groups with effective two-
5way communications.
Creating Public Education Tools to Reach the Masses. There needs to be a variety of
media tools to conduct outreach for the overall goals. Community group meetings will
only obtain a small percentage of residents. We must understand the needs of our
urban, suburban and rural communities and develop a variety of tools and methods to
reach into each residence. It's usually not the strategy or principles that fail; it's the buy-
in and action of the targeted stakeholders.
Focus on our Saves and not the Losses. After every emergency incident, the media
carries the story of how many lives and property were lost because these are tangible
numbers. What's harder to quantify are the number of homes and lives saved. Public
officials need to identify these numbers and communicate this message better.
4. Preparation of Structures and People
In the Institute for Business and Home Safety (lBHS) Mega Fire Report (2008) following
the Witch fire in San Diego, California, they reported the key to protecting lives and
reducing property losses begins with hardening structures. Hardening structures
focuses on new construction and/or retrofitting existing structures to modern building
codes that recognize the wildland fire threat and .the installation of home fire sprinklers.
Studies have shown that most structures within the wildland are not destroyed from
direct flame impingement, but rather from the ember environment. Embers may precede
the flaming fire-front, carried by the winds and distributing burning brands or embers
over long distances. These embers fall, or are wind driven into receptive fuels at
structures, often going undetected for some time. As the fire front passes, these-small-
embers may ignite incipient fires that spread to the home and then from home to home
in a neighborhood. Key retrofits include fire-safe roofs and vent rescreening to 1/8 inch
mesh or approved vents.
In new developments, updated fire and building codes are addressing proper home
locations and construction types. Older, existing residences need to make retrofits to
improve-the structure's survivability. These actions need to include defensible space
areas, water supply, access, identification and ornamental landscaping. There are also
maintenance issues involved in living within the WUI. Residents should reduce the
ability of embers to start small fires by cleaning leaves, pine needles, twigs and
branches off roofs and rain gutters.
They should also remove combustibles near the structure like firewood stacked by the
house, patio furniture, attached wood fences and ornamental landscaping.
People need to mentally prepare themselves to handle the stress of a wildfire. They
need to create situational awareness of wildfires by understanding what the fire
environment is like. Then they need to create their own Wildfire Action Plan with a
checklist to enhance their preparedness status.
65. Human Understanding and Reaction
Researchers indicate that it takes a significant amount of mental preparation by
homeowners to not panic and flee when flames are licking at their doors. "The noise
alone of a wildfire front is phenomenal. Then the sun goes away, and the sky goes dark
in the middle of the day. It's haunting and the people need to understand that before
they ever think about staying."
(http://news.ucanr.orginewsstorymain.cfm?story=1180)
Ready, Set, Go is a program that tries to provide real-life wildfire situational awareness
for the public. Fire agencies will instruct what it's like before, during and after a firestorm
from a firefighter's perspective. The public will learn that even experienced firefighters
never treat one fire like the next as fire, fuel and weather conditions constantly change,
making every fire different. Hopefully, the public will learn from the firefighter's
experience and when a trusted public safety official issues evacuation orders, the public
will leave early so they don't become trapped.
Studies have shown that people who are taught about certain tactics and train on
exercising those tactics have a higher level of repeating those skills as a reaction, not
decision making during adverse conditions, based upon training and experience. The
fire service cannot readily expect that the public with only limited training will act and
make decisions as trained firefighters do during a firestorm condition. The "fight or flight"
syndrome occurs during these times and may manifest itself as panic or irrational
behavior. This is why this program focuses on the reaction to: LEAVE EARLY!
6. Contingency Planning (how to survive, if trapped)
Everyone who lives within a WUI area should have a contingency plan developed
before a fire starts in case they can't, or are prevented, from evacuating. Fire service
officials do not endorse anyone defying an evacuation order, but they realize some
people may get trapped and should have basic survival skills. These skills are based
upon public education information that provides the resident with some situational
awareness, proper actions to take before, during and after a fire.
Some residents have experienced a wildfire and may have the expectation that one fire
behaves like another. This false assumption can lead to complacency and reduce
preparedness. Just as experienced firefighters know that every fire behaves differently,
residents must be educated on fire behavior to understand its complexity and danger.
77. Recommended Actions and Desired Results
This program is just one option for a local government or fire agency to consider
adopting. It is a generic baseline public education program that can be modified to fit a
community's needs and desires. There also needs to be collaboration between
stakeholder groups involved; public, law enforcement, media, disaster relief
organizations, utility companies, government officials and the fire service.
Program implementation tools and processes include:
A. Conduct regional community meetings to provide an overview of the wildland fire
problem and the basic tenets of Ready, Set, Go. An overview video message and the
Wildfire Action Plan are available as educational resources. The program should be
introduced by high ranking fire officials and public education specialists.
B. The next step is to begin to reach the masses by mailing Wildfire Action Plans to
targeted groups and conducting small focus groups via CERT, FIREWISE groups, Fire
Safe Councils, Community Wildfire Prevention Programs (CWPP), etc. These small
group meetings are best instructed by the local fire company who has ties to these
groups. The public relies on these firefighters every day and trust what they say. These
firefighters are also the ones who can modify and/or provide specific information to
these residents based on local conditions. A video message is available that shows the
hands-on actions homeowners must take to implement the Ready, Set, Go program at their
own home.
C. The public education program needs to have commitment of all stakeholder groups
within the same media market, so there is a consistent message being transmitted to the
public. This is not a one-time public education campaign. To be successful, it needs to
be an on-going effort to reach residents who continue to relocate into WUI areas and
may not have any experience with wildfires. The printed Wildfire Action Plans and video
messages were designed as a more passive method to reach the masses and can be
mailed or posted on fire agency Web sites.
Remember - There's only one action when ordered to evacuate -
"LEAVE"-
8Links and Resources
General Resources
 California Fire Alliance-CWPP Resources: http://cafirealiiance.org/cwpp
 Firewise website: http://firewise.org
 Key Public Opinion Research Findings on the Ecological Role of Fire and the Benefits of Fire
Management, Partners in Fire Education (PI FE) study, 2008
 The Healthy Forests Initiative and Healthy Forests Restoration Act:
http://www.fsJed.us/projects/hfi/field-guide/web/page15.php
 International Association of Fire Chief's Leader's Guide for Developing a Community Wildfire
Protection Plan: http://www.iafc.orgiassociations/4685/files/CWPP_rev062005.pdf
 National Database of State and Local Wildfire Mitigation Programs, a source for information on
ordinances: http://ww.wildfireprograms.usda.gov
Tribal Wildfire Resource Guide (2006), Intertribal Timber Council:
http://www.itcnet.org/issues_projects/issues/forest_managementlreports.html
 Nevada's "Living with Fire" program
 BLM Partnership Web Site: http://www.blm.gov/partnerships/tools.htm
 Western Collaborative Assistance Network: http://westcanhelp.org/
 Forest Service Partnership Resource Center:
http://www. partnershipresourcecenter .org/index.shtml
 FIRESCOPE 2007 Field Operations Guide ICS 420-1, Chapter 20 "Protection Action Guidelines)
 Project Impact 1997, FEMA
 Rural Voices for Conservation Coalition (Collaboration issue paper):
http://www.sustainablenorthwest.org/quick-links/resources/rvcc-issue-papers
 Strategies for assisting low-income and underserved communities develop and implement
CWPPs: http://ri.uoregon.edu/programs/CCE/communityfireplanning.html
Reducing Structural ignitability
 Australian Safe in Place Information:
http://www.rfs.nsw.gov.au/dsp_content.cfm?CAT _ID=202 and
http://www.rfs.nsw.gov.au/dsp_content.dm?caUd=515
 California Ignition-Resistant Building and Fire Codes:
http://www.fire.ca.gov/fire_prevention/fire_prevention_wildland_codes.php
 Firewise Guide to Landscape and Construction, booklet:
https://www.cmsassociates.comifirewise.nsflavcatalog?open
 Wildfire! Preventing Home Ignitions DVD, explains the research of Jack Cohen, USDA Forest
Service, on how homes ignite and how to minimize potential for ignition:
https://www.cmsassociates.com/firewise.nsf/avcatalog?open
Reducing Structural Ignitability: Articles and Publications
 Cohen, Jack. Structural Vulnerability and the Home Ignition Zone: The key to preventing
residential fire disasters during extreme wildfire, letter from Jack Cohen to Douglas McDonald,
Feb. 4, 2008
 Cohen J. 2001. Wildland-urban fire-a different approach. In:
Proceedings of the Firefighter Safety Summit, Nov. 6-8, 2001, Missoula, MT. Fairfax, VA:
International Association of Wildland Fire & other articles by Jack Cohen:
http://www.nps.gov/fire/public/pub_publications.cfm.
 Institute for Business & Home Safety, (IBHS) 2008 Mega Fires - Witch Fire Study
9 ICC, International Wildland-Urban Interface Code 2006, International Code Council, Country
Club Hills, IL, 2006
 NFPA 1141, Standard for Fire Protection Infrastructure for Land Development in Suburban and
Rural Areas, 2008 edition, National Fire Protection Association, Quincy, MA, 2007
 NFPA 1144, Standard for Reducing Structural Ignitions from Wildland Fire, 2008 edition,
National Fire Protection Association, Quincy, MA, 2007
Fuels Reduction and Restoration Resources
 The National Association of State Foresters Field Guidance for Identifying and Prioritizing
Communities at Risk:
http://www.stateforesters.org/reports/COMMUNITIESATRISKFG.pdf
 Management Tools for CWPP Implementation: Stewardship Contracting and Biomass Utilization
http://ri.uoregon.edu/programs/CCE/communityfireplanning.html
 Woody Biomass Utilization Desk Guide:
http://www.forestsandrangelands.gov/Woody_Biomass/documents/biomass_deskguide.pdf
 USDA Forest Service Stewardship Contracting Resource page:
http://www.fs.fed.us/forestmanagementiprojects/stewardship/index.shtml
Monitoring and Evaluation Resources
 Community Wildfire Protection Plan Monitoring and Evaluation Guide:
http://ri.uoregon.edu/programs/CCE/communityfireplanning.html
 Public Response to Wildfire: Is the Australian "Stay and Defend or Leave Early" Approach an
Option for Wildfire Management in the United States, 2008, Sarah M. McCaffrey and Alan
Rhodes
 Multiparty Monitoring Resources:
Rural Voices for Conservation Coalition-Multiparty Monitoring Issue Paper:
http://ri.uoregon.edu/programs/CCE/communityfireplanning.html
 USDA Forest Service Collaborative Restoration Program-Multiparty Monitoring Guidelines:
http://www.fs.fed.us/r3/spf/cfrp/monitoring/index.shtml
 Red Lodge Clearinghouse: http://www.redlodgeciearinghouse.org/resources/handbook full.htm
Monterey County Community Wildfire Protection Plan
November 2010 v2
APPENDIX D
          Recommended Fuel Reduction Projects
Monterey County Community Wildfire Protection Plan
November 201 v20
APPENDIX D – Recommended Hazardous Fuel Reduction Projects
NOTE: This table may be updated by the MFSC without approval from the signatories to this
MCCWPP.
At-Risk
Community or
Area
Project/
Treatment
Agency/
Landowner
Funding Needs Time Table Community
Recommendation
2009
Aguajito/
Jack's Peak
Residential
chipping program
Private Agency budget Annually Yes
Aromas Residential
chipping program
Private Agency budgets Annually Yes
Big Sur Partington Ridge
hazard fuel
removal
Private Grant funding 2009 Yes
Big Sur Big Sur Fuel
Reduction
Private Grant funding 2009 Yes
Cachagua Tularcitos Ridge
Strategic
Fuelbreak; Rx
Fire Treatments
Private Private/Grant
funding
2009 Yes
Carmel Highlands Residential
Chipper Program
Private Agency budget Annually Yes
Carmel Highlands Empty Lot
Program
Private Grant funding 2009 Yes
Carmel Valley Rancho Tierra
Grande chipping
Private Grant funding 2009 Yes
Corral de Tierra Fort Ord fuel
reduction,
mowing
BLM Agency budget 2009 Yes
County wide Residential
Chipper Program
CAL FIRE Grant funding 2009 Yes
Del Rey Oaks Henneken Road
fuelbreak
BLM Agency budget 2009 Yes
Del Rey Oaks Manzanita Road
fuelbreak
BLM Agency budget 2009 Yes
Monterey County Community Wildfire Protection Plan
November 2010 v2
At-Risk
Community or
Area
Project/
Treatment
Agency/
Landowner
Funding Needs Time Table Community
Recommendation
Del Rey Oaks Eucalyptus Road
hazard fuel
reduction,
handwork
BLM Agency budget 2009 Yes
Fort Ord
Community
Henneken Road
fuelbreak
BLM Agency budget 2009 Yes
Fort Ord
Community
Barloy Road fuel
reduction
BLM Agency budget 2009 Yes
Fort Ord
Community
Three Sisters
Road fuelbreak
BLM Agency budget 2009 Yes
Fort Ord
Community
Fort Ord pile
burning
BLM Agency budget 2009 Yes
Gabilan Range Strategic
Fuelbreaks; Rx
Fire Fuel
Treatments
Private Private 2009 Yes
Marina Crescent Bluff
fuelbreak
BLM Agency budget 2009 Yes
Marina Crescent Bluff
hazard fuel
reduction
BLM Agency budget 2009 Yes
Marina Sandy Ridge
Road fuelbreak
BLM Agency budget 2009 No
Marina East Machine Gun
Flats fuelbreak
BLM Agency budget 2009 Yes
Marina Watkins Gate
fuelbreak
BLM Agency budget 2009 Yes
Monterey Chipping Private Grant funding 2009 Yes
Palo Colorado Palo Colorado
Wildfire Fuel
Reduction Project
Private Grant funding 2009 Yes
Pine Canyon/Reliz
Canyon
Strategic
Fuelbreaks; Rx
Fire Fuel
Reduction
Private/USFS Private 2009 Yes
Seaside Watkins Gate
fuelbreak
BLM Agency budget 2009 No
Seaside Watkins Gate
hazard fuel
reduction,
BLM Agency budget 2009 Yes
Monterey County Community Wildfire Protection Plan
November 2010 v2
At-Risk
Community or
Area
Project/
Treatment
Agency/
Landowner
Funding Needs Time Table Community
Recommendation
handwork
Seaside Sheep grazing BLM Agency budget 2009 Yes
Sierra de Salinas Strategic
Fuelbreaks; Rx
Fire Fuel
Reduction
Private/BLM Private 2009 Yes
Toro Park Estates Fuelbreak Private Grant funding 2009 Yes
Toro Park Estates Creekside Condo
hazard fuel
reduction
BLM Agency budget 2009 Yes
Toro County Park Recreation Sites
hazard fuel
reduction
BLM Agency budget 2009 Yes
White Rock Strategic
Fuelbreaks; Rx
Fire Fuel
Treatments
Private Private 2009 Yes
2010
Big Sur Fuel Reduction Private Grant funding 2010 Yes
Cacahagua Tularcitos Ridge
Strategic
Fuelbreak; Rx
Fire Treatment
Private Private/Grant
Funding
2010 Yes
Carmel Highlands Residential
Chipper Program
Private Grant funding 2010 Yes
Carmel Valley Rancho Tierra
Grande
demonstration
garden
Private Grant funding 2010 Yes
Corral de Tierra Lookout Ridge
fuelbreak
BLM Agency budget 2010 Yes
Fort Ord
Community
Eucalyptus Road
fuelbreak
BLM Agency budget 2010 Yes
Fort Ord
Community
Sandstone Ridge
fuelbreak
BLM Agency budget 2010 No
Fort Ord
Community
Barloy Road
fuelbreak
BLM Agency budget 2010 Yes
Fort Ord Fuelbreak hazard BLM Agency budget 2010 Yes
Monterey County Community Wildfire Protection Plan
November 2010 v2
At-Risk
Community or
Area
Project/
Treatment
Agency/
Landowner
Funding Needs Time Table Community
Recommendation
Community reduction
King City Sierra de Salinas
fuel treatment
Strategic
Fuelbreaks, Rx
Fire Treatment
BLM/Private Private 2010 Yes
Marina Cuervo VMP Private Grant funding 2010 Yes
Marina Fort Ord mowing BLM Agency budget 2010 Yes
Marina Merill Road
fuelbreak
BLM Agency budget 2010 Yes
Palo Colorado Palo Colorado
Wildfire Fuel
Reduction Project
Private Grant funding 2010 Yes
Salinas Reservation
roadside hazard
reduction
BLM Agency budget 2010 Yes
Seaside Barloy Road
fuelbreak
BLM Agency budget 2010 Yes
Seaside Guidotti Bridge
hazard fuel
reduction
BLM Agency budget 2010 Yes
Seaside Engineer Canyon
hazard fuel
reduction.
Handwork
BLM Agency budget 2010 Yes
2011
Highway
68/Laureles Grade
Ryan Ranch
fuelbreak
Private Grant funding 2011 Yes
Reliz Canyon Fuelbreak USFS/Private Grant funding 2011 Yes
2012
Del Rey Oaks Fuelbreak Private Grant funding 2012 Yes
Monterey County Community Wildfire Protection Plan
November 2010 v2
APPENDIX E 
General Guidelines for Creating
   Defensible Space Guidelines
General Guidelines for Creating Defensible Space  
 
 
State Board of Forestry and Fire Protection (BOF) 
California Department of Forestry and Fire Protection 
 
Adopted by BOF on February 8, 2006 
Pending Filing with Office of Administrative Law 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
General Guidelines for Creating Defensible Space        1 
February 8, 2006 
 
Contents 
 
 
A. Purpose of  Guidelines ............................................................................................................ 2 
 
B. Definitions ................................................................................................................................ 3 
 
C. Fuel Treatment Guidelines ...................................................................................................... 4 
 
  1. Firebreak within 30 feet of building........................................................................ 4 
 
  2. Dead and dying woody fuels removal .................................................................... 4 
 
  3. Down logs or stumps............................................................................................... 4 
   
  4a. Fuel Separation ........................................................................................................ 4 
 
  4b. Defensible Space With Continuous Tree Canopy ................................................. 8 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
General Guidelines for Creating Defensible Space        2 
February 8, 2006 
 
 
Effective defensible space 
A. Purpose of Guidelines 
 
Recent changes to Public Resources Code (PRC) 4291 expand the 
defensible space clearance requirement maintained around buildings and 
structures from 30 feet to a distance of 100 feet.  These guidelines are 
intended to provide property owners with examples of fuel modification 
measures that can be used to create an area around buildings or 
structures to create defensible space.  A defensible space perimeter 
around buildings and structures provide firefighters a working 
environment that allows them to protect buildings and structures from 
encroaching wildfires as well as minimizing the chance that a structure fire 
will escape to the surrounding wildland. These guidelines apply to any person 
who owns, leases, controls, operates, or maintains a building or structure in, upon, or adjoining any 
mountainous area, forest-covered lands, brush-covered lands, grass-covered lands, or any land that is 
covered with flammable material, and located within a State Responsibility Area. 
 
The vegetation surrounding a building or structure is fuel for a fire.  Even the building or structure itself is 
considered fuel.  Research and experience have shown that fuel reduction around a building or structure 
increases the probability of it surviving a wildfire.  Good defensible space allows firefighters to protect and 
save buildings or structures safely without facing unacceptable risk to their lives.  Fuel reduction through 
vegetation management is the key to creating good defensible space.   
 
Terrain, climate conditions and vegetation interact to affect fire behavior and fuel reduction standards.  The 
diversity of California’s geography also influences fire behavior and fuel reduction standards as well.  While 
fuel reduction standards will vary throughout the State, there are some common practices that guide fuel 
modification treatments to ensure creation of adequate defensible space: 
 
• Properties with greater fire hazards will require more clearing. Clearing requirements will be greater 
for those lands with steeper terrain, larger and denser fuels, fuels that are highly volatile, and in 
locations subject to frequent fires.  
 
• Creation of defensible space through vegetation management usually means reducing the amount 
of fuel around the building or structure, providing separation between fuels, and or reshaping 
retained fuels by trimming.  Defensible space can be created removing dead vegetation, separating 
fuels, and pruning lower limbs.  
 
• In all cases, fuel reduction means arranging the tree, shrubs and other fuels sources in a way that 
makes it difficult for fire to transfer from one fuel source to another.  It does not mean cutting down 
all trees and shrubs, or creating a bare ring of earth across the property. 
 
• A homeowner’s clearing responsibility is limited to 100 feet away from his or her building or 
structure or to the property line, which ever is less, and limited to their land. While individual 
property owners are not required to clear beyond 100 feet, groups of property owners are 
encouraged to extend clearances beyond the 100 foot requirement in order to create community-
wide defensible spaces. 
 
• Homeowners who do fuel reduction activities that remove or dispose of vegetation are required to 
comply with all federal, state or local environmental protection laws and obtain permits when 
necessary.  Environmental protection laws include, but are not limited to, threatened and 
endangered species, water quality, air quality, and cultural/archeological resources.  For example, 
trees removed for fuel reduction that are used for commercial purposes require permits from the  
General Guidelines for Creating Defensible Space        3 
February 8, 2006 
 
 
California Department of Forestry and Fire Protection.  Also, many counties and towns require tree 
removal permits when cutting trees over a specified size.  Contact your local resource or planning 
agency officials to ensure compliance.  
 
