HomeMy WebLinkAbout2025-10-22 PC PacketPage 1 of 2
Planning Commission
Regular Meeting
AGENDA
(to be held both at the physical and virtual locations below)
Civic Center Council Chamber ♦ 300 Seminary Avenue ♦ Ukiah, CA 95482
To participate or view the virtual meeting, go to the following link: https://us06web.zoom.us/j/83128884939
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Alternatively, you may view the meeting (without participating) by clicking on the name of the meeting at
www.cityofukiah.com/meetings.
October 22, 2025 - 5:15 PM
1. CALL TO ORDER
2. ROLL CALL
3. PLEDGE OF ALLEGIANCE
4. AB 2449 NOTIFICATIONS AND CONSIDERATIONS
5. APPROVAL OF MINUTES
5.a. Approval of the Minutes of October 8, 2025, a Regular Meeting.
Recommended Action: Approve the Minutes of October 8, 2025, a Regular Meeting.
Attachments:
1. 2025-10-08 PC Draft Minutes
6. APPEAL PROCESS
All determinations of the Planning Commission regarding major discretionary planning permits are final unless a written appeal
stating the reasons for the appeal is filed with the City Clerk within ten (10) days of the date the decision was made. An
interested party may appeal only if he or she appears and states his or her position during the hearing on the decision from
which the appeal is taken. For items on this agenda, the appeal must be received by November 3, 2025, before 5:00 p.m.
7. COMMENTS FROM AUDIENCE ON NON-AGENDA ITEMS
The Planning Commission welcomes input from the audience. If there is a matter of business on the agenda that you are
interested in, you may address the Planning Commission when this matter is considered. If you wish to speak on a matter that
is not on this agenda that is within the subject matter jurisdiction of the Planning Commission, you may do so at this time. In
order for everyone to be heard, please limit your comments to three (3) minutes per person and not more than ten (10) minutes
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per subject. The Brown Act regulations do not allow action to be taken on audience comments in which the subject is not listed
on the agenda.
8. SITE VISIT VERIFICATION
9. VERIFICATION OF NOTICE
10. PLANNING COMMISSIONERS REPORT
11. DIRECTOR'S REPORT
11.a. Receive Community Development Director's Report (October 2025).
Recommended Action: Receive Community Development Director's October 2025 Report and
discuss questions with Staff.
Attachments:
1. Planning Division Projects Report (October, 2025)
12. CONSENT CALENDAR
The following items listed are considered routine and will be enacted by a single motion and roll call vote by the Planning
Commission. Items may be removed from the Consent Calendar upon request of a Commissioner or a citizen in which even
the item will be considered at the completion of all other items on the agenda. The motion by the Commission on the Consent
Calendar will approve and make findings in accordance with Administrative Staff and/or the Commission recommendations.
13. UNFINISHED BUSINESS
14. NEW BUSINESS
14.a. Consideration of Adoption of Resolution Providing the Planning Commission’s
Recommendation on a Proposed Ukiah City Code Ordinance to Establish the Open Space (O-
S) Zoning District.
Recommended Action: Adopt a resolution making the Planning Commission’s report and
recommendation to the City Council on a proposed amendment to the Ukiah City Code by adding
Article 11.5 to Division 9, Chapter 2, to establish and regulate the Open Space (O-S) Zoning
District.
Attachments:
1. Draft Ordinance - Open Space Zoning District
2. Draft Resolution - Open Space Zoning District
3. Draft Findings of Consistency - Open Space Zoning District
4. 14a PC Correspondence Received - Commissioner Johnson rev 10-21-25
15. ADJOURNMENT
Please be advised that the City needs to be notified 72 hours in advance of a meeting if any specific accommodations or interpreter services
are needed for you to attend. The City complies with ADA requirements and will attempt to reasonably accommodate individuals with
disabilities upon request. Materials related to an item on this Agenda submitted to the Planning Commission after distribution of the agenda
packet are available at the Civic Center 300 Seminary Ave. Ukiah, CA 95482; and online at: www.cityofukiah/meetings/ at the end of the next
business day.
I hereby certify under penalty of perjury under the laws of the State of California that the foregoing agenda was posted on the bulletin board at
the main entrance of the City of Ukiah City Hall, located at 300 Seminary Avenue, Ukiah, California, not less than 72 hours prior to the meeting
set forth on this agenda.
Kristine Lawler, City Clerk
Dated: 10/16/25
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Agenda Item 5a.
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CITY OF UKIAH
PLANNING COMMISSION MINUTES
REGULAR
Civic Center Council Chamber ♦ 300 Seminary Avenue ♦ Ukiah, CA 95482
Virtual Meeting Link: https://us06web.zoom.us/j/83128884939
October 8, 2025
5:15 p.m.
1. CALL TO ORDER
The City of Ukiah Planning Commission held a Regular Meeting on October 8, 2025. The meeting was
legally noticed on October 1, 2025. The meeting was held in person and at the following virtual link:
https://us06web.zoom.us/j/83128884939. Chair de Grassi called the meeting to order at 5:15 p.m.
CHAIR de GRASSI PRESIDING.
2. ROLL CALL
Roll was taken with the following Commissioners Present: Jacob Brown, Devery Montaňo, Rick
Johnson, Mark Hilliker, and Alex de Grassi. Staff Present: Jesse Davis, Chief Planning Manager and
Kristine Lawler, City Clerk.
3. PLEDGE OF ALLEGIANCE
The Pledge of Allegiance was led by Commissioner Montano.
4. AB 2449 NOTIFICATIONS AND CONSIDERATIONS
No notifications or considerations received.
5. APPROVAL OF MINUTES
a. Approval of the Minutes of August 27, 2025, a Regular Meeting.
Motion/Second: Hilliker/Montano to approve the minutes of the September 24, 2025, a Regular
Meeting, as submitted. Motion carried by the following Roll Call votes: AYES: Brown, Montaňo,
Johnson, and Hilliker. NOES: None. ABSENT: None. ABSTAIN: de Grassi.
6. APPEAL PROCESS
Chair de Grassi stated the appeals deadline date is October 20, 2025, before 5:00 p.m.
7. COMMENTS FROM THE AUDIENCE ON NON-AGENDA ITEMS
No public comment was received.
8. SITE VISIT VERIFICATION
Commissioners confirmed their site visit.
9. VERIFICATION OF NOTICE
The Clerk noted that the agenda was properly noticed.
10. PLANNING COMMISSIONERS' REPORTS
Presenter: Commissioner Johnson.
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Minutes of the Ukiah Planning Commission October 8, 2025, Continued:
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11. DIRECTOR’S REPORT
a. Receive Community Development Director’s Report.
Presenter: Jesse Davis, Chief Planning Manager.
No public comment was received.
Report was received.
12. CONSENT CALENDAR
No items on the Consent Calendar.
13. UNFINISHED BUSINESS
No items on Unfinished Business.
14. NEW BUSINESS
a. Adoption of Resolution Approving the Prezoning of One (1) City-owned Parcel (APN 167-
280-15), Located at 1 Carousel Lane, to the Public Facilities (PF) Zoning District and
Application of the General Plan Public (P) Land Use Designation.
Presenter: Jesse Davis, Chief Planning Manager.
No public comment was received.
Motion/Second: Johnson/Brown to adopt a Resolution (PC Reso 2025-04) recommending that the
City Council approve the prezoning of one (1) City-owned parcel (APN 167-280-15), located at 1
Carousel Lane, to the City’s Public Facilities (PF) zoning district and apply the General Plan Public (P)
land use designation; and determine the action is categorically exempt from CEQA pursuant to
Guidelines §15319, Class 19(a)(Annexations of Existing Facilities and Lots for Exempt Facilities).
Motion carried by the following Roll Call votes: AYES: Brown, Montaňo, Johnson, Hilliker, and de
Grassi. NOES: None. ABSENT: None. ABSTAIN: None.
15. ADJOURNMENT
There being no further business, the meeting adjourned at 6:16 p.m.
____________________________
Kristine Lawler, CMC
City Clerk
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Agenda Item No: 11.a.
MEETING DATE/TIME: 10/22/2025
ITEM NO: 2025-1191
AGENDA SUMMARY REPORT
SUBJECT: Receive Community Development Director's Report (October 2025).
DEPARTMENT: Community
Development PREPARED BY: Craig Schlatter, Community Development Director
PRESENTER: Jesse Davis, AICP
ATTACHMENTS:
1. Planning Division Projects Report (October, 2025)
Summary: Planning Commission will receive the Community Development Director's Report and discuss
questions with Staff.
Background: Director's Reports are bi-monthly oral reports given by the Community Development Director on
the status of projects, primarily within the Planning Division, of the Community Development Department.
Updates may include, but are not limited to, application status of major and minor discretionary permits, the
implementation status of advanced planning and related 2040 General Plan programs and projects, and
updates related to the activities of other divisions of the Department.
Discussion: This report is expected to provide updates in the following areas:
• October 2025 Planning Division Projects Report (Attachment 1)
o This is a monthly report produced on the first of each month. The October 2025 report and
previous monthly reports are located on the Planning Division Services web-page, under
"Current Planning Reports":
o https://cityofukiah.com/community-development/planning-services
• Any updates since the previous Director's report at the Planning Commission's meeting on October 8,
2025, will be provided verbally during the meeting.
Recommended Action: Receive Community Development Director's October 2025 Report and discuss
questions with Staff.
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Permit #Site Address Date
Submitted Summary of Project Status
17-3069 1294 N. State St. 7/11/23
Resubmitted Site Development Permit to allow for construction two retail suites
(including one drive-through), within the Community Commercial (C-1) zoning
district at the "Old Tackroom" location. Original submittal 9/13/17; initial DRB
evaluation on January 25, 2018; Resubmittal 8/29/25.
Agency Referral: Responses Due By 10/9/25
PA24-000020/21 534 E. Perkins St.12/23/24
Major Site Development Permit of APN 002-200-43 within the Pear Tree Center,
approximately 150 feet west of the E. Perkins St./S. Orchard Ave. intersection.
The proposal includes the construction of a ±1,700 sq. ft. Starbucks retail,
operating as carry-out and drive-through only, with no interior dining, and a total
gross building area, including the outdoor canopy, of approximately 2,885 sq. ft.
Incomplete/awaiting applicant response - February 2025
PA25-000015 1201 Airport Park Blvd.8/18/25
Minor Site Devleopment Permit to facilitate façade and signage alterations to an
existing restaurant in the Airport Industrial Park Planned Development (AIP-PD)
Retail Commercial Land Use Designation
Design Review Board (DRB) recommended approval on
9/25/25; Zoning Administrator (ZA) public hearing scheduled
for 10/2/25.
PA25-000016 295 Brush St.8/29/25
Director's Determination to facilitate parking lot improvements to an existing
facility used for religious assembly in a Heavy Commerical (C-2) zoning district
per Use Permit No. 01-29 (Eastern Catholic Mission of Ukiah), approved in
2001
Agency Referral: Responses Due By 09/15/25
PA25-000019 1240 Airport Park Blvd.9/10/25
Major Site Development Permit and Lot Merger of APNs (180-080-74; 180-080-
75) converting a ±7,129-square-foot structure into an an ‘Urgent Care and
Administrative Office’ within the AIP-PD Mixed-Use Airport Industrial Park
Planned Development.
Agency Referral: Responses Due By 10/01/25; DRB Hearing
Scheduled 10/24/25
#LLA25-000005 401 Cooper Lane.9/23/25
A Lot Merger that mergese three contiguous parcels to facilitate the
development of a 15-unit Inter-Tribal Elder Village: Parcel 1 (APN 003-582) –
approximately 0.64 acres; Parcel 2 (APN 003-572-18) – approximately 1.75
acres; Parcel 3 (APN 003-572-17) – approximately 0.19 acres
Agency Referral: Responses Due By 10/03/25
City of Ukiah
Submitted Planning Applications
10/1/2025
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ATTACHMENT 1
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General Plan
Element
Implementation
Program Date Due Description Status / Comments
Land Use E - Zoning Code
Amendments 12/31/2025
Zoning districts and map consistency with the 2040 Land Use diagram.
This Ordinance Amendment will facilitate the creation of an Open
Space (O-S) zoning designation, as envisioned in the Ukiah 2040
General Plan. The designation seeks to preserve and manage areas of
significant natural value, such as wildlife habitats, riparian corridors,
creeks, and scenic resources, while supporting community resilience
and sustainable land use practices.
On 10/22/25. the PC will hold a public
hearing to consider a proposed
ordinance establishing regulations for an
Open Space (O-S) Zoning District,
consistent with previous workshops
conducted on 01/08/25 & 05/28/25, and
the City’s 2040 General Plan.
Land Use E - Zoning Code
Amendments 12/31/2025
Zoning amendment to establish a consistent program for new signage,
streamlining the application process and implementing design
standards. This Ordinance Amendment addresses goals related to
lighting, community character, and consistency across zoning
designations, focusing on reducing poor signage that detracts from the
built environment.
Completed. Updated sign ordinance
adopted by City Council (CC) on 6/4/25.
Effective: 7/4/25.
Land Use E - Zoning Code
Amendments 12/31/2025 The City shall amend the Zoning Code to addres the following topics:
Downtown Zoning Code and Design Guidelines
In progress. Commissioner Hilliker
selected by PC to provide input to
Downtown Zoning Code City Council Ad
Hoc Committee. Committee met in
August 2025; scheduled to meet again in
late-October 2025.
