February 2, 2021

Dear City Council Members:

On behalf of the Board and membership of the Riviera Association (RA), we are grateful for this opportunity to comment on the Community Wildfire Protection Plan (CWPP). Founded in 1930, the RA is a non-profit organization whose membership includes residents who live on the Riviera and in the foothills immediately behind and below the Los Padres National Forest.  Since most of our membership lives in a high fire risk area, wildfire prevention and defense is of obvious concern to the Association.

We support the Santa Barbara Fire Department’s (SBFD’s) efforts to update and improve our fire plans. We’d like to thank SBFD staff, and especially Amber Anderson and Joe Poire, for the time they spent holding outreach meetings and their responsiveness to our questions. After reviewing the CWPP, the Program Environmental Impact Report (PEIR), and the prior 2004 plan, the RA does have several outstanding concerns and recommendations:

First, City parks and their vegetation types should be mapped in the City’s highest fire risk zones. On page 23 the map titled, Figure 4: Santa Barbara City Vegetation Types, shows a legend for Parkland (Up) and maps Elings and Douglas Preserve Park in that category. Oddly, none of the eight City parks in the Foothill/Extreme Foothill area are mapped. Those parks will be most at risk because they are in the “Very High Fire Hazard Severity Zone (VHFHSZ). Vegetation types for some of those parks, e.g., Franceschi and Orpet, are also missing completely. If the vegetation analysis for parks is incomplete, is the fire risk assessment and the prioritization of which areas require vegetation management inaccurate?

Second, Eucalyptus trees should be mapped in the Foothill zone where they are most prevalent. Eucalyptus trees are discussed extensively as a key “Tree/Woodland” vegetation type (Section 2.5.2). The extreme fire risk associated with eucalyptus trees is alarming: “Given average weather conditions and terrain, eucalyptus has potential for a high rate of spread, torching and crown fire, and extreme fire behavior (p. 27).”  Moreover, “the fuel build up in blue gum eucalyptus stands is very rapid, exceeding that of other tree species (p. 26).” Given their flammability, why are no eucalyptus groves mapped in Figure 4 (p. 23)?  We believe the lack of eucalyptus mapping is a serious oversight in the Foothill zone where “…eucalyptus groves within this area are extensive, dense, and have significant accumulations of dead fuel that threaten the surrounding area (CWPP, p.13).” Of special concern to our membership is the absence in the City’s analysis of the eucalyptus in Franceschi Park.

Third, Vegetation Management Units (VMUs) should include Franceschi Park. VMUs are where the SBFD plans to focus its intensive defensible space and fire abatement efforts. There are 18 VMUs in the Foothill area, and more than half of these are smaller in acreage than Franceschi Park which is 40 acres (p. 33 CWPP). As indicated on Figure 15, VMUs cover all or part of the grounds of several City-owned parks, such as Skofield, Hale, Parma, and Sheffield (p. 73). Given that Franceschi is in the highest fire risk area (VHFHSZ), is south-facing, has canyons and terrain that slopes more than 30%, has highly flammable vegetation (e.g., eucalyptus groves, chaparral, and oak trees) and is in the center of the Riviera surrounded by moderately dense housing, we’re perplexed as to why this park is not considered a priority.

Franceschi also shares a border with VMU #21 (Hillcrest Rd) and sits right between VMU #21 and VMU #2 (Jimeno/Garcia Canyon). Together, these three areas (VMU #21, #2 and Franceschi) would be a critical and formidable line of fire defense if there were another fire on the Riviera. There has already been a serious fire on the Riviera: in 1977, during the 679-acre Sycamore Canyon Fire, over 200 Riviera homes were destroyed in one night between Mountain Drive and APS. For these reasons, we’d like to know the specific criteria that were used to exclude Franceschi and include other parks as part of VMUs?

For historical context, we reviewed the 2004 Wildfire Plan and its EIR. We discovered that the City had detailed “Vegetative Fuels Management Plans” for Franceschi Park and other parks in 1993 (see Five Year Vegetative Fuels Management Plan In 1993, Incident Management Concepts). The 2004 Wildland Fire Plan called for those park fuels management plans to be updated as per Actions 10.1-4 on page 56. It’s unclear if the City or SBFD ever updated the vegetation fuels management plans between 2004 and now. If concerted fire management for Franceschi Park fell through the cracks 17 years ago, we hope the City Council will take this opportunity to reinstate it and include it as part of the VMUs in the 2021 CWPP.

Lastly, fire insurance and other financial impacts to homeowners as a result of renaming fire zones should be better analyzed and addressed. The CWPP proposes merging residents in the current Foothill and Extreme Foothill areas into a single VHFHSZ, as outlined in the policy actions section (p. 86). While the financial impacts may not cause a “physical environmental impact” as defined by CEQA, this does not absolve the City of its responsibility to provide residents with more support and analysis, e.g. information about homeowners’ legal rights to contest insurance policy changes and insights into what other local governments are doing to protect homeowners from questionable insurance practices. After the Thomas Fire, some residents’ fire insurance carriers did not renew them or raised their rates significantly. In addition to higher insurance rates, Riviera residents that plan to remodel or add to their existing homes may incur increased landscaping costs to conform with SBFD high fire hazard guidelines, as outlined in Action 3.1 (CWPP, p. 87). Finally, we believe the more accurate description of the action the City intends to take is not “to rename” but instead conform with the pre-existing CalFire fire designations. In 2007, CalFire already identified the Foothill and Extreme Foothill area as a VHFHSZ – see legend on Figure 14 (p. 69).

Thank you for listening to our concerns and recommendations.  We look forward to partnering with the City and the SBFD to educate our membership on the CWPP when finalized and we thank all involved for their efforts.

Respectfully yours,

The Riviera Association