The methods used to manage fuel can be important in the safe creation of defensible space.  Care should be 
taken with the use of equipment when creating your defensible space zone.  Internal combustion engines 
must have an approved spark arresters and metal cutting blades (lawn mowers or weed trimmers) should be 
used with caution to prevent starting fires during periods of high fire danger.  A metal blade striking a rock 
can create a spark and start a fire, a common cause of fires during summertime. 
 
Vegetation removal can also cause soil disturbance, soil erosion, regrowth of new vegetation, and introduce 
non-native invasive plants.  Always keep soil disturbance to a minimum, especially on steep slopes.  Erosion 
control techniques such as minimizing use of heavy equipment, avoiding stream or gully crossings, using 
mobile equipment during dry conditions, and covering exposed disturbed soil areas will help reduce soil 
erosion and plant regrowth.   
 
Areas near water (riparian areas), such as streams or ponds, are a particular concern for protection of water 
quality.  To help protect water quality in riparian areas, avoid removing vegetation associated with water, 
avoid using heavy equipment, and do not clear vegetation to bare mineral soil.  
 
B. Definitions 
 
Defensible space:  The area within the perimeter of a parcel where basic wildfire protection practices are 
implemented, providing the key point of defense from an approaching wildfire or escaping structure fire.  The 
area is characterized by the establishment and maintenance of emergency vehicle access, emergency water 
reserves, street names and building identification, and fuel modification measures.   
 
Aerial fuels:  All live and dead vegetation in the forest canopy or above surface fuels, including tree 
branches, twigs and cones, snags, moss, and high brush.  Examples include trees and large bushes. 
 
Building or structure:  Any structure used for support or shelter of any use or occupancy. 
 
Flammable and combustible vegetation:  Fuel as defined in these guidelines. 
 
Fuel Vegetative material, live or dead, which is combustible during normal summer weather.  For the 
purposes of these guidelines, it does not include fences, decks, woodpiles, trash, etc. 
 
Homeowner:  Any person who owns, leases, controls, operates, or maintains a building or structure in, upon, 
or adjoining any mountainous area, forest-covered lands, brush-covered lands, grass-covered lands, or any 
land that is covered with flammable material, and located within a State Responsibility Area. 
 
Ladder Fuels:  Fuels that can carry a fire vertically between or within a fuel type.  
 
Reduced Fuel Zone:  The area that extends out from 30 to 100 feet away from the building or structure (or to 
the property line, whichever is nearer to the building or structure). 
 
Surface fuels:  Loose surface litter on the soil surface, normally consisting of fallen leaves or needles, twigs, 
bark, cones, and small branches that have not yet decayed enough to lose their identity; also grasses, forbs, 
low and medium shrubs, tree seedlings, heavier branches and downed logs. 
 
 
 
 
General Guidelines for Creating Defensible Space        4 
February 8, 2006 
 
 
 
 
C.  Fuel Treatment Guidelines 
 
The following fuel treatment guidelines comply with the requirements of 14 CCR 1299 and PRC 4291. All 
persons using these guidelines to comply with CCR 1299 and PRC 4291 shall implement General 
Guidelines 1., 2., 3., and either 4a or 4b., as described below.  
 
General Guidelines: 
 
1. Maintain a firebreak by removing and clearing away all flammable vegetation and other combustible 
growth within 30 feet of each building or structure, with certain exceptions pursuant to PRC 
§4291(a).  Single specimens of trees or other vegetation may be retained provided they are well-
spaced, well-pruned, and create a condition that avoids spread of fire to other vegetation or to a 
building or structure. 
 
2. Dead and dying woody surface fuels and aerial fuels within the Reduced Fuel Zone shall be 
removed. Loose surface litter, normally consisting of fallen leaves or needles, twigs, bark, cones, 
and small branches, shall be permitted to a depth of 3 inches.  This guideline is primarily intended to 
eliminate trees, bushes, shrubs and surface debris that are completely dead or with substantial 
amounts of dead branches or leaves/needles that would readily burn.  
 
3. Down logs or stumps anywhere within 100 feet from the building or structure, when embedded in 
the soil, may be retained when isolated from other vegetation.  Occasional (approximately one per 
acre) standing dead trees (snags) that are well-space from other vegetation and which will not fall 
on buildings or structures or on roadways/driveways may be retained.  
 
4. Within the Reduced Fuel Zone, one of the following fuel treatments (4a. or 4b.) shall be 
implemented.  Properties with greater fire hazards will require greater clearing treatments.  
Combinations of the methods may be acceptable under §1299(c) as long as the intent of these 
guidelines is met. 
 
 
4a.  Reduced Fuel Zone:  Fuel Separation  
 
 In conjunction with General Guidelines 1., 2., 
and 3., above, minimum clearance between 
fuels surrounding each building or structure 
will range from 4 feet to 40 feet in all 
directions, both horizontally and vertically.  
 
Clearance distances between vegetation will 
depend on the slope, vegetation size, 
vegetation type (brush, grass, trees), and 
other fuel characteristics (fuel compaction, 
chemical content etc.).  Properties with greater 
fire hazards will require greater separation 
between fuels.  For example, properties on steep slopes having large sized vegetation will require 
greater spacing between individual trees and bushes (see Plant Spacing Guidelines and Case 
Examples below).  Groups of vegetation (numerous plants growing together less than 10 feet in 
total foliage width) may be treated as a single plant.  For example, three individual manzanita plants 
growing together with a total foliage width of eight feet can be “grouped” and considered as one 
plant and spaced according to the Plant Spacing Guidelines in this document. 
.
Defensible Space:  
Reduced Fuel Zone
30 ft. Reduced Fuel Zone: 
30 ft. to 100 ft. 
General Guidelines for Creating Defensible Space        5 
February 8, 2006 
 
 
 Vertical clearance between aerial fuels
  4 ft to 40 ft. depending on slope and vegetation size/type  
10 ft. to 30 ft. 
depending on 
slope and 
vegetation 
type and size  
4 ft. to 40 ft 
depending 
on slope and 
vegetation 
type and size  
 Grass generally should not exceed 4 inches in height.  However, homeowners may keep grass and 
other forbs less than 18 inches in height above the ground when these grasses are isolated from 
other fuels or where necessary to stabilize the soil and prevent erosion. 
 
Clearance requirements include:  
 
• Horizontal clearance between aerial fuels, such as the outside edge of the tree crowns or 
high brush.  Horizontal clearance helps stop the spread of fire from one fuel to the next.   
 
                                                                                                           
 
 
 
 
 
 
 
 
 
 
                                Trees                                                                               Shrubs 
 
Horizontal clearance between aerial fuels 
 
 
• Vertical clearance between lower limbs of aerial fuels and the nearest surface fuels and 
grass/weeds.  Vertical clearance removes ladder fuels and helps prevent a fire from 
moving from the shorter fuels to the taller fuels.  
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Effective vertical and 
horizontal fuel 
separation 
Photo Courtesy 
Plumas Fire Safe 
Council. 
General Guidelines for Creating Defensible Space        6 
February 8, 2006 
 
 
 
 
 
 
Adapted from: Gilmer, M. 1994. California Wildfire LandscapingLandscaping 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
Plant Spacing Guidelines 
 
Guidelines are designed to break the continuity of fuels and be used as a “rule of thumb” for achieving 
compliance with Regulation 14 CCR 1299. 
 
Minimum horizontal space 
from edge of one tree canopy to the edge of the next 
Slope Spacing 
0% to 20 % 10 feet 
20% to 40% 20 feet 
 
Trees 
Greater than 40% 30 feet 
Minimum horizontal space between edges of shrub 
Slope Spacing 
0% to 20 % 2 times the height of the shrub 
20% to 40% 4 times the height of the shrub 
 
 
Shrubs 
Greater than 40% 6 times the height of the shrub 
Vertical 
Space 
Minimum vertical space between top of shrub and bottom of lower tree branches: 
3 times the height of the shrub 
Case Example of Fuel Separation:  Sierra Nevada conifer forests  
 
Conifer forests intermixed with rural housing  
present a hazardous fire situation.  Dense vegetation,  
long fire seasons, and ample ignition sources related 
to human access and lightning, makes this home  
vulnerable to wildfires.  This home is located on  
gentle slopes (less than 20%), and is surrounded by 
large mature tree overstory and intermixed small  
to medium size brush (three to four feet in height).  
 
Application of the guideline under 4a. would result 
in horizontal spacing between large tree branches of  
10 feet; removal of many of the smaller trees to create  
vertical space between large trees and smaller trees and 
 horizontal spacing between brush of six to eight feet (calculated by using 2 times the height of brush).  
General Guidelines for Creating Defensible Space        7 
February 8, 2006 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case Example of Fuel Separation:  Southern California chaparral  
 
Mature, dense and continuous chaparral  
brush fields on steep slopes found in  
Southern California represents one of the  
most hazardous fuel  situations in the  
United States.  Chaparral grows in an  
unbroken sea of dense vegetation     
creating a fuel-rich path which spreads fire  
rapidly.  Chaparral shrubs burn hot and  
produce tall flames.  From the flames come 
burning embers which can  ignite homes  
and plants. (Gilmer, 1994).  All these factors  
results in a setting where aggressive defensible  
space clearing requirements are necessary.    
 
Steep slopes (greater than 40%) and tall,  
old brush (greater than 7 feet tall), need significant 
modification.   These settings require aggressive  
clearing to create defensible space, and would require maximum spacing.  Application of the guidelines 
would result in 42 feet horizontal spacing (calculated as 6 times the height of the brush) between 
retained groups of chaparral.   
Case Example of Fuel Separation:  Oak Woodlands 
 
Oak woodlands, the combination of oak trees and  
other hardwood tree species with a continuous  
grass ground cover, are found on more than  
10 million acres in California.   Wildfire in this  
setting is very common, with fire behavior dominated  
by rapid spread through burning grass.  
 
Given a setting of moderate slopes (between 20%  
and 40%), wide spacing between trees, and  
continuous dense grass, treatment of the grass is  
the primary fuel reduction concern. Property owners  
using these guidelines would cut grass to a  
maximum 4 inches in height, remove the clippings,  
and consider creating 20 feet spacing between trees.  
General Guidelines for Creating Defensible Space        8 
February 8, 2006 
 
 
Clear surface fuels 
Prune branches 
at least 6 ft. 
Defensible Space retaining continuous trees
 
 
 
 
 
 
4b. Reduced Fuel Zone: Defensible Space with Continuous Tree Canopy 
 
To achieve defensible space while retaining a stand of larger trees with a continuous tree canopy 
apply the following treatments: 
 
• Generally, remove all surface fuels greater than 4 inches in height.  Single specimens of trees 
or other vegetation may be retained provided they are well-spaced, well-pruned, and create a 
condition that avoids spread of fire to other vegetation or to a building or structure. 
 
• Remove lower limbs of trees (“prune”) to at least 6 feet up to 15 feet (or the lower 1/3 
branches for small trees).  Properties with greater fire hazards, such as steeper slopes or 
more severe fire danger, will require pruning heights in the upper end of this range. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                       
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Authority cited: Section 4102, 4291, 4125-4128.5, Public Resource Code. Reference: 4291, Public Resource 
Code; 14 CCR 1299 (d).  
Photo Courtesy Plumas Fire Safe Council.
Defensible space with continuous tree canopy by clearing understory and pruning 
Monterey County Community Wildfire Protection Plan
November 2010 v2
APPENDIX F
CEQA Flowchart
  
Monterey County Community Wildfire Protection Plan
November 2010 v2
APPENDIX G
Forest Practice Rules Checklist
Monterey County Community Wildfire Protection Plan
November 2010 v2
APPENDIX G – Forest Practice Rules Checklist
Revised: June 4, 2008 updated with post fire documents on 8/20/08
TREE REMOVAL INFORMATION COMMONLY ASSOCIATED WITH
BUILDING PERMITS AND OTHER DEVELOPMENT PROJECTS
STATE REGULATIONS
In addition to Fire Code Regulations for State Responsibility Areas noted in the 4290 Checklist,
the California Department of Forestry and Fire Protection (CAL FIRE) is responsible for
administering Timber Harvesting Regulations conducted throughout California on all non-
federal timberland. This applies regardless of zoning and includes lands inside of city limits.
The removal of California native "commercial" timber species from forested lots, areas of
pending new construction, and from around existing structures is included under these
regulations. The following information is compiled from Title 14, California Code of
Regulations and the Public Resources Code to assist in the determination of the necessity of a
Timber Harvest Plan (THP), Timberland Conversion Permit (TCP), or other type of timber
harvest plan exemption or emergency document.
The following checklist can be used to determine if a permit is required from CAL FIRE for
removal of trees.
Determining if a harvesting permit is required from CAL FIRE:
1. Is the project occurring on timberland?
Yes….Go to question #2. In Monterey and San Benito Counties, qualifying
commercial timber species include Coast Redwood,
Douglas Fir, Monterey Pine, Coulter Pine, Ponderosa Pine,
Jeffrey Pine, White Alder, Cottonwood, Pacific Madrone,
California Black Oak and Tanoak. Timberland includes
areas where the above species are now growing naturally or
have grown naturally in the recorded past, even if not
currently present.
No….This does not constitute timber operations and a THP or other harvest document is
NOT required by CAL FIRE. STOP HERE
2. Are you cutting trees and plan to sell, barter, exchange or trade any type of wood product?
Monterey County Community Wildfire Protection Plan
November 2010 v2
Yes…. A THP or other timber harvest plan exemption document is required by CAL
FIRE prior to cutting any trees. Refer to Section II titled "Types of Harvest Documents."
No…. A THP or other timber harvest plan exemption document may still be required by
CAL FIRE. Go to question #3.
3. Are you cutting or removing trees from timberland, and converting the area to a non-timber
use? NOTE: These requirements apply even if the wood products are not sold commercially or
the trees aren't of merchantable size.
a) Yes, and the area involved is less than three acres… Do not harvest without an
approved Less than 3-acre conversion exemption (14 CCR 1104.1)
b) Yes, and the area involved is greater than three acres…A TCP and THP are required.
c) Yes, and the area is an approved subdivision under the Subdivision Map Act ... An
Exemption for Conversion of Non-TPZ137 Land for Subdivision Development (14 CCR
1104.2) can meet the TCP requirement and either a THP or Less than 3-acre conversion
exemption are required.
d) No…. If questions number 1, 2, and 3 above are answered no, a THP or other harvest
document is not required by CAL FIRE.
NOTE: In San Benito and Monterey Counties, the most common examples of conversions
include commercial developments or construction of individual residential structures on lands
classified as timberland.
Types of Harvest Documents:
Timber Harvest Plans are detailed documents that allow timber operations and provide analysis
of environmental impacts, and will not be discussed in detail. The harvest documents required
for Timberland Conversions are addressed in Section I, question 3 above. The following list
describes the most commonly used harvest exemptions and emergencies from Title 14 of the
California Code of Regulations.
1. §1038(c)138 Removal of Fire Hazard Trees Within 150 Feet of a Structure
Exemption
This exemption is required for the cutting or removal of trees in compliance with sections 4290
and 4291 from within 150 feet of existing permitted structures which is intended to reduce the
fuels and fire hazard. This exemption is required only if wood products are offered for sale,
barter, exchange or trade. A Registered Professional Forester services are not required, however
a Licensed Timber Operator must be listed on the exemption. Extensive slash disposal
requirements apply and the exemption is valid for one year. See 14 CCR 1038 (c).
137 TPZ: Zoning classified as Timberland Production Zone.
138 (14 CCR 961.2) Notwithstanding 14 CCR 1038, exemptions from plan filing requirements in the Coastal
Commission Special Treatment Areas shall only be allowed for minor operations where no live trees are cut.
Monterey County Community Wildfire Protection Plan
November 2010 v2
2. §1038(a) and (b) Christmas Tree; Dead, Dying, or Diseased; Fuelwood or
Split Products Exemption
This exemption is required when removing trees that are dead or are obviously dying from insect
attack or disease (harvest can not exceed 10 percent of the average volume per acre), or when
removing fuelwood or other miscellaneous products such as Christmas trees, fencing, etc. This
exemption is required only if wood products are offered for sale, barter, exchange or trade.
Registered Professional Forester services are not required, however a Licensed Timber Operator
must be listed on the exemption. The exemption is valid for one year. See 14 CCR 1038 (a &
b).
3. §1104.1(a) Less Than Three Acre Conversion Exemption
This one-time exemption is required for property owners who intend to cut or remove trees for
structures and other needed improvements. This exemption is required whether or not wood
products are offered for sale, barter, exchange or trade. A Registered Professional Forester must
prepare this exemption. Building contractors are ineligible to perform this work, unless they are
also a Licensed Timber Operator. The exemption is valid for one year. See 14 CCR 1104.1.
4. §1104.1(b) and (c) Public Agency, Public and Private Utility Right of Way
Exemptions
These exemptions are used for construction or maintenance of right-of-way by a public agency
on its own or any other public property; or the clearing of trees from timberland by a private or
public utility for construction of gas, water, sewer, oil, electric, and communications (transmitted
by wire, television, radio, or microwave) rights-of-way, and for maintenance and repair of the
utility and right-of-way. This exemption can only be used to remove trees that are marked or
felled as hazard trees in established utility right-of-ways, or for construction of right of ways that
have been approved by the county.
5. §1052 Emergency
Before cutting or removing timber on an emergency basis, a Registered Professional Forester
(RPF) on behalf of a timber owner or operator shall submit a Notice of Emergency Timber
Operations to the Director. A Notice of Emergency Timber Operations can be filed for removal
of damaged, dead, or dying trees due to fire. Per the 14 CCR 895.1 definition of "dying trees," it
is up to the RPF to designate dying trees for harvest. Given the provisions of this definition, it
would be the RPF's responsibility to designate only those trees that are likely to die within one
year.
Some of the applicable laws and regulations that apply are summarized on the following pages.
The rules cited may not be quoted, and are not intended to be authoritative. The code section has
been included to provide reference to the official law or rule language can be found at
www.leginfo.ca.gov/calaw.html, or the official publications by Barclays Official California
Code of Regulations (1-800-888-3600).
Monterey County Community Wildfire Protection Plan
November 2010 v2
If you have any questions or need additional information on the different types of harvest
documents that may be applicable to your project, please contact the Unit Forester or the Area
Forester where the project is located.
Area Forester Telephone
All of San Benito Jonathan Pangburn (831) 333-2600
and Monterey Counties
or contact Mike Bacca – Forest Practice Manager (559) 243-4114
Southern Region
Z'berg-Nejedly Forest Practice Act of 1973
CAL FIRE has enforcement responsibility for the Z'berg-Nejedly Forest Practice Act of 1973.
CAL FIRE is also the lead agency for those parts of projects involving the scope of the Forest
Practice Act. This involves the regulation of "Timber Operations", as defined in Section 4527 of
the Public Resources Code (PRC), on all non-federal private lands.
PRC 4526 – Timberland
"Timberland" means land, other than land owned by the federal government, which is available
for, and capable of, growing a crop of trees of any commercial species used to produce lumber
and other forest products, including Christmas trees.
PRC 4527 - Timber Operations
"Timber Operations" means the cutting or removal or both of timber or other solid wood forest
products, including Christmas trees, from timberlands for commercial purposes, together with all
the work incidental thereto, including, but not limited to, construction and maintenance of roads,
fuelbreaks, stream crossings, landings, and skid trails. "Commercial purposes" includes (1) The
cutting or removal of trees which are processed into logs, lumber, or other wood products and
offered for sale, barter, exchange or trade, or; (2) The cutting or removal of trees or other forest
products during the conversion of timberlands to land uses other than the growing of timber
which are subject to the provisions of Section 4621, including, but not limited to, residential or
commercial developments, production of other agricultural crops, recreational developments, ski
developments, water development projects, and transportation projects. Removal or harvest of
incidental vegetation from timberlands, such as berries, ferns, greenery, mistletoe, herbs, and
other products, which action cannot normally be expected to result in a threat to forest, air, water,
or soil resources, does not constitute timber operations.
PRC 4581 – Necessity of timber harvest plan
No person shall conduct timber operations unless a timber harvesting plan prepared by a
registered professional forester has been submitted for such operations.
Other pertinent rule sections regarding conversion of timberlands: 14 CCR 1100-1110 and PRC
4621.
APPENDIX H
       Sample Threat Assessment Study Summaries
APPENDIX H – Special Study Areas: FRAP Fire Behavior Modeling and Threat
Assessment Protocol
Three representative areas within Monterey County were selected for special study: Fort Ord,
Carmel Valley, and the North County. Fire behavior modeling was conducted by FRAP utilizing
the refined topography and fuels data, and refined local 3D wind modeling data obtained from
the Monterey Naval Postgraduate School Meteorology Section. Employing FlamMap and
FARSITE computer based models, simulations were conducted for each area. Two ignition
scenarios and two weather scenarios (moderate and severe) were evaluated to assess fire
behavior potential. The following summarizes the FRAP findings for each area, based on
modeling results, and the field validation performed by the fire threat assessment team.
A. Former Fort Ord
During severe weather conditions, wildfire in maritime chaparral on Fort Ord is expected to
produce high spread rates, moderate to high intensity, and typically close range and long range
spotting of up to one mile (BEHAVE, Jim Bishop, 2002; Barry Callenberger, 2006). Due to the
distribution of flammable maritime chaparral and sage fire fuel types and rapidly fluctuating
winds and relative humidities in combination with solar preheating, Fort Ord presents a unique
and challenging fire threat.
Historical fire suppression experience at Fort Ord documents difficulty of control for fires
occurring under moderate weather with limited tactical effectiveness against fires not contained
by first responders. Of concern is the capability of a fire to leave the Fort Ord property, affecting
adjacent properties and assets. Modeling results indicate this potential under moderate and
severe weather conditions. Recommendations resulting from FARSITE modeling efforts and
field validation indicate that a 200-300 foot wide linear fuelbreak along South Boundary Road
somewhat slows the frontal spread of the accelerating fire front of an uncontrolled wildland fire,
but does little to reduce spotting and escaped spot fires. Direct attack is unsafe and is neither
recommended nor effective.
The presence of Unexploded Ordnance (UXO) in substantial portions of the Fort Ord maritime
chaparral fuel beds presents a danger to direct attack suppression and the deployment of tactical
air support in those areas, most significantly at Del Rey Oaks, where UXO is present proximate
to the development boundary. UXO fragmentation distance can be up to 1,701 feet.
Nevertheless, current policy allows tactical air support down to 100 feet in these areas.
A comprehensive system of interconnected Strategic Fuelbreaks, Defensible Polygons, and a
reduced fire fuel reduction buffer zone maintained by rotational prescribed burn application of
one to ten years of Fort Ord's chaparral fuel bed is indicated by the Bureau of Land
Management's and US Army's Fire Management Plans. Coordination of attack strategy and
community evacuation from within adjacent fire jurisdictions in the pre attack and County
Emergency Operational Plan (EOP) is essential.
Documented ground level wind streams have the potential to drive uncontrolled wildland fire to
identified topographical decision points at Laguna Seca/Pasadera/York School/Ryan Ranch,
Canyon Del Rey, East Garrison, "The Bluffs," and Seaside.
(See FRAP Figures 14 and 15 at the end of this appendix.)
B. Carmel Valley
Modeling efforts evaluated assume ignitions along the Laureles Grade with variations in wind
and fuel moisture conditions. Under severe weather conditions, fires burn rapidly in light, flashy
fuels. Those in light and heavier shrub fuels progress slightly slower, although high heat
intensity and short- and mid-range spotting are problematic making direct attack ineffective. Of
note is the slowing of fire progression when encountering oak woodland/forest vegetation types
under both weather conditions, although the benefit is usually offset by the increasing number of
miles of uncontained flaming fire perimeter threatening residences, structures, and steep
watershed in a short period of time.
(See FRAP Figures 10 and 11 at the end of this appendix.)
C. North County
Simulations for the North County area indicate potential fire growth in annual grasslands
assumed to be rested from grazing pressure. Under severe weather conditions, fire spread is
rapid in light, flashy fuels, but slows when it reaches closed-canopy oak forests. Presence of
significant stands of manzanita and Eucalyptus tree torching and fire brand spotting encourage
fire growth. Of note in this area is the potential for a relatively broad fire front and significant
fire perimeter distance. Issues of evacuation routes, timing, and large fire potential may receive
further consideration.
(See FRAP Figures 12 and 13 at the end of this appendix.)
MCCWPP Fire Threat Assessment Protocol
To complement the FRAP analysis, the fire threat assessment team provided field verification of
threat, including identification of :
 Factors of fire behavior change (fuels, slope, topography, weather).
 Fire behavior decision points (predetermined locations (i.e. proximity to structures,
change in slope, etc.) or set of meteorological thresholds that may require a change in
tactics to deal with changing conditions (location or weather)).
 Fire severity alignment scenarios (situations in which the slope, fuels, and/or weather
align to create an increase in fire activity and subsequent fire severity and possibly fire
intensity).
 Direction of fire spread (influenced by prevailing winds, topography, and fuels).
 Tactical suppression thresholds of control (identification of potential wildfire control
lines or anchor points, such as ridges, roads, and drainages).
 Fire history (the number and geographic extent of previous fires in a given area).
 Tactical fire suppression capacity (level of firefighting resources available).
Fire behavior prediction tools such as BEHAVE, FARSITE, and Campbell Prediction System
(CPS) are utilized.
MCWPP Interagency Fire Threat Assessment Team
Chris Orman MoCo Fire Chiefs Fire Chief, North County Fire
Tom Plymale USFS Division Chief, Monterey District
Mario Marquez BLM Fire Management Officer
Jonathan Pangburn CALFIRE Registered Professional Forester
Jack Riso POM/Fort Ord Fire Chief
Steve Davis USFS Fuels Chief, LPNF
Bob Nunes MBUAPCD Meteorologist
Wendell Nuss NPS Meteorologist
Joe Rawitzer MC2WG Fire Behavior Specialist
With technical assistance provided by Mark Rosenberg and Dave Sapsis, FRAP Fire Scientists,
and Doug Campbell, Fire Behavior Analyst.






