Comments about the July 2007
Nevada County Fire Plan
Virginia Moran
August 15, 2007
www.ecooutreach.com

General Comments:

What follows are my comments influenced also by others that have contacted me and thank you. There is much more than this I could have commented on but I had to narrow it down. What follows are what I feel are the most important elements to be aware of in the new Fire Plan and with this issue. I'm sorry if I repeat myself in areas but I wanted to get these up asap. I may continue to do some editing but I had to post these sooner rather than later since no one is sure how long the public comment period will go. If you are going to comment, and I hope you do, do it soon. Thank you.

Since I started these comments, there was a fire less than a mile from my home. At this point, it is not known what caused it (but probably was human caused) -- only that it appeared I was the only one of my neighbors that took the fire seriously. To reiterate a member of the Alta Sierra Property Owners association who spoke at the Fire Plan meeting, people seem to have NO IDEA about fire. They do not know how to prepare for it, evacuate for it, what to grab (like your homeowners insurance policy) nor did it seem my neighbors fully understand how absolutely devastating the fire could have been had there been WIND. As far as I could tell, I was the only one that laid out my hoses on my driveway, packed my car, and observed the fire with the idea to ACT. I was ready. I was on alert. I cringed when I heard some of my neighbors say "this is almost like a big party!" Almost fun! In the meantime, firefighters and pilots were risking their lives for this "party." This experience has made me even more adamant about the need to make FIRE EDUCATION ONE OF THE TOP PRIORITIES OF THE FIRE PLAN. I cannot for the life of me figure out why "fuels treatments" is number one unless it is in fact the influence of "Disaster Capitalism" because fuels treatments will not save anyone's home. It will HELP to save homes but it SHOULD NOT be the first priority and coupled with the need to hire "private consultants" is suspect.

Watching CalFire and our local firefighters fight this 3 acre fire was impressive. I offer unlimited thanks and kudos to what Calfire does best: FIGHTING FIRES. There can be no better firefighting outfit than CalFire. Kudos too to the helicopter and fixed wing pilots. The willingness of other human beings to risk their lives to save other living beings is the foundation of compassion and human civilization. Once we lose this compassion for other beings, we are doomed. (Some would say we are approaching this).

These are now my original comments. Thank you.

Speak to visitors from Europe and South America as well as other locations and they will tell you that there is an undercurrent of fear that seems to run everything in America. This issue is no different. Prior to 2003 and the Bush "Healthy Forest" programs, I do not remember the level of hysteria about vegetation that now accompanies the issue of fire (as if fire in the west is a new thing). Fire is not a new thing but the hysteria is and much of the hysteria is from agencies and politicians. It serves no purpose but to foster reactionary measures that may not even make us safer. Politicians can go a lot of distance on fear. Fear is a great thing to grandstand around but fear of the inevitable is not productive and fire in California under a new climate regime with a growing population pushing more and more into the "urban-wildland interface" is inevitable. If you live in an especially fire-prone area in California, you can, at any time, lose your home in a fire. The best thing you can do to face this reality is PREPARE for it. Be ready. Create sensible defensible space around your home, make changes to your home that you can such as fire-safe roofing and decking as well a roof-top sprinkler systems, document everything in your home with photographs, list your possessions, READ YOUR HOMEOWNERS INSURANCE POLICY--don't find out what it says AFTER the loss like I did and so many Hurricane Katrina victims did. Think about if you had 20 minutes to leave your home, what would you take? The hell of a fire is often after it when you have to deal with the insurance company and all the paperwork so take a copy of your policy. Take essential personal information and papers. Family heirlooms. Photographs. Irreplaceables. What are your "irreplaceables"? Identify them and when fire season starts, make them easy to grab.

We don't hear much about the Pines Fire of 2002 but this was a devastating fire in San Diego County that almost took out my home. Another fire that almost took out my home was started by a firefighter, who when he was bored, would light his own pants on fire....I was evacuated from my home multiple times in 2002 and by the time the Cedar Fire came through in 2003, I was damn good at evacuating. Even when the Cedar fire was still miles away, I got everything ready to go. I was packed when the fire was 2 miles from my home. Everything I wanted was boxed up and sitting right by the door. I was ready. You should be too.

