Save Lives or Treat “Fuel?”

Such devastating losses due to the 2017 wildfires are beyond tragic.

Forty-six people have died.
More than 9,500 structures have burned.
The community of Santa Rosa has been devastated.

Rescuers in Montecito are trying to find families buried in the massive wave of rock and mud that tore into the seaside town after heavy rains slammed into the mountainside above the community after its protective layer of chaparral was burned off during the Thomas Fire. The number of people killed in the mudslide has increased to 19. Some are still missing.

Such losses are unacceptable.

We respectfully ask the State of California  to consider the following questions:

1. Why were so many homes burned despite the fact that most had complied with state fire codes when built and had reasonable amounts of defensible space?

2. Why did the vegetation clearance projects (fire breaks, prescribed burns, etc.) found in many of the burned areas fail to protect lives and homes?

3. Would the newly proposed vegetation clearance program by Cal Fire and the Board of Forestry, have prevented or significantly reduced the devastating loss of life and property during and after the 2017 Tubbs Fire, Nuns Fire, Atlas Fire, and the Thomas Fire?

The answers are similar in each case. Unlike how we deal with earthquakes, we think we can stop wildfires. Cities and counties also allow developers to place homes in harm’s way. As a result, taxpayers pour millions of dollars in vegetation clearance operations that are designed to assist fire suppression efforts for 90% of the fires. Ninety percent. The problem is, those are not the fires that kill people and destroy communities.

Meanwhile, we are not addressing the conditions that are actually causing so many lost lives and homes.

It is time for the State of California, the Board of Forestry, and Cal Fire to recognize that what we have been doing to reduce fire hazard is not working.

The nearly exclusive focus on clearing vegetation and attempting to fight wind-driven fires has failed us. Why? Because we are attempting to treat symptoms of a chronic disease – an economic model that encourages poor land use planning, flammable homes, and a willingness to allow developers (and planning entities) avoid responsibility.

Below is our solution as explained in our comment letter on Cal Fire’s and the Board of Forestry’s currently proposed Vegetation Treatment Program (VTP). It was submitted January 12, 2018.

You can also read about our fight over the past 13 years to fix the Program to better protect lives, property, and the natural environment here. Thus far, the Board of Forestry and Cal Fire have ignored our efforts along with those of dozens of other fire scientists and environmental groups.

Here is a brief summary of what we wrote:

The Three Main Points

1. Focus on saving lives and property, rather than trying to control wildfires – two different goals with two radically different solutions. Wildfires are inevitable. Make our communities safe through proper land use planning and fire-safe retrofits.

2. Vegetation clearance projects repeatedly fail to protect large numbers of lives and homes during wind-driven wildfires, the kinds of fires that do nearly all the damage. Stop wasting time and taxpayer money by focusing so heavily on such projects.

3. The best way to protect lives and property is by making cities, counties, and developers responsible for losses caused by wildfires in the future for developments built in very high fire hazard zones. Prevent developers from externalizing costs and making taxpayers pay for their mistakes.

Ten Reasons Why the Vegetation Treatment Program Draft is Flawed

1. The Environmental Impact Report for the new Vegetation Treatment Program (VTP) fails to provide the public with the information it needs to properly evaluate the Program. The Report often cherry picks statements out of research papers that have nothing to do with the research cited, ignores the main conclusions of such papers, and attempts to use personal stories to diminish scientific findings contrary to the Program’s biases.

2. The Report continues to misrepresent the work of scientists to promote the Program’s approach despite the fact that the scientists involved have informed Cal Fire and the Board that it misrepresented their work in previous Reports.

3. The Report eliminated several opportunities to provide transparency to the public about where and how vegetation clearance projects would be placed.

4. The Report continually contradicts itself. For example, in one section the Report says chaparral is in danger of elimination by too many fires (true). Then in another section, the Report says Cal Fire needs to burn large areas of chaparral to restore it (false).

5. The Report is based on 2003 data and older. Fifteen of the 20 biggest fires in California history have occurred since 2002. None of them would be reflected in this 2003 analysis that Cal Fire proposes to base statewide public policy on in 2018 and beyond.

6. The Report attempts to disregard research that clearly shows that large, high-intensity fires are the normal pattern for chaparral.

7. The Report cites quotes from polarizing politicians as if they were legitimate scientists in order to support the Program’s goals.

8. The maps and descriptions of the areas the Program intends to “treat” are so illegible and so lacking in detail that they are useless.

9. The Report violates the California Environmental Quality Act in both content and omissions.

10. The measures offered by the Report to prevent the loss of habitat, increased carbon emissions, and the destruction of valuable ecosystem services are impossible to enforce and thus illegal under the California Environmental Quality Act.

