ATTACHMENT 14. Bill Balson. From: Sent: To: Subject: Bill Balson [ ] Wednesday, March 11, :39 PM 'Duffy Price' RE: WUI Issue

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1 Bill Balson ATTACHMENT 14 From: Sent: To: Subject: Bill Balson [ ] Wednesday, March 11, :39 PM 'Duffy Price' RE: WUI Issue Hi Duffy, I'll outline my present concerns, with two caveats. First my research is incomplete so I might modify my opinions in light of what I learn in the future. Second, these ideas are not a complete statement of what I've learned, just a good faith response to your questions. Risk management deals with the probability of damage (sometimes called the hazard) and the magnitude of damage. State Fire has recently completed a thorough update of the state fire hazard maps. These maps are intended to assess the likelihood and severity of a wildfire, so they are an incomplete risk assessment as they do not deal with the damage aspect. Nonetheless, the maps are used by a wide array of state and local agencies as well as private companies engaged in insurance. The maps are created through a assessment of lot-specific risk factors such as moisture, slope, and fuel load. The result is a lot-specific hazard rating for most of the state. The relevant hazard ratings for the mid-peninsula are High and Very High. All of Los Altos Hills lots are rated High. Most of the neighboring Towns are also rate High. There are small areas of Cupertino and Portola Valley that have recently been rated Very High, probably due to slope factors. In Southern California, large areas are designated Very High. The distinction between High and Very High is quite important for insurance purposes and also for building code purposes. Many insurance companies will not insure a home in a Very High rating zone. Los Altos Hills has a separate set of ordinances for Very High zones and High zones, which mostly arises by incorporation of the State Building Codes. Los Altos Hills has additionally adopted several practical code requirements irrespective of the fire hazard rates. Two of those are Class A roofs and chimney spark arrestors. Studies going back to the 1970s confirm the cost-benefit value of these building features. The definition of a WUI is separate from the State classification of fire hazard. It is based primarily on the distinction between rural/wildland and urban areas. As a result, it is possible to have a scenario in which a lot is in a designated WUI zone that has no reasonable nexus to lots designated Very High hazard. In fact, most of Los Altos Hills is a prime example of this scenario. Historically, all of Los Altos Hills has followed the building codes for High zones. Nonetheless, the default building code is now that lots in WUI zones must comply with building code requirements that are unique to Very High zones. Presumably LAH will be required to comply with the Very High codes. The high-benefit requirements like Class A roofs and spark arrestors are not the problem. But, there are a host of more onerous and expensive building code requirements that have a less compelling cost-benefit rationale in LAH. Outdoor decks are highly restricted if not banned outright. Severe restrictions cover roof overhangs and patio gazebos. Exterior storage buildings must be nonflammable. Commonly seen design features of LAH homes may be prohibited. These building code requirements for the Very High zones were developed and justified largely for Southern California situations. The landscaping requirements for the Very High zones are also restrictive, but are ambiguous without detailed research by a homeowner. The requirements are violated by virtually every lot in LAH: Evergreen shrubs next to a house, mulching a garden along the exterior wall of a house, trees within 10 feet of a house, trees within the drip zone of each other, fire-laddering all trees, etc. In fact, some of the Town's landscape screening requirements for new building permits may violate the requirements for Very High zones. One component of the landscaping requirements involves the distinction between flammable and nonflammable landscaping. But, there is no uniformly agreed definition of flammable plants. These requirements may make good sense within the Very High zones, but there is no data I can find that presents any case, much less a compelling cost-benefit case for all those measures in the High hazard zones. My personal experience is that there is a verv low risk of wildfire damage in LAH based on mv insurance rates. I reolaced mv cedar roof with a