Another reality of being a victim of a disaster is the blame game which will go on, sometimes for the rest of your life. I was almost stalked by disaster chasing attorneys who wanted to represent me in one of many "class action" lawsuits. It's a heated mess even after the fire because on top of the shock and pain of losing everything, there is the anger many people experience as a result of the trauma. You will not be done with the fire even after your home is gone. It will go on for months, perhaps years, as you do the clean-up, work with the insurance agencies....Losing a home to a "natural" disaster is a lot of work. Part of being ready to lose your home is being ready to face this reality and it's damn tough when the compassion starts to run thin and you are living in your car. Prepare. This is all I can say. None of us want to think about these things but if nothing else, please read your homeowner's policy. Do this for yourself and your children and you can even call your agent and go over with him/her a "what if" scenario...Ask him/her, "if I lost my home today from a fire, what's next? What would be covered...what would happen." One phone call. Do it.

Prior to the Bush Administration, there was no Disaster Capitalism--in other words, folks who make a ton of money off someone else's loss. It's a cold side of capitalism but compassion has no place in capitalism. Part of the benefit of creating fear around fire is the industry this fear will excuse the term, fuel. Disaster capitalism is alive and well with the "fuels thinning" and if you want proof, note how quickly Exxon and Forestry Industry lobbyist Dr. Thomas Bonnicksen popped up after the Angora Fire. His articles were everywhere and what was his solution? Cut more trees. Well, "surprise, surprise, surprise"! The Nevada County Fire Plan capitalizes on this because the first priority of the Fire Plan is fuels treatments using "private consultants." The words of former Fire Chief, Tony Clarabut ring through my head when he declared to the Board of Supervisors years ago, "this is the creation of a whole new industry." He did not say, "we are going to save lives and property"---no, he said, "this is the creation of a whole new industry." As a fire victim, I find this appalling--we are going to make certain people money (using YOUR MONEY) off this...Disaster capitalism is one major component of the Fire Plan. I quote from page 27:

"authorize grant programs to improve the commerical value of forest biomass (that otherwise contributes to the risk of catastrophic fire, or insect or disease infestation) for producing electric energy, useful heat, transportation fuel, and petroleum based product substitutes and for other commercial purposes."

How about a grant program for fire-safe roofs? Water tanks? Barricade products? But this won't make certain people in the fire business money. HOW ABOUT A GRANT PROGRAM TO SERVE THE IMMEDIATE NEEDS OF THE HOMEOWNER TO SECURE THEIR HOME? Education is sorely needed. Do most people know even a tractor can cause a spark and start a fire? Isn't this more important than the endless removal of vegetation?

Most telling is that evacuation takes a back seat to fuels treatments when NOTHING is more important than getting people OUT of the danger zone safely. NOTHING. The Nevada County Fire Plan elevates "the whole new industry" over public safety. Watch out for Disaster Capitalism. It's in your own backyard.

The word "fuels" takes the whole of our ecosystems and biodiversity and shoves into one word that is entirely anthropocentric. Now the sum of our incredible (or shall I say, our incredibly shrinking?) ecosystems is shoved into the word "fuels" based entirely on human-determined values. This is a coup d'etat for the Disaster Capitalists because instead of seeing that beautiful old oak tree in the yard, suddenly all he plants on your property are co-conspirators destined to burn your house down. I shudder when I hear the word "fuels". They are NOT "fuels"--they are PLANTS. They are just plants. (Settle down people). They are worth far more ALIVE then dead. Our native wildlife depend on them for cover and forage. Our native plants evolved with our native wildlife so they are tied to one another. (I amused too by the lands I have seen "cleaned" in which they pile up dead manzanita then declare themselves fire safe. Standing green is less flammable then curing dead). Plants produce shade, oxygen, absorb CO2, and hold the soil and stem erosion. None of these plants spontaneously combust. They have to have a spark and where does the spark come from most of the time? Humans---and what drives the fire after it gets started? WIND. But calling all of nature "fuels" forces you to detach emotionally from any attachment you may have to the land and in fact creates an "us" versus "them" approach (and politicians love this). It will be so much easier to "clean out" your land if you just call it all "fuels". It will also require far less intellectual energy on your part because you no longer have to care what any of it is. Just call it all "fuels" and clean it out much like cleaning out a drawer or a closet. It's ever so simple.

