The Alliance for Practical Fire Safety (AFPFS) will have two representatives serving on the working group tasked with reviewing and providing recommendations to the City Council regarding the EMBER ordinance. We are committed to keeping the Alliance community informed as this important work progresses.
At AFPFS, a grassroots organization of over 500 Berkeley residents, we advocate for practical and pragmatic fire safety solutions that protect our homes without sacrificing our natural habitats, increasing erosion risks, or harming the character of our communities.
We believe in science-based alternatives and common-sense mitigation practices that are sustainable and effective. We stand with our firefighters and uphold public safety as both a mission and a shared community value.
California State’s Zone 0 law is in the final stage of validity check.
And BOF's financial calculation, revealed this weekend, of the cost to homeows is $960.
—that’s for EVERYTHING: gates, trees, plants, gravel, you name it
Here in Berkeley we have the opportunity to share what Zone 0 is actually costing.
—for example, a quote for replacing 2 gates alone came to $6,489. Others have had expenses as high as $20,000.
Since this is an emergency rule-making, the community has until this Wednesday (Sep 2) to let them know concerns.
HOW TO SUBMIT YOUR COMMENT
Email:
Office of Administrative Law
staff@oal.ca.gov
IMPORTANT: You Must Identify the filing in your subject line:
Zone 0 Defensible Space — OAL File No. 2026-0828-03E
IMPORTANT: You MUST also copy the Board of Forestry:
Tony Andersen, Executive Officer
publiccomments@BOF.ca.gov
KEEP IT PERSONAL, SHORT, AND SIMPLE
Comments are due September 2, 2026.
Zone Zero draft regulations have been distributed by the State. Their approval will be finalized once the full Board convenes. We are enclosing the URL for the draft regulations, registration for the meeting and a video explaining the changes. Please register for the meeting so you can offer support for the finalized rules or offer perspective on them.
The City of Berkeley should reconvene the WUI Working Group that assisted in the regulations to compare the existing work to the proposed state regulations as part of the process established and the commitment made by the City in the enabling directive. This will ensure review of any relevant changes.
There must always be collaborative stakeholder engagement.
FIRE AND FORESTRY COMMISSION APRIL 2026 DRAFT REGULATIONS
REGISTER FOR THE MEETING ON APRIL 23RD 1PM-7PM
A VIDEO HAS BEEN RELEASED BY CAL FIRE AND THE FIRE AND FORESTRY COMMISSION TO EXPLAIN THE DRAFT
https://calfire.app.box.com/s/3ja7vbmjy4rqwuqxhs4lr9uw2ec04khn
To:
California Board of Forestry and Fire Protection
P.O. Box 944246
Sacramento, CA 94244-2460
From:
[Your Full Name]
[Your Street Address]
[City, State, ZIP Code]
[Email Address]
[Phone Number]
[Date]
Subject: Formal Objection to Proposed Zone 0 Regulations Under AB 3074 – Request for Revisions
Dear Members of the California Board of Forestry and Fire Protection,
I am writing to formally express my strong objection to the proposed Zone 0 vegetation clearance regulations released in the June 10, 2025 draft, pursuant to Assembly Bill 3074. While I support the goal of reducing wildfire risk, the current draft adopts a rigid, one-size-fits-all approach that departs from the intent of AB 3074, bypasses critical scientific findings, and could unintentionally make some communities less safe, less livable, and ecologically degraded.
1. Increased Fire Risk
Requiring the removal of all vegetation within 5 feet of structures risks creating wind tunnels that accelerate ember movement toward buildings. This was evident in the Palisades Fire, where cleared areas contributed to rapid ember travel and structure exposure. Strategically placed vegetation can act as a buffer, not just a hazard.
2. Scientific Consensus
Leading fire ecologists such as Dr. Jon Keeley have shown that certain types of vegetation can slow ember spread and reduce heat exposure when properly managed. The current draft does not incorporate this growing body of peer-reviewed, field-based research, favoring a removal model not rooted in site-specific evidence.