2 From: Sent: To: Cc: Subject: Bill Balson [ Thursday, March 19, :13 PM Steve Padovan; jima.pc@gmail.com; 'Jitze Couperus'; 'John Justice'; 'Jim Abraham'; 'Melvin Vaughn'; j Suzanne Avila; Jeanne Evilsizer; 'Duffy Price' RE: Los Altos Hills WUI Map Update Subcommittee Meeting Thanks everyone for a great first meeting. I mentioned a few times the role of cost-benefit studies as a partial way to examine the merit of proposals to reduce risk, which is the aim of the WUI regulatory structure. While cost-benefit studies are an incomplete analysis, they form a useful step in assembling the information on the social benefits and social costs of proposals to reduce wildfire risk. Since, many people are not too familiar with the specifics of cost-benefit studies I want to offer a hypothetical and highly simplified illustration using some of the information that various folks at yesterday's meeting pointed out. Clearly a hypothetical is not a substitute, but it can offer some ideas and guideposts for balancing the choices to be made. One relevant observation Yitze made was the very real risk of wildfire, and the Liddicott fire some years back was the prime illustration, in which about a dozen homes were destroyed in Another relevant observation by Jim was that the WU I-required building modifications added about $50k to a recent home construction he was familiar with. A cost-benefit study can help make these disparate facts more comparable. For example, measured in today's home prices (median home value of $3m net of the lot) the homes destroyed represent an economic loss of $36,000,000 which is a substantial sum. However, the risk to all homes in LAH over the relevant period of time at risk is also relevant. There were about 2800 households in LAH in So, we can calculate that there was an average wildfire damage of $12,857 /household in today's dollars over the 30-year period. There are many variations on that calculation that are worth testing. Perhaps LAH was lucky and the average frequency in Santa Clara is higher. Perhaps, we've taken substantial mitigation steps that reduce the risk below the historical observation. Perhaps home prices are higher, or in some cases lower. Perhaps a range of scenarios is even more appropriate. Perhaps the wildfire damages should be expressed as a probability of a large event} rather than averaged over all homes. (On a probabilityper-year-per-household basis 1 it's a risk of 3/1000, which is less than the likelihood of a severe earthquake, a car accident, or a fall down the home stairs.) Perhaps environmental and other values should be added. But 1 the resulting wildfire damage estimate, however expressed, should than be compared to the resources we require homeowners and the town to expend to reduce that risk. The California insurance department examined various homeowner perils in 2004 focusing of water damage. Surprisingly, the most frequent peril claimed is water damage from overflowing toilets, washing machines, etc. They examined at the zip-code level all claims in California for a three-year period. They found that in about 5% of "exposure-years" homeowners file a claim for water damage and that the average claim was $6-11,000 depending on the zip code. To put that on a comparable basis to the calculation above, the average water-related damage per household over thirty years would be $16,500 (using the high end of the range of claims). So, roughly speaking, LAH's historical wildfire-related home damages based on Liddicott are comparable or even a bit less than the more mundane water damages. But, we spend many times more on fire protection than water-damage prevention 1 or a host of other perils with which homeowners must contend. The high value mitigation LAH residents already take such as a Class A roof, chimney spark arrestors, tree removal, brush removal, disking, etc. are likely equal to or more than the Liddicott-based historical damage estimate. And 1 that comparison assumes full risk mitigation 1 when in fact the WUI mandates are only a partial risk mitigation. So, when it is opined by Mel that $50,000/house is not so much to spend, the question arises What is the probability-weighted benefit to the typical household? Bill Balson file:// IC :/U sers/spac\ovan/ AppData/Local/Microsoft/Winc\ows/Temporarv%20Internet% /2015

3 SMALL FIRES -INFRASTRUCTURE -FUEL LOAD REDUCTION -RAPID RESPONSE MODERATE FIRES -DEFENSIVE ZONES -CLASS A ROOFS -PREVENT/SLOW SPREAD LARGE FIRES -MUTUAL AID -COMMUNICATION -COMMON EQUIPMENT BENEFIT OF EXTREME DEFENSIVE MEASURES -SPRINKLER RETROFIT -VH ZONE BUILDING REQUIREMENTS EXTREME FIRES -EVACUATION -WEATHER CHANGE -BURN OUT.!Et, FEW