Finally, as with everything, hypocrisy is rife in this issue. The "private property issue" almost sank the Endangered Species Act and it killed NH2020. Neither of these two things would have taken anyone's property but under the Bush Administration, the government can now seize your home for private profit and not a peep from the so-called "private property rights" sector. While I have never thought of myself as a private property rights person per se, I do own one measly acre of land and I do derive pleasure from watching the things live and grow on it. (Bunny hugger? I have tried to hug the black-tailed jackrabbits that hop through my yard but they will not have any of it). Part of the pleasure of owning my measly little acre is it is mine to manage as I see fit. I like the wildlife on my property. I like the native habitat on my property and native plants. This gives my property a whole new set of values that I treasure. In this way, I preserve a tiny piece of habitat. I make a contribution to my community in this way because my little piece of habitat performs essential ecosystem services for my whole community and our dying planet. I do not like the idea of an ecologically uneducated class of society telling me what I can or cannot have on my property based on sheer anthropocentric values. There is a proposal to require CalFire or a county fire marshal to sign off on your property in order that you may sell it. Suddenly, it looks like the sanctity of my measly little acre or even my right to sell it and get a decent return from it is going to be turned over to some other entity and this is a slippery slope with no end because at what point do you decide a place is "clean" enough? What if the judgment of Bill is not the same of Susan? More to the point, your house will possibly burn down anyway which brings me to my last general observation:

why did they pick "fuels treatment" as the priority when this has no final end point? Are the taxpayers going to pay for this forever? Also, this is not the good old days anymore where we have pristine forests. Disturbance now leads to type conversions into nonnative FLAMMABLE nonnative plants (esp. grasses). In some ways, the best thing one can default to is to leave as much native vegetation as possible as this may be all that is preventing a "takeover" by nonnative noxious plants. I do think as far as the native herbaceous layer is concerned in California, we have reached a critical tipping point and the native herb layer in California is going extinct. "Fuels treatments" will accelerate this and where you had a stand of old growth manzanita, you will end up with acres of far more flammable annual grasses. This is why ecologically ignorant personnel should not be making all the decisions about "fuels" treatment. Also, at what point are you "done"? If I clear and my house burns down, do I just clear some more and some more and some more....? Do I cut my trees down? At what point am I "fire safe"? At no point--- (and by now you may have spent thousands of dollars) and this is the truly baffling thing about this whole issue. Why not focus on the things you CAN measure that ARE known to save homes and these measures do not drain the finances and taxes of citizens? These things require true leadership and vision from our representatives but at this time, this county (indeed this country) could not be lacking more in creative leadership and vision. In fact, we seem to be at a time where we shoot for the lowest common denominator in everything--not the highest. Here is the true crux and if you will, hypocrisy of the issue:

--the on-going permitting of homes in high fire prone areas.
Recent research by fire ecologists has shown that "increasing human settlement is exacerbating fire hazard in California." "Ultimately, as more low-density housing development spreads into California's undeveloped wildlands, the greater the risk will be that more fires will ignite and that fire hazard will increase" said Dr. Jon Keeley, a USGS research ecologist...read about it at
http://www.yubanet.com/artman/publish/article_62951.shtml
--counties, such as Nevada, that actually make it EASIER to build on steep slopes.
This is NOT mentioned in the new version of the Fire Plan by the way even though
steep slopes role in fire are mentioned.
--The mixing of human health and safety with Disaster Capitalism. Disaster capitalism is contaminating this issue BIG TIME and confusing the public. Disaster capitalism makes money off of disasters and now we are even seeing this BEFORE a disaster strikes. Everyone is going to cash in. Get on the bandwagon.
--all these "fuels treatments" the agencies talk about. Who is going to pay for them indirectly through your taxes or directly? You are going to pay for them. Where is the economic analysis for all these "fuels" programs? Our money is better spent making sure you can get out safely and you can secure your home with fire safe remodeling, sprinkler systems, water tanks, etc. How about a grant program so homeowners can purchase the new barricade products that are sprayed on a home before you leave? They are leaving homes standing. This costs up to $1000 for an average home. I have a feeling this would be far more productive time and money spent then the never ending "fuels" treatments. While I reiterate that some sensible level of plant removal is warranted, the first priority of the plan should be getting out, securing your structure, then plant/vegetation removal. Grants should be available to take the measures listed above, not just to remove, and kill your plants.

