Tree Loss Equals more Forest Fires

The WA Building Code Council care of Bumbalov, Stoyan (DES)

Washington's State Building Code Council (SBCC) in November 2022 adopted a Wildland Urban Interface Code (WUIC). As of March 15, 2024, ALL new developments, homes, and expansion-oriented remodels located in yellow and red areas shown in this Department of Natural Resources map must abide by this new Code.

The Code's intent is to reduce the loss of life and property due to wildfires. It includes extensive building 'hardening' requirements, which wildfire science unanimously shows IS very effective.

Unfortunately, the adopted code also requires removal of most trees and vegetation in a “defensible space” up to 100 feet around any structure. Wildfire science does NOT support this immense scale of landscape removal.

As national wildfire expert Chad Hansen wrote, "This is not about cutting down trees; in fact, it is important to maintain tree cover for the cooling shade it provides. Defensible space is about reducing the most combustible material immediately adjacent to homes, especially dry grass, seedlings and shrubs, lower limbs (prune them to 6 feet above the ground), limbs that touch the house or deck (remove these, but not the tree), and dead leaves and pine needles on the ground."

Over time, the WUIC's defensible space provisions will denude a growing percentage of the landscape in virtually all communities in western Washington -- wherever new or remodel construction occurs, which in our high-growth state will be extensive.

Additionally, the defensible space provisions are in conflict with numerous other state and local policies, such as for climate action, urban tree canopy retention, stormwater and shoreline regulations, SEPA requirements for critical areas and wetlands, and more.

It is important to save this large number of trees because of the carbon and pollutants they draw down every year and store, because they do stormwater management - including recharging aquifers, have positive health and mental health benefits, provide needed wildlife habitat, protect against drought and landslides, provide summer cooling and winter warming effects for nearby buildings, and ironically the loss of their drawdown heats the planet making more forest fires likely.

Want to learn more? See the white paper to the SBCC and an Association of Washington Cities letter to the SBCC here.

Sponsored by
Olympia, WA

To: The WA Building Code Council care of Bumbalov, Stoyan (DES)
From: [Your Name]

To: The Washington State Building Code Council
From the Undersigned:

The passage of SB 6109 in 2018 requires the use of ignition-resistant building construction with no reference to defensible space around residences. We were unaware until recently the impact the Wildlife Urban Interface code will have on our communities. Similarly, the 2020 Wildlife Urban Interface map referenced in the WWUIC was intended by the Washington Department of Natural Resources to be used for guiding home-hardening, not to create defensible space.
It is our strong belief the WWUIC code will interfere with the following state laws and mandates:

Besides conflicting with local jurisdictions’ codes for tree preservation and re-planting, stormwater retention, and slope stabilization, the defensible space part of the WWUIC conflicts with the following state-level codes or regulations:

– WA State Urban Forest Management Plan (RCW 76.15.005)

– WA State Climate Commitment Act’s carbon sequestration goals

- WA State Growth Management Act, Chapter 365-190, which requires counties to protect habitat, including wetlands and critical areas, and to prepare for climate change.

-WA Critical Area Regulations

-WA Shoreline Regulations

-WA Stormwater Regulations

-WA State DNR's Small Forest Landowner Program

It is our belief the code has many unintended consequences:
Climate change impacts, water impacts, an unacceptable amount of tree loss, loss of heating and cooling functions and other eco services trees provide, effects on housing costs, the development process and ironically, through increased emissions, the possibility of increased wildfires.

For the above reasons we ask the SBCC to leave defensible space out of this code cycle and use the next three years to work on a plan that does not create large and unacceptable consequences.