APPENDIX I
Detailed Priority Threat Descriptions
APPENDIX I - Detailed Priority Threat Descriptions
The following areas are listed in alphabetical order. See the map at the end of this appendix for
the location of the following areas.
A. Bryson-Hesperia
Bryson Hesperia in southwest Monterey County is adjacent to San Antonio and Nacimiento
Resevoirs in a rural suburban WUI intermixed with grass, dense chaparral, and oak woodland.
Bryson Hesperia borders Los Padres National Forest and Fort Hunter Liggett. Project includes
creation of defensible space around structures, ingress and egress, neighborhood fuel reduction,
and a series of cooperative interconnecting Strategic Fuelbreaks, Defensible Polygons, and
hazardous fuel reduction prescribed burns.
B. Former Fort Ord
The Former Fort Ord Lands are encircled with WUI boundaries of Monterey, Del Rey Oaks,
Seaside, Marina, East Garrison, Toro Park/Serra Village, Los Laureles, Laguna Seca, Pasadera,
Ryan Ranch, Hidden Hills, and Highway 68. These undeveloped lands may present the single
greatest hazardous fuel and fire threat to WUI in Monterey County. The area is currently divided
into two federal jurisdictions, although local governments also manage some of the undeveloped
lands in these areas. The federal lands include: 1) lands that BLM manages and controls (i.e.
about 7,200 acres), and 2) lands that the Army manages and controls (i.e. about 6,500 acres) until
such time they are transferred to the BLM. Lands managed and controlled by the Army will
likely continue to be managed by the Army until 2020-2025 while the Army conducts a
munitions and explosives of concern (MEC) remediation of these former range areas under the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). After
the lands have been remediated, the BLM has indicated an interest in managing these former
range lands for the Army as part of the base closure process.
The highest fire threat in the area consists of the 6,500 acres of maritime chaparral within the
former Fort Ord Multi Range Area (MRA) where the presence of MEC hampers tactical
firefighting effectiveness and presents additional life threat to firefighters and the public,
especially at Del Rey Oaks and Seaside. Within the MRA, the Army maintains a system of
fuelbreak roads that facilitate prescribed burning as part of the steps to remove brush for MEC
remediation. The Army intends to prescribe burn up to 800 acres per year in the MRA to
facilitate the MEC remediation. Generally, the Army maintains 15 foot wide roads with 15 feet
of vegetation cutting on both sides of each fuelbreak road. Some of these roads are in poor
and/or sandy condition and wildfire suppression efforts can be hampered. The Army is working
to gravel many of these roads and/or road segments in coordination with the BLM. Around
individual burn units, the Army has generally mechanically cut 200 feet of vegetation along
primary containment lines to support the burning of standing vegetation, with width depending
upon the age/expected flame lengths of the adjoining vegetation, however, secondary and tertiary
containment lines are generally 15 foot wide roads with 15 feet of vegetation cutting on both
sides of the road.
Along General Jim Moore Boulevard, the City of Seaside and Del Rey Oaks have land that is
adjacent to the Army's former MRA. These lands will require careful firewise planning as
developments are being contemplated. These parcels currently require a 200 foot setback from
the Army lands (i.e. future BLM lands) where flammable structures may not be developed
without preparation and approval of a firewise plan. The Healthy Forests Restoration Act
provides that at-risk communities may recommend in a CWPP that fuel reduction work be
performed on lands administered by the Bureau of Land Management, which may enable this
problem to be addressed by fuel reduction work on Federal land rather than by restricting use of
private land.
After the MRA lands are remediated and transferred to the BLM, the lands will be managed in
perpetuity as a habitat reserve under the BLM's Resource Management Plan (RMP) and the
Army's Habitat Management Plan (HMP). The HCP/RMP dictate a change in the historical
vegetation distribution at Fort Ord. Until 1991, the majority of maritime and coastal chaparral
has burned at one to ten year intervals in defensible polygon mosaics. According to the HCP, the
frequent fire interval mosaics will be replaced by a mixed age distribution. This will increase the
average age class from 1-10 years with average fire fuel loads of 1 to7 tons per acre, to 10 to50+
years, with average fire fuel loads of 5 to 35 tons per acre. Without the historic mosaic and
firebreaks, the threat from both wind driven fires and fuel driven fires that progress beyond
initial attack increases significantly.
Management as a habitat reserve will involve the BLM promulgating a mixed-age structure of
maritime chaparral and periodic prescribed burning. The BLM anticipates that this prescribed
burning may treat up to 1,500 acres each decade. The BLM intends to use the Army's fuelbreak
roads in long-term management of the area, and may develop new fuelbreaks to support future
prescribed burning operations.
Failure to assertively maintain reduced hazardous fuel zones, with prescribed burning or other
means, will increase the likelihood of high-intensity uncontrolled wildland fires under severe fire
weather conditions. Uncontrolled wildland fires originating at former Fort Ord threaten the
Highway 68 corridor, specifically at Ryan Ranch, York School, Pasadera, Laguna Seca, and
Hidden Hills. Del Rey Oaks, Monterey, Seaside, and the Bluffs off Reservation Road as well are
identified in the county wide fire threat assessment, and document the at-risk community fire
threat profile.
C. Highway 68
Wildland fires originating at Fort Ord and Laguna Seca threaten the areas contiguous to the
Highway 68 corridor. Ryan Ranch, York School, Pasadera, Hidden Hills, Corral de Tierra, Toro
Park, Del Rey Oaks, Monterey, Seaside, and the Bluffs are indicated as high threat by modeled
FARSITE fire growth projections and fire threat assessment team evaluations. BLM land
adjacent to Creekside and Toro Creek near Reservation Road has also been identified as a high
priority for treatment.
D. North County
Presence of significant stands of manzanita and Eucalyptus trees subject to torching and fire
brand spotting encourage fire growth in North County. Royal Oaks subdivision, Manzanita Park,
Elkhorn Slough, Pesante Canyon, Mallory Canyon, and Long Valley present a complex of fire
problems and public safety issues. Fire models and field verification for the North County area
indicate rapid fire growth and a relatively broad fire front and asymmetric fire perimeter under
severe fire weather conditions. Neighborhood-level evacuation routes, timing, safety zones, and
large fire potential may receive further consideration and evaluation by the fire threat assessment
team. Project includes enforcement of PRC 4291 defensible space around structures, providing
improved ingress, egress, and evacuation planning, neighborhood fuel reduction, and a series of
cooperative interconnecting strategic fuelbreaks, identification of defensible polygons, and
hazardous fuel reduction prescribed burns.
E. Pine Canyon (South)
Pine Canyon west of King City is a rural suburban WUI intermixed with dense chaparral. The
upper reaches of Reliz Canyon joins the upper watershed of Pine Canyon at the border of
Ventana Wilderness, Department of Defense (Fort Hunter Liggett), and multiple private
ownerships. A series of cooperative interconnecting strategic fuelbreaks, defensible polygons,
and hazardous fuel reduction prescribed burns are planned. Cooperating agencies: CAL FIRE,
USFS, BLM, FHLFD, NRCS, AND MBUAPCD.
F. Santa Lucia Fire Defense System (in Progress)
WUI occurs in and near the LPNF and Ventana Wilderness in Monterey County, at multiple
locations where the wilderness boundary and/or LPNF boundary occur within the boundaries of
an at-risk community's WUI. In the event of wildfire, at-risk communities such as Big Sur, Palo
Colorado, White Rock, Carmel Valley, Jamesburg-Cachagua, Arroyo Seco, Reliz Canyon, Pine
Canyon (South), Sierra de Salinas, Bryson Hesperia, and South Coast are threatened by and are
threats to the LPNF and Ventana Wilderness, depending upon the fire's origin. Maintenance of
historic and present firebreaks, fuelbreaks and hazardous fuel reduction zones both within and
outside the LPNF/Ventana Wilderness is determined to be a high priority by this MCCWPP, and
this MCCWPP makes recommendations in Section 9 and Appendix D accordingly.
The Santa Lucia Fire Defense System (in progress) is a network of interconnecting fire lines and
fuelbreaks that protects at-risk communities from fires originating in the LPNF, and protects the
LPNF from fires originating in at-risk communities. Development of the Santa Lucia Fire
Defense System (SLFDS) is supported by private landowners adjacent to LPNF and BLM threat
areas. Initial work was started on the SLFDS as part of the USFS Monterey Defensible Fuel
Profile Zone (DFPZ) and the BLM Sierra de Salinas-Gabilan Fuel Reduction Project and
Strategic Fuel Break System.
G. Sierra De Salinas-Gabilan Fuel Reduction Project and Strategic Fuelbreak
System
The Sierra de Salinas rises on the west side of the Salinas Valley and extends from Fort Ord and
Toro Park to Arroyo Seco in the north, continuing through Reliz Canyon to Camp Roberts in the
south.
The ridge top of the northern Sierra de Salinas has historically been a Strategic Fuelbreak and is
known as the Paloma Ridge Fire Trail. Ownership is principally private, with approximately
8,000 acres of Bureau of Land Management jurisdiction intermingled. BLM and landowners are
cooperatively managing hazardous fuel reduction treatments. Structures and high value world
class vineyards are at risk from high intensity wildfire, smoke damage, and erosion due to
hazardously overgrown contiguous brush fields in the watershed. Stakeholders, fire districts,
CAL FIRE, and the Bureau of Land Management are planning and defining interconnecting
hazardous fuel treatment defensible polygons from Fort Ord and Toro Park south to the Jolon
Grade.
The Gabilan Range runs on the east side of the Salinas Valley from the San Juan Grade in the
north, south to the San Luis Obispo county line. In some locations the ridge top of the Gabilan
Range is the Monterey-San Benito county line, part of which has historically been a Strategic
Fuelbreak and fire access road. BLM has designated treatment within the Sierra de Salinas-
Gabilan Fuel Reduction and Strategic Fuel Break Project. Stakeholders and agencies have
cooperatively delineated contiguous strategic fuel breaks and prescribed fire units forming
Defensible Polygons from San Juan Grade south to the Topo Ranch and Pinnacles National Park.
Prioritization is given to hazardous fuel reduction and annual maintenance of strategic fuelbreaks
and defensible polygons with manual and mechanical treatments, livestock grazing, and frequent
controlled burns. The Bureau of Land Management is in the process of establishing a permit
procedure to allow adjacent private landowners to maintain fuelbreaks, conduct prescribed burns
to include BLM lands, and to ultimately form strategic management response agreements
between landowners and agencies for the project area.
A combination of cooperative Range Improvement burn projects and Vegetation Management
Program projects are planned with the objective of treating 10,000 acres annually.
H. Tularcitos Ridge
Tularcitos Ridge in the Jamesburg-Cachagua community is adjacent to Los Padres National
Forest in a rural suburban WUI intermixed with dense chaparral and heavy mixed woodland. The
project is subdivided into Tularcitos Ridge North, which extends from Sky Ranch to Rancho
Galante, and Tularcitos Ridge South, which extends from Rancho Galante to Trampa Canyon
and Tassajara Road. Project includes maintenance of defensible space around structures, ingress
and egress, neighborhood fuel reduction, and a series of cooperative interconnecting Strategic
Fuelbreaks, Defensible Polygons, and hazardous fuel reduction prescribed burns are planned.
I. White Rock
White Rock consists of approximately 100 residences at the confluence of White Rock Creek
and Black rock Creek adjacent to the LPNF Ventana Wilderness boundary in the Carmel Valley
area. Fuel reduction in the White Rock area may include maintenance of strategic fuelbreaks and
hazardous fire fuel reduction projects, fire and non-fire.