From: Dr. Thomas Power from the book Wildfire: A Century of Failed Forest Policy. Page 208. Island Press. 2006.

"We actually know very little about how changes in forest structure in particular settings affect fire behavior and fire damage. In a report to the federal joint Fire Science Program, two of the nation's leading fire scientists put it this way: "Evidence of fuel treatment efficacy for reducing wildfire damage is largely restricted to anecdotal observations and simulations, and easily dismissed by skeptics. The lack of empirical data is not surprising, since it is hard to conduct laboratory experiments with full-blown forest fires. Most of the current proposals for hazardous fuel reduction are tied to computer modeling rather than to empirical analysis of how actual wildfires responded to different fuel treatments. The computer models, like all such models, whether in macroeconomics or weather analysis or other complex systems, are calibrated on the basis of a variety of previous research and informed assumptions. But this type of analysis of still modeling and simulation. Just as economic and weather forecasters rarely get it right, we cannot act as if these wildfire fuel management models represent entirely reliable "scientific fact."

Specific Comments

The plan is much improved. Kathleen Edwards was handed a huge undertaking and she has held up well under the stress from all sides, I am sure. Thanks also to the Nevada County Planning Department (Randy Wilson) the hand of which I could see immediately in this document. It covers the regulatory context, particularly from an environmental standpoint, far more thoroughly and accurately.

In spite of the improvements, the Nevada County Fire Plan should not be considered a scientific document. It is a political document with some science.

The plan does not assess what the effects of the plant/vegetation removal on climate change will be and ironically, the removal of vegetation will only worsen climate change impacts and with the worsening of climate change impacts comes the strong likelihood of more frequent fires.

The process of removing vegetation will contribute to climate change by the use of hydrocarbon fuels to remove the vegetation then the possible burning of this vegetation. Removing the vegetation will also allow greater amount of sunlight to hit the ground thereby drying out the ground encouraging the invasion of these areas with weeds and possible making these areas more fire prone. Vegetation helps mediate the impacts of CO2 levels in the atmosphere by absorbing CO2. This ecosystem service will be affected. Plants also produce our oxygen. Is the price for removing "fuels" worth it when we weigh the other impacts and costs to the planet and society? Are there other things we could be doing to more effectively spend OUR money and save our homes? YES.

One big question: IS A PERMIT GOING TO BE REQUIRED TO FUELS CLEAR AND WILL THESE PROJECTS UNDERGO ENVIRONMENTAL REVIEW? I observed a "fuels project" which included the complete mastication of 40 acres and the total destruction of a creek. Is this what we have in mind? What about the developers who want to develop their property and suddenly are overcome by concerns for public health and safety and clear their property prior to a biological survey (but it's ok, it's all for "fire safety")? Is this fair to the landowners who do the right thing?

Is an Environmental Impact Report going to be prepared on this plan?

The plan fails to elucidate on the science that what drives fires is WIND, not "fuels". It does not mention this highly proven scientific fact. The primary goal of the fire plan is still plant removal and private consultants. In some ways, it almost reads more like a Business Plan rather than a plan focused on saving lives and property.

