Codify — Article

SB 815: Expands California general plan duties on wildfire retrofits, connectivity, and multimodal safety

Requires new local planning tasks — a wildfire retrofit strategy, wildlife‑connectivity analysis, FHWA Safe System planning for circulation, climate vulnerability work, and environmental justice elements.

The Brief

SB 815 amends the statutory list of required general plan elements to deepen how cities and counties plan for wildfire risk, climate impacts, and habitat connectivity. It directs planning agencies to add or update specific analytical work and deliverables — notably a comprehensive retrofit strategy for residential buildings and infrastructure in high fire–risk areas and expanded conservation and circulation analyses — when they next revise their plans.

The bill forces local planning bodies to turn broad safety and conservation goals into discrete actions: inventories, prioritized retrofit lists, measurable milestones, consultation obligations, and incorporation or cross‑referencing of existing local hazard or conservation plans. For local governments, developers, and emergency managers, that means new planning tasks, data needs, and possible funding or permitting implications tied to wildfire and climate resilience requirements.

At a Glance

What It Does

Establishes new content requirements in multiple general plan elements — safety, conservation, circulation, and environmental justice — including a mandated comprehensive retrofit strategy for residential and infrastructure fire hardening, an analysis of wildlife connectivity and passage features, and circulation planning that adopts the Federal Highway Administration’s Safe System Approach with bicycle and pedestrian plans tied to 25‑year goals.

Who It Affects

Cities, counties, and city‑counties that prepare general plans and housing elements, state agencies that provide maps or guidance (e.g., State Fire Marshal, Dept. of Fish and Wildlife), and stakeholders who own or operate residential property and transportation infrastructure in very high fire hazard zones.

Why It Matters

The measure converts several high‑level planning duties into specific, datadriven tasks (inventories, prioritized milestones, funding strategies, and required submittals). That raises the stakes for local compliance, regional coordination, and for property owners in mapped very high fire risk areas who will appear on municipal retrofit inventories.

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What This Bill Actually Does

SB 815 layers new, actionable requirements onto the general plan elements California law already requires. For the safety element it does more than ask municipalities to map hazards: the bill forces a planning agency, at the next housing element or hazard mitigation update on or after January 1, 2026, to produce a comprehensive retrofit strategy focused on reducing wildfire losses.

The strategy must identify the types of retrofits needed in an area, provide a process to inventory residential structures and supporting infrastructure, set goals and milestones, and list potential funding and financing approaches. The statute directs planners to prioritize structures in very high fire hazard areas and to send the adopted strategy to the state clearinghouse for land use and climate work.

On conservation, SB 815 requires localities updating their plans on or after January 1, 2028, to identify and analyze connectivity areas, permeability, and natural landscape areas; to inventory existing or planned wildlife passage features (including those on or adjacent to the state highway system); and to evaluate how planned development could impair wildlife movement. Cities and counties may meet these requirements by adding a dedicated wildlife connectivity element or by incorporating qualifying existing plans by reference, and they are expected to consult Department of Fish and Wildlife and nearby tribes where appropriate.The circulation element revision obligations are more prescriptive as well.

When a substantive circulation update occurs, local governments must incorporate the FHWA Safe System Approach and prepare bicycle, pedestrian, and traffic‑calming plans for urbanized areas that identify safety corridors and high‑concentration activity sites, use evidence‑based countermeasures, and set initiation and completion targets within 25 years. Implementation must begin within two years of adopting the modified circulation element, and jurisdictions must periodically review progress and revise the element if the 25‑year goals become unattainable.Climate adaptation and related hazard planning receive parallel elevation: vulnerability assessments and adaptation/resilience policies must accompany safety element revisions (previously required under other dates) and agencies can rely on, or incorporate by reference, existing hazard mitigation or adaptation plans that substantially comply.

The statute also preserves flexibility by allowing jurisdictions that already have equivalent material in other local documents to incorporate that material rather than duplicate work, while still expecting a summary showing how requirements have been met.

The Five Things You Need to Know

1

The safety element must include a comprehensive retrofit strategy (triggered by the next housing element or hazard mitigation plan update on or after January 1, 2026) that inventories residential structures and infrastructure and prioritizes retrofits in very high fire hazard areas.

2

The retrofit strategy must list retrofit types needed by fire risk area, provide processes for identification/inventory, set goals and milestones, and identify potential funding and financing options; adopted strategies must be submitted to the Office of Land Use and Climate Innovation clearinghouse.

3

When a circulation element undergoes a substantive revision, the legislative body must adopt the Federal Highway Administration’s Safe System Approach and develop bicycle, pedestrian, and traffic‑calming plans for urbanized areas with initiation and completion targets within 25 years and implementation beginning within two years.

4

Conservation element updates on or after January 1, 2028 must identify connectivity areas, analyze wildlife passage features (including those inventoried for the state highway system), and consider measures to avoid, minimize, or mitigate barriers to wildlife movement.

5

Jurisdictions may incorporate existing fire safety, hazard mitigation, or climate adaptation plans by reference if those documents substantially comply, but they must still summarize how each statutory requirement is met in the general plan.

Section-by-Section Breakdown

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(b)(2)(B)-(C)

Circulation updates: Safe System Approach and 25‑year multimodal goals

These paragraphs require local circulation elements that are substantively revised to adopt FHWA’s Safe System principles and to produce detailed bicycle, pedestrian, and traffic‑calming plans for urbanized areas. Practically, jurisdictions must identify safety corridors and sites that generate high cyclist/pedestrian volumes, adopt evidence‑based countermeasures, and set timelines to initiate and complete actions within 25 years. The law further obliges implementation to begin within two years of adoption and mandates periodic reviews to track progress and identify impediments — a structure intended to push planning documents toward execution rather than remain aspirational.