Environment &
Sustainability
H - Cultural and Historic
Registry 12/31/2025 The City shall update the list of cultural and historic resources worthy of
nomination to state or national preservation lists.
In progress but will be deferred until after
the historic preservation ordinance is
developed and adopted.
City of Ukiah
2040 General Plan Implementation
Overview
10/1/2025
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General Plan
Element
Implementation
Program Date Due Description Status / Comments
Environment &
Sustainability
I - Historic Preservation
Ordinance 12/31/2030
The City shall adopt a Historic Archaeological Preservation Ordinance
to review permanent changes to the exterior or setting of designated
historic or impacts to Archaeological resources. Among other topics,
the Ordinance should address the following: archaeological resource
impact avoidance, new development in historically sensitive
neighborhood, compatibility of energy conservation retrofitting, design
review standards for new structures replacing demolished historic
structures, and requirements for preservation of records and artifacts
from demolished historic structures.
In progress.
Environment &
Sustainability
M - Adopt a Municipal
Climate Action Plan
(CAP)
12/31/2025
A Climate Action Plan (CAP) and a Climate Adaptation & Resilience
Strategy (CARS) are currently being prepared. Together, the CAP and
CARS will establish a strategic roadmap for how the City will reduce
greenhouse gas emissions, prepare for climate hazards, & build a more
resilient community.
Completed. Climate Action Plan
adopted by the City Council at a Public
Hearing on 05/21/25.
Economic
Development
A - Economic
Development Strategy 12/31/2025
The City shall prepare, adopt, and regularly update an Economic
Development Strategy, which shall be used as an operational guide to
implement the economic development goals and policies of the General
Plan.
Economic Development Strategy
currently deferred until the City's
reorganization application is further
progressed.
Agriculture E - Reduce Regulation
for Local Agriculture 12/31/2025
Ordinance Amendment to bring consistency to create a new
Administrative Use Permit (AUP) process in the City of Ukiah’s Zoning
Code. The new process would allow certain low-impact uses, which are
currently subject to a public hearing, to be reviewed and approved by
City staff if they meet specific standards. The ordinance also introduces
detailed criteria for uses such as noncommercial animal keeping,
outdoor sales, community gardens, live entertainment, and specialty
food and beverage tastings. The goal is to simplify the review process
for qualifying projects while maintaining protections for neighbors and
the surrounding community.
Zoning Reform Ad Hoc Committee met
to discuss the ordinance on 07/23/25.
City Council Introduction and Public
Hearing held 08/20/25. Adoption
scheduled for 09/03/25.
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General Plan
Element
Implementation
Program Date Due Description Status / Comments
Housing Element
3c - Explore other
policies and regulations
that facilitate new infill
housing development
3d - Facilitate
improvements to permit
processing to
streamline housing
development
Completed/Ongoing
An ordinance amending the Ukiah City Code in response to comments
from the California Department of Housing and Community
Development (HCD). This ordinance updates the City’s zoning
regulations to implement state law requirements for Accessory Dwelling
Units (ADUs) and Junior Accessory Dwelling Units (JADUs) pursuant to
Government Code Section 65852.2, establishing and expanding
ministerial allowances. The ordinance also amends, removes, and adds
regulations in response to written findings issued by HCD on April 24,
2025.
Zoning Reform Ad Hoc Committee met
to discuss the ordinance on 07/23/25.
City Council Introduction and Public
Hearing scheduled for 08/20/25.
Adoption scheduled for 09/03/25. On
09/17/25, HCD reviewed the City of
Ukiah’s ADU Ordinance No.1244 and
found it to be substantially compliant with
State ADU Law.
Agriculture
Element, Land
Use Element
C - Align Agricultural
Standards Completed/Ongoing
Align City Agricultural Standards with those of Mendocino County; and
Development Pattern LU-7, to ensure the orderly and timely growth and
expansion of the City.
On 10/08/25, the PC will consider
prezoning one unincorporated parcel,
Assessor’s Parcel Number (APN) 167-
280-15, addressed as 1 Carousel Lane,
to the Public Facilities (PF) Zoning
District, applying the Public (P) land use
designation under the City’s 2040
General Plan. The prezoning is proposed
in anticipation of, and to facilitate,
annexation of the property into the City
of Ukiah.
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Agenda Item No: 14.a.
MEETING DATE/TIME: 10/22/2025
ITEM NO: 2025-1192
AGENDA SUMMARY REPORT
SUBJECT: Consideration of Adoption of Resolution Providing the Planning Commission’s Recommendation
on a Proposed Ukiah City Code Ordinance to Establish the Open Space (O-S) Zoning District.
DEPARTMENT: Community
Development PREPARED BY: Jesse Davis, Chief Planning Manager, Darcy
Vaughn, Assistant City Attorney
PRESENTER:
Jesse Davis, AICP; Blake Adams, Chief
Resilience Officer; Katherine Schaefers,
Planning Manager
ATTACHMENTS:
1. Draft Ordinance - Open Space Zoning District
2. Draft Resolution - Open Space Zoning District
3. Draft Findings of Consistency - Open Space Zoning District
4. 14a PC Correspondence Received - Commissioner Johnson rev 10-21-25
Summary: The Planning Commission will review a proposed ordinance to create an Open Space (O-S)
zoning district in Ukiah City Code. The proposed zoning district aligns with the Ukiah 2040 General Plan
Open-Space land Use Designation, and aims to protect land for agriculture, natural resources, recreation,
scenic preservation, and hazard mitigation.
Background:
On December 7, 2022, the Ukiah City Council adopted the Ukiah 2040 General Plan, which includes a clear
directive to enhance open space preservation through coordinated planning and regulatory tools. The various
elements of the plan emphasize alignment with Mendocino County’s land use policies, focusing on the
protection of agricultural lands, watershed areas, scenic resources, and wildlife habitat. A key implementation
priority identified in the General Plan is the creation of a dedicated Open Space (O-S) Zoning District. This
district would formalize the purpose, standards, and protections for lands designated as open space and serve
as a compatible implementation tool for the Public (P), Recreational (REC), Agriculture (AG), and especially
the Open-Space land use designation. The City's Safety Element and Public Facilities Element also
emphasize the need for such a zoning district, particularly to protect the community against hazards while
providing opportunities for recreation, education, and community access to the City’s open spaces.
At its January 8, 2025, regular meeting, the Planning Commission initiated workshop discussion on
establishing an OS zoning district. The conversation focused on clarifying the intent of the existing General
Plan open space designation, particularly in areas such as the Western Hills, which were recently annexed
into the City. Key topics discussed included the role of open space zoning in supporting habitat preservation,
wildfire resilience, recreational access, and long-term watershed protection. The Commission also discussed
the need to distinguish Ukiah’s zoning standards from Mendocino County’s, particularly by discouraging
incompatible uses such as mining and major utility infrastructure, both of which are currently allowed under the
County’s open space district per Chapter 20.104 of Mendocino County Code. The Commission emphasized
the importance of public access, trail connectivity, and maintaining the natural character of sensitive areas.
Following this initial workshop, staff reconvened with the Planning Commission at the Commission's meeting
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on May 28, 2025, with a draft of the proposed O-S Zoning District ordinance for discussion. The Commission
reviewed preliminary zoning language, including draft definitions, permitted uses, development standards, and
administrative roles. A focal point of this workshop was the identification of publicly owned lands potentially
suitable for the proposed OS designation. Areas discussed included the Western Hills, Eastern Hills, Riverside
Park, the former Doolin Creek Fish Hatchery, and portions of Low Gap Park.
During the second workshop, Commissioners offered feedback on the following topics:
• Setbacks and development allowances, such as residential units;
• Clarification of permitted agricultural activities; and
• Cross-departmental responsibilities for managing open space areas (e.g., Community Development, Public
Works, and Community Services).
At that time, the Planning Commission voiced support for the proposed open-space zoning district as a key
implementation tool for the General Plan and as a proactive approach to preserve Ukiah’s open space
resources. Staff has since refined the ordinance (Attachment 1) to incorporate the Commission’s input and
now presents the final draft for public hearing and a formal recommendation to the City Council via an adopted
Resolution (Attachment 2). As recommended and requested by the Planning Commission, staff has removed
previously allowed residential uses (Caretaker/Ranger Station), aligned agricultural terminology and definitions
with existing regulations, and clarified allowable uses that would require a separate plan review and approval
(e.g., conservation, fuel management, and habitat restoration plans).
In addition to advancing local planning goals, the proposed O-S Zoning District directly supports broader state-
level general plan mandates and conservation initiatives. Specifically, the ordinance aligns with the intent of
California Government Code Sections 65302 and 65560–65570, which require cities to implement the Open
Space and Conservation Elements of their General Plans through concrete regulatory measures. By
establishing a dedicated zoning classification for open space, the City establishes a framework for identifying,
conserving, and managing open-space lands consistent with evolving State priorities such as climate
adaptation, natural resource protection, sustainable land use, and equitable public access.
The ordinance also supports the goals of California’s 30x30 Initiative, which seeks to conserve 30 percent of
the state's lands and coastal waters by 2030. The O-S Zoning District contributes to this effort by ensuring
durable protection of identified lands, restricting incompatible uses, and promoting ecological conservation,
including the preservation of wildlife habitat, water resources, and wildlife corridors. The zoning framework
also helps ensure these goals are maintained over time through enforceable standards, aligning Ukiah’s local
efforts with the State’s long-term conservation strategy.
Discussion: The draft Open Space (O-S) Zoning District represents a key implementation step of the Ukiah
2040 General Plan. The proposed ordinance establishes a dedicated zoning district to preserve and manage
lands identified for open space use, consistent with the City’s long-term vision for natural resource protection,
recreation, and hazard avoidance. The intent of the O-S District is to provide a clear regulatory framework that
supports conservation and compatible public access, while ensuring the long-term protection of the City’s most
valuable environmental and scenic resources.
A central focus in the development of the O-S District was the creation of open space–specific definitions that
reflect the City’s policy direction and regional context. Staff based draft definitions on input from City
Departments, the Ukiah 2040 General Plan, County of Mendocino Chapter 20.104 (Open Space Zoning
District), the City of Walnut Creek’s Open Space zoning regulations, and relevant State definitions, ensuring
consistency with contemporary open space management practices. Each definition was developed to clearly
describe allowable activities within open space areas while maintaining the district’s conservation intent.
Examples include rewilding, habitat banking, native plant propagation, environmental education centers, and
non-obtrusive towers. These terms provide regulatory clarity and ensure that the City’s zoning language aligns
with both state conservation policy and regional standards, reducing ambiguity in the review and
implementation of future open space projects.
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The proposed ordinance also introduces a comprehensive setback framework designed to protect
environmentally sensitive areas and minimize visual, slope, and stability impacts. A minimum 100-foot setback
is required from creeks, wetlands, and mapped sensitive habitats. Additional setback provisions apply to
hillside areas to maintain slope stability and minimize grading. Of particular note, the O-S District establishes a
reverse setback requirement for adjacent development. This means that new projects on properties adjoining
designated open space lands must also provide transitional yards to ensure compatibility, maintain scenic
character, and prevent encroachment into open space areas.
Although the O-S District identifies several uses as allowed by right, most activities will still require
environmental review and approval under the California Environmental Quality Act (CEQA). Even seemingly
minor improvements such as trails, signage, or restoration work may require formal CEQA determination when
located near sensitive resources or habitats. This ensures that all projects are carefully evaluated and that
potential environmental impacts are avoided or mitigated in accordance with State law.
To further protect resource values, the O-S District requires that most activities occur as part of an approved
Conservation, Fuel Management, Habitat Conservation, or Grazing Plan. Activities such as vegetation
management, slope stabilization, or trail construction must therefore demonstrate consistency with an adopted
management plan to ensure that they contribute to long-term ecological resilience and land stewardship. This
structure provides a coordinated approach to implementing conservation and wildfire resilience goals across
open space lands, similar to how the City recently approved the Lookout Peak Trail environmental review.
At this stage, staff emphasizes that all properties proposed for the O-S zoning designation will be publicly
owned lands. Public ownership ensures appropriate stewardship, equitable access, and alignment with the
City’s management responsibilities. Privately owned parcels will not be rezoned to O-S until suitable long-term
protection mechanisms such as conservation easements or acquisitions are in place to ensure consistent
management.
The City’s next step will be to identify and apply the O-S zoning designation during the upcoming Zoning and
Land Use Map update later this year. At that time, staff will bring forward a formal zoning map amendment that
applies the O-S district to appropriate publicly owned parcels, including areas such as the Western Hills,
Eastern Hills, Riverside Park, and Low Gap Park. This phased approach allows adoption of the regulatory
framework now while ensuring that its application is methodical and consistent with the City’s comprehensive
mapping update.
The proposed O-S Zoning District also draws from Mendocino County Code Chapter 20.104 (Open Space
District), which historically guided open space and conservation land management within the unincorporated
areas surrounding Ukiah. While the County’s zoning code provided a valuable reference point, the City’s
approach intentionally diverges in several key areas. The County’s Open Space District permits limited
residential development, mineral extraction, and certain municipal or utility infrastructure, including renewable
energy facilities. While these activities may be appropriate in a rural county context, they are inconsistent with
the City’s policy direction for urban-adjacent open space lands. Within Ukiah, such uses would introduce
impacts and intensities incompatible with the City’s conservation, recreation, and resource management
objectives. Staff does not discount the potential appropriateness of those uses but identifies them as more
suitable within the Public Facilities (P-F) Zoning District or similar designations that can accommodate
infrastructure and energy-related projects while maintaining operational flexibility.