IDEA: Prepare a county map of the locations that received the highest winds most frequently. The county may already have something like this. If there are structures, make these locations the priority for fire safety. How secure are the structures for a fire? Do they have fire-safe roofs? Sprinkler systems? How about a fire safety program based on those areas most likely to have catastrophic fires: places that get the highest winds. Then re-enact the ordinance in Nevada County banning construction on steep slopes (no structures on anything over 30% slope).

Nevada County Fire Plan Committee is still overwhelmingly represented by firefighters and foresters. It is not a multidisciplinary committee. Ideal members could have been fire ecologists and experts in fire science, biologists, botanists, specialists in fire-safe structure technology, members of the Red Cross, victims of fires, "the average Joe or Joey", and members of other sectors of law enforcement such as a representative from the police and sheriff departments.

Our ecosystems are fire-adapted but the idea that these ecosystems HAVE to have fire in order to sustain themselves is controversial.

Many people have no idea what "stewardship responsibilities" means.

Fire Fighting agencies and responsibilities are incredibly confusing to the public ("whose on first..?").

Typo on page 12. It's "public" not pubic and God forbid they start...nevermind.

Document needs to state clearly verbiage from SB 1369 which amended 1491. The public needs to FULLY KNOW that insurance companies can require greater than 100 feet and CalFire can place a lien on your home for not clearing vegetation. This is in the law. Tell the public this.

Plan talks about steep slopes but does not mention that Nevada County relaxed its own steep slope ordinance.

Excellent addition is that the new plant includes adaptive management and post-implementation monitoring. This is a strong element of the plan that as Kathleen said, makes it a "living document" meaning one the taxpayers pay for that does not end up sitting on a shelf.

Research has shown that a Community Wild Protection Plan can work. This is not a massive Vietnam-type defoliation program which is what was in the first version of the fire plan. This is building fuel break outside of communities as a first line of defense. This is an option but only if surveys are conducted in the area beforehand and nonnative plant invasions are controlled afterwards. Again, ecologically ignorant
personnel should not be making these decisions and we must weigh in the actions to make "fuel breaks" equal the benefits. One method cannot be applied across the whole landscape. Ecological assessments beforehand must be done.

Disaster capitalism is one major component of the Fire Plan. I quote from page 27
"authorize grant programs to improve the commercial value of forest biomass (that otherwise contributes to the risk of catastrophic fire, or insect or disease infestation) for producing electric energy, useful heat, transportation fuel, and petroleum based product substitutes and for other commercial purposes."

Why are all the "grant programs" to remove "fuels"?

Page 30: "Nevada County assumes no fire protection authority for providing wildfire protection service.However, the relationship between wildfire protection and development is relatively important to distinguish: CAL FIRE assumes no responsibility for wildfire protection, but has no authority to regulate development in wildfire prone areas....How property is developed and used is a matter between the county and the property owner and (the) property owner's interest in managing their property."

This begs the question, should CalFire be given the authority to weigh in on developments?

The "natural fire cycle" existed centuries ago and it is IMPOSSIBLE to restore this in light of population growth. It is also basically a near lie to tell the public that "fuels treatments" and logging mimic the old fire regimes. THEY CANNOT. If you want to saturate yourself in this fact, read the papers by renowned fire ecologist Jon Keeley.

I could comment extensively on pages 38-40 on fire and fire behavior only to say that critical new science is lacking in this discussion the least of which is
the new fire-fighting technology such as the German IFEX 3000. This is an amazing new
type of water delivery system that puts out fires far far faster and with much less water. I am learning how much research is being done in technologies to fight fires more effectively. The county should avail itself of this information as well.

Also, please read the coffee table book that can also double as a coffee table: WILDFIRE, A CENTURY OF FAILED FOREST POLICY to bring you up to speed on this topic. Keep in mind, new research is being cranked out constantly.

Page 46: "Actively engaging in vegetation management to reduce fuels to those pre-settlement "natural" levels in and around our communities in the first positive step."

Gee, what if 50% or more of the flora now is NON NATIVE WEEDS NOT PRESENT AT "PRESETTLEMENT" times and all you will do with your "treatments" is SPREAD THESE AROUND? Many of these weeds are also MORE FIRE PRONE THAN THE NATIVE PLANTS YOU WILL REMOVE! This statement is absolutely FALSE and this goal is IMPOSSIBLE and it is DISINGENUOUS of the agencies and county to present this problem in this context.