Monterey County Community Wildfire Protection Plan
November 2010 v2
APPENDIX J
Comments on the 2010 MCCWPP
1Monterey Fire Safe Council
2221 GARDEN ROAD, MONTEREY, CA 93940 (831) 333-2606 info@firesafemonterey.org
------------------------------------------------------------------------------------------------------------------
Protecting lives and property from harm by wildfire,
we pledge our expertise, attention and support for fire safe
projects throughout Monterey County.
November 20, 2010
Honorable Simon Salinas
Chair, Monterey County Board of Supervisors
168 West Alisal St., 3rd Floor
Salinas, CA 93901
Dear Chairman Salinas and Members of the Board:
The Monterey Fire Safe Council (MFSC) is the author of the enclosed Monterey County
Community Wildfire Protection Plan (MCCWPP). The November 2010 MCCWPP has been
significantly revised at the request of the Ventana Wilderness Alliance, Ventana Chapter of the
Sierra Club, LandWatch, California Chaparral Institute, Monterey County staff and other interest
groups, and differs significantly in principle and content from the original January 2010 and
September 2010 MCCWPPs that had already been signed by the current 18 signatories of the
November 2010 MCCWPP.
Notwithstanding the foregoing, the MFSC continues to fully support the discussions and
recommendations that were removed from the January 2010 and September 2010 MCCWPPs to
obtain Monterey County's signature on the November 2010 MCCWPP. The MFSC objects to
the removal of those discussions and recommendations, which were intended to encourage the
maintenance of firebreaks and reduce regulatory burdens that hinder hazardous fuel reduction
work, in order to better protect life, property, and the environment, in that order of priority.
In order to foster continued discourse on the need to maintain firebreaks and the need to
change laws and policies to expedite the hazardous fuel reduction work recommended in the
MCCWPP, the MFSC is providing herewith the discussions and recommendations that were
changed or removed from the January 2010 and September 2010 MCCWPPs as they were edited
to the November 2010 MCCWPP. The MFSC believes that these discussions and
recommendations are essential components in solving the problem of wildfire
protection/prevention in Monterey County.
We ask that you carefully consider these discussions and recommendations during your
deliberation on the November 2010 MCCWPP, and accordingly, direct your staff to work with
the MFSC to solve the indicated problems.
The MFSC is supported in its position by the wildfire protection agencies that have
joined the MFSC in signing this letter.
2Discussions and Recommendations Changed in and/or Removed from the
November 2010 MCCWPP to Obtain Monterey County's Signature on the MCCWPP
I. Note on the Collaborative Process used to write the MCCWPP
The MCCWPP was developed by a committee of the Monterey Fire Safe Council
(MFSC) using Wildland Fire Leadership Council’s Preparing a Community Wildfire Protection
Plan, A Handbook for Wildland-Urban Interface Communities, (Handbook) as a guide, and
accordingly, the development process was an open and collaborative process.
The MCCWPP was written over the course of years. Table 4 of the MCCWPP lists
organizations that were sent letters of intent to develop the MCCWPP, and invited to participate
in drafting it. Some groups that were not included in the original notice were added as the
MFSC became aware of their interest. Participants in this process included fire professionals,
concerned citizens, and representatives from various organizations including homeowners
associations and conservation groups.
During this collaborative process, the working draft was placed on the Internet in an on-
line document collaboration application (Acrobat Buzzword), and invitations to participate and
enter comments were sent out to a lengthy email list of interested parties, thus affording
interested parties an opportunity to collaborate using this convenient and accessible interface.
The January 2010 MCCWPP, which was signed by 18 agencies including CAL FIRE; the
Monterey County Fire Chiefs Association and local fire districts, departments and volunteer fire
brigades; USFS; BLM; the Presidio of Monterey/Fort Ord; and the California Department of
Parks and Recreation), contained recommendations to amend local, state and federal laws and
regulations to expedite fuel mitigation and fire preparedness efforts, to better protect lives,
property and the environment, in that order of priority.
However, after the MCCWPP was finalized and signed by these 18 agencies, comments
on the January 2010 MCCWPP were received from various environmental groups, some of
which were invited to the meetings and had access to the document for submitting comments in
Acrobat Buzzword. These late comments by some who chose not to participate during the two
year collaborative process, included a request to remove the recommendations to change laws
from the MCCWPP and strongly implied litigation against Monterey County if it signed the
MCCWPP as then drafted.
In response to these comments, the MCCWPP was revised in the September 2010
MCCWPP. During Monterey County’s review of the September 2010 MCCWPP, Monterey
County staff and various environmental organizations requested additional changes to the
document such as removing the following key discussions and recommendations from the
MCCWPP: (1) recommended changes to laws to avoid hindrance of fuel reduction work, (2)
recommendations that firebreaks be maintained, (3) the priority of protecting life, property and
the environment in that order, (4) recommendations to Monterey County and other governmental
agencies to interpret all laws and regulations to expedite hazardous fuel reduction work, and (5)
fire science discussion. In order to help ensure signing of the MCCWPP by Monterey County to
complete the document under the Healthy Forests Restoration Act (HFRA), revisions were made
3that compromised the basic principles of the MFSC and potentially reduce the protection of life,
property and the environment from wildfires in Monterey County.
II. Protecting Life Property and the Environment, in that Order of Priority
The January 2010 and September 2010 MCCWPPs contained numerous references to the
need for all laws and regulations to be interpreted in the manner that is most protective of lives,
property and the environment, in that order of priority. This important concept has been
removed from the November MCCWPP at the request of environmental groups and Monterey
County staff.
This order of priorities was inspired by The Emergency California-Nevada Tahoe Basin
Fire Commission Report to the governors of California and Nevada, prepared by the Tahoe
Basin Fire Commission in 2008 after the Angora Fire, which destroyed 254 homes. The
Commission found that a contributing factor to the devastation was overregulation of vegetation
removal by various agencies. For example, see Finding 7 on page 22 of the report, which can be
found at
http://resources.ca.gov/TahoeFireCommission/downloads/Final%20Docs/TahoeReport.pdf. The
Commission repeatedly states the need for this order of priorities (i.e., life, property, and the
environment). For example, see Category 5 (page 10 in the report), Recommendation 16 (page
79), Recommendation 74 (page 104), Recommendation 89 (page 110), Finding 2 (page 122),
Finding 47 (page 224).
The MFSC recommends that Monterey County and other regulatory agencies adopt this
order of priorities, and implement it, to reduce regulatory hindrances to performance of
hazardous fuel reduction work to the minimum required by state and federal law.
III. Discussion of Vegetation/Fuels in Monterey County
Vegetation (or fuel) (as well as weather and topography) plays a major role in affecting
fire behavior and shaping fire hazard potential. Vegetation distribution throughout the County
varies by location and topography, with dramatic differences observed between coastal and
inland regions. Current land cover/fuels distribution within the County is characterized by
fourteen different vegetation/fuel types, as presented in the table below. Dominant vegetative
cover within Monterey County is herbaceous or grassland cover (31.3 percent), distributed
primarily in the low-lying valley areas along the Highway 101 corridor. While this fuel type can
burn quickly under strong, dry wind patterns, it does not produce the high heat intensity and high
flame lengths associated with chaparral fuel types. Other significant vegetative cover types
include light brush (21.3 percent), light grass/woodland (14.8 percent), and hardwood litter (13.1
percent). These vegetation types are primarily associated with the steeper, upland areas in the
southern, western, and northern portions of the County. Fire behavior in brush fuel types
produces flame lengths greater than 12 feet, and resistance to control is high. Fire behavior in
woodlands is variable, depending on surface fuel conditions and the presence of ladder fuels.
However, crown fire is common if slope and wind conditions are favorable to allowing fire to
enter into the crowns.
4The distribution of fuels in Monterey County is graphically presented in Appendix B-2 of
the MCCWPP.1
Table - Monterey County Land Cover/Fuels Distribution*
Fuel Model**
Number
Description Approximate Acreage Percent Cover
1 Grass 662,270 31.3%
5 Light Brush 450,958 21.3%
2 Light Grass/Woodland 312,639 14.8%
8 Hardwood Litter 276,924 13.1%
97 Agriculture 240,714 11.4%
4 Heavy Chaparral 58,945 2.8%
28 Urban 43,525 2.1%
9 Light Conifer Litter 35,039 1.7%
98 Water 15,033 0.7%
10 Heavy Conifer Litter w/ Understory 9,007 0.4%
7 Young Maritime Chaparral 6,209 0.3%
99 Barren 5,698 0.3%
30 Maritime Live Oak Forest 95 0.0%
6 Moderate Brush 70 0.0%
Total: 2,117,126 100.0%
*FRAP Monterey Fire Risk Analysis, 2006
** Fuel Model is a rating of vegetation and dead woody material and their volume, type, condition, arrangement,
distribution and location.
Variations in vegetative cover type and species composition have a direct effect on fire
behavior. Some vegetation types and their associated plant species have increased flammability
based on plant physiology (resin content), biological function (flowering, retention of dead plant
material), physical structure (leaf size, branching patterns), and overall fuel loading. For
1 Higher resolution vegetation cover maps are currently under development by CAL FIRE (FRAP), USGS and
local universities. Due to the small scale patch mosaic characteristics of Monterey County's landscape, these maps
may provide a more accurate representation of forest and vegetation cover than those currently available. The
Watershed Institute at CSUMB has produced a 30 meter resolution map of the Central Coast Bioregion. The map is
being edited to provide GIS data and ground cover percentages limited to the boundaries of Monterey County. First
approximations suggest that both Mixed Conifer/Montane Forests and Oak Woodland/Mixed Forest cover may be
greater than current estimates due to the lower resolution used in current maps.
5example, the overgrowth of native shrub species that compose chaparral vegetation types present
a high potential hazard based on such criteria.2
Vegetation type and condition plays a significant role in fire behavior. A critical factor to
consider is the dynamic nature of vegetation types. Fire presence and absence at varying cycles
or regimes affects vegetation type succession. Biomass and associated fuel loading will increase
over time, assuming that fire disturbance does not occur or hazardous fuel reduction efforts are
not implemented.
Over the past century, public policy has required the active suppression of fires, which
has resulted in large contiguous areas of overgrown and overmature hazardous fuel beds with a
large concentration of down-dead fuel that contribute to high-cost, suppression-resistant, high
intensity wildfires, thereby threatening communities, natural vegetation types, wildlife habitat
and lives and property. On balance, current fire suppression policy is beneficial, however, it has
resulted in hazardous fuel loads that should be reduced to lower the risk of high intensity
wildfires.3
Lack of fire has changed habitat that is critical for certain wildlife species. When the
number and extent of forest openings, or gaps, is reduced as forest density increases due to fire
suppression, key shade-intolerant herbaceous and shrub species are also diminished (particularly
nitrogen fixers such as Ceanothus spp.). Wildlife that depends on these plants, such as deer, has
less available habitat.4
These overgrowth conditions affect the abundance and diversity of wildlife species
directly by creating unfavorable habitat conditions for some species. For example, dense
understory growth may adversely affect habitat quality for California spotted owls and northern
goshawks by limiting their access to prey.5
Problems associated with vegetation changes that increase the risk of unnatural high-
intensity wildland fires tend to be especially prevalent at elevations common in mountainous
2    Griffin, J.R. 1978.  The Marble-Cone fire ten months later.  Fremontia 6(2):8–14. 
Hanson & Usner 1993. The Natural History of Big Sur. University of California Press, Berkeley, pp. 232-238.
Minnich, R.A., and Chou, Y.H. 1997.  Wildland fire patch dynamics in the chaparral of southern California and 
northern Baja California. Int. J. Wildland Fire 7, 221–248.
3 Agee, J. K. 1993. Fire ecology of Pacific Northwest forests. Island Press, Wash., D.C. p. 493.
Agee, J.K. 2002. The fallacy of passive management: managing for firesafe forest reserves. Conservation Biology
in Practice 3(1):18-25.
Franklin, J.F. & Agee, J.K. 2003. Forging a Science-Based National Forest Fire Policy. Issues in Science and
Technology. Fall 2003 pp. 1-8.
Moghaddas, J.J 2006. A Fuel Treatment Reduces Potential Fire Severity and Increases Suppression Efficiency in a
Sierran Mixed Conifer Forest. In: Andrews, Patricia L.; Butler, Bret W., comps. 2006. Fuels Management—How
to Measure Success: Conference Proceedings. 28-30 March 2006; Portland, OR. Proceedings RMRS-P-41. Fort
Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station.
4 Page I-6, Environmental Impact Statement, Final Yosemite [National Park] Fire Management Plan (Yosemite
EIS); citing Bonnicksen and Stone 1982; www.nps.gov/archive/yose/planning/fire/pdf/fire.pdf. This paragraph and
the following three paragraphs are taken almost verbatim from the above referenced document.
5 Yosemite EIS, page IV-34; citing Weatherspoon et al. 1992, Maurer 2000.
6areas of Monterey County. There, the natural mosaic of diverse vegetation types and ages can be
replaced by dense, continuous stands of shrubs and trees because of the success of fire
suppression.6
The density of trees and shrubs can create a hazardous arrangement, both horizontally
and vertically, of closely-standing burnable vegetation, or fuel ladders, in the understory. Fuel
ladders help fires ascend into the larger trees, or overstory. This combination of fuel ladders and
a high density of fuels can also increase the potential for insect and pathogen infestations which,
if they cause tree die-off, increase the potential for fire. In the event of high-intensity
uncontrolled wildfire, whole landscapes can be denuded and reverted to shrub communities,
watershed processes can be compromised, and other environmental values can be greatly
altered.7
California is a fire-adapted ecosystem. However, abnormal high-intensity wildfire
disturbances can have dramatic impacts on plants and plant composition.
The normal post-fire response to moderate and low-intensity fire for most species is
diverse vegetative reproduction and desirable stimulation of flowering and fruiting. However,
fire suppression can contribute to high vegetation density, which in turn increases fire intensity
in the event of a wildfire. Unnaturally high heat intensity fires alter natural processes and can
result in hydrophobic layers in soils, vegetation type-conversion and loss of habitat. The
combustion of aboveground biomass alters seedbeds and temporarily eliminates competition for
moisture, nutrients, heat, and light. Species that can rapidly take advantage of the available
resources will flourish.
Hydrophobic soil conditions resulting from unnatural high intensity wildfires can cause
debris flows and mudflows, which have potential to alter streambed and riverbed conditions and
water turbidity. Altered streambed and water quality conditions can in turn result in adverse
impacts on species that rely on natural streambed conditions and water quality for survival.
For purposes of establishing new, or maintaining historic Strategic Fuelbreaks and
wildfire buffer zones in overgrown areas in and around at-risk communities, it is possible to alter
successional pathways to reduce fire intensity for varying vegetation types through applied
vegetation management, prescribed fire application, manual and mechanical alteration, and
prescribed grazing, restoring an approximation of natural conditions. This concept is a key
component in the overall establishment and maintenance of the Strategic Fuelbreaks, Mitigation
Zones, and other hazardous fuel reduction measures included in this MCCWPP.
Sudden Oak Death - Of concern within Monterey County is the presence of the Sudden
Oak Death (SOD) pathogen (Phytophthora ramorum) that primarily affects tanoaks (Lithocarpus
densiflorus), coast live oaks (Quercus agrifolia), and other oak and tree species found in forest
and woodland environments, both coastal and inland. Other affected species include California
bay trees (Umbellularia californica), rhododendron, coast redwood (Sequoia sempervirens) and
many other tree and plant species. The potential for SOD is concentrated primarily in the coastal
6 Yosemite EIS, page I-7.
7 Yosemite EIS, page I-7.
7portions of Monterey County, as the pathogen is a water mold that requires moist environments
for survival and spore dissemination. The SOD pathogen infects the water flow system of
susceptible trees and shrubs, eventually blocking this flow and resulting in rapid plant/tree
mortality. Precautions must be used when handling infected plant material and/or tools used in
trimming/removal of infected wood if they will be transported outside Monterey County. More
information on SOD can be found via the California Oak Mortality Task Force
(http://www.suddenoakdeath.org/index.html).
Pitch Canker - Also of concern is the continuing effect of pitch canker disease on the
pine forests in Monterey County. Although the disease affects a number of pine species, the
largest impact is on the signature Monterey pine trees (Pinus radiata) in the forested coastal
areas of the County. Pitch canker occurs in response to a fungal infection and is characterized
by resinous cankers on the trunk, branches or roots accompanied by needle wilt, limb dieback
and eventual tree mortality. Monterey Pines in close association with disturbed or developed
areas have a higher disease rate than native stands. The fungus (Fusarium circinatum) is spread
through distribution of the fungal spores by contact with infected material and by insect vectors
including several species of bark, twig and cone beetles. A management and research program
was adopted in 1995 under the direction of the Pine Pitch Canker Task Force
(http://frap.cdf.ca.gov/pitch_canker/). Precautions to prevent the spread of the disease were
developed as part of the Pitch Canker Action Plan (available at the above website) and are
similar to those outlined in the above discussion of Sudden Oak Death.
The implication of these forest diseases and insect infestations in relation to fire
prevention and protection is the relatively rapid mortality that occurs, resulting in increased dead
fuel loads. Standing dead fuels contribute to increased wildfire hazard and require treatment
and/or removal, especially within wildland-urban interface areas.
The Wilderness Act provides a special provision for "fire, insects and diseases" that lists
exceptions to the act's prohibitions, which includes among others, the use of mechanized
equipment within wilderness when needed to address these problems.8
IV. Regulatory Framework Discussion and Interpretation of Laws and Regulations
The MFSC recommends that the complex framework of federal, state and local laws and
regulations that affect the ability to perform wildfire fuel reduction work be interpreted by all
regulatory agencies in the manner most favorable to allowing and facilitating such work where it
is needed to protect lives, property or the environment, in that order of priority.
Long term benefits to plants and wildlife from wildfire fuel reduction outweigh short-
term impacts that may result from vegetation management activities. Vegetation in some areas
has not burned for multiple natural fire-return intervals, which, together with regulations that
may make it difficult and costly to remove excess vegetation, can result in hazardous
overgrowth. Such overgrowth can adversely impact the ability of wildlife to forage, and
threatens all species, including protected species, with unnatural high heat intensity wildfire
when fire inevitably occurs.
8 16 USC 1133(d)(1) and Sierra Club v. Lyng (1987) 663 F.Supp. 556.
8The goal is to enable and encourage landowners to perform the essential task of
managing vegetation, to advance and foster much needed wildfire fuel reduction work as
expeditiously as possible. To the extent that favorable interpretation of regulations is not
adequate to avoid regulatory hindrances, the MFSC recommends changes to law to allow and
facilitate reduction of hazardous fuel loads in Monterey County.
In order to understand this complex regulatory framework, applicable federal, state and
local laws are summarized below.
A. Applicable Federal Laws
1. Healthy Forests Restoration Act
Devastating wildfires in the western United States at the turn of this century resulted in
action by the Western Governors Association in concert with the Secretaries of Agriculture and
Interior, counties, southern governors, and tribes, to address the wildfire fuel overgrowth
problem at a national level. In 2002, the Western Governors Association agreed on a plan called
A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the
Environment: 10-Year Strategy.
In 2003, Congress enacted the Healthy Forests Restoration Act of 2003 (HFRA). The
HFRA improves the ability of the United States Secretary of Agriculture and Secretary of
Interior to conduct hazardous fuel reduction projects on National Forest System lands and BLM
lands, to protect communities, watersheds, and infrastructure from catastrophic wildfire. The
major provisions of the HFRA include the following: (1) a streamlined National Environmental
Policy Act (NEPA) process for wildfire fuel treatments and other activities that would reduce
hazardous wildfire fuels on Federal land and, (2) incentives for local communities to prepare
Community Wildfire Protection Plans (CWPP) that prioritize where fuel reduction should take
place on Federal lands, and where federal fuel reduction funds should be expended on private
lands (e.g., fuel reduction grants).
The MCCWPP was prepared pursuant to provisions of the HFRA, recognizing that
certain large federal land holdings influence wildfire risk to nearby state, county and private
lands, and local communities. In accordance with section 101 of the HFRA, this MCCWPP: (1)
identifies and prioritizes areas for hazardous fuel reduction treatments and recommends the types
and methods of treatment on federal and non-federal land that will protect at-risk communities,
watersheds and essential infrastructure; and (2) recommends measures to reduce structural
ignitability throughout at-risk communities. Pursuant to section 103 of the HFRA, through the
preparation of the MCCWPP and subsequent community-specific CWPPs, federal fuel reduction
funding priorities on federal and non-federal land should be allocated to protecting those at-risk
communities described in the MCCWPP and local CWPPs, and to those fuel reduction projects
prioritized in Appendix D of the MCCWPP.
92. Wilderness Acts
Approximately 86 percent of the Monterey Ranger District of the LPNF is designated as
wilderness, totaling about 263,000 acres or 12.5 percent of Monterey County's land area.
The wilderness is designated as two areas, (1) the Ventana Wilderness and (2) the Silver
Peak Wilderness. Each wilderness area has been the subject of multiple acts of Congress.
Congress has repeatedly stated its intent that exceptions are made to wilderness prohibitions so
these wilderness areas can and will be managed to protect communities and watersheds from
wildfire.
2.1. Wilderness Act of 1964
The Wilderness Act of 1964 (Wilderness Act) generally prohibits use of motor vehicles
and motorized equipment within wilderness areas.
However, the Wilderness Act also provides a special provision for "fire, insects and
diseases" as exceptions to its prohibitions, including, among others, the use of mechanized
equipment within wilderness areas to plan for and combat these specific dangers.9
The MFSC recommends to the Secretary of Agriculture that certain firebreaks and
fuelbreaks in the LPNF be maintained year round. Some of these firebreaks and fuelbreaks are
in wilderness, hence this exception to Wilderness Act prohibitions on use of motorized
equipment is important to the protection of lives, property and the environment.
2.2. The Endangered American Wilderness Act of 1978
The Endangered American Wilderness Act of 1978 (Wilderness Act of 1978) builds upon
the above referenced exceptions in the Wilderness Act, applying additional exceptions for fire
presuppression measures and techniques specifically to the Ventana Wilderness to guarantee the
continued viability of watersheds and the continued health and safety of communities. The
Wilderness Act of 1978 authorizes the USFS to take whatever appropriate actions are necessary
for fire prevention, reading in pertinent part:10
In order to guarantee the continued viability of the Ventana watershed and
to insure the continued health and safety of the communities serviced by
such watershed, the management plan for the Ventana area to be prepared
following designation as wilderness shall authorize the Forest Service to
take whatever appropriate actions are necessary for fire prevention and
watershed protection including, but not limited to, acceptable fire
presuppression and fire suppression measures and techniques. Any special
provisions contained in the management plan for the Ventana Wilderness
area shall be incorporated in the planning for the Los Padres National
Forest. …
9 See, 16 USC 1133(d)(1) and, Sierra Club v. Lyng (1987) 663 F.Supp. 556.
10 See, the Endangered American Wilderness Act of 1974, section 2(d).
10
The legislative history of the Wilderness Act of 1978 clarifies that Congress intended the
above language to allow exceptions to wilderness prohibitions due to the extreme hazard of
forest fires in the LPNF. The report on the Wilderness Act of 1978 by the Senate Committee on
Energy and Natural Resources reads in pertinent part as follows:11
Due to the extreme hazard of forest fires in the Los Padres National
Forest, the committee adopted the special management language for the
Santa Lucia and Ventana Wilderness areas approved by the House
authorizing the Forest Service "to take whatever appropriate actions are
necessary for fire prevention and watershed protection included [sic] but
not limited to acceptable fire pre-suppression and fire suppression
measures and techniques."
2.3. The California Wilderness Act of 1984
The California Wilderness Act of 1984 (Wilderness Act of 1984) expanded the Ventana
Wilderness, and section 103(b)(2) of this Act referenced the following exception in the
Wilderness Act for the control of fire:12
As provided in subsection 4(d)(l) of the Wilderness Act, the Secretary
concerned may take such measures as are necessary in the control of fire,
insects, and diseases, subject to such conditions as he deems desirable. …
Legislative history on the Wilderness Act of 1984 explains that the intent of Congress
was to emphasize the authority of the Secretary of Agriculture to address the threat of fire in
whatever manner the USFS determines to be necessary in California wilderness areas due to
overgrown forests and California's arid climate. Expressing this intent, the report by the House
Committee on Interior and Insular Affairs on the Wilderness Act of 1984 reads in pertinent part
as follows:13
Fire management—Due to the arid climate, high seasonal temperatures
