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I have uploaded two my classmate report. Please write Contextual Comments (two-100 words) and Final Comments separately. (about 300word each, total 600)

  • Executive Summary
    California has a long history of destructive wildfires; however, the severity and frequency of
    wildfires has been on the rise in recent decades, yielding a significant increase in the amount of
    damage and destruction that comes as a result. Climate change is a known contributor to said
    increase, however this report focuses on issues in the wildland-urban interface and with utility
    companies and wildfire cost distribution. Urbanization in wildland areas creates an environment
    that is more prone to wildfires; this also leads utility companies to supply ratepayers in high-risk
    areas. California’s unique inverse condemnation laws allows for homeowners to make liability
    claims against utility companies, even if the utility was not negligent. As a result, utility
    companies are left with a higher portion of wildfire costs which then prevents their expenses to
    be put toward mitigation strategies, like utility vegetation management. If nothing is done to
    solve this problem, the situation will only get worse and may cause irreversible damage to
    California communities, land, plants, and animals. Thus, it is imperative for effective solutions to
    be enforced state-wide. Our recommendations include creating a ratepayer class for WUI
    residents to reflect the higher risks of their location choice, developing tools that better
    incorporate current and future risk into land use decisions in fire-prone areas, and reform inverse
    condemnation by eliminating strict liability for wildfires.
    In recent years, the severity and frequency of wildfires across California has increased.
    Wildfires contribute significantly to economic, environmental, and health issues for the people,
    animals, and plant life in California; thus, it is imperative to develop new, more effective
    solutions to mitigate wildfire risk. In 2020, California experienced what is recorded as the largest
    wildfire season to date; there was a total of over nine thousand fires recorded, which burned up
    about 4.2 million acres of land. The 2018 wildfire season was also considered one of the most
    destructive and deadliest in California history to date with 100 fatalities, and this trend is only
    anticipated to increase in the future (California Department of Forestry & Fire Protection 2019).
    In this report, we will evaluate significant contributing factors to the increasing severity of
    California wildfires and identify the most effective and reasonable recommendations for you to
    enact as the Governor.


    According to your (Gov. Newsom) recent Executive Order N-05-19, it is clear that
    anthropogenic climate change is well-understood to be a key contributor to the upward trend in
    wildfire severity and frequency, as well as forest maintenance practices. However, many
    scientists argue that the current approaches to managing wildfires focus on fire suppression and
    managing fuel build-up in wildlands, but that the reliance on these strategies alone has clearly
    proven inadequate (Mahmoud & Chulahwat, 2020); it is clear we must implement more effective
    Figure 1.
    The number of annual wildfires in the Western United States is increasing. The severity of said
    wildfires has similarly been on the rise. Both are projected to continue increasing if new solutions are
    not put in place immediately (Patel, 2018).

    wildfire mitigation strategies.
    The Wildland-Urban Interface
    In addition to climate change, the main causes of increasing wildfire risk and severity are
    issues with the wildland-urban interface (WUI) and utility companies. The WUI is most
    commonly defined as “an area of urban sprawl where homes and other development press
    against the boundaries of public or private wildlands or rural areas” (Macie & Hermansen, 2003).
    Over recent decades, the population of California has increase significantly, forcing more and
    more people into the WUI where wildfire risk is naturally higher. In fact, as of 2010, California
    had “more than 4.4 million homes in the wildland-urban interface, the largest number of any
    other state, representing an increase of 36 percent since 1990” (Kousky et al., 2018).

    Figure 2.
    (Left) Area burned by
    wildfires between 2000
    and 2016 across the
    western United States
    inside and outside the
    2010 WUI including a
    2.5-km community
    protection zone.
    (Right) From 20002016,