The Introduction to our Comment Letter

We respectfully ask Cal Fire to consider the following question: Would the fuel treatments, as envisioned in the proposed Vegetation Treatment Program (VTP), have prevented or significantly reduced the devastating loss of life and property during the 2017 Tubbs Fire, Nuns Fire, Atlas Fire, and the Thomas Fire?

Based upon our preliminary research, we do not believe it would have.

Considering that such fires are predicted to increase due to climate change, the presence and continued building of communities in very high fire hazard zones, and the frequency of ignitions likely increasing with a growing population, the second question that we respectfully ask is:

How can we help Cal Fire develop a comprehensive fire risk reduction plan that will save lives, property, and protect natural resources from the wildfires that are responsible for killing the most people and causing the most damage?

We understand that strategic fuel treatments beyond community boundaries can be effective fire suppression tools during non-wind-driven fire events. But those are not the fires that that cause the most devastating losses. In fact, we believe the VTP’s current focus on vegetation treatments may facilitate the type of poor planning that allowed the kind of developments that were devastated by the 2017 wildfires.

We also understand that Cal Fire believes that vital fire risk reduction activities (e.g. regulating buildings in which people live, land planning, defensible space), “exist outside the scope of the proposed program.” (1-15)

However, after witnessing multiple, wind-driven fires devastate so many lives and communities in which fuel treatments of the type the VTP envisions have had little impact, we believe it is time for Cal Fire and the Board of Forestry to change their approach to a comprehensive one. Rather than focusing on trying to control wildfires with fuel treatments, a more effective approach would be to focus on saving lives and property.

If not the Board, the State Fire Marshal, and Cal Fire, who would be responsible for coordinating such a comprehensive program?

The number of lives lost and homes burned in the 2017 wildfires should inspire a new approach to fire protection, because what we have been doing (focusing on fuel) is not working.

For example, nearly all of the homes in the Fountaingrove II community of Santa Rosa (Figs. 1 and 2) were built either right on or near ridgelines, geographical features well known for high fire danger (Fig. 3). Despite significant amounts of defensible space (note cluster of homes in the cul-de-sac at the lower right in Fig. 1), the homes were devastated by the Tubbs Fire. Also note the post-fire condition of forested areas in the upper portion of Figs. 1 and 2, and upper right in Fig. 3.

As was the case in the 2007 Witch Creek Fire (IBHS 2009), it is likely nearly all these homes ignited from wind-blown embers and/or house to house radiant heat rather than flame contact from surrounding wildland vegetation.

The Fountaingrove II Open Space Maintenance Association had a rigorous fuel management program. The Association also understood well the danger of dry grasses and embers. In a 2013 bulletin to homeowners they warned,

Over 90% of the homes destroyed by fires generated in the Wildlands are lost due to flying embers, not from fire lapping at their doorstep. A properly “Fire-scaped” home next to the Wildland Urban Interface can survive – if the owners have landscaped their property in a fire wise manner and keep all weeds and grasses clipped. (FOSMA 2013).

Yet the community was devastated in the Tubbs Fire.

We respectfully ask the Board and Cal Fire, given that the Fountaingrove II community followed a vegetation management program with a focus similar to what is being proposed in the VTP, what policies would the Board help facilitate that would more successfully address the devastation caused to the community by the Tubbs Fire?

Figure 4 shows the community of Coffey Park in Santa Rosa (at the tip of the red arrow) devastated by the Tubbs Fire, and its distance from the nearest significant amount of wildland vegetation. – nearly a mile. Highway 101 was also between the community and the fire. Similar fire jumps over multi-lane highways and other large areas occurred during the 2003 Cedar Fire and the 2007 Witch Creek Fires in San Diego County.

We respectfully ask the Board and Cal Fire, what would have prevented these homes from igniting during the Tubbs Fire and what policies would the Board be willing to propose to prevent this kind of disaster in the future?

One of the key treatments described in the VTP is prescribed burning. As evidenced in Fig. 6 above, recent prescribed burn treatments (shown in blue) were not helpful in preventing the spread of the 2017 Thomas Fire.

The easternmost prescribed burn off Salt Marsh Road is approximately downwind of the probable origin of the Thomas Fire. The middle burn is in Aliso Canyon. Neither of these appear to have provided much in the way of anchor points for fire suppression activities.

Wind-driven fire generally spreads faster through grassy fuels than shrub fuels. Consequently, it is likely that the fire actually spread faster through these fuel treatments than it might have through the native shrubs that were present prior to treatment. Of course, with the high winds and low humidity that characterized the fire, nothing else really mattered than the extreme fire weather conditions.

The burns near the southern edge of the fire, in Hall, Barlow, and Sexton Canyons, have been worked on for years and were intended to create opportunities for controlling a fire.

