Public Comment at Board of Forestry Zone 0 Event, April 23, 2026

Good afternoon Committee Members and Foresters.     

I have worked in facilities management for residential and large-scale commercial properties for decades, and in my professional view the cost of zone 0 conversions presented today are delusional.  Moreover, and once again, not one image in today’s presentations represents  homes like mine or many of my neighborhood’s homes.

I take living in the fire hazard zone seriously, which is why I started studying the published peer-reviewed fire science decades ago.  That’s why I know that the problem is that you’re using a conifer forest model to solve an urban fire problem.  Published peer-reviewed science and work from scientists such as Dr Jack Cohen acknowledges that mismatch.

So, I’m not going to comment about 1 foot or 5 feet.  If the model is wrong for the urban environment, no amount of fine-tuning the rule will make it right because the fatal flaw in your rule is that you are using a conifer forest model to solve an urban fire problem. 

I have 2 documents here on my desk right now that acknowledge that mismatch.

The first is an email from on-again-off-again retired fire chief Dave Winnacker to Committee Member J. Lopez. 

In that email, Chief Winnacker explicitly acknowledges that our legacy wildfire safety approach—developed for conifer timber landscapes—is not optimized for dense suburban and urban environments, and that the BOF should  introduce a different, more appropriate approach.

That’s a remarkable statement, because it confirms what many of us have been saying: the model you are using does not fit the environment you are regulating here. 

And yet, despite that acknowledgment, this new rule continues to rely on that same legacy framework—focusing on live green vegetation in the urban environment as the primary driver of risk within five feet of structures.

The second document reinforces why that matters.

A recent study in a controlled testing of structure-to-structure fire spread from IBHS shows that in wind-driven conditions, once structures ignite, fire spreads from building to building in a domino effect, with density and spacing determining loss—not nearby vegetation. Not plants within 5 feet of the house.  Not at all. 

Now, to be clear—vegetation can play a role in ignition if it’s dead, poorly maintained, water deprived or droughty. No one is disputing that.

But what the IBHS research shows is that under extreme wind conditions, once structures ignite, fire spreads from building to building in a domino effect. That’s what drives large-scale loss in communities.

So the question isn’t whether vegetation can ignite. The question is whether focusing policy on vegetation within five feet of a structure addresses the driver of loss in the urban environment.

And the evidence says it does not.

So we have a clear disconnect between what is acknowledged and what is being implemented.

If your own materials recognize that the conifer forest model is not appropriate for urban conditions, then continuing to base policy on that model is not a refinement—it’s a fundamental error

Experts have identified the mismatch—but this rule still institutionalizes it.

If the model is wrong, the rule won’t work—so I’m asking you to fix the model before finalizing the rule or choose option 4 and 2, which actually works for the urban environment.