3. Environmental Damage
Mass vegetation clearance—particularly in urban areas—will have cascading environmental consequences, including:
4. Legislative Mismatch
AB 3074 was designed to establish a collaborative, science-informed process that respects regional differences, financial realities, and environmental impacts. The June 10 draft falls short of that legislative mandate by proposing one-size rules with limited flexibility and no clear mechanism for local discretion.
To bring the Zone 0 rules in line with California’s diverse geography, urban needs, and scientific understanding, I respectfully urge the Board to:
If enacted as written, these regulations could require homeowners and municipalities to remove or radically alter nearly all vegetation within 5 feet of buildings, including privacy hedges, foundation plantings, and community landscaping. Non-compliance could even be criminalized.
This extreme approach risks degrading neighborhoods without meaningfully improving fire safety. By ignoring science, local knowledge, and environmental impacts, the Board would be enacting rules that are neither practical nor effective.
We can—and must—do better.
Please revise the proposed Zone 0 regulations to reflect the true intent of AB 3074: fire safety through collaboration, scientific integrity, regional sensitivity, and environmental stewardship.
Sincerely,
[Your Full Name]
[City or Affiliation, if desired]
[Email and/or Phone Number]

* Woodmont block household: $8000
* Creston block household: $7200
* Grizzly Peak block household: $6500
* Wildcat Canyon household: $12,750
* Sunset block household: $5300
* Vistamont block household: $12,500
Average household cost: $8,700

CALIFORNIA NATIVE PLANT LIST
https://firesafesdcounty.org/wp-content/uploads/2017/05/Comprehensive-Fire-Resistant-Plant-List.pdf
"“Findings indicate that properly selected, irrigated, located, and maintained urban vegetation is not always complicit in building loss during fire events.”
overall housing density and characterises (i.e. patterns) were more influential than local-scale vegetation in determining building loss outcomes (Schmidt 2022; Syphard et al., 2021). However, our parcel- level study complements other studies from California such as Kramer et al, (2019) and Syphard et al. (2021), by focusing on factors that have previously been little studied, specifically vegetation composition, type, moisture and location relative to burned buildings (Tables 2). . . our study is one of the first to specifically analyze the influence of parcel-level 3.0 m resolution: vegetation type, densities, and moisture as well as its distance and direction relative to DSB and building loss (Figs. 5, 6 and 7). . . . Findings indicate that properly selected, irrigated, located, and maintained urban vegetation is not always complicit in building loss during fire events. Furthermore, we corroborate how dense urban or suburban developments (i.e. 2–9 structures within 30 m; Tables 4 and 5) are more susceptible to widespread building damage during wildfire events; regardless of parcel-level or landscape-level vegetation fuel characteristics. And as expected, burning buildings likely acted as sources of not only embers, but direct flame contact and radiant heat that can ignite nearby structures as shown by Suzuki et al. (2014). . .
Specifically the use of well-maintained urban vegetation types near homes for climate regulation, aesthetics, and human well-being versus the increased risk of wildfire and home ignition due to increased fuels adjacent to homes. . . We also document how tree, shrub, and herbaceous moisture in yards are better predictors of building loss – or survival − than just percent vegetation cover alone. Indeed according to our urban chaparral model, homes with nearby trees with higher NDWI moisture content were more likely to survive. This influential role of high moisture tree cover – relative to other factors- in home survival has rarely been documented."
https://www.sciencedirect.com/science/article/abs/pii/S0169204625001288?via%3Dihub
"A postdoc study analysis has discovered some quick numbers out of the new CALFIRE tree canopy cover dataset
"Unfortunately Berkeley already saw a tree canopy cover decrease in Zone 0 in the last few years.
An analysis of 21,318 buildings in the city, gathered this summary:
Across all risk categories, even in Non-Wildlands areas, vegetation cover decreased over these four years.
These results are only for Zone 0 (the first 5 feet surrounding buildings), so we’re already getting a sense of how much vegetation would need to be removed to comply with the new regulations (87.6 acres more and less 66 American football for some reference).
While canopy cover loss is a general trend across CA and elsewhere, we need to ensure that new policies are sensible and grounded in science and hard evidence."
We welcome all interested community members to participate as part of our steering committee. Please email us directly at afpfs120@gmail.com
Stay Connected and Informed
Berkeley, CA, USA
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