4 Wildfire Risks in Los Altos Hills Are Low and Getting Lower Through Existing Plans for Fuel Reduction, Defensive Zones, and Class A Roofs By Bill Balson This paper is an overview of some issues confronting the City Council in determining which lots, if any, within Los Altos Hills should be required to apply building codes that would have the effect of altering the design of eaves and prohibiting common deck designs, among other actions. 1 The purpose of defining a Wildland Urban Interface (WUI) is to apply greater regulatory controls over the risks due to wildfires, principally through the building code and fire code. 2 Wildfire risk arises as a special concern in Los Altos Hills as a result of environmental conditions such as the buildup of fuel in the form of dead biomass and the low moisture content due to lack of rainfall in the summer. 3 Rapid response by firefighters to an initial wildfire alarm is critical, so an additional environmental factor is slope, which can slow access by fire fighters. Cal Fire has evaluated each lot in Los Altos Hills based on fuel load, moisture content, and slope steepness as part of its statewide wildfire hazard assessment. CalFire refers to their detailed quantitative analysis as a hazard assessment because it deals with the likelihood of a wildfire and not the magnitude of the potential damage caused. 4 Wildfires can be started by natural causes, such as lightning, and manmade causes, such as discarded cigarettes. However, most wildfires are caused by people and a large percent are intentionally set. Wildfires are rarely initiated as a result of a residential fire, although many residences in California have been destroyed as a result of wildfires. There are thousands of wildfires in California every year, most of which are small and rapidly extinguished. 5 Los Altos Hills has less fuel accumulation, greater ground moisture, and more moderate hillsides than many areas, consequently the frequency of wildfires is much lower than elsewhere in California and even elsewhere in Santa Clara County. 6 Many parts of Los Altos Hills receive roughly twice the annual precipitation as other areas of Santa Clara County. 7 CalFire's hazard assessment categorizes most areas using its quantitative methodology. The category "Very High" is used to refer to areas of the state with the highest hazard arising from fuel loading, low moisture, and steep slopes. For example, the San Diego hillsides covered with dry chaparral are Very High. A few locations near Cupertino and Portola Valley are categorized Very High. 1 The facts described in this paper are based on the information submitted to the WUI Subcommittee of the Los Altos Hills Planning Commission and additional information cited. The author reserves the right to amend any opinions stated herein based on additional information provided by the committee. 2 WUI is defined by state law but implemented by local agencies. California Fire Code Chapter 49, Section "The establishment of limits... shall be designated... by a local agency... following a finding... that the requirements are necessary for effective fire protection... ". 3 See Cal Fire documentation b1!:.j2.jfwww.fire.ca.gov/fire prevention/fii:g_qrevention wildland zones maps.phg 4 Together, hazard combined with damage potential is often considered to equate to risk. 5 The Liddicott fire in 1985, attributed to arson, is the worst fire in Los Altos Hills experience, in which nine homes were reportedly damaged. On a historical claims basis, wildfire damages in Los Altos Hills are lower than commonly experienced damage claims such as water damage from overflowing washing machines. 6 The Santa Clara Unit completed its Fire Management Plan in Page iii shows all county fires between Page iv shows fuel load ranking, with no Very High zones in Los Altos Hills. Page 12 shows the types of wildfires by vegetation classification. 7 National Weather Service data reported by San Jose Mercury News and altos hills is highly variable depending on altitude. 1

5 The category "High" or "Moderate" is used to categorize most other non-urban areas. All lots in Los Altos Hills are categorized as Moderate or High. 8 The distinction between High and Very High hazard zones has both a regulatory and an insurance application, which apply risk assessment in different but related contexts. In California, only a few home insurance companies will insure a home within a Very High hazard zone. Almost all insurance companies that offer home insurance in California cover fire risk in Los Altos Hills 9 in part because all lots are rated at the lower hazard category and in part because of the Town's proactive mitigation. 10 Premiums for home insurance are elevated in Very High hazard zones due to the higher wildfire risk.11 However, within High hazard zones few insurance companies separately rate 12 a home for wildfire risk despite the fact that there are well-known observable risk-factors, such as shake roofs. 13 The lack of pricing sensitivity arises due to the low overall risk posed by wildfires within Los Altos Hills compared to the numerous other risks that homeowners face. Wildfire risk, viewed by a homeowner or their carrier, is one of many causes of a residential fire. Residential fires are dominated by kitchen fires as ignition sources. 14 Wildfire damage is not high on the list of claim histories kept by insurance companies and reported to the state insurance department even though it warrants continuous vigilance. 