Goals and Recommendation Section

Recommended reordering of the Goals. Reorder the Goals to the following:

Goal 1: Enhance Public Safety and Emergency Services (includes evacuations)
Goal 2: Involve Stakeholders in Meeting County-Wide Goals (this could affect the emergency response so it is important)
Goal 3: Increase Community Awareness and Education
Goal 4: Fuels Treatments (Reasonable--no defoliation projects and remove
profit incentive from this plan; focus on public health and safety, not making money. This contaminates the issue. Remove Disaster Capitalism from the plan!)
Goal 5: Revise Codes and Ordinances (reinstate steep slope ordinance, my comment)

Format of report is confusing. Think about revising.

Goal 1 is Fuels Management
Recommendation is to adopt Defensible Space Guidelines (Appendix B)

Conduct Economic analysis on just what all these "fuel treatments" and "private consultants" will cost the taxpayer versus taking more definitive measures such as those mentioned above (evacuation plans and securing the structure). Most likely expenditure of funds will be better spent doing the two measures over the fuels management which has limited returns for time and money spent.

Goal 2 is Enhance Public Safety and Improve Effectiveness of Emergency Services....

In the Cedar Fire, no one came to evacuate our neighborhood. We evacuated ourselves. Include this in the evacuation discussions---there is a good chance no one will come for you. Set up citizen evacuation team leaders to help out in this situation (note I said "help out" not take control). Exchange phone numbers and set up a phone tree. Make sure the evacuation plan is one that can work INDEPENDENTLY of any
public safety agency as these personnel may not be available.

Include in this APPLICATION OF BARRIER PRODUCTS TO SAVE THE HOME including grants to purchase these products and free public demonstrations. Include grant programs to purchase water tanks and do other things to SECURE THE STRUCTURE.

GOAL III-Revise Codes, Ordinances, etc.

Reinstate the steep slope ordinance which was "relaxed" in 2004. Fire Plan "forgets" to mention this little fact.

GOALS IV and V: Increase Community Awareness and Involve Stakeholders
Priorities of this goal are those advocated for (page 62). First priority is ignition resistant construction then defensible space...Good. On the right track. Offer free demos/fairs to the public about these materials/barricade products.

Recommendation 26: Ban all burning in the county, period.

"Same practical effect" means what exactly?

Recommendation 34 is scary and why is creating a biomass reutilization center by the Fire Safe Council under Public Education and Awareness? This needs to be under FUELS MANAGEMENT. This recommendation includes "effort will result in a monetary value being placed upon removed vegetative fuels that will, at least, in part, pay for their removal." Disaster capitalism once again. Suddenly you are
fuels clearing" not for fire but to make some money. C'mon folks. Call it what it is!!! No mention that the "biofuels" created from this will contribute to poorer air quality and climate change. Again, this is folks seeing this as an opportunity to make some money. Does this help public health and safety? This recommendation and any recommendations have no place in a Fire Plan that is supposed to prioritize PUBLIC HEALTH AND SAFETY, NOT MAKING MONEY.

Recommendation 37: hold a fair at the fairgrounds STRICTLY on fire safe building materials and demonstrate techniques to secure the structure using barricade gels, etc. NO FUELS CLEARING. NO MASTICATORS. NO disaster capitalism. Let's think of the homeowners and the public.

The plan is BIG on providing private consulting services. This is repeated throughout the plan including even preparing lists of experts. How exactly does one get on this list? What are the criteria? Who do you have to know? Do they have to know anything or just own a chain saw?

Recommendation 14B: good (page 71). Sorely needed.

Appendix B should be guidelines ONLY. It is burdensome and nearly impossible to implement. As said in the last public hearing, ecological education and common sense. Let's not get ridiculous and get people out there measuring the height of their pine needles for God's sake.