Pursuant to Section 15183 of the California Environmental Quality Act (CEQA), the project qualifies for a
statutory exemption. The project is consistent with the development density and use characteristics
established by the existing General Plan and zoning regulations for which an Environmental Impact Report
(EIR) has already been certified. Upon review and drafting Findings of Consistency (Attachment 3), no
additional significant environmental effects peculiar to the project or its site have been identified.
Overall, the proposed O-S Zoning District provides the City with a clear, defensible regulatory framework to
protect natural and scenic resources, implement the Ukiah 2040 General Plan, and guide the responsible use,
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stewardship, and access to the City’s open space lands into the future. Staff recommends the Planning
Commission adopt the resolution recommending the proposed Ukiah City Code Ordinance to establish the
Open Space zoning district.
Recommended Action: Adopt a resolution making the Planning Commission’s report and recommendation to
the City Council on a proposed amendment to the Ukiah City Code by adding Article 11.5 to Division 9,
Chapter 2, to establish and regulate the Open Space (O-S) Zoning District.
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Page 1 of 10
ORDINANCE NO.X
ORDINANCE OF THE CITY COUNCIL OF THE CITY OF UKIAH ADDING A NEW ARTICLE 11.5
TO DIVISION 9, CHAPTER 2 TO UKAH CITY CODE TO ESTABLISH AND REGULATE THE OPEN
SPACE (O-S) ZONING DISTRICT.
The City Council of the City of Ukiah hereby ordains as follows:
SECTION ONE. FINDINGS
1. The City Council finds that establishing an Open Space (O-S) Zoning District implements
and is consistent with the Ukiah 2040 General Plan, particularly Goal ENV-1 to preserve
open space lands for agricultural production, natural resource protection, recreation, scenic
enjoyment, and hazard avoidance.
2. The City Council finds that the establishment of the proposed Zoning District is consistent with
and effectuates the Ukiah 2040 General Plan. In particular, the proposed zoning district
implements the land use designations of Agriculture (A), Open Space (OS), Public (P), and
Recreation (REC), and is aligned with Goal ENV-1, which promotes the preservation and
management of open space lands for agricultural productivity, natural resource conservation,
public recreation, scenic values, and hazard avoidance. The zoning district establishes a
regulatory structure that supports and reinforces these General Plan objectives, ensuring that
future land uses remain compatible with the City’s long-term vision for sustainable land
stewardship.
3. The City Council finds that the O-S Zoning District fulfills Policy ENV-6.7 and Policy LU-6.3 by
identifying, preserving, and managing creek corridors, hillsides, and ridgelines for trails,
wildlife habitat, and public access. When applied to real property, the district provides a
regulatory mechanism to ensure open space resources are protected, managed, and
maintained in alignment with the intent of the 2040 General Plan, and any City-approved
conservation, fuel management, or habitat restoration plan.
4. The City Council finds that the O-S Zoning District aligns with Action Item ENV-1.2(C) of the
Ukiah 2040 General Plan by establishing allowances within open space designated areas,
ensuring compatibility with long-term land conservation and watershed management
objectives, including those identified in the Western Hills Watershed Protection Area
Management Plan (2024) and the Western Hills Fire Break Maintenance Plan (2025).
5. The City Council finds that the Planning Commission held duly public workshops at regular
meetings on January 8, 2025, May 28, 2025, and duly noticed public hearing on October 22,
2025, to review the purpose, standards, and applicability of the proposed O-S Zoning District.
The Commission received public comments, discussed implementation options, and
recommended the draft ordinance for adoption following consideration of staff reports,
meeting materials, and related management plans.
6. The City Council finds that creating the O-S Zoning District promotes the public health, safety,
and welfare by preserving natural and scenic resources, protecting against environmental
hazards, and providing opportunities for recreation, education, and community enjoyment of
ATTACHMENT 1
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the City’s open spaces.
7. The City Council finds that adoption of the O-S Zoning District aligns with the intent of
California Government Code Sections 65302 and 65560–65570, which require cities to adopt
measures necessary to implement the Open Space and Conservation Elements of their
General Plan. Establishing a dedicated zoning district provides an essential tool to designate,
conserve, and manage open-space lands in response to evolving State requirements for
resource protection, climate adaptation, equitable public access, and sustainable land use.
8. The City Council finds that the establishment of the proposed Zoning District supports and
advances the goals of the State of California’s 30x30 Initiative, which aims to conserve 30
percent of the state’s lands and coastal waters by 2030. Specifically, the zoning designation
ensures that identified lands are durably protected, supports the expansion of equitable
access to nature, and promotes the long-term conservation of ecological values such as
wildlife habitat, farmland, water resources, and carbon sequestration. Furthermore, the zoning
district establishes appropriate management standards to preserve these values over time,
consistent with the broader state conservation framework.
9. The City Council finds that the adoption of this O-S Zoning District Ordinance is a legislative
action that implements and is consistent with the development expectations and policies
established in the Ukiah 2040 General Plan. Accordingly, the proposed project qualifies for
streamlined environmental review pursuant to the California Environmental Quality Act
(CEQA). Further CEQA review of this action is limited in scope as provided by Public
Resources Code Section 21083.3 and CEQA Guidelines Section 15183 (Projects Consistent
with a Community Plan or Zoning), based upon the Environmental Impact Report (EIR)
previously certified for the Ukiah 2040 General Plan.
SECTION TWO.
A new Article 11.5, entitled “REGULATIONS IN OPEN SPACE (O-S) DISTRICTS” is hereby
added to Division 9, Chapter 2 of the Ukiah City Code and shall read as follows:
§ 9140 PURPOSE AND INTENT
The purpose of the Open Space (O-S) zoning district is to conserve natural resources, preserve ecological
systems, protect scenic and cultural landscapes, and provide opportunities for passive recreation and
public access where appropriate. This designation is intended to identify lands not suited for development
or to land most valuable in its undeveloped state. Factors limiting the development of land would include
such constraints as unstable soils, high fire hazard, remote location, poor access, or susceptibility to
flooding. Valuable natural areas could include rare and endangered species and habitat, wildlife corridors,
riparian vegetation zones, areas with creeks or water features, or designated scenic resources.
The O-S District is consistent with the Open Space, Public, Agriculture, and Recreational Land Use
Designations in the General Plan. The regulations contained in this Article shall apply in all Open Space
(O-S) Districts except for the Airport Industrial Park Planned Development – Open Space designation.
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§ 9141 DEFINITIONS
For purposes of this Article, the words and phrases set out herein shall have the following meanings within
the Open – Space Zoning District:
BOARDWALKS AND ELEVATED WALKWAYS: Structures that allow passage over sensitive areas
such as wetlands or riparian zones, reducing ground disturbance and preserving natural hydrology
and vegetation.
CAMPGROUND – OPEN SPACE: Areas designated for overnight camping, including tent sites, fire
rings, picnic tables, and restrooms, with minimal permanent infrastructure, intended for recreational
use compatible with natural open space settings.
CULTURAL, HISTORIAL, OR ARCHAEOLOGICAL INTERPRETIVE FACILITIES: Facilities or
installations that convey the cultural, historical, or archaeological significance of a site through
signage, exhibits, or programming. Such uses shall be low-impact and compatible with preservation
of the surrounding environment.
ENVIRONMENTAL EDUCATION CENTERS: Small-scale facilities dedicated to outdoor learning,
interpretation, and stewardship. May include classrooms, demonstration gardens, or displays
focused on ecology, conservation, and sustainable practices, provided they maintain the character
of the surrounding open space.
FIREBREAK: A linear or perimeter strip of land or area where combustible vegetation and materials
are removed or reduced to a noncombustible condition to slow or stop wildfire spread and support
firefighting operations. Width, location, and maintenance shall comply with the applicable fire code or
an approved Fuels Management, Vegetation Management/Wildfire Mitigation Plan.
GRAZING. The controlled feeding of livestock on open land for the purpose of vegetation
management, fuel reduction, or habitat restoration, consistent with an approved conservation, fuel
management, or habitat restoration plan.
HABITAT BANKING OR MITIGATION SITES: Lands preserved, enhanced, or restored to offset
environmental impacts elsewhere, typically under a conservation easement or regulatory agreement.
These areas support long-term ecological functions and comply with state or federal mitigation
requirements.
INTERPRETIVE SIGNATE AND EDUCATIONAL KIOSKS: Signs or display stations designed to
inform visitors about the natural, cultural, or historical features of a place. They often include text,
images, maps, or interactive elements.
NATIVE PLANT PROPAGATION; NURSERY AREAS: Designated spaces used to grow and
reproduce local, native plant species, usually from seeds or cuttings to support restoration,
conservation, or landscaping projects that aim to preserve the local ecosystem.
NON-OBTRUSIVE TOWER: A structure intended for wildfire detection, environmental monitoring,
emergency communication, or similar public safety functions, and is designed to have minimal
visual and environmental impact. These towers are typically slender, uninhabited, and constructed
using neutral colors or materials that help them blend with the surrounding landscape. They avoid
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prominent placement on ridgelines or scenic vistas whenever possible and do not include large
equipment shelters or features that would significantly alter the natural character of the site. Lighting
is not permitted unless required by state or federal safety regulations
OUTDOOR EDUCACTION: Organized programs that provide structured instruction and hands-on
learning in outdoor or natural settings, including field studies, environmental science, ecology,
outdoor skills, and natural interpretation.
PARKING LOTS (TRAILHEADS OR OPEN SPACE ACCESS): Surface parking areas intended
solely to support public access to trails, parks, or open space areas. These lots shall be minimally
sized, use permeable materials where feasible, and be sited to reduce visual and environmental
impacts.
PUBLIC PARKS AND RECREATION AREAS WITH LIMITED FACILITIES: Open space areas
accessible to the public for passive or low-impact recreation, such as walking, wildlife viewing, or
picnicking. May include benches, restrooms, or shade structures, but do not permit large-scale or
intensive recreational infrastructure.
REWILDING: The restoration or protection of land and ecosystems to support native species,
natural processes, and ecological functions, with minimal ongoing human management.
SLOPE STABILIZATION: Engineering, vegetative, and bioengineering measures to prevent or
correct slope failure and erosion, including grading/terracing, soil reinforcement, rockery/riprap,
retaining systems, slope drains, and temporary/permanent erosion control BMPs (e.g., silt fence,
fiber rolls, hydro-mulch, check dams, sediment basins).
SPECIAL EVENTS OR TEMPORARY USES CONSISTENT WITH OPEN SPACE VALUES: Short-
term activities such as nature walks, educational workshops, cultural gatherings, or community
celebrations that promote awareness, stewardship, or enjoyment of open space resources without
significant alteration of the site.
TRAIL, BICYCLE (SHARED-USE PATH): A Public Trail or path primarily designed for bicycle travel,
typically with a stabilized surface for bicycle traffic. Equestrian and pedestrian use is not allowed
unless expressly posted and designed.
TRAIL, EQUESTRIAN: A Public Trail primarily designed, constructed, and maintained for
horseback riding. May run parallel to, or be separated from, a Multi-Use Trail. Includes equestrian-
specific features such as hitching rails, mounting blocks, manure bins, and trail width/clearance
suitable for horses.
TRAIL, MULTI-USE: A Public Trail designed and signed for concurrent use by multiple non-
motorized users, typically including hikers, bicyclists, and may include equestrian use where
specifically posted and designed. Surfaces may be stabilized.
TRAIL, NATURE/FOOTPATH: A Public Trail intended for pedestrian travel only (hiking, walking,
running), typically with a natural surface and minimal improvements to protect sensitive resources.
Bicycles and equestrian use are not allowed unless expressly posted and designed.
TRAIL, PUBLIC: A publicly accessible route for travel and recreation located in parks, open space,
or easements, designed for pedestrian use and, where signed or improved, may include other
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permitted non-motorized users.
TRAIL SPUR (ACCESS SPUR): A short Public Trail segment that provides connection from a
trailhead, street, school, park, or neighborhood to a Multi-Use, Bicycle, Equestrian, or
Nature/Footpath.
TRAILHEAD: A designated access point to one or more trails that may include parking, restrooms,
potable water, signage/maps, staging areas (including equestrian staging), and maintenance
access while safeguarding open-space from prohibited access or usage.
WATER DETENTION AND RECHARGE FACILITIES: Infrastructure designed to temporarily
capture, hold, and infiltrate stormwater to reduce runoff, prevent erosion, and recharge
groundwater. Includes bioswales, retention basins, and percolation ponds designed to integrate
with natural systems.
WILDFIRE PUBLIC SAFETY INFRASTRUCTURE: Equipment intended to support wildfire
preparedness, detection, and emergency response. This includes, but is not limited to, dedicated
firefighting assets (e.g., water storage tanks, staging areas) and emergency communication
infrastructure (e.g., public alert systems, emergency sirens, and related systems) necessary to
ensure operational readiness during wildfire events.