In the initial run, the head fire spread 14 miles from the origin outside of Santa Paula to downtown Ventura in about five hours, spreading by ember ignited spot fires the entire way. This kind of fire behavior would likely defeat any fuel break – nothing on the ground can stop a fire that is basically flying through the air.

Further research is obviously needed to determine all the factors involved in the Thomas Fire’s spread, but the consequences are clear from the damage assessment shown in Figure 7 below. The prescribed burns did little to protect the community. This is especially the case for the southernmost prescribed burn just above the northern edge of Ventura.

In the 2007 Grass Valley Fire, the US Forest Service and the Natural Resource Conservation Service conducted several fuel treatments around the community of Lake Arrowhead (Fig. 8). Reportedly, the fuel treatments performed as expected by allowing firefighters to engage the fire directly and reducing the rate of spread and intensity (Rogers et al. 2008). However, the end result for the community was much less positive. One hundred and seventy-four homes were lost (Fig. 9).

The comprehensive analysis of the Grass Valley Fire by US Forest Service scientists (Cohen and Stratton 2008) concluded that,

Our post-burn examination revealed that most of the destroyed homes had green or unconsumed vegetation bordering the area of destruction. Often the area of home destruction involved more than one house. This indicates that home ignitions did not result from high intensity fire spread through vegetation that engulfed homes. The home ignitions primarily occurred within the HIZ (Home Ignition Zone) due to surface fire contacting the home, firebrands accumulating on the home, or an adjacent burning structure.

Home ignitions due to the wildfire were primarily from firebrands (embers) igniting homes directly and producing spot fires across roads in vegetation that could subsequently spread to homes.

The 2013 Silver Fire near Banning, California (Fig. 10) challenged the fundamental assumption of the DPEIR that treating older vegetation is an effective way to prevent devastating wildfires. Most of the fire burned through invasive weeds and young, desert chaparral that was recovering from the deadly 2006 Esperanza Fire. Twenty-six homes were lost in a fire that was fueled by seven-year-old vegetation.

There are numerous other examples and a number of solid research papers explaining why and how homes burn. What nearly all of them demonstrate can be best summarized by Cohen and Stratton (2008). They wrote,

These incidents remind us to focus attention on the principal factors that contribute to a wildland-urban fire disaster—the home ignition zone.

We know that the DPEIR cites numerous case studies as well, claiming to show how effective fuel treatments can be. We also know there are numerous examples of when fire suppression has been facilitated when the flames meet previous fire perimeters. Suppression of the 2017 Thomas Fire was reportedly aided when its western edge interacted with the 2008 Tea and 2009 Jesusita Fire perimeters in the mountains above Santa Barbara. However, the weather changed as well.

We are not arguing with the fact that fuel modification is a tool that can be used to help control non-wind driven wildfires. However, the nearly exclusive focus, both financially and through time spent in planning, on fuel modification as presented in the DPEIR has failed us. How else can we account for the loss of 46 lives and more than 9,500 structures in wildfires from October to December this past year?

We believe nearly everyone can agree that that level of loss is unacceptable.

We also believe the current approach in dealing with fire risk as proposed in the DPEIR is also unacceptable. It is unacceptable not only because the DPEIR’s justifications for its approach are flawed, but because it does not deal with the wind-driven fires that cause nearly all the damage nor the actual causes that place people in harm’s way in the first place.

In its only attempt to address the effectiveness of fuel treatments involved in devastating wind-driven fires, the VTP cites Jin et al. (2015), listing the percentage of final fire perimeters found along fuel breaks (8%) and roads (56%) (4-38). Although fire perimeter data can be helpful, it does not necessarily indicate why a fire stopped where it did. Was it a change in the weather? Was it a back fire? Was it fuel moisture?

However, consistent with previous research, Jin et al. (2015) concluded when examining the full data set that,

SA (Santa Ana wind-driven) fire probability did not depend on stand age, and we did not find evidence that age-dependent flammability limits SA fire spread…

In other words, whether it be young or old-growth, sparse or dense chaparral and associated plant communities (including highly flammable non-native grasses), wind-driven fires defy control and basically stop when the weather permits.

The omission of this conclusion by Jin et al. (2015) is symptomatic of a problem that plagues the entire VTP document – substandard research and a failure to provide substantial evidence that the program’s goals, and the goals of the revised 2010 California Fire Plan, will be achieved.

Even though the latest draft makes efforts to incorporate relevant science, it often cherry picks statements out of papers that have nothing to do with the research cited, ignores the main conclusions of cited papers, or attempts to use anecdotal stories to diminish scientific findings contrary to the VTP’s assumptions about fuel treatments.