Nevada County has far more than three vegetation types. You have this information at your fingertips with the NH2020 report. This section needs to be revised. It is terribly simplistic and misrepresents the ecosystems of the county.

Here is another list that is far more accurate but still does not reflect ecosystem diversity:

Annual (non-native) grasses/nonnative herbs (weeds) (this vegetation type is growing daily)
Annual Grassland/Mixed herb (native and nonnative)
Mixed Conifer
Montane Mixed Conifer
Montane Herb
Foothill Chaparral
Native Grassland
Oak woodland
Riparian
Wetland

Please prepare something that more accurately reflects the ecosystems of Nevada County. The plan does a poor job of this.

If we remove all the "understory fuels" where will the trees come from for future generations? People are wiping out seedlings and saplings. We basically have what is referred to as "museum forests" or "museum woodlands" in that nothing is coming in underneath them to replace them. This point MUST be made in ANY plant clearing.

Don't pit neighbor against neighbor!!! This could be a disaster of a different kind.

Comments on the Wildland Stewardship Program:

How is this defined?

Who is going to run this program? Pay for it? Is this yet another thing the property owner gets to pay for?

Plan is a good idea in a general sense but totally contradicts other elements of the plan such as encouraging vegetation removal.

People need to learn how to identify plants. This is the bottom line to really implementing this program.

"Framed to resolve the fundamental assumption, which is the overabundance of hazardous vegetation that fuels the wildfires, recognizes that at some point the overabundance of vegetation will results in a major disturbance, whether it is insects or disease processes or wildfire."

This statement is not true and is ridiculous. What is "overabundance" of vegetation? How is this defined? Is it defined by someone who wants to make money off your land by removing your "overabundance" of trees? This is found in other parts of the fire plan. Either cite credible scientific research or REMOVE.

Monitoring of fuels treatments by ecological scientists (that lack a resource extraction incentive) is an excellent idea.

Appendix D: No comments. Looks good. Standard environmental regulations. Question is that proposed above: when are environmental reviews going to be required for fuels treatments and will this be communicated to the public effectively?

Appendix E. All contractors should read this section.

The steep slope ordinance should be revised to greatly restrict homes on steep slopes as was the original ordinance. If this happened, it may significantly change proposed changes in Appendix E. Also, this section should incorporate the new building codes being proposed via the State Fire Marshall's office, once these codes go final.

Section L-XVI2.9: This requires continued maintenance of the cleared areas as a
condition of the permit, map and parcel. Once again placing a new economic burden on all landowners that is not included in any analysis. It even requires that the person doing the maintenance is designated in the plans. This is an incredible burden to the public. This is not included in any analysis. Do these provisions violate the California State Constitution and U.S. Constitution?

Because the effectiveness of clearing is completely unpredictable and a person's home could still burn down after considerable time and expenditure, the lack of emphasis on protecting the structure is worrisome. Appendix E is not based on the most up to date science. The placement of structures at the WUI increased the RISK of fire especially on steep slopes. This is a one size fits all provision and it is
a burden to the public, may violate constitutional protections and may not even be effective. There is NO CRITERIA for these consultants doing this work in this document. What is THEIR CRITERIA? The burden is once again, placed soley on the shoulder of the public while "private consultants" stand to make tons of money.
For the latest science on homes promoting fire, see HUMAN INFLUENCE ON CALIFORNIA FIRE REGIMES. A. Syphard et al. Ecological Applications 17 (5) 2007. pp. 1388-1402.

Appendix E should greatly expand fire-safe building construction incentives and information including DESIGN, MATERIALS, SOURCES, INFORMATION and instead of
placing the burden on arbitrary removal of vegetation which will have questionable effectiveness, switch the burden to securing the structures and provide tax incentives to do so. The emphasis, is again, on something akin to managing the sky.
"Fuels reduction" is catch as catch can, expensive, with questionable effectiveness. It can also greatly damage ecosystems and ecosystem functions. Revise Appendix E to place greater emphasis on STRUCTURE protections both in intital design and materials but also for existing homes. The information and technology is out there. (One example: www.barricadegel.com).