§ 9142 ALLOWED USES
The following uses are allowed by right in the Open Space (O-S) District:
Conservation and Habitat Restoration Activities, consistent with approved conservation, fuel
management, or habitat restoration plans
Grazing, consistent with approved conservation, fuel management, or habitat restoration plans
Fuel Break, consistent with approved conservation, fuel management, or habitat restoration plans
Habitat Corridors and Linkages, consistent with approved conservation, fuel management, or habitat
restoration plans
Interpretive signage and Educational Kiosks
Native Plant Propagation Areas
Native Tree Nurseries
Outdoor Education
Rewilding, consistent with approved conservation, fuel management, or habitat restoration plans
Row & Field Crops and Animal Raising – General Agriculture, excluding permanent structures
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Slope Stabilization And Erosion Control, consistent with approved conservation, fuel management, or
habitat restoration plans
Wildfire Public Safety Infrastructure
§ 9143 PERMITTED USES
The following uses require approval of an appropriate use permit pursuant to the provisions contained in
Article 20 of this Chapter.
Campground (Open-Space)
Cultural, historical, or archaeological interpretive facilities
Environmental education centers
Habitat banking or mitigation sites
Park and recreation services
Parking lot(s) serving trailheads or open-space recreation areas
Special events or temporary uses consistent with open space purpose and intent
Trail, Bicycle (Shared-Use)
Trail, Equestrian
Trail, Multi-Use
Trail, Nature/Footpath, consistent with approved conservation, fuel management, or habitat restoration
plans
Trail, Public
Trail-Spur
Trailhead
Water detention and recharge facilities
§ 9144 HEIGHT LIMITS
A. Primary structures: Maximum height of 25 feet.
B. Accessory structures: Maximum height of 15 feet or height of main building, whichever is less.
C. Improvements:
1. Non-obtrusive towers and equipment used exclusively for wildfire detection, emergency
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communications, or similar public safety purposes may exceed 25 feet. Any such increase would
be subject to discretionary review, and must be the minimum necessary for operational
effectiveness and designed to reduce visual and environmental impact.
2. Fences or walls: Maximum height of 7 feet, unless consistent with an approved
conservation, fuel management or habitat restoration plan, or approved by Use Permit.
§ 9145 SITE AREA
There is no minimum site area for uses in the O-S District; however, development intensity must conform
to open space purpose and intent.
§ 9146 SETBACKS
Yard setbacks apply to all new structures, additions, grading, and site improvements, including fences,
walls, pavement, and other hardscape features, as conveyed below.
A. Environmental. A minimum 100-foot setback is required from the edge of sensitive environmental
resources, including creeks and rivers (measured from the top of bank), wetlands (from the delineated
wetland boundary), and mapped sensitive habitat areas.
B. Visual. To minimize visual impacts, development within or near setback areas shall be sited and
designed to maintain natural sightlines and reduce visual prominence through building placement, height
and massing control, material selection, and landscape screening, with particular attention to ridgelines.
C. Slope. For sloped terrain, additional setbacks from the top of slope and toe of slope are required
to avoid excessive grading. Slope percentage shall be measured as average grade over a horizontal
distance of at least 25 feet, based on existing (pre-project) topography.
1. On slopes 15% to less than 30%, principal structures and foundations shall be set back a
minimum of 10 feet from the top of ridge and 10 feet from the toe of slope.
2. On slopes 30% or greater, new structures and grading to create building pads are
prohibited unless the review authority finds that no practicable alternative exists and that a
geotechnical report demonstrates stability without increasing erosion risk; where allowed, the
minimum top- and toe-of-slope setbacks shall be 30 feet.
D. Yard Setbacks: Any adjacent lot that shares a side or rear lot line with land zoned O-S shall provide
a transition yard measured from that line as follows for the following uses:
1. Single Family Residential: Rear 25 feet, side 12 feet;
2. Multifamily: Rear 30 feet, side 15 feet;
3. Non-Residential: Rear 35 feet, side 15 feet.
E. Exception. As part of the applicable Use Permit process, the Zoning Administrator or the Planning
Commission may allow encroachments into required setbacks when no practicable alternative exists and
the proposed design minimizes both physical and visual disturbance. Findings shall be supported by site-
specific analysis, including (as applicable) a geotechnical report, erosion and sediment control plan, and
visual analysis.
§ 9147 PARKING
A. For all trailheads and recreation areas the parking requirements shall be one space per ten (10)
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average daily visitors. The required number of parking spaces may be adjusted by the Community
Development Director through a Determination of Appropriate Use, based on anticipated patterns of use,
including but not limited to similar regional facilities; bicycle or pedestrian access requirements; equestrian
facilities; educational or group programming; seasonal or event-based usage; proximity to public transit
or urbanized areas.
B. Parking surfaces shall be permeable and screened with vegetation, where feasible.
C. No overnight public parking is allowed unless allowed by an issued Special Event or Use permit.
D. Other Uses: All other uses are subject to the provisions contained in Article 17 of this Chapter.
§ 9148 ADDITIONAL REQUIREMENTS
A. Resource Protection: Grading or vegetation removal shall only be permitted with approval from
the Community Development Director or Public Works Director on an emergency basis when not part of
an approved conservation, fuel management or habitat restoration plan.
B. Lighting: Artificial lighting in the Open Space District is generally discouraged. Any lighting must
be minimal and dark-sky compliant according to International Dark-Sky Association's (IDA) guidelines for
outdoor lighting to minimize light pollution.
C. Fencing: For Allowed uses, the use of fencing in the Open Space Zoning District is generally
discouraged. Any fencing installed used must be wildlife-friendly or implemented to maintain public safety.
Fences are prohibited if they would impede wildlife movement within a designated wildlife or habitat
corridor, as determined by the City based on substantial evidence.
D. Parking Lot & Recreation Area Landscaping: Landscape plantings in the Open Space District
must be either native or drought-tolerant species. Parking and recreation surfacing shall be permeable
except where infeasible for compliance with the Americans with Disabilities Act or to serve emergency
access.
E. Requirements for Special Events: Events in the Open Space District must be consistent with the
purpose of the zoning district set forth in this Article and shall not significantly degrade natural resources
or impair public enjoyment of the area. All events require prior approval through a use permit.
§ 9149 DETERMINATION OF APPROPRIATE USE
Whenever a use is not listed in this Article as a used allowed by right or a use subject to a use permit in
the O-S Zoning District, the Community Development Director shall determine whether the use is
appropriate for the Zoning District, either as of right or subject to a use permit. In making this
determination, the Planning Director shall find as follows:
A. That the use would not be incompatible with other existing or allowed uses in the O-S Zoning
District.
B. That the use would not be detrimental to the continuing preservation of resources or access to
the area in which the use would be located.
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C. That the use involves a similar scale and impact to uses that are designated allowed uses in this
Article.
D. That the use is consistent with the purpose and intent of the Open-Space Zoning District, including
the protection of natural resources, scenic values, and the long-term preservation of open space for public
or ecological benefit.
E. In the case of determining that a use not listed in this Article as an allowed or permitted use could be
established with the securing of a use permit, the Community Development Director shall find that the
proposed use is similar in nature and intensity to the uses listed as permitted uses. All determinations of
the Community Development Director regarding whether a use can be allowed or permitted in the Open-
Space Zoning District shall be final unless a written appeal to the City Council, stating the reasons for the
appeal, and the appeal fee, if any, established from time to time by City Council resolution, is filed with
the City Clerk within ten (10) days of the date the decision was made. Appeals may be filed by an applicant
or any interested party. The City Council shall conduct a duly noticed public hearing on the appeal in
accordance with the applicable procedures as set forth in this Chapter. At the close of the public hearing,
the City Council may affirm, reverse, revise or modify the appealed decision of the Open-Space District
Director. All City Council decisions on appeals of the Director’s actions are final for the City.
SECTION THREE.
1. Publication: Within fifteen (15) days after its adoption, this Ordinance shall be published once
in a newspaper of general circulation in the City of Ukiah. In lieu of publishing the full text of the
Ordinance, the City may publish a summary of the Ordinance once 5 days prior to its adoption and
again within fifteen (15) days after its adoption.
2. Effective Date: The ordinance shall become effective thirty (30) days after its adoption.
3. Severability: If any section, subsection, subdivision, paragraph, sentence, clause or phrase of
this Ordinance, or its application to any person or circumstance, is for any reason held to be invalid
or unenforceable, such invalidity or unenforceability shall not affect the validity or enforceability of the
remaining sections, subsections, subdivisions, paragraphs, sentences, clauses or phrases of this
Ordinance, or its application to any other person or circumstance. The City Council of the City of
Ukiah hereby declares that it would have adopted each section, subsection, subdivision, paragraph,
sentence, clause or phrase hereof, irrespective of the fact that any one or more other sections,
subsections, subdivisions, paragraphs, sentences, clauses or phrases hereof be declared invalid or
unenforceable.
Introduced by title only on , 2025, by the following roll call vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
Adopted on , 2025, by the following roll call vote:
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AYES:
NOES:
ABSENT:
ABSTAIN:
Douglas F. Crane, Mayor
ATTEST:
Kristine Lawler, CMC/City Clerk
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Page 1 of 3
DRAFT RESOLUTION NUMBER PC-2025-05
CITY OF UKIAH
OCTOBER 22, 2025
RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF UKIAH RECOMMENDING
CITY COUNCIL ADOPTION OF AN ORDINANCE AMENDING THE UKIAH CITY CODE TO
ESTABLISH AN OPEN SPACE (O-S) ZONING DISTRICT CONSISTENT WITH THE UKIAH 2040
GENERAL PLAN
WHEREAS, on December 7, 2022, the Ukiah City Council adopted Resolution No. 2022-
79 certifying the Environmental Impact Report for the Ukiah 2040 General Plan (State
Clearinghouse No. 2022050556), which evaluated the environmental impacts of the General Plan,
and included adoption of a Mitigation Monitoring and Reporting Program and Statement of
Overriding Considerations; and
WHEREAS, the Ukiah 2040 General Plan calls for the preservation and long-term
stewardship of open space lands for the purposes of agriculture, natural resource conservation,
public recreation, scenic values, and hazard mitigation, particularly through the implementation of
Goal ENV-1 and related policies and action items of the Ukiah 2040 General Plan; and
WHEREAS, Government Code Sections 65302 and 65560–65570 require cities to adopt
measures that implement the Open Space and Conservation Elements of their General Plans,
including the designation and regulation of open space lands; and
WHEREAS, the City of Ukiah has prepared a draft ordinance establishing the Open Space
(O-S) zoning district to implement the Ukiah 2040 General Plan and to regulate land uses,
development standards, and allowable activities within designated publicly-owned open space
areas; and
WHEREAS, the proposed O-S Zoning District allows for implementation of key General
Plan policies including ENV-6.7 (Public Open Space) and LU - 6.3 (Open Space Access) by
identifying and preserving riparian areas, hillsides, ridgelines, and habitat corridors for
conservation, recreation, and hazard mitigation; and
WHEREAS, the O-S Zoning District also implements Action Item ENV-1.2(C) by
formalizing zoning standards that align with the objectives of the Western Hills Watershed
Protection Area Management Plan (2024) and the Western Hills Fire Break Maintenance Plan
(2025); and
WHEREAS, while the adoption of the Open Space Zoning District Ordinance does not
designate any specific parcels of real property, it is intended to be applied to publicly owned lands
under the jurisdiction of the City of Ukiah or other public entities, consistent with the goals and
policies of the Ukiah 2040 General Plan; and
WHEREAS, the O-S Zoning District supports the goals of the State of California’s 30x30
Initiative, which seeks to conserve 30% of the state’s lands and waters by 2030; and
ATTACHMENT 2
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WHEREAS, the proposed Ordinance promotes the public health, safety, and welfare by
protecting open space lands from incompatible development, supporting climate adaptation and
water resource protection, and preserving areas for low-impact public recreation and education;
and
WHEREAS, the Planning Commission held two publicly noticed workshops on January 8,
2025, and May 28, 2025, to review and discuss the intent, purpose, applicability, and draft
language of the proposed Open Space (O-S) Zoning District, received public comments, and
provided feedback to staff to guide ordinance development; and
WHEREAS, on October 22, 2025, the Planning Commission held a duly noticed public
hearing to consider the proposed Ordinance, received public comment, reviewed staff reports and
supporting documentation, and closed the public comment period; and
WHEREAS, the Ordinance has been reviewed for environmental compliance pursuant to
the California Environmental Quality Act (CEQA), and is consistent with the Environmental Impact
Report certified for the Ukiah 2040 General Plan, qualifying for streamlined CEQA review under
CEQA Guidelines Section 15183 and Public Resources Code; and
WHEREAS, the Planning Commission finds that the Ordinance is in the public interest,
consistent with the Ukiah General Plan, advances key environmental and land use goals, and
provides a clear regulatory framework for the use and preservation of open space lands in the
City of Ukiah.
NOW, THEREFORE, BE IT RESOLVED that the Planning Commission of the City of Ukiah,
based on the staff report, environmental review, public testimony, and all written and oral materials
presented at the hearing, makes the following findings and recommendations:
1. The above recitals are true and correct and are incorporated herein by reference.
2. The proposed Ordinance is consistent with the Ukiah 2040 General Plan and implements
the goals, objectives, and policies of the Open Space, Land Use, and Environmental
Elements, particularly Goal ENV-1 and related policies.
3. The Ordinance qualifies for streamlined CEQA review pursuant to CEQA Guidelines
Section 15183 and Public Resources Code Section 21083.3 because it implements and
is consistent with the policies of the adopted 2040 General Plan, and no significant effects
beyond those identified in the certified General Plan EIR are anticipated.