15 Water damage due to broken faucets or washing machine overflow is the single largest damage category according to those claim histories. Continuous efforts by communities over many decades have mitigated overall average-annual wildfire damages despite increasing home values and increasing number of homes. 16 The number of residential fires nationally peaked in 1980, annual civilian fire-related deaths peaked in 1978, and annual residential fire damage peaked in In California, the acres burned, the number of wildfires, and the number of structures destroyed in 2013 was near the ten-year average in spite of dry conditions Fire Management Plan, pp See also Los Altos Hills Hazard Mitigation Plan, 2013, p Los Altos Hills Hazard Mitigation Plan, 2013, p. 13 (Chapter 23 of Santa Clara County Hazard Mitigation Plan) 10 See Los Altos General Plan, Safety Element, 2007, p.11; see also minutes of the Los Altos Hills County Fire District Board of Directors reporting the removal of over 100 dead trees and dozens of eucalyptus trees as a result of its free program ( 11 Specialty fire insurance carriers such as Einhorn Insurance exist and a pooled-risk carrier of last resort is supported by the industry. Jn the highest hazard zones, insurance companies use detailed models similar to Cal Fire but more granular, and contractually require specific property modifications regarding roofs and defensive zones. 12 Rating is a procedure in which an insurance carrier makes adjustments to a base premium to account for divergences of the property from a typical property. 13 In one recent anecdotal example in Los Altos Hills replacing a 30-year old untreated shake roof (worst possible roof) with a Class A composition roof (best possible roof) had no impact on the homeowner's premium. 14 "Home Structure Fires", National Fire Protection Association (NFPA) "Spatial Analysis of Frequency and Severity for Water versus Non-water Homeowners Claims in California", California Department of Insurance, See for example "Homeowners Wildfire Mitigation Guide", University of California See also the Santa Clara Firesafe Council athttp:// 17 "Fire Loss in the United States 2013", Michael J. Karter, Jr., NFPA, September "Wildfire Activity Statistics (Red book)", CalFire, These annual reports began in

6 Regulatory risk management includes a host of risk mitigation actions in both High and Very High zones. 19 Building codes in both High and Very High zones prohibit shake roofs, which have been known since the 1970s to increase the potential for a wildfire to propagate since burning embers can land on the wood roof and easily start a fire. In Los Altos Hills, shake roofs are prohibited or required to be treated to provide equivalent Class A protection. Just as importantly, fuel load reduction is conducted by the Town, by the Fire Department, and by homeowners. These fuel reduction actions include removal of eucalyptus trees, which are highly flammable, removal of dead trees, and creation of fire breaks. An important element of controlling wildfire risk is rapid response and the Fire Department's fire-fighting capability is designed for that purpose. Water access in most of Los Altos Hills for firefighting is gravity fed, removing an important risk factor compared to historical fires in other communities. Fire access requirements are part of the Town's building codes and enforced by the Fire Chief. These include street width, driveway turnarounds, brush reduction, and fire hydrant placement among others. The U.S. Fire Administration routinely conducts an ex-post analysis of the causative factors in major wildfires. The conclusions of several of these reports are instructive in assessing the effectiveness of Los Altos Hill's overall efforts at wildfire risk mitigation. For example, in a Pebble Beach fire 20 all homes with shake roofs were destroyed, while all homes with a composition roof and a defensive zone survived. High winds, slow access, and poor water access were contributing factors in Pebble Beach. Some wildfires are too severe for a residential home to survive in spite of risk mitigation efforts. In the Oakland Hills fire, the Diablo winds fanned temperatures to such an extreme that cars were melted and homes were ignited by radiant heat. 21 When a home is ignited by radiant heat, building code requirements such as eaves, decks, roofs, windows, and fire sprinklers would have no benefit. Fortunately, the risk factors involved in slowing the spread of wildfires are well-known and the lessons learned have been applied in Los Altos Hills. These lessons fall into two categories: infrastructure for firefighting and homeowner property management. Infrastructure includes reliable water access, reliable communications, common equipment standards 22, and adequate access. In Los Altos Hills, the periodic Fire Management Plan by Battalion 3 anticipates and actively improves each of these mitigation factors. 