and buildup of fuel that exists in so many California roadless areas,
especially in Southern California, fire management is a key concern. …
Not only does the threat of wildfire pose a danger to public safety, but
uncontrolled fires can also cause severe damage to watersheds, water
quality and other beneficial wilderness values.
To address this concern in the [Wilderness Act of 1984], the Committee
reiterated the fire provisions of Section 4(d)(1) of the Wilderness Act. …
As the Committee stressed … this provision is intended to grant the Forest
Service with the means of utilizing such measures or tools as it deems
"necessary" and "desirable" in the control of [sic] presuppression of fire in
11 See, Senate Report 95-490 on H.R. 3454 (The Endangered American Wilderness Act of 1978), 95th Congress
1st session October 11, 1977, Senate Committee on Energy and Natural Resources.
12 16 USC 1133.
13 See, House Report 98-40 on H.R. 1437 (P.L. 98-425), 98th Congress 1st session, March 18, 1983, House
Committee on Interior and Insular Affairs.
11
wilderness areas. In some instances, the Forest Service has exercised this
broad authority [for] fire roads, fuel breaks or other management. … The
major point to be made however, is that the Wilderness Act permits the
Forest Service to utilize measures necessary to control wildfire, or the
threat of fire, in wilderness areas. Obviously, such measures should, to the
maximum extent practicable, be implemented consistent with maintaining
the wilderness character of areas, while at the same time protecting the
public health and safety and protecting private property located
immediately adjacent to wilderness areas.
2.4. Los Padres Condor Range and River Protection Act (1992)
The Los Padres Condor Range and River Protection Act (Los Padres Act of 1992)
expanded the Ventana Wilderness and created the Silver Peak Wilderness in Monterey County.
In the Act, Congress again reiterated exceptions to the Wilderness Act prohibitions which allow
for fire presuppression measures within wilderness in order to protect watersheds and
communities. Section 3(b) of the Los Padres Act of 1992 reads as follows:
FIRE PREVENTION AND WATERSHED PROTECTION —In order to
guarantee the continued viability of the watersheds of the wilderness areas
designated by this Act and to ensure the continued health and safety of the
communities serviced by such watersheds, the Secretary of Agriculture
may take such measures as are necessary for fire prevention and watershed
protection including, but not limited to, acceptable fire presuppression and
fire suppression measures and techniques.
2.5. Big Sur Wilderness and Conservation Act of 2002
The Big Sur Wilderness and Conservation Act of 2002 (Wilderness Act of 2002)
expanded the Ventana Wilderness and the Silver Peak Wilderness. Congress again provided
exceptions to wilderness prohibitions to allow for fire presuppression measures and techniques.
Section 4 of the Wilderness Act of 2002 reads as follows:
SEC. 4. WILDERNESS FIRE MANAGEMENT.
(a) REVISION OF MANAGEMENT PLANS.—The Secretary of
Agriculture shall, by not later than 1 year after the date of the enactment of
this Act, amend the management plans that apply to each of the Ventana
Wilderness and the Silver Peak Wilderness, respectively, to authorize the
Forest Supervisor of the Los Padres National Forest to take whatever
appropriate actions in such wilderness areas are necessary for fire
prevention and watershed protection consistent with wilderness values,
including best management practices for fire presuppression and fire
suppression measures and techniques.
(b) INCORPORATION INTO FOREST PLANNING.—Any special
provisions contained in the management plan for the Ventana Wilderness
12
and Silver Peak Wilderness pursuant to subsection (a) shall be
incorporated into the management plan for the Los Padres National Forest.
2.6. Los Padres National Forest Management Plan (LPNF Management Plan)
Consistent with the Wilderness Act of 1978 and the Wilderness Act of 2002, the USFS
prepared the LPNF Management Plan. An EIS and a ROD was adopted for the LPNF
Management Plan in April 2006. The ROD includes the following language to describe the
overall intent of the plan:
[W]e will be doing fuels work in the Wildland/Urban Interface (WUI)
Defense and Threat zones for community protection. In these areas, the
emphasis is on vegetation treatments that are expected to create conditions
allowing fire fighters to work safely in the area. Wildlife habitat
requirements are still an emphasis. However, to be absolutely clear, the
protection of human life and property is our highest priority. While we do
the work in the WUI Defense and Threat zones, we will try to maintain
habitat in a condition that will support the species that live there, but we
will meet the criteria for community defense. If there is a trade-off,
human life and property will be the priority.14
The LPNF Management Plan describes the WUI and WUI zones as follows:
There are extensive areas within and adjacent to the national forests of
southern California meeting the definition of Wildland/Urban Interface
(WUI) as described in the Healthy Forests Restoration Act of 2003. WUI
(as defined by the Act) is a variable width … as defined in individual
community fire protection plans. This forest plan further identifies a
direct protection zone (WUI Defense Zone) and an indirect protection
zone (WUI Threat Zone) that fall within the broader definition of WUI. A
WUI Defense Zone is the area directly adjoining structures and evacuation
routes that is converted to a less-flammable state to increase defensible
space and firefighter safety. The WUI Threat Zone is an additional strip
of vegetation modified to reduce flame heights and radiant heat. The
Threat Zone generally extends approximately 1 1/4 miles out from the
Defense Zone boundary. Yet, actual extents of Threat Zones are based on
fire history, local fuel conditions, weather, topography, existing and
proposed fuel treatments, and natural barriers to fire and community
protection plans, and therefore could extend well beyond the 1 1/4 mile.
The two zones together are designed to make most structures more
defendable.15
14 Record of Decision, Los Padres National Forest Land Management Plan, page 11
15 Appendix K, Guidelines for Development and Maintenance of WUI Defense and Threat Zones, page 81 in Part
3, Design Criteria for Southern California National Forests, of the Land Management Plan [for the Los Padres
National Forest, 2005].
13
Thus, the LPNF Management Plan provides for fire presuppression measures in WUI
areas, where the WUI areas are defined in the MCCWPP and local CWPPs, including WUI that
is within the national forest.
Moreover, the EIS for the LPNF Management Plan analyzed impacts from constructing
fuelbreaks at distances up to 7.5 miles from structures, or more, depending upon the distance fire
may burn in the area during a 24 hour period (calling this area the "WUI environment"):
Fuelbreak construction and maintenance … usually would occur outside
the Defense zones, in both the WUI Threat zone and in the WUI
environment (a distance of up to 7.5 miles from developments, or the
distance that fires may burn in a 24-hour period during normal summer
conditions).16
The LPNF Management Plan includes fire and fuel management planning. Forest Goal
1.2 discusses community protection through vegetation treatment in the WUI and strategically
located fuelbreaks and associated burns. The LPNF Management Plan also states that existing
fuelbreaks are to be maintained using prescribed fire, fireline explosives, grazing, herbicide or
mechanical methods.17 As explained above, such measures in the LPNF Management Plan are
allowed in wilderness (it is specifically mandated), pursuant to the wilderness acts and the
express intent of Congress, to the extent they are needed to protect communities and watersheds
from wildfire.
3. National Environmental Policy Act (NEPA)
Any proposed fuel treatment projects on federal land or requiring federal discretionary
approval will require compliance with NEPA. Fuel reduction treatments on non-federal land that
do not use federal funding and do not require federal discretionary approval generally do not
require NEPA review. If NEPA review applies, projects implementing a fuel reduction
recommendation in a CWPP on Federal land, that is within a WUI, or within 1.5 miles of an at-
risk community, are afforded expedited NEPA review under the HFRA.
Moreover, fuel reduction treatments recommended for USFS and BLM land in a CWPP
must be considered in the NEPA analysis by the USFS or BLM as an alternative to the agency's
proposed project. As provided by the HFRA, if a federal fuel reduction project is within a WUI,
but more than 1.5 miles from the at-risk community's boundary, the USFS and BLM are required
to consider only one alternative other than the proposed project.18 If the fuel reduction project is
within 1.5 miles of the boundary of the at-risk community, the USFS and BLM are not required
to consider any alternative to the proposed project. This expedited NEPA process does not apply
to certain fuel reduction treatments within wilderness areas. As discussed previously, the USFS
prepared the LPNF Management Plan and an associated EIS, and a ROD was issued in April
16 Final Environmental Impact Statement, Volume 1, Land Management Plan [for the Southern California National
Forests], page 315,
17 See, page 22, Los Padres National Forest Land Management Plan, Part 2, Los Padres National Forest Strategy.
18 Note that without this provision, 2 or more alternatives must be considered, one of which must be a "no action"
alternative.
14
2006. The key community protection factors in the ROD for the LPNF Management Plan are
listed below:19
 Emphasizes the protection of lives and property;
 Includes the flexibility to adjust WUIs according to CWPPs; and
 Retains access.
As noted above, the LPNF Management Plan also discusses the maintenance of existing
fuelbreaks using prescribed fire, fireline explosives, grazing, herbicides or mechanical methods.
Herbicide use may delay need for mechanical treatment, especially when there is a diminished
workforce. Most of the fuelbreaks are in high-hazard chaparral areas and are designed to limit
wildland fire size and provide firefighter access and improve firefighter safety. A few of the
fuelbreaks are in coniferous forest and serve to limit fire spread from or towards communities or
timber stands in poor condition. Most of the existing fuelbreaks are on ridgetops or along
roads.20 The potential environmental impacts associated with the following activities were fully
analyzed in the EIS and, therefore, comply with NEPA: (1) the establishment of WUIs, (2) fuel
reduction activities, and (3) the maintenance of existing fuelbreaks in the LPNF, as described in
the LPNF Management Plan.
The Departments of Agriculture and Interior enacted categorical exclusions to NEPA for
hazardous fuel reduction activities and rehabilitation activities for lands and infrastructure
impacted by fires or fire suppression.21 The categorical exclusions are limited to (1) those
activities identified through a collaborative framework as described in the 10-Year
Comprehensive Strategy Implementation Plan; (2) fuel reduction activities that are within a
WUI, or, if outside the WUI, in Condition Classes 2 or 3 in Fire Regime Groups I, II, or III; (3)
hazardous fuels reduction activities using fire, limited to 4,500 acres; (4) mechanical hazardous
fuels reduction activities, limited to 1,000 acres; (5) fuel reduction and rehabilitation activities
that are not in wilderness areas or where they would impair the suitability of wilderness study
areas for preservation as wilderness; and (6) fire rehabilitation activities of not more than 4,200
acres.
4. Federal Endangered Species Act (ESA)
In accordance with the ESA, fuel reduction activities proposed in the MCCWPP must
avoid a take of federally listed threatened or endangered species, or, if a take cannot be avoided,
the take must be authorized pursuant to the ESA. The USFWS has the authority to expressly
authorize the take of threatened or endangered species or impacts to their critical habitat
incidental to fire prevention/protection activities. Such authorization may be received pursuant
to a memorandum of understanding between the USFWS, fire authorities, and other interested
entities, as demonstrated in the memorandum of understanding (MOU) executed by and between
USFWS, the California Department of Fish and Game (CDFG), CAL FIRE and other fire
19 Record of Decision, Los Padres National Forest Land Management Plan, page 5.
20 See, Los Padres National Forest Land Management Plan, Part 2 Los Padres National Forest Strategy, page 22.
21 See, Federal Register, Vol. 68, No. 108, June 5, 2003.
15
agencies and districts for fuel reduction activities in San Diego County. The purpose of San
Diego County's memorandum of understanding (San Diego MOU) is,
[T]o establish guidelines by which the CDF, Fire Chiefs and the Districts
can continue to protect lives and property from the threat of fire by
requiring the abatement of flammable vegetation pursuant to State Law,
County and District ordinances and Cities' municipal codes and to
establish a cooperative mechanism whereby the [US Fish and Wildlife]
Service and [the] Department [of Fish and Game] may assess, minimize,
and help account for potential adverse impacts to sensitive species and
habitats resulting from vegetation abatement activities.22
In addition to creation of defensible space, the San Diego MOU states:
The management purposes for which this San Diego MOU is issued are:
***
4. Any measures as deemed necessary by the Fire Chief and in
accordance with the Guideline section of this MOU.
The San Diego MOU also provides in section IV:
Property owners, their lessees, [CAL FIRE], fire districts and cities shall
not be required to perform biological surveys as a condition precedent to
performance of the fire protection activities established by the guidelines
set forth in Section 1.
Because the MCCWPP aims to ensure that wildfire fuel reduction work that is needed to
protect lives, property or the environment, in that order of priority, can be achieved with as little
regulatory hindrance as possible, the MCCWPP recommends that a similar MOU be entered into
by and between applicable regulatory agencies to allow the take of listed species and impacts to
critical habitats incidental to the fuel reduction activities described in the MCCWPP and in local
CWPPs, without requiring biological surveys, incidental take permits, mitigation measures,
conservation plans, or other requirements as a condition to performance of such activities.
B. Applicable State Laws
1. California Constitution
Article 1, Section 1 of the California Constitution reads as follows:
All people are by nature free and independent and have inalienable rights.
Among these are enjoying and defending life and liberty, acquiring,
possessing, and protecting property, and pursuing and obtaining safety,
happiness, and privacy.
22 San Diego MOU can be found at the following link:
http://www.co.san-diego.ca.us/dplu/docs/MemoofUnder.pdf
16
While no rights are absolute, fundamental rights such as the rights to defend life, protect
property, and pursue and obtain safety, may be infringed only to the minimum extent necessary
to promote a compelling government interest. The MFSC recognizes that wildfire fuel
overgrowth is a threat to lives, property and the environment, and seeks to help residents of
hazardously overgrown areas in Monterey County exercise their right to defend their lives,
protect their property, and pursue and obtain safety by enabling them to complete wildfire fuel
reduction work and provide for emergency ingress and egress with the least regulatory hindrance
permissible under law.
2. Division 4 of California Public Resources Code (PRC) – Forests, Forestry and
Range and Forage Lands
2.1 Title 14 CCR 1299 and Defensible Space Guidelines
In 2006, the Board of Forestry and Fire Protection, which a government-appointed
body within CAL FIRE, promulgated a regulation to implement the defensible space provisions
of PRC section 4291. The regulation was codified in Title 14, section 1299 of the California
Code of Regulations (14 CCR 1299).
14 CCR 1299(b) provides the following specific mandatory language: "Any
vegetation fuels identified as a fire hazard by the fire inspection official of the authority having
jurisdiction shall be removed or modified provided it is required by subsection (a)(1) & (a)(2)."
Subsections (a)(1) and (a)(2) state as follows:
(a) A person that owns, leases, controls, operates, or maintains a building
or structure in, upon, or adjoining any mountainous area, forest-covered
lands, brush-covered lands, grass-covered lands, or any land that is
covered with flammable material, and is within State Responsibility Area,
shall do the following:
(1) Within 30 feet from each building or structure maintain a firebreak by
removing and clearing away all flammable vegetation and other
combustible growth pursuant to PRC § 4291(a). Single specimens of trees
or other vegetation may be retained provided they are well-spaced, well-
pruned, and create a condition that avoids spread of fire to other
vegetation or to a building or structure.
(2) Within the 30 feet to 100 feet zone (Reduced Fuel Zone) from each
building or structure (or to the property line, whichever is nearer to the
structure), provide a fuelbreak by disrupting the vertical and/or horizontal
continuity of flammable and combustible vegetation with the goal of
reducing fire intensity, inhibiting fire in the crowns of trees, reducing the
rate of fire spread, and providing a safer environment for firefighters to
suppress wildfire pursuant to PRC § 4291(b).
Subsection (c) broadens and adds flexibility to CAL FIRE's authority by stating the
following:
17
Within the intent of the regulations, the fire inspection official of the
authority having jurisdiction may approve alternative practices which
provide for the same practical effects as the stated guidelines. (Emphasis
added.)
The mandatory language provided in 14 CCR 1299 does not provide or allow for any
discretion by any other agency to prohibit or disapprove the defensible space activities required
under 14 CCR 1299. That is, the creation of defensible space is an absolute requirement and not
subject to any discretionary approval.
14 CCR 1299(c) also references a guidance document for implementation of this
regulation, which is entitled, General Guidelines for Creating Defensible Space (Guidelines), as
published by the Board of Forestry by resolution adopted on February 8, 2006. The Guidelines
provide criteria intended to instruct individuals and fire officials on acceptable ways to comply
with 14 CCR 1299, and are incorporated into section 14 CCR 1299 by reference. See Appendix
J for the Guidelines.
2.1.1 California Environmental Quality Act (CEQA) Review of 14 CCR
1299 and Guidelines
The Board of Forestry considered adoption of 14 CCR 1299 and its
associated Guidelines a "project" subject to CEQA (Project), and the scope of the
CEQA review was the Project's ultimate effect on the environment. Generally,
CEQA defines the term "project" as an activity carried out, supported by, or
authorized by a public agency, "which may cause either a direct physical change
in the environment, or a reasonably foreseeable indirect physical change in the
environment. ..."23 CEQA is discussed further in Section 3.3.2.4 of this
MCCWPP.
CAL FIRE24 is the lead agency for the Project, because it has the principal
responsibility for carrying out or approving the Project. CAL FIRE, as the lead
agency, is responsible for preparing the appropriate CEQA review for the
Project.25
An initial CEQA review26 concluded that the Project was categorically
exempt from CEQA. This initial review considered impacts to water quality, fish,
wildlife and plant habitat, and aesthetic settings. The Board of Forestry then
published a Notice of Public Hearing on January 24, 2006. As part of the Notice,
the Board of Forestry discussed the possibility that the Project may fall within
exceptions to the categorical exemption due to the Project's potential to cause
significant adverse environmental effects.
23 PRC section 21065; 14 CCR 15378(a).
24 The Board of Forestry is a government-appointed body within CAL-FIRE.
25 See, PRC section 21067; 14 CCR 15050.
26 Initial Statement of Reasons, published on October 28, 2005.
18
CAL FIRE then conducted further, more detailed environmental review of
the Project's "potential significant effects to arthropod species and invasion [sic]
native plants from fuel modification, air quality impacts, cumulative effects of
treatment, historical or archeological impacts, significant effects from unusual
circumstances, and Scenic Highways."27 It is important to note that CEQA does
not require findings of the nonexistence of each of the exceptions to a categorical
exemption. Rather, where there is some information or evidence in the record
that the project might have a significant environmental effect, CEQA requires the
lead agency to consider the issue of significant effects and cumulative impacts of
a proposed project in determining whether the project is exempt from CEQA.28
The preliminary environmental review process included consultations with
various responsible agencies.29 For example, the Board of Forestry consulted
with the CDFG to evaluate the Project's potential to impact ground cover and
understory habitats. Upon consultation with the CDFG, the Board of Forestry
concluded as follows: "The clearing requirements under this law, regulation and
guidelines have been brought to the attention of the California Department of Fish
and Game, the responsible agency to [sic] for considering effects of regulations
proposed by the Board of Forestry on the state's fish and wildlife resources. The
agency has reply [sic] that the activity is not of concern to CDFG staff."30
The Board of Forestry noted in its Public Comment and Preliminary
Response that the Project does not relieve landowner responsibility for complying
with other environmental protection laws such as the ESA and Migratory Bird
Treaty Act. However, in discussing a "take" issue associated with soil
disturbance in impaired watersheds, the Board of Forestry concluded the
following: "Treatments within riparian zone, particularly for watercourses listed
… as impaired … is determined by the [Forestry] Board not to be a Take, as the
term means the actual harm to a species, not a general degradation of habitat
unless that degradation has a direct adverse impact on a species." To support this
conclusion, the Board of Forestry discussed recent case law (although it did not
cite the specific case) where challenges to projects based on a "take" of critical
habitat were overturned because no harm to a species was demonstrated.31
Upon completing the preliminary environmental review, the Board of
Forestry determined the Project to be categorically exempt under CEQA under the
Class 4(i) exemption, minor alterations to land, water, or vegetation. Subsection
(i) states as follows:
Fuel management activities within 30 feet of structures to reduce
the volume of flammable vegetation, provided that the activities
27 Page 6, Notice.
28 See, Association for Protection etc. Values v. City of Ukiah, 2 Cal. App. 4th 720, 732.
29 Public Comment and Preliminary Response, dated January 11, 2006.
30 Page 19, Public Comment and Preliminary Response.
31 Pages 42-43, Public Comment and Preliminary Response.
19
will not result in the taking of endangered, rare, or threatened plant
or animal species or significant erosion and sedimentation of
surface waters. This exemption shall apply to fuel management
activities within 100 feet of a structure if the public agency having
fire protection responsibility for the area has determined that 100
feet of fuel clearance is required due to extra hazardous fire
conditions.
The Board of Forestry also concluded that the Project does not fall within
an exception to the categorical exemption.
The Board of Forestry further determined that the proposed activities in 14
CCR 1299 and the Guidelines are necessary "to prevent or mitigate an
emergency." The Board of Forestry stated "that an emergency exists and the
activity proposed is necessary to prevent or mitigate forest fire emergencies."32
Using this basis, the Board of Forestry referenced PRC section 21080(b)(4).
Section 21080 lists "specific actions necessary to prevent or mitigate an
emergency" as an exemption to the environmental review requirements of the
PRC's environmental quality division.
At the time of the Board of Forestry's adoption of the Guidelines on
February 8, 2006, the Board of Forestry deliberated on the issue of CEQA and
concluded not only that the categorical exemption applies, but also that the
Project "is consistent with the CEQA statutory exemption under section
21080(b)(4) specifying that actions [are] necessary to prevent or mitigate an
emergency."33
2.1.2 14 CCR 1299 and Guidelines – CEQA Determination
The Board of Forestry concluded that the activities proposed pursuant to
14 CCR 1299 and the Guidelines are categorically exempt, and that an exception
to the categorical exemption does not apply. The Board of Forestry also
concluded that an emergency exists, that the Project is necessary to avoid the
emergency, and that the Project is exempt from environmental review under a
statutory exemption and under PRC 21080.
It is important to note that if a project is subject to a categorical
exemption, no formal environmental evaluation is required.34 An activity that is
categorically exempt may be implemented without any CEQA compliance
whatsoever.35
32 Page 8, Notice.
33 Item 9 of Meeting Minutes.
34 City of Pasadena v. State (1993) 14 CA4th 81.
35 Association for Protection of Envrt'l Values v. City of Ukiah (1991) 2 CA4th 720, 726.
20
Other agencies such as Monterey County can be considered a "responsible
agency" for the Project's CEQA review. Responsible agencies are bound by
certain decisions made by the lead agency, including the decision on whether an
Environmental Impact Report (EIR) should be prepared for a proposed project.36
Once the lead agency has acted, the responsible agencies generally rely on the
lead agency's CEQA conclusion and ordinarily are not allowed to prepare a
separate EIR or negative declaration.37 Here, CAL FIRE, as the lead agency,
made the CEQA determination that can be relied upon by Monterey County. If
the County decides to allow the fuel modification activities described in 14 CCR
1299 and the Guidelines, no further review is required by CEQA for that decision.
2.2 Public Resources Code Section 4291 (PRC 4291)
PRC 4291 requires that any person who owns, leases, controls, operates, or
maintains a building or structure in, upon, or adjoining a mountainous area, forest-covered lands,
brush-covered lands, grass-covered lands, or land that is covered with flammable material, shall
maintain defensible space of 100 feet from each side and from the front and rear of the structure,
or as further provided in PRC 4291, but not beyond the property line unless allowed by state law,
local ordinance, or regulation, and with the consent of the adjacent landowner.
The statute provides that the amount of fuel modification necessary shall take into
account the flammability of the structure as affected by building material, building standards,
location, and type of vegetation.
PRC 4291 provides that a distance greater than 100 feet may be required by state
law, local ordinance, rule, or regulation, with limitations on requiring fuel modification beyond
the property line, including consent by the adjacent landowner.
PRC 4291 also provides that an insurance company that insures an occupied
dwelling or occupied structure may require a greater distance if a fire expert, designated by the
Director of Forestry and Fire Protection, provides findings that such fuel reduction is necessary
to significantly reduce the risk of transmission of flame or heat sufficient to ignite the structure,
and there is no other feasible mitigation measure possible to reduce the risk of ignition or spread
of wildfire to the structure. The greater distance may not be beyond the property line unless
allowed by state law, local ordinance, rule, or regulation. The statute also requires other fuel
reduction measures, such as a minimum distance of 10 feet between trees and the outlet of a
chimney or stovepipe.
PRC 4291 further provides that the Director of Forestry and Fire Protection may