4. The Planning Commission recommends that the City Council introduce and adopt an
Ordinance adding Article 11.5 to Division 9, Chapter 2 of the Ukiah City Code, as shown
in the attached Exhibit A, establishing the Open Space (O-S) zoning district.
BE IT FURTHER RESOLVED that the Planning Commission designates the City Clerk as the
custodian of the documents and other materials constituting the record of proceedings upon which
this resolution is based. These materials are available at the City of Ukiah Community
Development Department, 300 Seminary Avenue, Ukiah, CA 95482.
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I hereby certify that according to the Provisions of Government Code Section 25103 delivery of
this document has been made.
ATTEST:
____________________
Kristine Lawler, City Clerk City Clerk
___________________________ ___________________________
Craig Schlatter, AICP Alex De Grassi
Community Development Director Chair, Ukiah Planning Commission
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Draft Findings of Consistency:
Open Space Zoning Ordinance
CEQA Section 15183 Statutory Exemption
October 22, 2025
SCH No: XXXXXXXXXX
Prepared by:
City of Ukiah
Community Development Department
Planning Division
300 Seminary Avenue, Ukiah, CA 95482
www.cityofukiah.com/community-development/planning-services/
ATTACHMENT 3
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Page 2 of 9
Table of Contents
I. PROJECT INFORMATION 3
II. INTRODUCTION 4
1. Purpose of the CEQA Guidelines Section 15183 Findings of Consistency 4
2. Ukiah 2040 General Plan EIR 4
III. PROJECT DESCRIPTION 4
1. Project Purpose 4
2. Environmental Setting and Project Location 5
IV. EVALUATION OF ENVIRONMENTAL EFFECTS 5
1. Density 6
2. Project-Specific Effects Peculiar to the Project or its Site 7
3. Significant Impacts Not Analyzed in the Prior EIR 7
4. Cumulative Impacts 8
5. New Information 8
V. DETERMINATION 8
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I. PROJECT INFORMATION
Project Title: Ordinance of the City Council of the City of Ukiah Adding a New Article 11.5 to
Division 9, Chapter 2 to Establish and Regulate the Open Space (O-S) Zoning District
Lead Agency Address and Phone Number:
City of Ukiah
Community Development Department
300 Seminary Avenue
Ukiah, California 95482
CEQA Contact Person and Phone Number:
Katherine Schaefers, Planning Manager
City of Ukiah, Community Development Department
(707) 463-6203
KSchaefers@cityofukiah.com
Applicant: City of Ukiah
Property Owner: City of Ukiah
Project Location: City-wide within the Open Space (O-S) Zoning District
General Plan Designation: Those designations listed as compatible with the proposed O-S
Zoning District, including: Public (P), Recreational (REC), Open Space (OS), Agriculture (AG)
Zoning Designation: Open Space (O-S) - Proposed
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II. INTRODUCTION
1. Purpose of the CEQA Guidelines Section 15183 Findings of Consistency
California Public Resources Code section 21083.3 and California Environmental Quality Act
(CEQA) Guidelines Section 15183 provide an exemption from additional environmental review for
projects that are consistent with the development density established by existing zoning,
community plan or general plan policies for which an Environmental Impact Report (EIR) was
certified, except as might be necessary to examine whether there are project-specific significant
effects which are peculiar to the project or its site.
Section 15183 specifies that examination of environmental effects shall be limited to those effects
that:
(1) Are peculiar to the project or the parcel on which the project would be located, and were
not analyzed as significant effects in a prior EIR on the zoning action, general plan, or
community plan, with which the project is consistent,
(2) Are potentially significant off-site impacts and cumulative impacts which were not
discussed in the prior EIR prepared for the general plan, community plan or zoning action,
or
(3) Are previously identified significant effects which, as a result of substantial new information
which was not known at the time the EIR was certified, are determined to have a more
severe adverse impact than discussed in the prior EIR.
Since the adoption of a zoning ordinance is considered a discretionary action and a "Project"
under CEQA Guidelines Section 15378, the application of Section 15183 is appropriate for this
legislative action. This section limits the examination of environmental effects to those effects
that are peculiar to the project or its site, or which the prior EIR failed to analyze.
2. Ukiah 2040 General Plan EIR
The Ukiah 2040 General Plan and its associated EIR (SCH# 2022050556) were certified in
December 2022. The General Plan designates land uses defining the type and amount of
development that can occur throughout the City and proposed annexation areas through the
planning horizon year of 2040 (over approximately 18 years). The EIR serves as the foundational
environmental document for subsequent projects and implementing ordinances, such as the
proposed Open Space Zoning District. The adoption of the O-S Ordinance is consistent with the
goals and policies of the General Plan and can therefore utilize this prior environmental analysis
for tiering and streamlining purposes.
III. PROJECT DESCRIPTION
1. Project Purpose
The Open Space (O-S) Zoning District Ordinance establishes a regulatory mechanism to
implement the open space conservation goals of the Ukiah 2040 General Plan. The purpose of
the O-S district is to conserve natural resources, preserve ecological systems, protect scenic
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and cultural landscapes, and provide opportunities for passive recreation and public access
where appropriate.
The ordinance addresses the following core goals and policies of the Ukiah 2040 General Plan:
• Goal ENV-1: To preserve open space lands for natural resource protection, recreation,
scenic enjoyment, and hazard avoidance.
• Policy ENV-6.7 and Policy LU-6.3: By providing a regulatory mechanism to identify,
preserve, and manage creek corridors, hillsides, and ridgelines for trails, wildlife habitat,
and public access.
• Action Item ENV-1.2(C): By establishing allowances ensuring compatibility with long-
term land conservation and watershed management objectives, specifically referencing
the Western Hills Watershed Protection Area Management Plan (2024).
• Government Code Compliance: The ordinance fulfills the intent of state law
(Government Code Sections 65302 and 65560–65570) requiring the City to adopt
measures to implement the Open Space and Conservation Elements of the General
Plan.
2. Environmental Setting and Project Location
The City of Ukiah is located in the Ukiah Valley, a region defined by a mix of urban development,
agricultural lands, and undeveloped natural areas. Open space, meaning land or water areas that
remain largely unimproved and support ecological, recreational, or scenic values, is an important
component of the broader landscape. The Ukiah Valley includes significant areas of hillside,
riparian corridors, and rural lands that contribute to the environmental and visual character of the
region.
Within the city limits, the City of Ukiah owns and manages a range of park and recreation facilities
totaling approximately 260 acres. These include neighborhood and community parks, as well as
Low Gap Park, an 80-acre open space area owned by Mendocino County. Low Gap Park features
an existing network of trails that extend into the hills west of the city and support passive recreation
uses. Additional regional open space areas within the City's planning sphere include Mill Creek
Park (400 acres), Lake Mendocino Recreation Area (5,110 acres), and Cow Mountain Recreation
Area (60,000 acres). These regional open space areas are managed by the County of Mendocino,
or Federal entities, such as the U.S. Army Corps of Engineers, or the Bureau of Land
Management. The Russian River also provides recreational opportunities for Ukiah residents, with
public access available at four locations within or near city limits: the City Softball Complex, Vichy
Springs Road crossing, Riverside Park, and the Talmage Road crossing.
The City’s existing holdings help to preserve the valley’s natural features and ecological health.
These lands include oak woodlands, hillside areas, and riparian corridors that provide important
wildlife habitat and natural space for residents. While some areas are open to the public, others
feature restricted access or lack formal infrastructure. Recent acquisitions such as the City-
Owned Annexation (2023) and the Western Hills Annexation (2024) have expanded the City’s
open space inventory and provide future opportunities for preservation and management. These
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areas contribute to long-range goals for viewshed protection, wildfire risk reduction, and public
recreation. While these lands currently function as open space, they are designated Public (P) in
the General Plan and zoned Public Facilities (PF) in the zoning code.
With the adoption of the Ukiah 2040 General Plan, the City established a new Open Space land
use designation. This designation applies to lands that are unsuitable for development due to
environmental constraints such as slope instability, fire hazard, poor access, or flood risk, or that
are otherwise considered most valuable in their undeveloped state. Typical areas include creek
corridors, hillsides, and ridgelines. The Open Space designation is intended to ensure the long-
term protection of these areas for ecological, recreational, or scenic purposes.
At present, the City’s zoning code does not include a corresponding Open Space zoning district.
As a result, lands designated as Open Space in the General Plan cannot be zoned in a manner
consistent with the intended use. This ordinance would enable implementation of the General
Plan by providing a regulatory framework for the management, use, and protection of designated
open space lands. Although the ordinance applies citywide, it would initially affect a limited
number of parcels owned or controlled by the City. Future rezonings to apply the O-S district to
other properties would be subject to separate discretionary review and environmental evaluation,
as applicable.
IV. EVALUATION OF ENVIRONMENTAL EFFECTS
The following evaluation determines whether the proposed O-S Zoning Ordinance qualifies for
streamlined review pursuant to CEQA Guidelines Section 15183 by evaluating the three
mandatory findings (Density, Project-Specific Effects, and Unanalyzed Impacts) required by the
guidelines.
1. Density
Finding: The proposed Open Space Zoning Ordinance is consistent with the development
density established by the Ukiah 2040 General Plan policies for which an EIR was certified.
Discussion: The Open Space (OS) designation in the Ukiah 2040 General Plan explicitly
establishes the density and intensity as N/A (not applicable) for both Minimum/Maximum Density
(dwelling units per acre) and Floor Area Ratio. The designation is intended to identify lands that
are to remain undeveloped due to environmental constraints or conservation value. The O-S
Zoning District is designed specifically to enforce this intent, conserving natural resources and
restricting development.
The limited allowed uses in the O-S district, such as public trails, conservation and habitat
restoration activities, and native plant propagation areas, are inherently low-intensity and non-
residential. These uses fully conform to and support the General Plan's designated density of N/A,
thereby maintaining consistency with the General Plan and meeting the requirements of CEQA
Guidelines Section 15183.
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2. Project-Specific Effects Peculiar to the Project or its Site
Finding: There are no project-specific environmental effects which are peculiar to the adoption
of the O-S Zoning Ordinance or to its sites, and which the Ukiah 2040 EIR failed to analyze as
significant effects.
Discussion: The O-S Ordinance is a regulatory measure whose primary effect is environmental
preservation and protection of sensitive lands. The General Plan EIR inherently analyzed the
impacts associated with the lack of development in Open Space areas and established policies
(e.g., Goal ENV-1, Policy LU-6.2, Goal ENV-6) intended to minimize impacts on scenic vistas,
hillsides, and riparian habitats.
The O-S Zoning Ordinance directly implements these protective goals, such as safeguarding
creek corridors and managing open space resources. Since the ordinance focuses on
conservation, it reinforces the environmental baselines assumed in the EIR. Any future
development activities permitted by the ordinance (e.g., public trails or habitat restoration) would
be site-specific projects requiring subsequent environmental documentation (such as an Initial
Study or site-specific environmental review) to ensure compliance with the EIR and identify any
peculiar, site-specific effects. The adoption of the ordinance itself, being a consistent and
protective regulatory act, does not introduce new environmental effects peculiar to the parcels
that were not already contemplated under the General Plan's land use designation.
3. Significant Impacts Not Analyzed in the Prior EIR
Finding: There are no project-specific impacts which the Ukiah 2040 EIR failed to analyze as
significant effects.
Discussion: The EIR certified for the Ukiah 2040 General Plan is a program-level document that
analyzed the cumulative and regional impacts of land use patterns, including policies designed to
manage and protect natural resources and prevent land use conflicts. The O-S Ordinance is an
implementing measure that strictly adheres to the land use assumptions of the General Plan EIR
and furthers its protective policies, such as:
• Minimizing Land Use Incompatibilities: The ordinance reduces the potential for
urban/resource conflicts by restricting development in environmentally sensitive areas,
aligning with Policy LU-7.1 and Goal AG-1.
• Preservation of Resources: By protecting creek corridors, hillsides, and habitat (Policies
ENV-6.7/LU-6.3), the ordinance reduces the possibility of significant impacts on biological
resources, aesthetic resources, and water quality, which are all issues analyzed in the GP
EIR.
Because the ordinance restricts development and solidifies environmental preservation, it results
in impacts that are either equivalent to or less severe than those anticipated and analyzed in the
certified EIR, and therefore introduces no unanalyzed significant impacts.
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4. Cumulative Impacts
Finding: There are no potentially significant offsite and/or cumulative impacts that the Ukiah 2040
EIR failed to evaluate.
Discussion: The O-S Ordinance is a component of a larger City strategy aimed at achieving
sustainable growth by prioritizing infill development and preserving surrounding open space and
agricultural resources (Policy LU-7.1). The establishment of this zoning district contributes
positively to the regional environmental and cumulative land use context by providing legal
permanency to the protection of ecological systems, scenic areas, and hazard avoidance areas.
The cumulative impacts of development within the City limits, coupled with resource preservation
strategies, were addressed in the certified EIR. The O-S Ordinance supports the cumulative goal
of long-term sustainability of the region's resources.
5. New Information
Finding: There is no substantial new information that results in more severe environmental
impacts than anticipated by the Ukiah 2040 EIR.
Discussion: No substantial new information has been identified demonstrating that the proposed
regulatory adoption of the O-S Zoning District would result in more severe impacts than those
disclosed in the EIR. The ordinance is consistent with the established General Plan density and
land use policy directives. The purpose of the O-S district is to mitigate the hazards inherent to
these lands and conserve resources. This function prevents the environmental baseline
conditions (which supported the EIR's findings) from being undermined by incompatible
development.