23 Homeowners are responsible by ordinance for mitigating risks of propagation on their lots through vegetation management, defensive zones, and accessibility Risk mitigation refers to the actions taken in response to risk factors and are typically designed to reduce the probability-weighted damage from all possible fires through a combination of reducing the likelihood of ignition, the speed of response, the tendency of a fire to propagate, and/or the resulting damage from a wildfire. 20 "Urban Wildlands Fire; Pebble Beach, California", US Fire Administration, "The assessment team noted that no structure was lost that had a combination of composition roofing, double pane windows, PRC 4291 compiiance, and landscaping." Landscaping was defined as removal of most native vegetation and planting of typical landscaping varieties that are less flammable. PRC 4291 included items like a 30 ft defensive zone, brush removal, spark arrestor, and similar mitigations that are required in LAH. 21 "The East Bay Hills Fire", US Fire Administration, "... the exposure caused by burning trees and brush was often sufficient to cause interior ignitions by radiant exposure through windows." "The intensity of the exterior fire exposure was so severe that interior automatic sprinkler systems had no value in protecting the structures from ignition." 22 In the Oakland Hills, responding fire departments had hoses that did not fit the fire hydrants. 23 Battalion Three, Fire Protection Plan 24 Los Altos Hills Municipal Code, Chapter 2 3

7 The Town Council faces a decision regarding the selection of which lots, if any, to include within the designated WU!. This responsibility is delegated to the Town by the enabling legislation. 25 The regulatory consequence of the WUI is to apply the building code requirements defined for the Very High hazard zones to all lots within the WUI, even where those lots were judged by Cal Fire to have the lower hazard zone of Moderate or High. 26 There are some situations in other cities (e.g., Portola Valley) where a lot is judged High, but is next to a Very High zone, and thus prudence might warrant higher caution. All lots in Los Altos Hills however have been judged by CalFire to be in the Moderate or High hazard zone. Moreover, all lots bordering on Los Altos Hill's lots have similarly been judged to be in the High hazard zone. None are rated Very High hazard. Combined with the claim history of insurance carriers, this is powerful direct evidence that Los Altos Hill's residents have adequately controlled risk due to wildfires. No risk is zero, but added measures to reduce the risk of wildfires in Los Altos Hills is not necessary in light of the Town's extensive mitigation measures, the Cal Fire hazard designation, and existing building and fire codes. The necessary risk mitigation actions that could be taken are already required for all Los Altos Hills lots whatever action is taken with regard to the proposed WUI maps. The additional building code requirements that would be applied to lots included in a WUI are not otherwise required by virtue of Cal Fire hazard categorization for Los Altos Hills. These relate, for example, to the design of eaves and decks. The risk mitigation benefit of these building code requirements would occur in a hypothetical fire in which the fire was severe enough to ignite a home despite a defensive zone and Class A roof, but not so severe that the home would ignite irrespective of protective measures (e.g. by radiant combustion as in the Oakland Hills fire). Despite, extensive data collection efforts by CalFire, by the U.S. Forest Service, and by insurance carriers; the data evaluated by the WUI Subcommittee reveals not even a single instance of a home in a High hazard zone that was saved by those added requirements but that would have been otherwise lost. The reason for the lack of data is not for want of sufficient examples of wildfires, but because the existing regulatory requirements within High zones have been adequate risk mitigation. There is therefore no measurable homeowner benefit to applying those additional building code requirements in Los Altos Hills, other than a homeowner's own preference for their own residence. There are fundamental questions of equity that would arise by applying two different sets of wildfire building codes to different properties in Town that are nearly identical from a wildfire risk perspective. 27 The public has direct access to the Cal Fire hazard assessment through an online tool allowing the public to enter their street address and obtain the CalFire hazard ranking (i.e. Moderate, High or Very High). Since, all lots in Los Altos Hills have been judged to be in the Moderate or High category, any property owner using the CalFire tool will quickly discover the truth that there is no substantial difference in risk motivating the expenditures they would be required to undertake. 25 California Fire Code Building codes for lots in Very High hazard zones are severely restricted by regulation motivated by the higher hazard. For example, overhanging decking is prohibited, among other restrictions. 27 No study by a local agency has been offered to the WUI Subcommittee contradicting or amending the Cal Fire hazard assessment. Moreover, the Town's Hazard Mitigation Plan explicitly cites Cal Fire's assessment. 4