authorize removal of vegetation that is not consistent with the standards of PRC 4291.
36 PRC section 21080.1(a); 14 CCR 15050(c).
37 Bakman v. Department of Transp. (1979) 99 CA3d 665.
21
According to People v. Rhoades,38 PRC 4291 is a regulatory measure designed to
preserve California's forests from uncontrolled wildland fires. Thus, fuel reduction pursuant to
PRC 4291 protects not only California's vegetated lands, but also structures from wildfires.
PRC section 4291.1 describes the penalties for PRC 4291 violations. Penalties
range from a fine of not less than $100, to not less than $500, depending upon the number of
violations during a five year period. PRC section 4291.1 also provides that under certain
conditions, CAL FIRE may contract to have fuel reduction work done and bill the person
convicted of the violation for the cost of the work.
3. California Coastal Act (CCA) and Local Coastal Programs
The California Coastal Commission (CCC), in partnership with coastal cities and
counties, plans and regulates the use of land in the coastal zone. The Coastal Coastal Act (CCA)
provides that land uses that meet its definition of "development"39 require a coastal development
permit (CDP) from either the CCC or the local government that has been delegated permitting
authority.40 As relevant here, the term "development" in the CCA includes the following
definition: "Development" means… the removal or harvesting of major vegetation …41
(Emphasis added.)
Monterey County has been delegated CDP permitting authority through the adoption
and certification of Local Coastal Programs (LCP). However, the CCC retains appellate
authority. The need for a CDP is reviewed against the policies of the certified LCP.
Monterey County has divided its portion of the coastal zone into four separate coastal
planning areas: (1) Big Sur, (2) North County, (3) Carmel, and (4) Del Monte Forest. Each
coastal planning area has its own coastal land use plan and coastal implementation plan.
When adopted and certified, these coastal plans underwent environmental review that was
the functional equivalent of CEQA, and CEQA review was therefore not required.42 The
following sections discuss these four coastal land use plans, which are in certified LCPs.
3.1 Big Sur Coast Land Use Plan (Big Sur LUP) and Implementation Plan
(Big Sur CIP)
As stated above, the term "development" in the CCA includes the removal
or harvesting of major vegetation. However, the Big Sur LUP expressly states that
certain vegetation removal activities will not be considered removal of major vegetation.
Because these certain vegetation removal activities are not considered removal of major
38 People v. Rhoades (1970) 12 Cal App 3d 720.
39 See, PRC section 30106 for the CCA's definition of development.
40 See, PRC sections 30106, 30101.5 and 30600(a).
41 PRC section 30106
42 The CCC obtained certification from the Secretary of Resources that its regulatory program is the functional
equivalent of CEQA in 1979, and the LCP approval process has been exempt from EIR requirements ever since.
Santa Barbara County Flower and Nursery Growers Association, Inc. v. County of Santa Barbara, (2004) 121
Cal.App.4th 864; Title 14 CCR section 15251, subdivision (f); Title 14 CCR section 15265.
22
vegetation, these activities do not fall within the CCA's definition of "development" and
no CDP is required to implement them.
Big Sur LUP Policy 5.4.2.13 states as follows:
A coastal development permit must be obtained for the removal of trees
and other major vegetation. However, in the Big Sur Coast area, the
following will not be considered as removal of major vegetation:
a. Removal of non-native or planted trees, except where this would result
[in] the exposure of structures in the critical viewshed;
b. Removal of hazardous trees which pose an imminent danger to life or
property, or threaten contagion of nearby forested areas, subject to
verification by the County or California Department of Forestry;
c. Thinning of small (less than 12" diameter) or dead trees from density
[sic] forested areas, especially as needed to reduce unsafe fuel
accumulations adjacent to existing occupied buildings; and
d. Prescribed burning, crushing, lopping or other methods of brush
clearing which do not materially disturb underlying soils.
(Emphasis added.)
The exception to the exemption provided in subsection (a) (i.e., critical
viewshed) indicates that the drafters intended to call out exceptions where they apply.
Here, Policy 5.4.2.13 did not call out any other exception to the exemption, such as
vegetation removal in environmentally sensitive habitat areas. Thus, the only applicable
exception to this exemption can be interpreted to be the removal of non-native or planted
trees that would result in the exposure of structures in the critical viewshed.
The Big Sur CIP mimics the language of Policy 5.4.2.13 in its Forest Resources
Development Standards (Big Sur CIP section 20.145.060.) The Big Sur CIP's Forest Resources
Development Standards provide development standards for the protection and maintenance of
Big Sur's forest resources. Section 20.145.060 of the Forest Resources Development Standards
states as follows: "A coastal development permit must be obtained for the removal of trees and
other major vegetation with the following exceptions…." (Emphasis added.) The same
subsections (a through d) provided in Policy 5.4.2.13 of the Big Sur LUP follows that sentence.43
The following paraphrases the activities that are not "removal of major
vegetation" under Big Sur LUP Policy 5.4.2.13 and the Big Sur CIP's Forest Resources
Development Standards, and therefore, are not classified as "development" in the Big Sur coastal
planning area: 1) the removal of nonnative, planted, and hazardous trees; (2) thinning of live
trees that are 12 inches or less in diameter, and all dead trees, in densely forested areas; and (3)
brush clearance which does not materially disturb the underlying soil. Essentially all of the fuel
modification activities needed to create defensible space, and most other fuel reduction work
43 To the extent the language in the CIP fails to implement the language in the LUP, the language in the LUP
controls.
23
described in the MCCWPP, can be accomplished in a manner which falls within the above
described CDP exemptions.
Because these fuel modification activities are specifically removed from the
CCA's definition of "development," a CDP cannot be required for performing these activities.
Moreover, the CCA's definition of "development" refers to "removal" of vegetation. For this
reason, selective trimming and limbing of vegetation that leaves roots intact should not require a
CDP. In summary, the Big Sur LUP and Coastal Implementation Plan may reasonably be
interpreted not to require a CDP for removal or trimming of vegetation for the creation of
defensible space and other wildfire fuel reduction measures when accomplished in the manner
described in the stated CDP exemptions.
3.2 North County Land Use Plan (North County LUP) and
Implementation Plan (North County CIP)
Similar to the exemption to CDP requirement provided in the Big Sur LUP and
CIP, North County CIP Policy 20.144.050.A.1 provides the following exceptions to the CDP
requirement for major vegetation removal activities as they relate to fuel mitigation:
A coastal development permit must be obtained for the removal of trees
and other major vegetation with the following exceptions:
a. Removal of non-native or planted trees, except where this would be
ridgeline tree removal as per Section 20.144.050.D.8 or where the
trees are considered to be of significant or landmark status, as defined
in Section 20.144.050.D.1;
b. Removal of hazardous trees which pose an immediate danger to life or
structures;
c. Removal of native trees less than 12" diameter when measured at
breast height, or removal of oak trees less than 6" in diameter
measured 2 feet above the ground, or removal of marine trees less than
6" in diameter measured at breast height; and prescribed burning,
crushing, lopping, or other methods of clearing brush which do not
materially disturb underlying soils.
(Emphasis added.)
The exceptions to the CDP exception provided in subsection (a) (i.e., ridgeline trees or
trees of significant or landmark status) indicate that the drafters intended to call out exceptions
where they apply. Here, section 20.144.050.A.1 did not call out any other exception to the
exemption, such as major vegetation removal in environmentally sensitive habitat areas. Thus,
the only applicable exceptions to this CDP exception appear to be the removal of ridgeline trees
or trees of significant or landmark status.
The above listed vegetation removal activities apply to essentially all of the fuel
modification activities needed to create defensible space, and for most other fuel reduction work
described in the MCCWPP. The North County CIP may reasonably be interpreted not to require
a CDP for removal or trimming of vegetation for the creation of defensible space and other
24
wildfire fuel reduction measures when accomplished in the manner described in the stated CDP
exception.
3.3 Carmel Area Land Use Plan (Carmel LUP) and Implementation Plan
(Carmel CIP)
Similar to the provisions in the Big Sur and North County CIPs, Carmel CIP
Policy 20.146.060.A.1 provides exceptions to the CDP requirement for major vegetation removal
activities as they relate to fuel mitigation:
A coastal development permit must be obtained for the removal of trees
and other major vegetation with the following exceptions:
a. Removal of non-native or planted trees, except where this
would result in the exposure of structures in the critical view
shed area; where defined as habitat; where previously protected
by coastal permit or forest management plan or
scenic/conservation easement;
b. Removal of hazardous trees which pose an immediate danger
to life or structures;
c. Thinning of small (less than 12" in diameter) or dead trees
from densely forested areas, especially as needed to reduce
unsafe fuel accumulations adjacent to existing occupied
buildings;
d. Prescribed burning, crushing, lopping or other methods of
brush clearing which do not materially disturb underlying soils.
(Emphasis Added.)
The exceptions to the CDP exception provided in subsection (a) indicate that the
drafters intended to call out exceptions where they apply. Thus, the only applicable exceptions
to this CDP exception can be interpreted to be as follows: exposure of structures in the critical
view shed area; where defined as habitat; and where previously protected by coastal permit or
forest management plan or scenic/conservation easement.
The above listed vegetation removal activities apply to essentially all of the fuel
modification activities needed to create defensible space, and for most other fuel reduction work
described in the MCCWPP. The Carmel CIP may reasonably be interpreted not to require a
CDP for removal or trimming of vegetation for the creation of defensible space and other
wildfire fuel reduction measures when accomplished in the manner described in the stated CDP
exception.
25
3.4 Del Monte Forest Land Use Plan (Del Monte LUP) and
Implementation Plan (Del Monte CIP)
Similar to the provisions in the Big Sur, North County, and Carmel CIPs, Del
Monte CIP Policy 20.147.050.A.1 provides exceptions to the CDP requirement for major
vegetation removal activities as they relate to fuel mitigation:
A coastal development permit must be obtained for the removal of trees
and other major vegetation with the following exceptions:
a. Removal of non-native or planted trees, except where this would result
in the exposure of structures in the critical viewshed area; where
defined as habitat; where previously protected by coastal permit or
forest management plan or scenic/conservation easement;
b. Removal of hazardous trees which pose an immediate danger to life or
structures or where a diseased tree is determined by a qualified
professional forester to represent a severe and serious infection hazard
to the rest of the forest; and
c. Except for Monterey Cypress in its indigenous range, thinning of
small (less than 12" in diameter) or dead trees from densely forested
areas, especially as needed to reduce unsafe fuel accumulations
adjacent to existing occupied buildings; and
d. Prescribed burning, crushing, lopping or other methods of brush
clearing which do not materially disturb underlying soils.
(Emphasis added.)
The exceptions to the CDP exception provided in subsections (a) and (c) indicate
that the drafters intended to call out exceptions where they apply. Thus, the only applicable
exceptions to this CDP exception can be interpreted to be as follows: exposure of structures in
the critical view shed area; where defined as habitat; where previously protected by coastal
permit or forest management plan or scenic/conservation easement; and for Monterey Cypress in
its indigenous range.
The above listed vegetation removal activities apply to essentially all of the fuel
modification activities needed to create defensible space, and for most other fuel reduction work
described in the MCCWPP. The Del Monte CIP may reasonably be interpreted not to require a
CDP for removal or trimming of vegetation for the creation of defensible space and other
wildfire fuel reduction measures when accomplished in the manner described in the stated CDP
exception.
4. California Environmental Quality Act (CEQA)
A public agency must comply with the California Environmental Quality Act (CEQA)
when the agency undertakes an activity defined by CEQA as a "project." PRC section 21065
defines a "project" subject to CEQA as follows:
26
"Project" means an activity which may cause either a direct physical change in the
environment, or a reasonably foreseeable indirect physical change in the
environment, and which is any of the following:
(a) An activity directly undertaken by any public agency.
(b) An activity undertaken by a person which is supported, in whole or in part,
through contracts, grants, subsidies, loans, or other forms of assistance from one
or more public agencies.
(c) An activity that involves the issuance to a person of a lease, permit, license,
certificate, or other entitlement for use by one or more public agencies.
If the activity does not meet the definition of a "project" above, the California
Environmental Quality Act (CEQA) does not apply and CEQA analysis is not required. Even if
the activity qualifies as a project, CEQA analysis may not be required. The legislature has
exempted many types of projects from CEQA by statute. Because CEQA is a legislative
enactment, the legislature is free to create exemptions regardless of their consistency with
CEQA's environmental purposes.44 Statutory exemptions are enacted to lift the burden of
environmental review from specified classes of projects that may have significant effects;
limiting a statutory exemption to projects that will not adversely affect the environment would
defeat the purpose of the exemption.45
CEQA also requires the Secretary of the Resources Agency to designate in the CEQA
Guidelines classes of projects that the Secretary has found do not have a significant effect on the
environment.46 These exemptions are generally referred to as "categorical exemptions."47 Public
agencies may not require preparation of an environmental document for a project that is
categorically exempt unless the activity falls within one of the exceptions to the categorical
exemption.48
4.1 MCCWPP Not a Project Subject to CEQA
The MCCWPP is a voluntary guideline and comprises recommendations by the
community to various governmental agencies. The MCCWPP does not legally commit any
agency to a specific course of action, including by the act of signing the MCCWPP. The
MCCWPP is not a project subject to CEQA or NEPA.
4.2 Implementation of MCCWPP
Implementation of vegetation management activities recommended in the
MCCWPP might be a project subject to CEQA, unless:
44 See Napa Valley Wine Train, Inc. v. PUC (1990) 50 C3d 370, 381.
45 See, e.g., Surfrider Found. V. California Coastal Commission (1994) 26 CA4th 151.
46 PRC 21979(b)(1), 21084(a).
47 14 CCR 15354.
48 14 CCR 15300.2 & 15300.4
27
 An environmental review has already been completed that can be relied upon by
an agency or agencies,
 A statutory or categorical exemption applies to the activity, or,
 The project does not involve any discretionary approval by a public agency, does
not involve public funding, and will not be carried out by a public agency.
4.2.1 Monterey County a Responsible Agency
As discussed in above, CAL FIRE promulgated a regulation necessary to
implement a legislative amendment to PRC 4291. The implementing regulation is
found at 14 CCR 1299. 14 CCR 1299 includes, by reference, a document entitled,
General Guidelines for Creating Defensible Space (Guidelines).49 The Guidelines
provide criteria intended to instruct individuals and fire officials on acceptable
ways to comply with PRC 4291. Hereafter, 14 CCR 1299 and the Guidelines,
together, are called the Defensible Space Regulations.
CAL FIRE considered adoption of the Defensible Space Regulations a
"project" subject to CEQA (Project), and the scope of the CEQA review is the
Project's ultimate effect on the environment, including creation of defensible
space throughout California, consistent with the Defensible Space Regulations.
Accordingly, CAL FIRE conducted an environmental review of the ultimate
effect of the Project on the environment. Upon completing its initial review, CAL
FIRE concluded that the activities proposed pursuant to the Defensible Space
Regulations are categorically exempt, and that an exception to the categorical
exemption does not apply. This categorical exemption is discussed further above.
CAL FIRE also concluded that an emergency exists; that the Project is necessary
to avoid the emergency; and that the Project is exempt from environmental review
under a statutory exemption and under PRC section 21080. This statutory
exemption is discussed further below.
CAL FIRE is the lead agency for the Project because it has the principal
responsibility for carrying out or approving the Project. Monterey County, on the
other hand, can be considered a "responsible agency" for the Project's CEQA
review. Responsible agencies are bound by certain decisions made by the lead
agency, including the decision on whether an EIR should be prepared for a
proposed project.50 Once the lead agency has acted, the responsible agencies
49 See, Title 14 CCR 1299(d), which reads, "Guidance for implementation of this regulation is contained in the
publication: 'General Guidelines for Creating Defensible Space' as published by the Board of Forestry and Fire
Protection by resolution adopted on February 8, 2006." Also see the Initial Statement of Reasons, which states, "The
guideline document describes criteria for conformance with proposed regulation and existing statute. This document
is incorporated by reference pursuant to Title 1, California Code of Regulations (CCR), Regulation General
Provisions, and section 20."
50 PRC section 21080.1(a); 14 CCR 15050(c).
28
generally rely on the lead agency's CEQA conclusion and ordinarily are not
allowed to prepare a separate EIR or negative declaration.51
That is, CAL FIRE, as the lead agency, made the CEQA determination
which can be relied upon by Monterey County. If the County decides to allow the
fuel modification activities described in the Defensible Space Regulations, no
further review is required by CEQA for that decision.
4.2.2 Statutory Exemption
PRC section 21080(b)(4) and 14 CCR 15269(c) provide a statutory
exemption for specific actions necessary to prevent or mitigate an emergency.
This statutory exemption may apply to mitigating hazardous fuel loads and work
needed to maintain emergency access.
As discussed in the coastal land use plans/local coastal programs, many
areas of Monterey County are hazardously overgrown and specific actions are
necessary to prevent or mitigate emergencies caused by wildfires. The statutory
exemption should apply to those areas of Monterey County that are hazardously
overgrown as determined by the Fire Authority Having Jurisdiction (FAHJ).
As discussed above, the authority to make this determination was granted
to the FAHJ under 14 CCR 1299(b), which provides the following mandatory
language:
Any vegetation fuels identified as a fire hazard by the fire
inspection official of the authority having jurisdiction shall be
removed or modified provided it is required by subsection (a)(1) &
(a)(2).
4.2.3 Categorical Exemption
The Class 4 categorical exemption, i.e., minor alteration to land, may
apply to fuel reduction and fire access maintenance activities. Class 4 activities
consist of minor public or private alterations in the condition of land, water,
and/or vegetation. As relevant to fuel mitigation activities, subsection (I) of Class
4 states as follows:
Fuel management activities within 30 feet of structures to reduce
the volume of flammable vegetation, provided that the activities
will not result in the taking of endangered, rare, or threatened plant
or animal species or significant erosion and sedimentation of
surface waters. This exemption shall apply to fuel management
activities within 100 feet of a structure if the public agency having
fire protection responsibility for the area has determined that 100
51 Bachman v. Department of Tramps. (1979) 99 CA3d 665.
29
feet of fuel clearance is required due to extra hazardous fire
conditions.
If a project is found by the lead agency to be subject to a categorical
exemption (which occurred with the Defensible Space Regulations), no formal
environmental evaluation is required.52 An activity that is determined to be
categorically exempt may be implemented without any further CEQA
compliance.53
5. California Endangered Species Act (CESA) and Native Plant Protection Act (NPPA)
The California Endangered Species Act (CESA)54 generally parallels the main
provisions of the federal Endangered Species Act and is administered by the CDFG. A lead
agency is required to consult with CDFG if any action it undertakes is likely to jeopardize the
continued existence of any endangered or threatened species.
The California Native Plant Protection Act (NPPA) was "enacted to preserve, protect
and enhance endangered or rare native plants of this state." The NPPA authorizes the California
Fish and Game Commission to designate species of native plants as endangered or rare. The
NPPA provides:
The NPPA grants authority to the Commission to adopt regulations governing the
taking of any endangered or rare native plants.55 However, the NPPA also includes specific
provisions that provide exclusions from the NPPA regulation.
Section 1912 of the Fish and Game Code states that the provisions of this chapter "shall
not be applicable to emergency work necessary to protect life or property."56 As stated above,
CAL FIRE, in promulgating the Defensible Space Regulations, determined that an emergency
exists and that the fuel modification activities proposed are necessary to prevent or mitigate this
emergency. Accordingly, the activities pursuant to the Defensible Space Regulations may be
considered emergency work and fall within the exclusion provision of Fish and Game Code
section 1912.
The NPPA also states:
[T]he provisions of this chapter are not intended and shall not be construed
as authorizing any public agency to mandate, prescribe, or otherwise
52 City of Pasadena v. State (1993) 14 CA4th 81.
53 Association for Protection of Evart's Values v. City of Ukiah (1991) 2 CA4th 720, 726.
54 Fish & Game Code section 2050, et seq.
55 California Fish & Game Code §1907(a).
56 Section 1912 includes the following notification requirement: "[N]notification by the person or agency
performing such emergency work shall be made to the department within 14 days of the commencement of such
work."
30
regulate management practices, including [among others] … clearing of
land for … fire control measures."57 (Emphasis added.)
Under the provisions of Fish and Game Code sections 1912 and 1913, emergency
work and land clearing for fire control measures are excluded from NPPA regulation. Fuel
modification activities to create defensible space and those proposed in the MCCWPP are land
clearing for fire control measures, and as such are excluded from the NPPA regulatory
requirements.
This interpretation is supported by the Attorney General's Published Opinion No. 98-
105.58 Former California Assembly member Keith Oberg requested the Attorney General's
opinion on the following question: "Under what circumstances may a landowner destroy a plant
on his property that is listed as threatened or endangered under the California Endangered
Species Act?" Opinion No. 98-105 cites section 2080 of CESA. Section 2080 states as follows:
No person shall import into this state, export out of this state, or take, possess,
purchase, or sell within this state, any species, or any part or product thereof,
that the commission determines to be an endangered species or a threatened
species, or attempt any of those acts, except as otherwise provided in this
chapter, the Native Plant Protection Act (Chapter 10 (commencing with
Section 1900) of this code), or the California Desert Native Plants Act
(Division 23 (commencing with Section 80001) of the Food and Agricultural
Code)). (Emphasis Added.)
Opinion No. 98-105 then cites the above mentioned NPPA provisions that provide the
exclusions from the NPPA regulations, concluding that threatened and endangered plants may be
destroyed59 by a landowner as authorized by CESA or NPPA. Opinion No. 98-105 concludes as
follows:
We thus conclude in answer to the … question that a landowner may destroy a
plant on his property that is listed as threatened or endangered under CESA
when … (7) incidental to specified emergency projects, or (8) incidental to …
the clearing of certain property under the provisions of NPPA.
Thus, the NPPA provides express allowance to take endangered and rare plant species for
the purposes of fire control measures, which provision may be applicable to fuel reduction work.
Further (as discussed previously), the emergency work exception may be applicable to fuel
reduction work in those areas determined by the FAHJ to be hazardously overgrown.
57 California Fish and Game Code §1913(a).
58 81 Ops. Cal. Atty. Gen. 222.
59 With reference to plants, the term "take" as used in section 2080 means to destroy. (§ 96 ["'Take' means … kill
…"]; see Department of Fish & Game v. Anderson-Cottonwood Irrigation Dist. (81 Ops. Cal. Atty. Gen. 222.)
31
V. Firebreaks, Fuelbreaks and Wilderness Discussion
A. Firebreaks
Comments to the January 2010 MCCWPP included concerns over the use of the term,
"firebreak" instead of the term "fuelbreak". Unpaved rural roads in Monterey County are
essentially the same as firebreaks except for their lack of strategic placement, and some
strategically located roads double as firebreaks (e.g., the North Coast Ridge Road). As with
unpaved roads, existing firebreaks may be maintained year round at low cost with little
environmental impact by use of suitable techniques. Miles of trails are maintained in Monterey
County each year, including in wilderness areas, some up to 4 feet wide and constructed much
like narrow firebreaks, with all vegetation removed. Though trails in wilderness serve relatively
few users and are typically for recreational use, a Ventana Firebreak located on the existing Big
Box Firebreak would serve to protect the lives and homes of thousands of residents in at-risk
communities around the LPNF. Firebreaks could also help protect the Monterey Peninsula's
tourist economy by helping protect Highway 1 south of Carmel from closure, and could help
protect Monterey County's wine grape economy from impacts by smoke taint.
B. Sierra Club’s Expert’s Support for Maintaining Existing Firebreaks
As part of the comments on the January 2010 MCCWPP,60 the Ventana Chapter of the
Sierra Club included as an exhibit, an opinion memo by Dr. Scott Stephens, Associate Professor of
fire Science at the University of California, Berkeley. Mr. Stephens stated in his memo the
following: "The CWPP specifies where existing fire and fuel breaks are located throughout the
county (Pg 72, 73, 74). Since these are already installed maintaining them into the future makes
sense. They can act as anchor points for fire suppression operations and safety areas for fire
fighters." As acknowledged by Dr. Stephens, the existing Big Box/Ventana Fuelbreak/Firebreak
should be maintained, before fire starts, and treatments should be provided on each side to help
