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I feel an urgent need to summarize some key points which I feel must be highlighted in our conversations about establishing a more accurate and acceptable Wildfire Risk Map under SB 762. We know that ODF is aware of and working on addressing the unacceptable degree of inconsistencies stemming from computer modeling and lack of ground-truthing. However, the conversation needs to double down on identifying other important flaws so that we aren’t served up a “revised” map with the same problems as the first. We only have a limited amount of time before ODF moves forward. Together we can work to identify what needs to be addressed. To my eye, this will include redrawing WUI lines and putting more emphasis on road accessibility, availability of local fire responders, and local wind patterns, as I will describe in this letter. I believe these items must be adequately addressed by rule makers, or else new legislation will be needed to restore or update the law.
Under the proposed map model, we have seen that entire neighborhoods and watersheds with excellent road access and good fire response ISO ratings could be mislabeled as extreme risk. This is in stark contrast to our actual observations and experience during past fire seasons. Highest risk has historically been observed along the interface between public/private forestlands and residential areas, especially in the more remote reaches. In order to arrive at a more accurate determination of high risk areas, local access and fire response must be considered. I would propose that there should be no “extreme” ratings within easily-accessible populated areas, except along recognized wind corridors to address the rare but troubling threat of runaway urban fires such as the Almeda Fire. Why not look at the number of fire incidents in each neighborhood which hop to adjacent properties before being extinguished? That would provide some true evidence-based data. Broadspread assignment of high and extreme risk across entire local populations acts to obscure the ability to discern where the elevated risk actually exists. If every property is labeled extreme risk, then how do we know which properties are at a greater risk? Under the SB 762 model, we have already seen the potential for pushing most homeowners into higher categories than warranted by actual conditions and insurance claims indicate. To make matters worse, the appeals process only provides for moving one step down the scale even if the property in question was previously considered to be a far lower rating.
In addition to more accurate mapping of risk, the re-drawing of the WUI outline is critically important. It must be revised so that it serves its intended purpose of delineating the “edge” or overlap where yearly fires in unpopulated public forestland can occasionally spill over to rural residential properties. This should be a single line following the edge of forestlands, leaving any expansive developed areas outside its reaches- only small residential inlets would need to be included. Illogical WUI islands within the larger residential areas should be removed from the risk map, considering that local fire responders have complete access to these areas from all sides through developed areas. Furthermore, to accomplish the purpose of distinguishing a zone of elevated risk, the WUI width must be decreased from 1.5 miles to a figure more representative of typical spread of fire across residential properties. In many cases, nearby adjacent roadways could be used as an appropriate border since they are commonly utilized as fire lines. Any excess in the width of the WUI will obscure the actual areas of higher risk and unfairly penalize landowners, so the line must be drawn with care. The Obenchain Fire of 2020 represents the most severe recent wildfire in our two local counties, with 33 homes lost. A WUI line drawn per my suggestions would encompass the entire footprint of this and other severe wildfires in our area.
Accordingly, the definition of WUI criteria in 629-044-1011 must be completely revised so that it can be mapped in a logical way. Any part of its criteria which duplicates the calculation of the fire risk ratings is a redundancy which needs to be removed so that the two separate components of the model (WUI and risk ratings) can function as separate layers. Reduction of the WUI criteria to reflect a single line demarking the transition to unpopulated wildlands is the best way to make the process understandable and fair to landowners, and put to rest much of the need for the expensive appeals process.
I would ask everyone to merely consult their own common sense- neighborhoods with active fire departments within easy reach should not be given a blanket extreme risk category. I would go a step further in suggesting that extreme risk does not exist in most residential settings with good fire response, and this category should be used sparingly. Fires within most populated areas are extinguished promptly due to simple visibility- This is why the largest fires start in remote areas- these fire starts are not detected until they are large or cannot be controlled promptly due to accessibility. In Josephine and Jackson Counties, our wildland fire response is outstanding, and despite decades of yearly fire events our structural losses adjacent to wildfires continue to be low.