V. DETERMINATION
In accordance with CEQA Guidelines Section 15183, the City Council finds that the proposed
Open Space (O-S) Zoning District Ordinance qualifies for streamlined environmental review
because the following conditions are met:
1. The project (adoption of the O-S Zoning Ordinance) is consistent with the development
density (N/A) established by the Ukiah 2040 General Plan policies for which an EIR was
certified.
2. There are no project-specific effects peculiar to the regulatory action or its general site,
and which the Ukiah 2040 EIR failed to analyze as significant effects.
3. No specific parcels are being rezoned by this action, and no real property is being
affected. If rezoning is proposed for any parcel in the future, a site-specific review will be
conducted to evaluate the environmental impacts of applying the O-S zoning district to
that property.
4. There are no project-specific impacts which the Ukiah 2040 EIR failed to analyze as
significant effects.
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Therefore, the City Council relies upon the EIR previously certified for the Ukiah 2040 General
Plan, and further CEQA review is limited pursuant to CEQA Guidelines Section 15183 and
Public Resources Code Section 21083.3.
Page 35 of 46
These stocker cattle graze seasonally, during
spring, reducing fine fuels across a large
landscape. Photo: Devii Rao.
RESEARCH ARTICLE
Cattle grazing reduces fuel and leads to more
manageable fire behavior
Grazing cattle can help reduce fuel loads on rangelands and mitigate the ever-growing risk of
catastrophic wildfires.
by Felix Ratcliff, Devii Rao, Sheila Barry, Shane Dewees, Luke Macaulay, Royce Larsen, Matthew Shapero, Rowan Peterson, Max Moritz and Larry Forero
Online: https://doi.org/10.3733/ca.2022a0011
Recent wildfire seasons in California have been
some of the worst on record. This “new reality”
highlights the importance of understanding how
land management practices such as cattle grazing af-
fect wildfire behavior. Fire behavior is characterized
in this paper by flame length. While climate change
can lead to more severe fire behavior for California
wildfires, our findings suggest that land managers can
help balance out these dangers in grasslands by us-
ing livestock grazing to reduce fuel loads. CAL FIRE’s
California Vegetation Treatment Program (CalVTP)
utilizes prescribed herbivory, which is the targeted
grazing of cattle, sheep and goats to reduce wildland
plant populations. While not included in CalVTP, con-
ventional grazing also plays an important role in fuel
load reductions.
Livestock grazing is a prevalent land use on
California’s rangelands and is considered a cost-
effective method of reducing fuel loads (Taylor 2006).
As such, fuel reduction through livestock grazing is a
Abstract
Cattle play an important role in wildfire management by grazing fuel
on California rangelands. The benefits of cattle grazing have not been
thoroughly explored, though. Using statewide cattle inventory, brand
inspection and land use data, we have estimated that cattle removed 11.6
billion pounds (5.3 billion kilograms [kg]) of non-woody plant material
from California’s rangelands in 2017. Regionally, these reductions varied
between 174 and 1,020 pounds per grazed acre (195 to 1,143 kg per
hectare). Fire behavior is characterized in this paper by flame length. Fire
behavior models suggest that these regional fuel reductions lower flame
lengths, and lead to more manageable wildfires. In addition, fire-based
models show that cattle grazing reduces fuel loads enough to lessen fire
hazards in many grazed areas. Moving forward, there may be significant
opportunities to expand strategic grazing on rangelands to add extra
layers of protection against wildfires.
60 CALIFORNIA AGRICULTURE • VOLUME 76, NUMBER 2–3
Page 36 of 46
common management goal in regional, state, county
and agency management plans (EBMUD 2000; EBRPD
2013; George and McDougald 2010; Rancho Mission
Viejo 2006; Santa Clara County Parks 2018). However,
management plans generally do not list target fuel con-
ditions to achieve through livestock grazing.
Since livestock grazing is already in widespread use
for wildfire fuel management in California, it is im-
portant to understand in greater detail to what extent
livestock reduce fuel loads across the state, including
how this varies spatially. More research on grazing for
fuel reduction has been done on sheep and goats than
on cattle (Nader et al. 2007). Especially in California,
much of this research has focused on forests and shrub-
lands rather than grasslands, and on woody rather than
herbaceous fuels (Green and Newell 1982; Minnich
1982; Narvaez 2007; Tsiouvaras et al. 1989). While
cattle graze all rangeland types in California, they pri-
marily graze grasslands, preferring herbaceous forage
like grasses and flowering plants (Launchbaugh et al.
2006; Van Soest 1994). When these fuels dry out, they
are known as “fine fuel” — fuels with a high surface-
area-to-volume ratio that can be quickly combusted in
wildfires (USFS 2022). Because they are by far the most
widespread and abundant domestic grazers in the state
(Saitone 2018), understanding the effects of cattle graz-
ing on rangeland fuel loads is particularly important.
Beef cattle account for the vast majority of range-
land cattle. However, the number of beef cows in
California today is only about 57% of their peak
numbers in the 1980s (Saitone 2018). This reduction is
mirrored by declines in authorized grazing on public
lands in the state over that time period (Oles et al. 2017;
Saitone 2018). The number of grazed rangeland acres
has been in decline as well, both on private (Cameron
et al. 2014) and public lands (Forero 2002; Oles et al.
2017). This reduction influences rangeland fuel levels,
as less fine fuel is removed through grazing.
Cattle grazing can reduce rangeland fuels in several
ways. The most frequently studied and perhaps most
important way is by removing fine fuels. This can af-
fect fire behavior by reducing rates of spread, flame
lengths and fire intensities. Despite widespread interest
in this topic, there is only one published study of the
impact of cattle grazing on fine fuels and fire behavior
in California (Stechman 1983). This study looked at fire
behavior in an annual grassland grazed by cattle; how-
ever, the level of residual dry matter (RDM) was much
higher than is typical for grazed annual grassland in
California. RDM is the amount of herbaceous plant
matter from the previous season immediately prior
to the first fall rains (Bartolome et al. 2006). Other
studies from western U.S. rangelands in sagebrush
steppe, mesquite savanna and cheatgrass-dominated
grasslands have shown that cattle grazing can reduce
fine fuel loads and, in turn, slow fire spread and flame
length (Bruegger et al. 2016; Davies et al. 2010; Davies
et al. 2015; Diamond 2009; Schmelzer et al. 2014).
Several of these studies rely on fire behavior models to
analyze the effects of fine fuel reduction on fire behav-
ior (Bruegger et al. 2016; Diamond 2009).
Cattle grazing can also reduce rangeland fuels by
causing long-term changes in species composition
and vegetation structure. Perhaps the most important
example of this in California is that cattle grazing can
prevent or slow the encroachment of shrubs and trees
into grassland. Much of coastal California has shown a
trend of shrub encroachment on grassland (particularly
by coyote brush, Baccharis pilularis) in the absence of
grazing and fire disturbances (Ford and Hayes 2007).
For instance, in the San Francisco Bay Area, limited
grazing in the mid- to late 20th century has been
linked to widespread shrub encroachment and loss
of grassland (Keeley 2005; McBride and Heady 1968;
Russell and McBride 2003). Coyote brush encroach-
ment is also occurring on the southern California coast
(Brennan et al. 2018). Shrub encroachment, even if by
native species, presents a challenge for fire management
because dense stands of shrubs increase fire hazard and
fire intensity (Ford and Hayes 2007; Parker et al. 2016).
Grazing is a key management technique to minimize
these more severe wildfires in areas where retention of
grasslands is an important goal.
The amount of herbaceous fuel on the ground
during fire season in grazed California rangelands is
largely a function of herbaceous growth in any given
year, the number of livestock grazing per acre (grazing
pressure), and vegetation biomass loss due to weath-
ering (Frost et al. 2008; Larsen et al. 2021). Forage
production is notoriously variable and unpredictable
in California, both between years and across the land-
scape at a fine scale (Becchetti et al. 2016; Devine et al.
2019). The number of livestock grazing in the state is
relatively stable by comparison.
The goals of this study are to inform planning, pol-
icy, and risk assessment at the state and regional scales
Comparison of ungrazed
grassland (inside exclosure)
versus grazed grassland
(outside exclosure). Photo:
Royce Larsen.
http://calag.ucanr.edu • APRIL–SEPTEMBER 2022 61
Page 37 of 46
and to clarify the benefit of strategic grazing to mitigate
wildfire risk. To accomplish this, we describe the de-
gree to which cattle remove fine fuels from rangelands
in different areas of the state and use models to try to
understand how this fine fuel removal affects fire be-
havior. We aim to help answer the following questions:
1. How much herbaceous fuel is removed by cattle
from grazed rangelands in California, and how does
this amount vary by region in the state?
2. What can fire behavior models tell us about how ef-
fective current levels of cattle grazing are at altering
wildfire behavior?
3. How do spatial patterns of grazing and fuel reduc-
tion within regions inform our understanding of
the impact of cattle grazing on fire behavior?
To answer the study questions, we first estimated
rangeland fine fuel reduction by cattle in California.
Next, we characterized year-to-year and spatial vari-
ability associated with fuel reduction. Finally, we ap-
plied fire models to predict how estimated regional fuel
reduction would affect grassland fire behavior.
Calculating fuel reductions
We assumed that fine fuel reduction by cattle equals
the amount of rangeland forage consumed by cattle in
California. This is a conservative estimate of the total
fuel reduction since it does not explicitly consider fine
fuels removed through trampling (Nader et al. 2007),
but see AUM in supplemental table 2 in the online
supplemental appendix. Consumed rangeland forage
is a function of the number of cattle grazing on range-
lands (head), the class of cattle, and the time spent
grazing on the rangeland (in months; equation 1). We
used five datasets to determine the values in equation
1, including the 2017 USDA Agricultural Census, Cali-
fornia Brand Inspection Data, County Crop Reports,
GAP LANDFIRE vegetation classification and MODIS
imagery (supplemental table 1). We also consulted with
livestock and range advisors from the University of
California Cooperative Extension (UCCE) to estimate
irrigated pasture use and further refine the data (See
“Animal Unit Months and Forage Removal” in the on-
line supplemental appendix).
The census data provides an inventory of beef cows
and “other cattle” in each county. “Other cattle” are all
non-cow classes (including both beef and dairy cattle).
We used the brand inspection data to estimate the
proportion of “other cattle” that were beef cattle, and
to estimate the proportion of these that belong to each
non-cow class (supplemental tables 1 and 2).
In order to account for inter-county movement of
cattle, we created beef production regions in California
(fig. 1). These regions were selected to account for the
majority of inter-county movements of cattle, and for
similarities in forage production and livestock produc-
tion practices for counties without pronounced pat-
terns of inter-county cattle movement.
Regional rangeland acres were calculated by:
(1) summing harvested rangeland acreage statistics
from the county crop reports to estimate “Grazed
Rangeland” acres, and (2) summing the rangeland
acreage types per region using the GAP/LANDFIRE
National Terrestrial Ecosystems (GAP) (USGS 2016)
classification to estimate “Total Rangeland” acres.
We used the following equation to calculate the
total pounds of forage removed on rangelands in each
region by cattle (variables are described in supplemen-
tal table 2):
forage consumed = ∑region k (∑county j (∑cattle
class i(headijk × monthsijk × AUEi –IP.adjustijk) ×
1,000 pounds/AUM ))
To estimate forage removed per rangeland acre, we
divided the estimated forage consumed by rangeland
acreage in each region. To account for differences in
approaches to estimating rangeland acreage, we calcu-
lated this using two datasets: county crop reports and
the GAP classification.
Forage production and RDM
RDM is the unused forage at the end of the grazing
season (fall) (Bartolome et al. 2006), measured in
pounds per acre or kilograms per hectare. The total
amount of forage produced per acre on rangelands
is generally measured in late spring at peak stand-
ing crop. It is an approximate measure of the amount
of fine fuel produced per acre annually (excluding
Humboldt Trinity
Del
Norte Siskiyou
Shasta Lassen
Modoc
Tehama
Glenn Butte
Plumas
Sierra
NevadaYubaPlacer
El Dorado
AlpineYolo
NapaSonoma
Lake Colusa
Mendocino
Sacramento Amador
CalaverasSan Joaquin
Solano
Contra Costa
Alameda Stanislaus
Santa
Clara Merced
Mariposa
Madera
San
Benito
Monterey Kings
Fresno
Tulare
Inyo
Kern
San Bernadino
Riverside
San Diego Imperial
Orange
Los AngelesVentura
Santa Barbara
San Luis
Obispo
Marin Tuolumne Mono
Sutter
San Francisco
San Mateo
Santa Cruz
Sacramento-
Sierra-Cascade
Southeast
Interior
San Joaquin-Sierra
South Coast
Central Coast
North Coast
FIG. 1. Beef cattle grazing regions of California.
62 CALIFORNIA AGRICULTURE • VOLUME 76, NUMBER 2–3
Page 38 of 46
non-forage species), which is an important determi-
nant of fuel load. RDM is not a perfect measure of fuel
load because it excludes non-forage species and is only
measured at the end of the fire season. Nevertheless, it
gives an approximate value for residual fuel load. When
compared to production measurements, RDM can be
used to determine fine fuel removal rates by livestock
in grazed rangelands.