As a consequence, among other reasons as described below, the VTP lacks substantial evidence to support its conclusion that the environmental impacts of the program would be mitigated below the level of significance, much less that the program would protect life, property, and the environment from exceptional, damaging wildfires.

As we have in the past, we urge the Board of Forestry and Cal Fire to produce a document that starts by responding to the following question, “How do we protect lives and property from wildfire?” instead of “How do we manage fuel?” These are two different questions resulting in two different answers. And focusing on lives and property suggests questions that are precluded by the fuel approach taken by the VTP – questions that allow us to address the actual problem (poor land planning) rather than just symptoms of the problem (lives lost, communities destroyed).

Such a powerful approach will challenge everyone to leverage their own experiences, be willing to consider new paradigms, and honestly collaborate with others, especially with those who have different perspectives. Otherwise, we will continue practices that have brought us to this point – increased loss of homes, increased loss of habitat, and increasing levels of carbon in our atmosphere.

After our testimony to the Board on August 26, 2015, the Board’s Chair said that, “Scientists used to believe a lot of things that we’ve learned were wrong. So, we can’t just wait around for science to find the correct answer. We need to move forward.”

We do need to move forward, but we need to do so by utilizing all the information available to us today, not depend on outdated models, poor research, and incorrect assumptions.

Therefore, we urge the Board to prepare a revised VTP by correcting the errors and incorporating the suggested improvements below.

We owe it to ourselves and future generations to get it right this time, especially because the changing climate will not be forgiving if we continue to squander the opportunity.

Key Improvements to the Program to Reduce Fire Risk
– Land Use Planning  and Embers –

We are aware that the Board prefers to only deal with vegetation management, but if such a strategy does not protect lives and property during wind-driven fires, what is the point?

The Board and Cal Fire should stop focusing on modifying fuels in order to try to control wildfires and focus instead on saving lives and property by focusing directly on communities. The science is overwhelming in support of this approach. Schoennagel et al. (2017) offers some compelling options that will help us move in this direction:

The majority of home building on fire-prone lands occurs in large part because incentives are misaligned, where risks are taken by homeowners and communities but others bear much of the cost if things go wrong. Therefore, getting incentives right is essential, with negative financial consequences for land-management decisions that increase risk and positive financial rewards for decisions that reduce risk. For example, shifting more of the wildfire protection cost and responsibility from federal to state, local, and private jurisdictions would better align wildfire risk with responsibility and provide meaningful incentives to reduce fire hazards and vulnerability before wildfires occur. Currently, much of the responsibility and financial burden for community protection from wildfire falls on public land-management agencies. This arrangement developed at a time when few residential communities were embedded in fire-prone areas. Land-management agencies cannot continue to protect vulnerable residential communities in a densifying and expanding WUI that faces more wildfire (Moritz et al. 2014).

Providing incentives for counties, communities, and homeowners to plan fire-safe residential development for both existing and new homes and discouraging new development on fire-prone lands will make communities safer (Calkin et al. 2014; Abrams et al. 2015; Syphard et al. 2013; Alexandre et al. 2016).

Changing incentives require policy changes, but such changes are achievable if properly organized. An example is requiring approving, local entities in charge of development (cities, counties) to assume responsibility for future losses due to wildfire and issue Fire Development Bonds for any development approved in a Very High Fire Hazard zone. These Bonds would be funded by a significant portion of the tax revenue that is generated by said development and the developer of the property. Residents could be responsible for a small portion of the Fire Development Bond as well. The bonds would be used to help pay for any damage caused by a future wildfire.

Such an approach would internalize the costs of fire hazards instead of forcing society to shoulder the burden. The ultimate goal would be to make development in Very High Fire Hazard zones prohibitively expensive.

All homes already within VHFH zones should be required to retrofit to improve fire safety within 20 years, similar to the code passed by the City of Los Angeles in 2016 to retrofit older buildings for earthquake safety.

A retrofit that is not typically used in California, but used effectively in Australia and Canada is external sprinklers (Mitchell 2005). Such an approach is uncommon because traditionally home fires started inside, hence the use of internal fire sprinklers. However, internal sprinklers are designed to save lives, not homes (Fig. 11 below).

External sprinklers, coupled with an independent water supply (swimming pool or water tank), should be required for all homes within very high fire hazard zones. Clusters of homes could be served by a community water tank that should be a requirement for every planned development.

Many residents have taken it upon themselves to retrofit their own homes with external sprinkler systems. Under-eave misters on the Conniry/Beasley home played a critical role in allowing the structure to survive the 2003 Cedar Fire in San Diego County. The home was located in a canyon where many homes and lives were lost to the flames (Conniry 2008).

You can read the full story concerning the Cal Fire Vegetation Treatment Program with file downloads here.