ensure the fuelbreak/firebreak can be safely manned and effectively used during wildfires.
C. Use of Fuelbreaks
Fuelbreaks typically contain vegetation, though at reduced volume. Fuelbreaks are
generally maintained over substantially wider distance than firebreaks, depending upon such
factors as topography and vegetation type and density. Due to their vegetation, fuelbreaks are
less likely to stop the spread of fire, and are primarily used to slow fires and lower fire intensity,
making it safer for firefighters to be present on firebreaks during wildfires and for increasing
firebreak defensibility and effectiveness.
Fuelbreaks may be improved with heavy equipment to be firebreaks during fires, if time
allows and resources are available. During catastrophic events like the 2008 Lightning Siege in
California, which started over 2,000 fires statewide61 including the Basin Fire, availability of
resources can be problematic.
60 July 13, 2010 Letter to Monterey Fire Safe Council from Lippe Gaffney Wagner LLP.
61 http://www.fire.ca.gov/index_incidents_overview.php
32
D. Wilderness Expansions
The Ventana Wilderness was created in 1969 encompassing approximately 98,000 acres.62
The 1968 report from the Secretary of Agriculture to President Johnson on the proposed Ventana
Wilderness states, "The boundary of this proposed Wilderness is very important and has been
intentionally established wherever possible to allow the construction of peripheral fuelbreaks, and
fire control access. Approximately 70 percent of the boundary of this area would be located 250 feet
below the crest of the ridge to permit the machine construction of effective fuelbreaks."63 The
boundary of the Ventana Wilderness has been expanded four times, and now encompasses over
236,000 acres.
In 2002, wilderness boundaries in the Monterey Ranger District of the LPNF were moved in
twelve areas, in some locations to within 30 to 100 feet of roads. Some of the roads serve as escape
routes in event of fire and some double as firebreaks. In at least one location, wilderness was
expanded over the Big Box Firebreak. These 2002 wilderness expansions are said to have blocked
the USFS from conducting 8 out of 10 fuel reduction projects64 that were part of what was called the
Monterey Defensible Fuel Profile Zone. The Monterey Defensible Fuel Profile Zone was being
scoped in 2001, and was intended to make use of roads as escape routes safer during wildfires. The
Coast Ridge Road was such an escape route and is also part of the Big Box Firebreak.65 All of the
fuel reduction projects in the Monterey Defensible Space Fuel Profile Zone were outside wilderness
prior to 2002.66
During the Basin Fire in 2008, wilderness designation appears to have caused delays opening
portions of the Big Box Firebreak due to prohibitions against use of heavy equipment in wilderness
without approval from up the USFS's chain of command.67 In one critical location the Basin Fire
crossed over the Big Box Firebreak where wilderness was moved over the firebreak in 2002. Work
was started to improve the firebreak with handcrews, but not completed in time.68 After crossing the
Big Box Firebreak, the Basin Fire went on to threaten over 300 homes in the Palo Colorado, Bixby,
62 Public law 91-58, August 18, 1969.
63 90th Congress, 2d Session, House Document No, 292, Part 9.
64 Statement of former Executive Director of the MFSC who was active in 2001 during scoping of the Monterey
Defensible Fuel Profile Zone project.
65 The project scoping letter for the Monterey Defensible Fuel Profile Zone is included in Appendix K, which
states, "Trained specialists with the Forest Service are planning to apply fuels reduction treatments to establish
defensible fuel profile zones (DFPZs) within ten identified units that cover a total of approximately 18,760 acres.
Primary focuses for this project are travel corridors (roads and trails), campgrounds, National Forest System Lands
adjacent to private property, administrative sites, and existing firelines." Page 1, USFS project scoping letter, August
13, 2001.
66 "Forest Service personnel are preparing to conduct an analysis of the proposed project area within the boundary
of the Monterey Ranger District on selected lands outside the Ventana and Silver Peak Wilderness areas." Page 1,
USFS project scoping letter, August 13, 2001 (underline added), see Appendix K.
67 Statement of CAL FIRE official who worked on the Basin Fire.
68 USFS East Basin Complex Final Rehab Map (Rehab Map), showing a hand line (near helispot H-26) continuing
off from the dozer line where the Big Box Firebreak enters the Ventana Wilderness, at the location where wilderness
was expanded over the Big Box Firebreak in 2002 by the Condor Range and River Protection Act. The Basin Fire
crossed over this area before the Big Box Firebreak could be reopened with hand crews, where a dozer line veered to
bypass the wilderness.
33
Garrapata and Rocky Creek watersheds and was stopped at the sole backup firebreak on Bixby
Mountain.
VI. Recommendations
A. Recommendations to the Secretary of Agriculture
1. Maintain the Ventana Fuelbreak/Firebreak (Big Box Firebreak)
Recommendation: Reduce the risk to communities by maintaining the Ventana
Fuelbreak/Firebreak, and treatment on both sides of it, at all times, in a condition that will
result in a high probability that the fuelbreak/firebreak will serve to allow firefighters to work
safely in the area, to change fire direction and spread, to drop fire to the ground, and to stop
the spread of wildfire under adverse fire conditions. The width of treatment should be
determined utilizing such factors as fuel loads, topography, predominant winds, values at risk
and fire behavior modeling. To the extent the Ventana Fuelbreak/Firebreak and the
treatments on both sides of it are on non-federal land, this recommendation should be
construed as recommending that federal funds be made available for their maintenance (e.g.,
through grants). The location of the Ventana Fuelbreak/Firebreak is shown on the map in
Appendix B-7 by the line representing the Big Box Firebreak.
Rationale: The Big Box Firebreak was used to protect at-risk communities surrounding the
LPNF from the 178,000 acre Marble Cone Fire in 1977, the 86,000 acre Kirk Complex Fire
in 1999, and the 163,000 acre Basin Fire and 81,000 acre Indians Fire in 2008. The Basin
Fire burned on the west side of an 8 mile segment of the western portion of the Big Box
Firebreak, consuming 26 homes and 32 other structures in the Big Sur at-risk community,
and threatening approximately 300 homes in the Palo Colorado at-risk community.
Maintaining and defending the Ventana Fuelbreak/Firebreak and treatments on both sides of
it will reduce the threat of harm to firefighters and to the communities surrounding the Los
Padres National Forest. As noted in a Congressional committee report,69 "Due to the extreme
hazard of fires in the Los Padres National Forest" Congress has provided special management
language for wilderness areas in the Los Padres National Forest, including allowing pre-
suppression measures such as those recommended in this MCCWPP. 70 The recommendation
to maintain the Ventana Fuelbreak/Firebreak and its side-treatments before fire starts is to
help ensure they can be used effectively and safely without delay to stop the spread of fire, to
protect lives, property and the environment.
2. Maintain the Bixby Mountain Fuelbreak/Firebreak
Recommendation: Reduce the risk to communities by maintaining the Bixby Mountain
Fuelbreak/Firebreak, and treatments on both sides of it, at all times, in a condition that will
result in a high probability that the fuelbreak/firebreak will serve to allow firefighters to work
safely in the area, to change fire direction and spread, to drop fire to the ground, and to stop
the spread of wildfire under adverse fire conditions. The width of treatment should be
69 Senate Report 95-490 on H.R. 3454 (The Endangered American Wilderness Act of 1978), 95th Congress 1st
session October 11, 1977, Senate Committee on Energy and Natural Resources.
70 Section 3.3.1.2.2, quoting Senate Report 95-490 on H.R. 3454 (The Endangered American Wilderness Act of
1978), 95th Congress 1st session October 11, 1977, Senate Committee on Energy and Natural Resources.
34
determined utilizing such factors as fuel loads, topography, predominant winds, values at risk
and fire behavior modeling. This recommendation includes lands that may be acquired by
the USFS in the future, on which the Bixby Mountain Fuelbreak/Firebreak or its side-
treatments are located. To the extent the Bixby Mountain Fuelbreak/Firebreak or its side-
treatments are on non-federal land, this recommendation should be construed as
recommending that federal funds be made available for their maintenance (e.g., through
grants). The location of the Bixby Mountain Fuelbreak/Firebreak is shown on the map in
Appendix B-7 as the Bixby Mountain Firebreak.
Rationale: The Bixby Mountain Firebreak protected the Palo Colorado at-risk community
from the Basin Fire in 2008. This community contains almost half the residential population
in the greater Big Sur at-risk community. Much of the land on which the Bixby Mountain
Firebreak is located is currently in private ownership. However, the USFS has acquired land
in the area, including the 1,200 acre Brazil Ranch and about 460 acres of neighboring Rancho
Calera. A third ranch, Rancho Aguilla, makes up much of the remaining private land
between the LPNF and the Brazil Ranch, and much of the Bixby Mountain Firebreak is on
Rancho Aguilla. The Bixby Mountain Fuelbreak/Firebreak is the "backup" firebreak referred
to in the rationale for Section 9.1.1, which was used to stop the Basin Fire from burning into
the greater Palo Colorado area. As a result of the 2002 wilderness expansions the Bixby
Mountain Firebreak effectively became the only firebreak for wildfires burning north from
the Los Padres National Forest southeast of Bixby Mountain. Recommendation 9.1.1 would
restore the Bixby Mountain Fuelbreak/Firebreak to its historic role as a backup/secondary
fuelbreak/firebreak. For additional explanation, see the rationale discussion for the Ventana
Fuelbreak/Firebreak above.
B. Recommendations to Congress
1. Enact Legislation to Enable and Require Firebreaks to be Maintained
Recommendation: Should the fuelbreaks/firebreaks and side-treatments described in
Sections V.A.1 and V.A.ll above not be installed, maintained and defended as recommended,
within three years from the date the MCCWPP is signed by the signatories required by the
HFRA, it is recommended that Congress enact legislation to clearly enable and require the
recommendations in Sections V.A.1 and V.A.ll.
Rationale: Though Congressional documents, for decades, have repeatedly stated that
the USFS is free to use whatever presuppression methods and techniques it finds are
necessary to manage wildfire fuels to protect communities near California's wilderness
areas, and the Ventana Wilderness and Silver Peak Wilderness areas in particular,71 little
or no such preparation has taken place. When wildfires come, communities remain
vulnerable, with their survival depending almost entirely on the weather and the location
of random lightning strikes.
After fire starts, bulldozers, hydraulic excavators, trucks, chainsaws, and other motorized
equipment must be approved for use in areas designated as wilderness. Obtaining such
71 See Section 3.3.1.2 in the MCCWPP, Wilderness Acts, for acts of Congress and Congressional reports related to
wilderness areas in Monterey County.
35
approval can be delayed as fire spreads.72 Once approval is obtained motorized
equipment is used in a race to reopen overgrown firebreaks and fuelbreaks. However,
depending on the weather and where lightning strikes, there is no assurance that work can
be done in time. This scenario plays out every 10 to 20 years in the Monterey Ranger
District of the LPNF (e.g., Marble Cone Fire (1977), Kirk Fire (1999), Basin Fire
(2008)).
2. Statutory Exemption From the Endangered Species Act (ESA) for Wildfire Fuel
Reduction Work
Recommendation: Provide a statutory exemption from the ESA for wildfire fuel
reduction work in Monterey County.
Rationale: We heavily regulate and limit logging and other vegetation removal in much
of our nation, and we suppress wildfires. Under these conditions vegetation grows
without man-made or natural controls. Congress has acknowledged that the resulting
hazardous overgrowth, including high-intensity catastrophic wildfires that result, is a
national problem, especially in the western states. It is certainly a problem in Monterey
County.
Hazardous overgrowth threatens lives, property and the environment, including protected
species. The cost, time and limitations required to comply with species protection laws
preclude or discourage landowners and agencies from doing fuel reduction work to
properly care for their land. This encourages more overgrowth, which increases the
threat to species, again, including protected species. The problem inevitably grows worse
every year. The long term benefits to species from appropriate fuel reduction work
outweighs the chance of short-term harm to species from such work. Congress should
address this problem by providing a statutory exemption to the ESA.
C. Recommendations to the California Legislature and the Governor
Various state laws lack clarity with regard to allowance of fuel reduction work, or
otherwise discourage or preclude such work. The MFSC recommends that such laws be
changed to ensure that wildfire fuel reduction work is allowed and facilitated in areas
where hazardous overgrowth threatens lives, property or the environment.
State laws should acknowledge that Californians have fundamental inalienable rights,
pursuant to Article 1, Section 1 of the California Constitution,73 to defend life, protect
property, and pursue and obtain safety, and that hazardous overgrowth assaults each of
these rights if individuals are not free to address it.
72 Fire professionals who worked on the Basin Fire have reported that delays of several days occurred before
approval for use of heavy equipment could be obtained for some areas.
73 Article 1, section 1 reads as follows, "All people are by nature free and independent and have inalienable rights.
Among these are enjoying and defending life and liberty, acquiring, possessing, and protecting property, and
pursuing and obtaining safety, happiness, and privacy."
36
1. Governor’s Proclamation of a State of Emergency and for Planning and
Regulatory Streamlining Improvements
Recommendation: The MFSC recommends that the Governor of the State of California
issue a Proclamation of a State of Emergency for Monterey County similar to the
Proclamation of Emergency made for Placer and El Dorado counties on May 27, 2008,74
modified to apply to Monterey County, to (1) provide immediate attention to regulations
and procedures "to eliminate or otherwise reduce the adverse effects of confusing,
overlapping, or unnecessarily restrictive regulations and regulatory procedures" and (2)
advocate planning and regulatory streamlining improvements to immediately empower
Monterey County residents to begin mitigating the threat of catastrophic wildfire by
removing hazardous fuel without regulatory hindrance.
Rationale: The Proclamation of Emergency made by the Governor for Placer and El
Dorado counties, states the following:
The current regulatory environment within the Basin for fuels treatment
projects is confusing, overly complex and often incompatible with the
immediate need to mitigate the threat of catastrophic wildfire, and that
such regulations and procedures require the immediate attention of
agencies and authorities having jurisdiction over the health and conditions
of the forests of the Basin including, but not limited to, the Tahoe
Regional Planning Agency (TRPA), in order to eliminate or otherwise
reduce the adverse effects of confusing, overlapping, or unnecessarily
restrictive regulations and regulatory procedures.
Monterey County has a similar regulatory environment, with confusing, overly complex,
unwritten and often incompatible regulations that interfere with the immediate need to
mitigate the threat of catastrophic wildfire. The Proclamation recognized that the Tahoe
Basin is "badly in need of dramatic and urgent wildfire mitigation actions across a wide
spectrum of fire suppression, fuels management, planning and regulatory streamlining
improvements."
Monterey County faces the same urgency, and accordingly, the MFSC advocates
planning and regulatory streamlining improvements to immediately mitigate the threat of
catastrophic wildfire, and asks the Governor to issue a Proclamation in support of
changes to policy comparable to his Proclamation of Emergency for Placer and El
Dorado counties, modified to address regulatory problems in Monterey County.
2. Amend the California Coastal Act (CCA) to Allow and Facilitate Wildfire Fuel
Reduction Work
Recommendation: Amend the CCA to expressly state that wildfire fuel reduction work
is allowed in Environmentally Sensitive Habitat Areas (ESHA), and in other areas in the
74 See Appendix N for the Governor's Proclamation for Placer and El Dorado counties.
37
coastal zone, without the need for permits, studies, mitigation or other requirements that
may discourage or preclude performance of such work.
Rationale: Monterey County's coastal land use plans allow removal of hazardous
overgrowth without the need for a coastal permit.75 However, it has been argued that the
CCA should be interpreted to not allow this work in ESHA and other areas. The CCC
has held that vast areas of vegetation are ESHA.76 If wildfire fuel reduction work is not
allowed in ESHA and other coastal areas without regulatory hindrance, lives, property
and the environment will be jeopardized by hazardous overgrowth. The CCA should be
amended to avoid threats of litigation that may discourage or preclude wildfire fuel
reduction work, by clearly stating such work is allowed in ESHA and elsewhere in the
coastal zone without the need for permits, studies, mitigation or other requirements.
3. Amend the California Endangered Species Act (CESA) to Allow Incidental Take
of Protected Species for Wildfire Fuel Reduction Work
Recommendation: Amend the CESA to allow incidental take of California protected
species for wildfire fuel reduction work without the need for permits, studies, mitigation
or other requirements that may discourage or preclude performance of such work.
Rationale: As previously discussed, hazardous overgrowth threatens species and habitat,
including protected species, and also threatens lives and property. In the 1990s, several
counties were able to obtain a memorandum of understanding (MOU) pursuant to an
early version of section 2081 of the Fish and Game Code (F&GC), to allow an incidental
take of protected species for wildfire fuel reduction work. The opportunity to obtain such
an MOU was effectively eliminated when the legislature amended F&GC 2081, and
added section 2081.1. As a result, such MOUs either have to have been approved before
January 1, 1998, or, must meet the requirements of the amended F&GC 2081, which now
requires mitigation and other measures that add cost, delay and limitations that
discourage or preclude wildfire fuel reduction work. To enable wildfire fuel reduction
work to proceed as quickly as possible with the least potential for litigation and other
delays, the legislature should directly address this issue by providing a clear statutory
exemption from the CESA for fuel reduction work.
4. Amend the California Environmental Quality Act (CEQA) to Provide a
Statutory Exemption for Wildfire Fuel Reduction Work
Recommendation: Amend CEQA to provide a statutory exemption for wildfire fuel
reduction work, without the need for permits, studies, mitigation, or other requirements
that may discourage or preclude performance of such work.
75 See, Section 3.3.2.2.2 of this MCCWPP.
76 For example, the Commission has found that maritime chaparral in central California is ESHA, and a California
Department of Fish and Game maritime chaparral expert has said that essentially all chaparral in California's coastal
zone is maritime chaparral, with few exceptions.
38
Rationale: The CEQA Guidelines currently provide a categorical exemption for fuel
management activities in areas within 30 to 100 feet from structures.77 However, the
exemption provides it applies only if the activities do not result in the take of threatened,
rare or endangered species. To know if such species are present may require a biological
survey, adding cost and delay to projects. Moreover, the exemption does not apply to
other defensible space measures, such as emergency access routes over 100 feet from
structures, or under conditions where distances greater than 100 feet are needed to protect
lives or structures. Nor does the exemption apply to other fuel reduction work that may
be needed further than 100 feet from structures, such as community fuelbreaks. A
statutory exemption from CEQA is needed for wildfire fuel reduction work to ensure that
CEQA does not threaten lives, property or the environment by hindering fuel reduction
work.
B. Recommendations to All Governmental Agencies
1. Interpret All Federal, State and Local Laws to Allow and Facilitate Hazardous
Fuel Reduction Work
Recommendation: The MFSC advocates that all federal, state and local regulatory
entities interpret all federal, state and local laws in the manner most conducive to
allowing and facilitating safe hazardous fuel reduction work in Hazardous Fuel
Reduction Zones, to protect life, property, or the environment.
Rationale: Some statutes, regulations, rules, policies, ordinances and court opinions may
be interpreted to have more than one meaning. Under one interpretation, they may have
the effect of discouraging or precluding hazardous fuel reduction work, and under
another interpretation, they may have the effect of allowing and/or facilitating hazardous
fuel reduction work. Hazardous fuel may adversely impact wildlife and habitat,
including threatened and endangered species. Moreover, such fuel makes suppressing
and controlling wildfires more difficult, and, in the event of wildfire, threatens lives,
property and the environment with high intensity fire. In order to avoid such threats from
hazardous fuel, the MFSC recommends that where laws are subject to more than one
interpretation, all regulatory entities interpret the law in the manner that will act to allow
and facilitate hazardous fuel reduction work.
2. Memorandum of Understanding (MOU) to Allow Incidental Take of Protected
Species in HFRZ for Fuel Reduction Work
Recommendation: The FAHJ, USFWS and CDFG should enter into an MOU or other
agreement to allow the incidental take of protected species within Hazardous Fuel
Restricted Zones (FRZ) in Monterey County and for creation of defensible space and
other wildfire fuel reduction work, without the need for mitigation, studies or other
measures that may discourage or preclude such work.
77 See, CEQA Guidelines, Title 14, California Code of Regulations, section 15304(i).
39
Rationale: The MCCWPP acknowledges that vegetation overgrowth is a threat to lives,
property and the environment, including protected species. Hazardous overgrowth can
adversely and directly impact protected species by interfering with foraging and by
converting habitat to other vegetation types. Hazardous overgrowth can further cause
adverse impacts on protected species by supporting unnatural, high heat intensity
wildfires, which can kill wildlife and convert habitat types. Short term impacts from
wildfire fuel reduction work are outweighed by long term benefits to species. It is
counterproductive to long term species protection goals to discourage or preclude
wildfire fuel reduction work due to the chance of short term harm to species.
C. Recommendations to Monterey County and to Municipalities and Districts
Within Monterey County
1. Include Language to Allow and Facilitate Hazardous Fuel Reduction Work in all
Planning Documents, Ordinances, Rules and Regulations
Recommendation: The MFSC recommends that Monterey County and all
municipalities and districts with jurisdiction in Monterey County include in planning
documents, ordinances, rules, regulations and department policies, language to allow and
facilitate hazardous fuel reduction work wherever it would advance protecting lives,
property or the environment, in that order of priority. Both removal and disposal of
hazardous fuels need accommodation. It is further recommended that Monterey County
(1) clarify county policies and modify ordinances to remove any permit or fee
requirements for hazardous fuel modification activities approved by the FAHJ, and (2)
clarify that the FAHJ has authority to authorize removal of hazardous fuels in areas
where hazardous fuels present a potential threat to lives, communities, structures,
infrastructure, access roads and/or watersheds in the event of wildfire.
Rationale: The source of the police power that justifies the existence of local and
regional government entities is the protection of public health and safety. Various well
intentioned planning policies, ordinances, rules and regulations can have the consequence
of adding costs, delays and limitations that discourage or preclude hazardous fuel
reduction work where it is needed to protect lives, property or the environment. In order
to allow and facilitate hazardous fuel reduction work, it is critical that all plans,
ordinances, rules and regulations include allowances for hazardous fuel reduction work to
facilitate and expedite such work with the least amount of regulatory hindrance
permissible under state and federal law. It is important to understand that the intent is to
restore areas with hazardous fuels to an approximation of the fuel loads they would have
had fire suppression not been practiced in the area, as determined by the FAHJ.
2. Include Language to Allow and Facilitate Wildfire Fuel Reduction Work in all
Planning Documents, Ordinances, Rules and Regulations
Recommendation: The MFSC recommends that Monterey County and all
municipalities and districts with jurisdiction in Monterey County include in all planning
documents, ordinances, rules and regulations, language to allow and facilitate safe
wildfire fuel reduction work wherever it would advance protecting lives, property or the
environment, in that order of priority, from the threat of hazardous vegetation
overgrowth. Both removal and disposal of vegetation needs accommodation.
Rationale: The source of the police power that justifies the existence of local and
regional government entities is the protection of public health and safety. However,
various well intentioned planning policies, ordinances, rules and regulations have the
consequence of adding costs, delays and limitations that discourage or preclude wildfire
fuel reduction work where it is needed to protect lives, property or the environment,
thereby threatening public health and safety and the environment. In order to allow and
facilitate wildfire fuel reduction work, it is critical that all plans, ordinances, rules and
regulations be amended to avoid hindering the performance of such work.
Thank you for your consideration of the foregoing. The Monterey Fire Safe Council
strongly supports these discussions and recommendations and looks forward to working with the
County to implement these concepts at all levels of government, to enable citizens and agencies
to perform needed hazardous fuel reduction work with the least regulatory encumbrance and at
the lowest cost possible under applicable state and federal law.
Sincerely,
____________________________________
Ke
M
__
Ri
Sa
Ar
Pe
So
__
M
M
Ca
M40
lly Erin O'Brien, President
onterey Fire Safe Council
__________________________________
chard C. Hutchinson Jr., Unit/Fire Chief
n Benito-Monterey Unit, CAL FIRE
omas Tri-County FPD, Carmel Highlands FPD
bble Beach CSD Fire Department, Cypress FPD
uth Monterey County FPD
__________________________________
ichael Urquides, President/Fire Chief
onterey County Fire Chiefs Association
rmel Valley FPD
onterey County Regional FPD
41
_______________________________________
Chris Orman, Chief
North County Fire Protection District
_______________________________________
Martha Karstens, Chief
Big Sur Volunteer Fire Brigade
_______________________________________
Cheryl Goetz, Chief
Mid Coast Fire Brigade
_______________________________________
Roderic McMahan, Chief
Cachagua FPD

































