8 Occasionally Asked Questions Does climate change increase the risk of wildfires? Climate change is thought by the Santa Clara County Water District to reduce the snow pack and has the potential to diminish the amount of water captured by California reservoirs. 28 Climate change may also increase the propensity for drought conditions in California. Precipitation in Los Altos Hills was slightly below average in 2014 despite the drought conditions for our water supply. 29 As a result ground moisture in Los Altos Hills is not exceptionally low this year, but was affected in Ignition sources of wildfires, such as lightening and cigarettes, are unlikely to be materially affected by climate change. Climate change could affect the moisture content of Los Altos Hill's lands through increased droughts and water restrictions, but would not affect the slope or fuel load. CalFire hazard rankings could be altered by an increase in drought conditions. Insurance carriers have recently increased fire insurance rates in areas with Very High hazard ratings by CalFire, partly justified by drought conditions. 30 Wildfire damage claims in Moderate and High hazard zones have shown no trend over the past decade. 31 Is there a shared community risk due to wildfires? Yes, and everyone must do their part. The largest quantifiable reduction in the risk of wildfire propagation is due to roofs, fuel load reduction and defensive zones, which are required of most land owners in Los Altos Hills (CalTrans and Foothill College being the main exceptions). The application of Very High hazard building codes to some lots in Los Altos Hills has no demonstrated material benefit to the risk of wildfire propagation. 32 Shouldn't homeowners bear the cost of wildfire firefighting? Yes. And they bear more than their fair share now. Cal Fire attempts cost recovery from people that cause fires, but private homeowners bear the remaining cost of firefighting though fees, parcel taxes and income taxes. Government entities, such as Foothill College and CalTrans; and nonprofits like churches, who aren't required to pay taxes, do not pay their fair share. Private homeowners make up the difference. Moreover, Los Altos Hill's ordinances cannot require state entities to comply with prudent fire-related risk management practices. 28 Santa Clara County Water District ( 29 Drought is a multiyear phenomenon so even though 2014 was near normal, a single year does not end the drought. Moreover, 2014 was a warm winter leading to an historically small snow pack and little runoff into reservoirs. 3 Cody Drabble, "California Wildfires Drive Up Insurance Costs For Homeowners", Capital Public Radio, Inc., "Wildfire Activity Statistics (Red book)", Cal Fire, A properly maintained defensive zone and Class A roof can save a house surrounded by a wildfire, except in the most extreme fires, as demonstrated both during wildfires and in controlled experiments as cited herein. The additional building code requirements developed for Very High hazard zones have no empirically demonstrated added benefit to Los Altos Hills homeowners and residents in Moderate and high hazard zones in information reviewed. 5

9 Shouldn't the Town enforce the highest building code measures on homeowners to protect them? The specific building codes that would be applied to WU! homes that are not already applied throughout Los Altos Hills are entirely beneficial to and are the expense of specific homeowners. So, community shared risks are not at issue, as they are for Class A roofs and defensive zones. The Town should apply a neutral cost-benefit standard to building codes that are motivated to protect homeowners. For example, fire sprinklers in new homes have a positive cost-benefit because the reduction in insurance costs outweighs the cost of the sprinklers. The additional building codes at issue in a WU! do not have a positive cost-benefit relationship based on CalFire analysis and empirical data. So, while some homeowners might choose them, the Town should not require them. Since many Los Altos Hills residents are wealthy, isn't money not important to them? The building code requirements at issue in the WU! are likely to cost tens of thousands of dollars per home and tens of millions in total. Moreover, most Los Altos Residents are not wealthy in terms of how they live. Many simply bought a California ranch many years ago and now face exorbitant taxes. Application of the Town's threshold for permitting remodels could easily turn a desired modest remodel into a teardown costing millions. Are homeowners' lives at risk in wildfires? Wildfires that get out of control can claim lives as did the Oakland Hills fire. Most civilian lives are lost in wildfires due to failure to follow evacuation orders and/or failure to practice safe evacuation procedures. Regulations on eaves and decks are unlikely to materially affect resident behavior during an evacuation order. Dying in a residence during wildfire is significantly less likely than dying in a fall on the stairs of a residence. 