    Urban sprawl, or the uncontrolled expansion of urban areas, has also contributed to the
    number of buildings in areas more prone to wildfires. Urbanization is detrimental to wildlands
    because it directly changes forest ecosystems; deforestation, fragmentation, and other human
    disturbances affect the biodiversity of native plants and animals by destroying habitats and even
    leading some species to extinction. Additionally, urbanization alters water flow and increases air
    pollutants, which yields adverse effects on forest health (Macie & Hermansen, 2003).
    Utilities and Wildfire Costs
    Another significant wildfire issue stems from utility companies. According to Kousky, et
    al., only about 5% of wildfire ignitions in California are from electrical equipment; however,
    when they do start, they are larger and account for nearly 11% of acres burned (Kousky et al.,
    2018) because the conditions that cause powerline to start wildfires also make wildfires spread
    rapidly and thus hard to contain. One aspect under particular consideration is how the costs of
    utility-started wildfires are distributed. Utility companies have long sought to prevent wildfires
    through “Utility Vegetation Management” (UVM), in which utilities eliminate protruding
    vegetation near powerlines by trimming trees, removing bushes, spraying herbicides, and
    stunting tree-growth (Nordman & Hall, 2020). UVM costs have increased as wildfire seasons
    have gotten longer and more severe, as well as liability insurance premiums, which has
    overburdened their share of wildfire mitigation costs in California. Because utility companies
    like PG&E are unable to afford the rising costs, much of the burden further gets passed onto
    ratepayers (Nordman & Hall, 2020). Issues revolving utility companies are intertwined with the
    WUI, as more electrical equipment is required to reach residents living in fire-prone land and
    thus creating even higher risk for wildfires to occur within the WUI. Many researchers suggest
    that urban ratepayers often heavily subsidize the liabilities created by rural retail electricity users
    (Kousky et al., 2018).
    California also has unique inverse condemnation laws, in which property owners can
    effectively recover damages against a utility company without having to prove negligence. The
    effects of such policies have proven detrimental to public utility companies, as they have been
    held liable for wildfire damages without proof of utility negligence, creating a significant
    financial burden on these companies (Nordman & Hall, 2020). Inverse condemnation laws
    significantly contribute to the imbalanced distribution of costs that fall on utility companies.
    Discussion of Findings

    Issue with the WUI and utility companies go hand in hand. The detrimental effects of
    urbanization on nearby wildland increases risk of wildfire destruction. Similarly, increasing
    population size in WUI land requires more utility involvement in fire-prone areas that leads to an
    increase in wildfire occurrence and severity. As a result, public utility companies end up paying
    a greater amount in wildfire costs and therefore increases customer utility rates, while urban
    ratepayers are covering increased liability costs from rural areas. California’s inverse
    condemnation laws also allow those inhabiting the WUI to file liability claims against utilities
    without proving negligence, while ignoring the wildfire-related risks of their development into
    rural communities.
    As wildfire severity and frequency continue to rise in California, it is vital to enforce
    aggressive strategies to reduce the impact of wildfires on our communities, animals, plant life,
    and more. Increasing residency in the WUI poses many issues regarding wildfire risk and public
    utilities, and by proxy – urban ratepayers, end up subsidizing this risk. Changes to California’s
    current legislation and new policy decisions are necessary in order to mitigate death and
    destruction caused by wildfires.

    The 2020-2021 Budget Report by the Legislative Analyst’s Office recommends “the
    Legislature require the development of a statewide strategic wildfire plan,” to inform and guide
    state policymakers regarding the most effective strategies for responding to wildfires and
    mitigating wildfire risks. As such, it is important to identify and prioritize strategies that will be
    the most beneficial to California residents, land, plants, and animals. My recommendations for
    you include the following:
    Priority Recommendation
    Reform inverse condemnation by eliminating strict liability for wildfires
    Require that fire risk be quantified across geographic areas and create a ratepayer
    class for WUI residents to reflect the higher risks of their location choice
    Develop tools that better incorporate current and future risk into land use decisions
    in fire-prone areas

    The current inverse condemnation laws in California create situations in which utilities unjustly
    cover the costs of fires caused by non-negligence, leading them toward bankruptcy. These funds
    could better be allocated toward fire prevention methods, like UVM and depletion of fuel stores.
    UVM is considered the most effective mitigation strategy utilities can implement for wildfire
    prevention, however it is very expensive. Additional income from increased WUI utility rates
    would allow utilities to invest in UVM or other fire suppression costs. Lastly, as the number of
    manmade structures rise in the WUI, land use planers need tools to understand and incorporate
    current and future risks to minimize the threats of wildfire to property, and, more importantly,
    human lives. Risk maps developed by Cal Fire and California Public Utilities Commission could
    benefit land-use practices to reduce wildfire risk.


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