 

Monterey County Community Wildfire Protection Plan
November 2010 v2
APPENDIX K 
USFS Defensible Fuel Profile Zone Letter
  Caring for the Land and Serving People Printed on Recycled Paper     
Agriculture
United States
Department of
Forest 
Service
 
Los Padres  
National 
Forest 
Monterey Ranger District 
406 S. Mildred 
King City, CA 93930 
(831) 385-5434 
 
               
 
 
 
 
File Code: 1950 
Date: August 13, 2001 
 
 
Dear Interested Party: 
 
 
 
The Monterey Ranger District of the Los Padres National Forest is proposing to implement a defensible 
fuel profile zone (DFPZ) project (Monterey DFPZ Project) on National Forest system lands.  Forest 
Service personnel are preparing to conduct an analysis of the proposed project area within the boundary 
of the Monterey Ranger District on selected lands outside the Ventana and Silver Peak Wilderness areas.  
Please see the enclosed map for a general location of the proposed project. 
The purpose of this letter is to invite you to participate in the analysis process by providing your 
comments and any concerns you may have about this proposed project.  To encourage your informed 
participation in this planning process, this letter includes a description of the proposed action and the 
purpose and need for action. 
 
 
PROPOSED ACTION 
 
Trained specialists with the Forest Service are planning to apply fuels reduction treatments to establish 
defensible fuel profile zones (DFPZs) within ten identified units that cover a total of approximately 
18,760 acres.   Primary focuses for this project are travel corridors (roads and trails), campgrounds, 
National Forest System Lands adjacent to private property, administrative sites, and existing firelines.   
Treatments used to establish DFPZs include: 

 Pruning, clearing and chipping hazardous fuels;  

 Burning of fuels using broadcast and spot burning methods; 

 Establishment of shaded areas by planting native tree species; and 

 Managing for native grasses. 
 
Implementation would begin in the fall of 2001 and continue over the next ten years.  Individual areas 
would be prioritized for burning to achieve desired results.  Burning would be applied when moisture 
and air quality conditions meet prescription criteria.  Prescription criteria are most likely to be met after 
fall season rains when moisture levels would limit fire severity and still be low enough to achieve 
desired levels of fuel consumption. 
 
In general, fuel profiles would be changed to: 

 Break-up horizontal and vertical continuity; 

 Reduce fire prone live fuels by managing for:  younger vegetation, native grasses, and trees; 

 Reduce quantity of dead fuels; and 

 Use Forest Service facilities (campgrounds and administrative sites) to create models of 
defensible space. 
  
   Page 2 
 
 
Defensible Space 
 
DFPZs would be created on either side of roads, and around administrative and special use facilities to 
serve as safety zones, pre-attack zones, and escape routes during fire situations.  A variable width buffer 
not to exceed 1,000 feet on each side of the road would be created by removing dead fuels, pruning live 
brush and trees, planting native trees, and managing for native grasses where appropriate.  Treatments 
would vary depending on position on slope, soils conditions for plant establishment and growth, and 
aspect. 
 
Fuels around campgrounds would be managed so they could serve as safety zones in the event of fire.  A 
1,000-foot buffer would be created by removing dead fuels, pruning live brush and trees, and managing 
for native grasses where appropriate.  Measures would be taken to ensure that unlawful access to open 
areas is controlled around campgrounds. 
 
Native grasses would be managed by burning and seeding where appropriate.  This would be 
implemented in small (15 to 20 acre) areas over time in coordination with a qualified botanist.  Natural 
seeding would be encouraged whenever possible.  Where prescribed fire and/or reestablishment of 
native grasses are proposed, maintenance burning would be implemented about every seven years. 
 
Shaded DFPZs would be established by planting native tree species.  Species mix for tree planting 
would be based on types of trees found presently or historically in the vicinity.  Species to be considered 
would be: ponderosa pine, incense-cedar, sugar pine, Santa Lucia fir, and madrone. Any seeding or 
planting that occurs would be done using locally collected seed.   
 
The Forest Service would work with State and County Fire Departments in a cooperative effort to create 
safety zones around private homes and facilities. 
 
Treatment Units 
 
The following table describes proposed actions by treatment unit. 
 
 
UNIT ACRES PROPOSED ACTION 
Arroyo 1,630 
Establish variable width DFPZs up to 1,000 feet on each side of road.  Apply prescribed 
fire at regular intervals and reestablish native grasses around the Horse Bridge/Santa 
Lucia Creek area.   Establish variable width DFPZs along trails outside of wilderness.  
Carmel 165 Prescribed fire would be applied to provide buffering between the wilderness and private property.   
Cone 2,605 Establish variable width DFPZs up to 1,000 feet on each side of road.  Plant trees to develop shaded DFPZs as part of roadside corridor where appropriate.   
Manuel 400 
Manage dozer lines and safety zones to favor native grasses.  Fuels profiles would be 
managed so line could be used without repeated dozer entry.  At specific locations where 
conditions are favorable, reestablish native grasses and/or plant trees to create a shaded 
DFPZ over ¼ mile segments.    
Park 2,630 Create and maintain 1,000-foot DFPZs around campgrounds. Use prescribed fire to discourage the spread of noxious weeds. 
Piney 1,710 Burn on a regular basis in the winter after the road has been closed.   
  
   Page 3 
UNIT ACRES PROPOSED ACTION 
Reliz 5,160 Continue on-going coordination with property owners to apply prescribed fire across 
ownership boundaries.   
Ridge 1,975 Manage segments of existing dozer line for native grasses and shaded DFPZ.  Establish a 
variable width DFPZ up to 1,000 feet on each side of road. 
Skinner 700 
Manage existing dozer line and safety zones as a long-term strategic facility.  This would 
be achieved by treating small patches over time.  Treatments include discouraging growth 
of non-native grasses through periodic burning, brush cutting, and reintroduction of native 
grasses. 
Tassajara 1,785 
Create variable width DFPZs up to 1,000 feet wide each side of road outside the 
wilderness area using a mix of the following methods: 
• Up to 100 acre prescribed fire projects, thinning, and brush piling; 
• Create a variable width road corridor with reduced amounts of large fuel by offering 
fuelwood sales for areas within 300 feet of the road; and 
• Manage for native grasses through periodic burning and seeding small areas where 
appropriate. 
 
 
 
PURPOSE AND NEED FOR ACTION 
 
The purpose of this project is to meet the following objectives: 
 
• Protect highly valuable real estate within and adjacent to the National Forest boundary; 
• Protect watershed values in the Carmel and Arroyo Seco watersheds; 
• Reduce risk to private property; 
• Reduce potential for damage to resources by reducing potential for high intensity fires; 
• Implement small, strategically located projects that can provide anchor points, pre-attack zones, 
and areas of reduced intensity during unplanned fire events; 
• Create corridors and safety zones around public use facilities such as roads, campgrounds, and 
special use permit sites; 
• Provide evacuation routes to forest users and residents in the event of wildfire; 
• Lower risk of fire ignition, reduce intensity once ignition occurs, and break-up continuity to inhibit 
and slow spread of wildfires; 
• Limit the intensity of unplanned fires at strategic locations; 
• Protect historic structures; 
• Reduce risk of establishment and spread of noxious weeds; and 
• Reduce risk of large fires by managing for younger vegetation and broken continuity.  
 
 
COMMENTS 
 
The proposed action will be fully analyzed prior to any 
decision on final project design.  For this project to result 
in the best possible outcome for people and the 
environment please send us any issues, concerns, 
suggestions or information you may have relating to this 
proposal.  Opinions and values will be noted, but the 
intent of the process is not to serve as a public opinion 
poll.   
Purpose of This Letter: 
To identify the range of issues and 
 determine their significance. 
An issue is: 
A point of discussion, dispute or debate 
about the environmental effects. 
Issues are Used: 
To focus the analysis and determine if 
any alternatives to the proposed action 
need to be developed. 
  
   Page 4 
 
The Los Padres National Forest has hired Forest Service Environmental Assessment specialists located 
in Happy Camp, California to work closely with the local specialists, guiding the analysis and preparing 
the decision document.  If you would like additional information please contact one of the following 
people:  
 
   
Names Address Phone Fax email 
Annie Buma 530-493-1725 abuma@fs.fed.us 
Judy Hahn 530-493-1721 jhahn@fs.fed.us 
Fran Smith 
c/o Happy Camp Ranger District  
P.O. Box 377 
Happy Camp, CA  96039 530-493-1788 
530-493-1775 
fjsmith@fs.fed.us 
 
 
Please send any issues or written comments to one of the individuals listed above at the indicated 
address by August 24, 2001.  Comments are a matter of public record and as such may be provided to 
interested parties upon request.  
 
Thank you for your participation in this process. 
 
 
Sincerely, 
 
JOHN S. BRADFORD 
Acting District Ranger 
 
encl. 
 
 
 
APPENDIX L  
Sample Fire Prescription
APPENDIX L – Sample Fire Prescription for Safe Controlled Burn in Chaparral
Rx Factors
CHAPARRAL
FUEL MODEL 4
Hot Moderate Cool
Fuel Load tons/acre 10 10 10
Relative Humidity %: 15% 18-25% 60%
Wind Speed (MFWS): 15 5-8 0
Wind Direction: ALL SSW ALL
Temperature
(Dry Bulb °)
95 70-75 40
Live Fuel Moisture%: 55 65-75 120
1 hr. T/L %: 4 5-7 10
10 hr. T/L: 5 6-8 14
100 hr. T/L 6 7-9 18
Soil/Duff Moisture %: Dry Dry/moist Moist
Probability of
Spot Fire Ignition
70 50-60 40
Flame Length (ft) 48 26 10
Effective Wind Speed (MPH) 12.6 6-8 1.9
Scorch Height (ft) N/A N/A N/A
Forward Rate of Spread (chains/hour) 449.6 140 18.7
Backing Rate of Spread (chains/hour) 6.7 6.0 2.8
Spotting Distance (miles) 1.4 .2 0
Monterey County Community Wildfire Protection Plan
November 2010 v2
APPENDIX M
Acronym Table
Monterey County Community Wildfire Protection Plan
November 2010 v2
APPENDIX M – Acronym Table
ACRONYM STANDS FOR
AMSL Above Mean Sea Level
BEU California Department of Forestry and Fire Protection San Benito-
Monterey Unit
BLM Bureau of Land Management
BLM FMU Bureau of Land Management Fire Management Unit
CAL FIRE California Department of Forestry and Fire Protection
Caltrans California Department of Transportation
CARB California Air Resources Board
CCA California Coastal Act
CCC California Coastal Commission
CCR California Code of Regulations
CDF California Department of Forestry (See CAL FIRE)
CDFG California Department of Fish and Game
CDP Coastal Development Permit
CDPR California Department of Parks & Recreation
CEQA California Environmental Quality Act
CERT Community Emergency Response Team
CESA California Endangered Species Act
CIP Coastal Implementation Plan
CPOA Coast Property Owners Association
CSD Community Services District
CWPP Community Wildfire Protection Plan
DFPZ Defensible Fuel Profile Zone
DOD Department of Defense
Monterey County Community Wildfire Protection Plan
November 2010 v2
EIR Environmental Impact Report
EIS Environmental Impact Statement
ESA Endangered Species Act
ESHA Environmentally Sensitive Habitat Area
F&GC California Fish & Game Code
FAHJ Fire Authority Having Jurisdiction
FANS Friends, Artists and Neighbors of Elkhorn Slough
FARSITE Fire behavior and growth simulating software
FlamMap Fire behavior mapping and analysis software
FMP Fire Management Plan
FMU Fire Management Unit
FPD Fire Protection District
FRAP Fire & Resource Assessment Program
GIS Geographic Information System
HCP Habitat Conservation Plan
HFRA Healthy Forest Restoration Act of 2003
HFRZ Hazardous Fuel Reduction Zone
HMP Habitat Management Plan
LCP Local Coastal Program
LPNF Los Padres National Forest
LUP Land Use Plan (coastal)
MBUAPCD Monterey Bay Unified Air Pollution Control District
MC2WG Monterey County Wildfire Working Group
MCCWPP Monterey County Community Wildfire Protection Plan
MFSC Monterey Fire Safe Council
MIST Minimum Impact Suppression Tactics
MOU Memorandum of Understanding
Monterey County Community Wildfire Protection Plan
November 2010 v2
NEPA National Environmental Policy Act
NPPA California Native Plant Protection Act
NPS National Park Service
NRCS Natural Resources Conservation Service
OES Office of Emergency Services
PBCSD Pebble Beach Community Services District
PNG Prunedale Neighbors Group
PPA Prunedale Preservation Alliance
PRC Public Resources Code
PSDLE Prepare, Stay and Defend, or Leave Early
ROD Record of Decision
SLFDS Santa Lucia Fire Defense System
SMP Smoke Management Program
SOD Sudden Oak Death
SPLATS Strategically Placed Landscape Area Treatments
SPOTS Strategic Placement of Treatments
SRA State Responsibility Area
USDA United States Department of Agriculture
USFS United States Forest Service
USFWS United States Fish & Wildlife Service
VMP Vegetation Management Program
WSA Wilderness Study Area
WUI Wildland-Urban Interface