We evaluated production data from 52 sites in the
Central Coast, North Coast and Sacramento-Sierra-
Cascade regions that was collected between 2000 and
2019, and RDM data from 105 sites collected between
1987 and 2019. We summarized these data to charac-
terize variability in production between regions and
at sub-regional scales, and to qualitatively assess het-
erogeneity of RDM and fuel reduction rates on grazed
rangelands (supplemental table 4). We then compared
these reduction rates to regional fuel reduction rates
from the census-based fuel reduction estimates.
Modeling fire behavior
Custom fuel models were built using the BehavePlus
6 fire behavior model application to determine how
variation in grassland fine fuel loads could affect flame
length. Initial parameters were based on the low fuel
load, dry-grass model GR2 (Scott and Burgan 2005),
and the two grass models from the “original 13 fuel
models” as described by Anderson (1982). However,
several variables were altered to represent a range
of fuel loads in different topographic positions and
weather conditions (supplemental table 6). The pattern
and scale of results from using the three different fuel
models as the base for custom fuel models were similar
(supplemental figs. 1–4). Therefore, our discussion is
limited to the results of using the GR2 fuel model.
A summer model was built to represent fuel con-
ditions after annual grasses had senesced and dried,
and when fire conditions should be most extreme in
a given year. For the summer models, we evaluated
flame lengths when wind speeds were between 0 and 40
miles per hour (0–64.4 kilometers [km] per hour), and
when fuel loads were between 100 and 2,000 pounds
per acre (112–2,242 kilograms [kg] per hectare [ha]).
Additionally, three separate dead fuel moisture sce-
narios (high at 13%, moderate at 6% and low at 2%) and
two separate slope scenarios (high at 100% and low at
0%) were run. The high dead fuel moisture scenario
was set to 13%, since our moisture of extinction (fuel
moisture at which fuels are no longer ignitable) was set
at 15% and is within the range of values that can be ex-
pected in California grasslands (Livingston and Varner
2016). While there is a dearth of literature on dead fuel
moistures in California grasslands, the moderate dead
fuel moisture scenario was set to 6%, because that was
the lowest value measured by Livingston and Varner
(2016) in late September. We set this as our moderate
value, instead of our low value, because their measure-
ments took place in Northern California, where we
might expect higher dead fuel moistures due to a more
mesic (moist) climate. Lastly, the low dead fuel mois-
ture value was selected to represent very extreme fire
conditions. The higher slope value of 100% slope was
selected to represent a high slope scenario, but one that
was still reasonable for firefighters to access.
A spring model that included more live fuel and
a higher fuel moisture content was also evaluated
(supplemental figs. 1 and 2). While the GR2 model is
dynamic and automatically reapportions some of the
live herbaceous fuel to a one-hour fuel load, we turned
off the dynamic feature of our fuel models because we
were manually setting the ratio of live to dead fuel as
part of the spring and summer scenarios.
BehavePlus 6 defaults to setting a maximum ef-
fective windspeed, but studies have shown that this
can underestimate flame lengths and rates of spread
(Andrews et al. 2013). Therefore, we turned off this
feature and did not impose a maximum effective
windspeed in our model calculations. Additionally,
BehavePlus 6 has the option for the windspeed to be
calculated at the midflame height, 20 feet above the
vegetation, or 10 meters above the vegetation. We set
the input for wind speeds to be at midflame height.
This is the average windspeed from the top of the fuel
bed to the height of the flame in relation to the fuel.
Regional variations
Approximately 1.8 million beef cattle grazed range-
lands in California in 2017. Although there was a slight
dip in the number of beef cows in the state during the
2012–2015 drought, their number had rebounded to the
decadal average by 2017 (CDFA 2010–2018), indicating
that 2017 Census numbers are representative of the pre-
drought cattle numbers.
Beef cows were by far the most abundant beef cattle
class, with 677,000 on range in the state in 2017. This
was followed by steers, heifers, “mixed” (an amalgama-
tion of different classes that couldn’t be separated using
the brand inspection data), and bulls.
The number of months cattle spent on rangeland
varied by county and by cattle class. Cows were esti-
mated to spend an average of 10.7 months on range-
land (this accounts for cows that were removed from
rangeland due to replacement). Steers and heifers
were estimated to be on range an average of 7.6 and
7.7 months, respectively, and bulls and “mixed” cattle
averaged 6.6 months on range. Time spent on range by
each class of cattle varied substantially between coun-
ties and regions.
The cumulative fine fuel removal by these cattle var-
ied by region from 85.0 million pounds (34.6 million
kg) in the South Coast region to 5,444 million pounds
(2,469 million kg) in the San Joaquin-Sierra region (fig.
2). In regions with higher levels of irrigated pasture use
(San Joaquin-Sierra and Sacramento-Sierra-Cascade),
estimates of fuel removal may be somewhat higher than
actual removal rates if irrigated pasture use was higher
http://calag.ucanr.edu • APRIL–SEPTEMBER 2022 63
Page 39 of 46
in 2017 than the regional estimates used in our analy-
sis. Across the state, the total fuel reduction by cattle in
2017 was 11.6 billion pounds (5.3 billion kg). Overall,
this is probably a conservative estimate of fuels reduced
on rangelands since it does not take into consideration
fine fuels trampled by cattle and incorporated into
mineral soil.
There were 19.4 million acres (7.9 million ha) of
rangeland grazed by livestock in California accord-
ing to county crop reports and county Agricultural
Commissioners’ offices. This is close to the 17 million
acres (6.9 million ha) of private grazed rangeland previ-
ously reported in the state (CAL FIRE 2017), which is
not surprising since many county crop reports do not
include federal grazing allotments in their rangeland
acreage estimates. On the other hand, our estimate of
the total rangeland acreage based on the California
GAP was 59.4 million acres (24 million ha). This es-
timate includes all public and privately owned range-
land, whether or not it is grazed.
The average amount of fuel removed across grazed
rangelands in the state was 596 pounds per acre (668
kg/ha). This number varied from 174 pounds per acre
(195 kg/ha) in the Southeast Interior region to 1,020
pounds per acre (1,143 kg/ha) in the San Joaquin-Sierra
Region (table 1; fig. 3).
When calculated across all rangeland acres identi-
fied in the GAP analysis (not just grazed acres), average
fuel reduction was only 195 pounds per acre (219 kg/
ha). This lower number is largely due to the fact that
there is rangeland that is not grazed in every region.
The per-acre fuel reduction using the GAP acreage has
similar regional trends to fuel reduction based on acre-
age from the county crop reports (table 1; fig. 4).
The regional values of grazing intensity are far be-
low the amount of forage produced by region in most
years. Valley grasslands in the interior of the state gen-
erally produce 2,000 pounds of forage per acre (2,242
kg/ha) or more in an average forage year (Bartolome
1987; Becchetti et al. 2016). Central and northern coast
TABLE 1. Acreage and average fuel reduction rates on grazed and total rangelands by region
Region
Grazed rangeland acreage
(from crop reports)
All rangeland acreage
(from GAP)
Fuels removed – grazed
rangelands (pounds/acre)
Fuels removed – all
rangelands (pounds/acre)
Central Coast 3,983,153
(1,611,925 ha)
7,242,014
(2,930,739 ha)
419
(470 kg/ha)
230
(258 kg/ha)
North Coast 1,857,912
(751,870 ha)
2,504,836
(1,013,671 ha)
419
(470 kg/ha)
450
(504 kg/ha)
Sacramento-Sierra-Cascade 5,827,095
(2,358,142 ha)
11,703,394
(4,736,196 ha)
495
(555 kg/ha)
246
(276 kg/ha)
San Joaquin-Sierra 5,336,824
(2,159,736 ha)
9,265,683
(3,749,689 ha)
1,020
(1143 kg/ha)
588
(659 kg/ha)
South Coast 211,560
(85,615 ha)
3,659,608
(1,480,991 ha)
401
(449 kg/ha)
23
(26 kg/ha)
Southeast Interior 2,232,720
(903,550 ha)
25,031,549
(10,129,908 ha)
174
(195 kg/ha)
16
(18 kg/ha)
Total 19,449,264
(7,870,838 ha)
59,407,085
(24,041,194 ha)
596 (average)
(668 kg/ha)
195 (average)
(219 kg/ha)
0
1,000
2,000
3,000
4,000
5,000
6,000
Mi
l
l
i
o
n
s
o
f
p
o
u
n
d
s
o
f
f
u
e
l
r
e
m
o
v
e
d
Cows
Bulls
Heifers
Mixed
Steers
Central Coast North Coast Sacramento-
Sierra-Cascade
San Joaquin-
Sierra
South Coast Southeast
Interior
0
1,000
800
600
400
200
Po
u
n
d
s
o
f
f
u
e
l
r
e
m
o
v
e
d
p
e
r
a
c
r
e
Central Coast North Coast Sacramento-
Sierra-Cascade
San Joaquin-
Sierra
South Coast Southeast
Interior
FIG. 3. Pounds per acre of fuel reduction on grazed rangelands in California regions.
FIG. 2. Millions of pounds of rangeland fuel removed by cattle in each region.
64 CALIFORNIA AGRICULTURE • VOLUME 76, NUMBER 2–3
Page 40 of 46
range grassland sites produce more than 3,000 pounds
of forage per acre (3,363 kg/ha) (Becchetti et al. 2016;
Larsen et al. 2020). Coastal prairie sites can be highly
productive, producing more than 4,500 pounds per
acre (5,044 kg/ha) on average in the Central Coast
(Larsen et al. 2020). In the highest production years,
forage production can be double the average in any
given region, and in the lowest production years it
can be less than 25% of average production (Larsen et
al. 2020). The relatively low grazing intensity reflects
the generally conservative stocking strategies used by
many ranchers across the state to hedge against the un-
predictable and highly variable annual forage produc-
tion (Macon et al. 2016).
It’s important to keep in mind that grazed acres and
forage removal rates in this paper are not “hard num-
bers,” but rather are estimates to inform large-scale
patterns of fuel removal by cattle. These estimates are
based on the best available data, but these data do not
describe the intricate (and dynamic) details of cattle
grazing across the state. These numbers should be in-
terpreted in the context of understanding regional fuel
reduction, not as predictive of grazing practices at sub-
regional scales. There is a need for more consistent and
accurate reporting of cattle numbers and grazed acres
across the state.
Based on several datasets, forage production and
RDM were highly variable within and between regions
of the state. Average RDM in each region was signifi-
cantly less than production, but the amount of fuel
reduced was highly variable (table 2).
Collectively, these data show that reductions of
fuels measured on ranches can differ significantly
from region-wide averages seen in the Census analy-
sis. The Census gives an indication of the county in
which grazing occurs, but it does not tell us where
those animals graze within the county. The RDM data
also show that spatial differences in forage production
and grazing practices can lead to differences in the
amount of fine fuels and the level of fuel reduction by
cattle. This is consistent with other research showing
that annual forage production is highly variable across
the state, varying at small and large scales in relation
to soil characteristics, microclimate, position on the
landscape, and tree canopy cover (Becchetti et al. 2016;
Devine et al. 2019; Frost et al. 1991).
Lower flame lengths
Keeping flame lengths below eight feet (2.4 meters [m])
is seen as a critical threshold that allows fire fighters
to use direct measures (such as heavy equipment) on
the ground to fight fires. Below four feet (1.2 m), fires
can be fought using hand tools (Andrews and Rother-
mel 1982). However, these thresholds are somewhat
fuzzy and dependent on other aspects of the fire, i.e.,
TABLE 2. Forage production and residual dry matter (RDM) from coastal prairie, coast range grassland, and valley grassland sites in Central and
Northern California
Region Data source
Average production
(pounds/acre)
Production
minus summer
decomposition
(75% of total)*
Average RDM
(pounds/acre)
Average fuel
reduction
(pounds/acre)
Central Coast (Coastal)Larsen et al. 2020 4,978
(5,580 kg/ha)
3,734
(4,185 kg/ha)
1,815
(2,034 kg/ha)
1,919
(2,151 kg/ha)
Northern California
(Coastal)
Bartolome et al. 2015
and Point Reyes
unpublished data 2020
7,053†
(7,905 kg/ha)
5,290
(5,929 kg/ha)
2,147
(2,406 kg/ha)
3,143
(3,523 kg/ha)
Central Coast (Coast
Range)Larsen et al. 2020 3,371
(3,778 kg/ha)
2,528
(2,834 kg/ha)
2,055
(2,303 kg/ha)
473
(530 kg/ha)
Central Coast (Coast
Range)
NRCS unpublished data
2010
3,055
(3,424 kg/ha)
2,138
(2,396 kg/ha)
1,775
(1,990 kg/ha)
363
(407 kg/ha)
Central Coast (Interior)Larsen et al. 2020 1,961
(2,198 kg/ha)
1,471
(1,649 kg/ha)
1,053
(1,180 kg/ha)
418
(469 kg/ha)
Sacramento-Sierra-
Cascade (Interior)
UC ANR unpublished
data
3,096
(3,470 kg/ha)
2,322
(2,603 kg/ha)
800‡
(897 kg/ha)
1,522
(1,706 kg/ha)
* Based on Frost et al. 2005.
† Production values from only two years of data.
‡ RDM values estimated not measured.