33 NFPA reports that the risk of dying in a residential fire 100 years ago was more than ten times greater than today. Are the lives of firefighters at risk in wildfires? Yes. Firefighters risk their lives to save resident lives and to save property. Even so, job-related death rates for firefighters are less than the average for all jobs. 34 Nationwide, about half of firefighter deaths are due to cardiovascular events among volunteer fire departments resulting from over exertion and lack of physical preparedness. Los Altos Hill's firefighters are typically professionals who are well trained. However, the relevant issue is whether the building codes at issue would make a difference. They would not because wildfire propagation risk would not be improved relative to the existing building codes applicable to High hazard zones. Firefighters' risks are primarily mitigated by appropriate investments in infrastructure, which make communication and coordination more effective. Firefighters' risk often arises from dangerous situations that could have been avoided by better commination and coordination. Of National Vital Statistics System, Centers of Disease Control and Prevention, 2015 ( deaths. htm) 34 Bureau of Labor Statistics, "Injuries, Illnesses, and Fatalities",

10 firefighter fatalities between during wildfire operations, the major causes of death were vehicle and aircraft accidents, burnovers, and heart attacks. 35 Would wildfire risks be reduced if all new development in Los Altos Hills were prohibited? No. Los Altos Hills is mostly developed already. Most new building occurs on existing lots with designs that are beneficial to the whole community due to increased energy efficiency, water efficiency, accessibility, landscape design, and easements. The Town's commitment to one-acre lot minimums and slope ordinance are substantial factors in mitigating the propagation risk since the distance between homes is rarely within 100 feet of each other. Areas like the Oakland Hills in contrast have average lots sizes of just a quarter acre, frequently placing homes within 30 feet of each other. Are Los Altos Hill's streams and creeks a special concern not considered by Cal Fire for wildfires? Not in terms of the proposed application of WUI building codes. Creeks in Los Altos Hills tend to have both more vegetation and more moisture than surrounding land. Creeks can provide a natural fire break to wildfire propagation due to the moisture content of the ground. 36 In the CalFire methodology, both fuel load and moisture is considered. However, the issue is best analyzed in terms of the creeks' potential for propagating wildfire from one lot to another. Since all lots in Los Altos Hills, including lots that span creeks, are categorized as High rather than Very High hazard, no creek could be a pathway to transmit a wildfire from a Very High hazard zone into the Town. Shouldn't the Town Council just define Los Altos Hills as Very High hazard to avoid the perception that there is higher risk? Risk perception is a two-way street. Wildfire risk in Los Altos Hills is empirically low because the Town and its residents are proactive. Communicating to the public that risks are higher than the empirical data describe might motivate extra protective efforts. It also might motivate prohibitive insurance premiums and forestall real estate transactions, ultimately resulting in less protective measures due to lower property tax revenues and fewer upgrades of 60-year old homes. What is the program called Firewise? It is a wildfire educational program operated jointly by National Fire Protection Association (NFPA), USDA Forest Service, the US Department of the Interior, and the National Association of State Foresters. What is the Santa Clara Firesafe Council? An association of dozens of fire departments, large land owners/managers, corporations, homeowners associations and individuals who develop local programs for the reduction of built- 35 National Wildfire Coordinating Group, PMS841, John Weir, "Conducting Prescribed Fires: A Comprehensive Manual", 2009, p

11 up hazardous fire-prone vegetation and the creation of informed communities with respect to Defensible Space, general fire safety, and fire's effect and role in our environment. What is Headwaters Economics? It is an 8-person research group led by Ray Rasker based in Montana. They have produced a series of papers focused on wildfire related to"... private land within 500 meters of forested federal land." They argue that preventing development near federal forests would reduce the costs of fighting wildfires born by the U.S. Forest Service. 8