0
600
400
500
200
300
100Po
u
n
d
s
o
f
f
u
e
l
r
e
m
o
v
e
d
p
e
r
a
c
r
e
Central Coast North Coast Sacramento-
Sierra-Cascade
San Joaquin-
Sierra
South Coast Southeast
Interior
FIG. 4. Pounds per acre of fuel reduction on all rangelands in California regions.
http://calag.ucanr.edu • APRIL–SEPTEMBER 2022 65
Page 41 of 46
spread and fire intensity (Andrews et al. 2011). Based
on our fire behavior models, on flat ground in dry
summer conditions (when dead fuel moisture is 6%),
fine fuel loads below 1,225 pounds per acre (1,373 kg/
ha; fig. 5) are predicted to keep flame lengths below
eight feet at wind speeds up to 15 miles per hour (24
km per hour). At higher dead fuel moisture levels and
lower wind speeds, flame lengths may be kept below
eight feet at higher fuel loads. However, in extreme
fire weather with very low dead fuel moisture (2%)
and wind speeds up to 40 miles per hour (64.4 km per
hour), fine fuel loads may need to be reduced below
214 pounds per acre (240 kg/ha) (fig. 5) to keep flame
lengths under eight feet. In high slope areas during dry
conditions (6% dead fuel moisture) with windspeeds
of 15 miles per hour, fine fuel loads would need to be
kept below 1,000 pounds per acre (1,121 kg/ha) to keep
flame lengths below eight feet. In very dry conditions
(2% dead fuel moisture), at wind speeds of 40 miles
per hour, fuel loads would need to be reduced below
205 pounds per acre (230 kg/ha) to keep flame lengths
below eight feet. While these models are useful for in-
terpreting potential impacts of estimated fuel reduction
levels, the results still need to be experimentally vali-
dated in California before they are used for policy and
planning purposes. Also, these models do not evaluate
ignition potential, level of shrub encroachment, and
areas with elevated ignition risk, which may have dif-
ferent fuel load thresholds. There is always a level of
uncertainty associated with fire behavior modeling.
Depending on the aptness of the fuel models, Behave-
Plus 6 results can be off by a factor of two or more
(Sparks et al. 2007).
Understanding the effect of cattle grazing on fire
behavior is complicated by the pronounced spatial and
temporal variability in forage production, fuel reduc-
tion, shrub encroachment and RDM at scales smaller
than the region or county. In their measurements at
43 different ranches spanning a rainfall gradient in
Central California, Larsen et al. (2020) found RDM
values ranging from 75 to 6,258 pounds per acre (84 to
7,014 kg/ha) from 2000 to 2019. Forty percent of graz-
ing fields had RDM values at or below 1,225 pounds
per acre (1,373 kg/ha), while only 4% were below 214
pounds per acre (240 kg/ha). This shows that many
areas of these grazed rangelands had good fuel condi-
tions for non-extreme fire weather, but few locations
had fuel levels low enough to keep flame lengths below
eight feet in extreme fire weather. No grazing fields had
RDM below these thresholds consistently across all
monitoring years.
Strategic grazing
The inherent heterogeneity of grazing intensity and
fuel reduction may in fact be its greatest asset in re-
ducing wildfire hazard and risk. Selective grazing
by livestock can create patchiness of fuels, reducing
continuity of fuels and reducing rate of fire spread and
total burned area (Bunting et al. 1987; Kerby et al. 2007;
2,000
1,500
1,000
500
0
0 10 20 30 40
Fu
el
l
o
a
d
(
l
b
/a
c
r
e
)
Wind speed (mi/hr)
A
DFM = 13%, slope = 0% model
B
DFM = 6%, slope = 0% model
C
DFM = 2%, slope = 0% model
D
DFM = 13%, slope = 100% model
E
DFM = 6%, slope = 100% model
F
DFM = 2%, slope = 100% model
0 10 20 30 40
Wind speed (mi/hr)
0 10 20 30 40
Wind speed (mi/hr)
2,000
1,500
1,000
500
0
0 10 20 30 40
Fu
e
l
l
o
a
d
(
l
b
/
a
c
r
e
)
Wind speed (mi/hr)
0 10 20 30 40
Wind speed (mi/hr)
0 10 20 30 40
Wind speed (mi/hr)
10.0
am
e
l
e
n
g
t
h
(
f
t
)
am
e
l
e
n
g
t
h
(
f
t
)
am
e
l
e
n
g
t
h
(
f
t
)
am
e
l
e
n
g
t
h
(
f
t
)
am
e
l
e
n
g
t
h
(
f
t
)
am
e
l
e
n
g
t
h
(
f
t
)
7.5
5.0
2.5
20
15
10
5
20
10
9
3
6 15
20
5
10
30
20
10
FIG. 5. Results from fire behavior modeling under summer conditions. Conditions were run under three dead fuel moisture scenarios of 13% (A, D),
6% (B, E) and 2% (C, F), and two slope scenarios of 0% (A, B and C) and 100% (D, E and F). Contour lines show when threshold flame lengths of 4 feet
(solid line), 8 feet (long-dashed line) and 11 feet (short-dashed line) are surpassed.
66 CALIFORNIA AGRICULTURE • VOLUME 76, NUMBER 2–3
Page 42 of 46
Launchbaugh 2016; Taylor 2006). At the ranch scale,
RDM data from the Central Coast shows that, even
in a region with relatively low grazing intensity, fuel
reduction of several thousand pounds per acre can be
achieved in select locations (Larsen et al. 2020).
Given that grazing intensity on California range-
lands is generally conservative relative to the amount
of forage produced in most years (as evidenced by the
generally low fuel reduction for most regions in the
Census analysis), strategic implementation of grazing
should be employed to maximize the benefit of live-
stock grazing for fuels reduction. A strategic grazing
program would target grazing on certain areas of the
landscape. It should consider maintaining fuel breaks,
controlling shrub encroachment, employing grazing
near the wildland-urban interface, proximity to urban
centers, annual weather patterns (i.e., grazing in ad-
vance of Santa Ana or Diablo winds), potential sources
of ignition, and the realities of grazing operations (in-
cluding animal distribution, nutrition, site accessibility,
and the need to bank forage for the fall). To be success-
ful, grazing strategies must be logistically feasible and
financially sustainable for the grazing operator.
A strategic approach to fuels reduction is especially
important given that California rangelands are man-
aged for multiple resource objectives. Reducing fuels on
all grazed rangelands to 1,225 pounds per acre (1,373
kg/ha) or less will not be compatible with some of these
objectives in some areas. RDM recommendations are
based on the type of grassland (dry annual grassland,
annual grasslands/hardwood rangeland, or coastal
prairie), terrain slope, and percent cover of woody veg-
etation (Bartolome et al. 2006). RDM standards vary
from 300 pounds per acre (336 kg/ha) on some dry,
flat inland sites to 2,100 pounds per acre (2,354 kg/ha)
on steep, coastal prairie sites (Bartolome et al. 2006).
Maintaining adequate RDM is expected to minimize
soil erosion, improve forage production, and influence
plant species composition at some sites — but many
areas have RDM standards above the preliminary fuel
load thresholds reported here. In particular, steeper
areas have higher minimum RDM recommendations
— but these areas would need even lower fuel loads to
keep flame lengths below eight feet. Testing these fuel
load thresholds on the ground and having discussions
between fire modelers and rangeland specialists will
be critical to making appropriate recommendations
about grazing levels to achieve both fire safety and
natural resource objectives. Furthermore, RDM is mea-
sured immediately prior to the first germinating rains
(September or October) and fuel reductions will need to
be achieved earlier in the year if they are meant to apply
to the bulk of the fire season. Fuel reduction also must
ensure that adequate forage is left to support continued
livestock grazing during the fall and winter months.
There are several potential synergies between re-
ducing residual biomass for fire safety and conserva-
tion objectives. Excessive residual biomass and height
have been found to negatively affect many sensitive or
threatened wildlife species (Ford et al. 2013; Gennet
et al. 2017; Germano et al. 2011; Riensche 2008), cause
problems for weed management (Becchetti et al.
2016), and negatively affect some native plant species
(Bartolome et al. 2014; Beck et al. 2015). Where pos-
sible, maximum biomass standards for fuel reduction
should be strategically implemented to simultaneously
promote these and other conservation goals.
Cattle grazing is not the only management tool that
can be used to reduce residual biomass. Unlike wildfires,
prescribed fires are well planned, and are implemented
to achieve one or more specific objectives. Prescribed
fires burn thatch, increasing seed access to the soil sur-
face, and creating more suitable light conditions and
ground temperatures for grassland forbs (Sugihara et al.
2006). This allows higher levels of seed production and
flowering in forbs after late spring fires. Prescribed fire
can be used alone, or in conjunction with grazing, to
improve habitat for some native plants and sensitive or
threatened wildlife species. In the early 1950s, ranchers
were permitted to burn a substantial amount of land in
California, up to more than 200,000 acres in one year
(Biswell 1999). Since that time, prescribed burn acreage
has been in steep decline. However, due to recent cata-
strophic wildfires, there is renewed interest in prescribed
burning. Though grazing is substantially more wide-
spread than prescribed burning today, thanks to new
This cow-calf operation
on the Central Coast has
cattle grazing on the
ranch year-round, helping
to reduce the potential
for catastrophic wildfire.
Photo: Devii Rao.
http://calag.ucanr.edu • APRIL–SEPTEMBER 2022 67
Page 43 of 46
legislation (SB 901 and SB 1260) and development of
prescribed burn associations across the state, prescribed
burning is becoming a viable option again.
Grazing can reduce fuel
Cattle grazing plays an important role in reducing fuels
on California rangelands. Without grazing, we would
have hundreds or possibly thousands of additional
pounds per acre of fuel on rangelands, potentially lead-
ing to larger and more devastating fires. Cattle grazing,
of course, can’t eliminate wildfires completely. But it
can make a big impact. Cattle don’t consume forage
uniformly on rangelands. Instead, they eat in more of
a patchwork pattern. Thus, while cattle grazing does
not reduce fuels enough to avoid hazardous 4- or 8-foot
wildfire flame lengths on all grazed rangelands, many
areas will be grazed sufficiently to significantly alter fire
behavior (especially in non-extreme fire weather).
To effectively reduce wildfire hazards, rangeland
managers and planners must strategically coordinate
fuel management practices, such as cattle grazing along
with other natural resource objectives and manage-
ment practices, including prescribed fire. This will
require the development of maximum residual biomass
standards that can be used to assess fuel loads at criti-
cal times and locations during the fire season. To help
develop these standards, we need to experimentally
validate fire behavioral models in herbaceous range-
lands in California.
Widespread wildfires are predicted to increase over
time in California due to ongoing climate change. This
new reality requires that we take advantage of all the
tools available to protect public safety while also meet-
ing broader rangeland management objectives. All of
this is occurring against the backdrop of the decline
of the number of beef cows grazing in California,
including on public lands, over the past several decades
(Oles et al. 2017; Saitone 2018). It is not feasible to graze
all rangelands to ideal fuel levels, nor is it compatible
with management goals across the state. However, there
are opportunities to improve fire safety in California by
grazing rangelands that are not currently being grazed
— or even by increasing grazing intensity on some very
lightly grazed areas. Strategic implementation of cattle
grazing, including potentially fee-for-service agree-
ments on key private and public lands, can meet mul-
tiple natural resource objectives while also lowering fire
hazards by reducing fine fuels, reducing fuel continuity
and slowing or even stopping shrub encroachment onto
grasslands. C
F. Ratcliff is Rangeland Conservation Scientist, LD Ford, Consultants
in Rangeland Conservation Science; D. Rao is UC Cooperative
Extension (UCCE) Livestock and Natural Resources Advisor, San
Benito, Monterey and Santa Cruz counties; S. Barry is UCCE
Livestock and Natural Resources Advisor, Santa Clara, San Mateo,
Alameda and Contra Costa counties; S. Dewees is Graduate
Student, Ecology, Evolution, Marine Biology, UC Santa Barbara;
L. Macaulay is Wildlife Management Specialist, University of
Maryland Extension; R. Larsen is UCCE Area Natural Resource/
Watershed Advisor, San Luis Obispo County; M.W.K. Shapero is
UCCE Livestock and Range Advisor, Ventura and Santa Barbara
counties; R. Peterson is M.S. Student, Graduate Group in Ecology, UC
Davis; M. Moritz is UCCE Wildfire Specialist, Bren School, UC Santa
Barbara; L. Forero is UCCE Livestock and Natural Resources Advisor,
Shasta and Trinity counties.
This project was funded by the California Cattle Council. The
authors would like to thank Dan Macon, Tracy Schohr, John Harper,
Scott Oneto, Laura Snell, Morgan Doran, Julie Finzel, Josh Davy,
Rebecca Ozeran, David Lile, Jeffery Stackhouse, Theresa Becchetti,
Brooke Latack, Rob Wilson, Fadzayi Mashiri, Callie Peek, Chris
McDonald and Stephanie Larson for providing irrigated pasture
and regional cattle production information.
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1
Kristine Lawler
Subject:14a PC Correspondence Received - Commissioner Johnson
From: Rick Johnson <rjohnson@cityofukiah.com>
Sent: Sunday, October 19, 2025 9:24 PM
To: Jesse Davis <jdavis@cityofukiah.com>
Subject: Open Space Topic
Jesse,
Here is a research article discussing the benefits of using grazing animals to manage fuel in areas like
open spaces. Might be helpful to provide to the other commissioners.
Thanks for your work in advancing this subject.
Rick
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