(d)(4)-(6)

Conservation element: wildlife connectivity and optional standalone element

Starting with revisions adopted on or after January 1, 2028, the conservation element must map and analyze connectivity areas, permeability, and natural landscape areas and catalog existing or planned wildlife passage features (including those on the state highway system). The provision also allows localities to meet the requirement by adopting a separate wildlife connectivity element or by incorporating qualifying existing plans by reference. The practical implication is that planners will need spatial data, coordination with regional inventories, and consideration of mitigation or design measures (lighting, fencing, buffers) to preserve or restore movement corridors.

(g)(6)

Safety element: mandated comprehensive retrofit strategy for wildfire resilience

This subsection compels planning agencies, when they next revise their housing element or hazard mitigation plan on or after January 1, 2026, to include a comprehensive retrofit strategy that identifies retrofit types, a process for inventorying residential structures and infrastructure, prioritized goals and milestones, and potential funding sources for both public and private retrofits. The statute specifically prioritizes structures in very high fire risk hazard areas and requires the adopted strategy be submitted to the state clearinghouse for land use and climate innovation, creating a transparent record and enabling state‑level aggregation of retrofit plans.

3 more sections
(g)(4)

Safety element: climate vulnerability assessment and adaptation measures

When local hazard mitigation plans are revised (or if none exist, by January 1, 2022), the safety element must include a vulnerability assessment that identifies at‑risk areas and assets and must adopt adaptation and resilience goals and feasible implementation measures. The provision anchors local work to statewide tools and data sources (Cal‑Adapt, the California Adaptation Planning Guide) and asks jurisdictions to inventory sensitive assets, current adaptive capacity, and existing/planned development in at‑risk areas — effectively making climate exposure a standard input to land use decisions.

(g)(7)-(11)

Review cadence, consultation, and use of existing plans

After the initial set of mandated revisions, planning agencies must review and, if necessary, revise safety elements at each housing element or hazard mitigation plan update, but not less than once every eight years. The statute requires consultation with state entities (California Geological Survey, Central Valley Flood Protection Board where applicable, Office of Emergency Services) and allows cities to adopt relevant portions of a county safety element when appropriately detailed. These provisions are procedural but important: they both set minimum update frequency and channel where local agencies must seek technical information.

(h)

Environmental justice element or integrated objectives

SB 815 preserves and clarifies the requirement that jurisdictions with disadvantaged communities include an environmental justice element or integrate related goals into other elements. The element must identify objectives to reduce pollution exposure, improve public facilities and food access, promote civic engagement, and prioritize investments for disadvantaged communities, using the CalEPA disadvantaged community definition or locally identified low‑income areas.

At scale

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Who Benefits and Who Bears the Cost

Every bill creates winners and losers. Here's who stands to gain and who bears the cost.

Who Benefits

  • Residents in very high fire hazard areas: will be prioritized for inventories and retrofit planning, which aims to reduce household and community wildfire risk and improve evacuation and response infrastructure.
  • Wildlife and conservation organizations: gain statutory weight for connectivity analyses and inventorying of wildlife passage features, strengthening the basis for habitat protection and mitigation measures in local plans.
  • Active‑transportation users and safety advocates: get new, evidence‑based bicycle and pedestrian plans and the requirement that jurisdictions adopt the Safe System Approach, increasing the likelihood of targeted infrastructure and safety investments.
  • Disadvantaged communities: receive focused planning attention via the environmental justice element, which must identify pollution‑reduction, facility, and civic engagement objectives that prioritize improvements for these communities.

Who Bears the Cost

  • Cities, counties, and planning agencies: must perform new inventories, technical analyses, consultation, and submittals; develop retrofit strategies and updated circulation/conservation elements; and show measurable milestones — all of which require staff time, data, and often consultant assistance.
  • Private property owners in high fire risk zones: face the prospect of being inventoried and prioritized for retrofit work that may impose retrofit costs if local programs move from planning to regulation or funding mechanisms rely on property owner contributions.
  • Local fire districts and emergency services: will need to coordinate on retrofit and infrastructure priorities and may face increased operational expectations tied to plan implementation without guaranteed new funding.
  • Developers and infrastructure operators: may encounter more stringent design expectations or mitigation obligations where proposed development intersects mapped connectivity areas, safety corridors, or retrofitting priorities.

Key Issues

The Core Tension

SB 815 forces a trade‑off between two legitimate priorities: reducing wildfire and climate risk through costly, data‑intensive retrofits and protective planning, versus preserving local capacity and housing supply by avoiding new unfunded mandates on jurisdictions and property owners — the bill demands concrete resilience plans but leaves financing and some legal thresholds unresolved.

The bill converts broad planning concepts into defined tasks, but it leaves several practical implementation questions open. It requires inventories and prioritized retrofit lists, yet it does not fund them; localities with thin budgets may struggle to perform the technical mapping, housing inventories, and milestone tracking the statute expects.

The option to incorporate existing plans by reference reduces duplication, but only if those plans "substantially comply," a standard that will require interpretation and could lead to uneven enforcement across jurisdictions.

There are competing policy tensions embedded in the language. The connectivity mandates can restrict where development is feasible—potentially clashing with state housing goals—and the retrofit focus may place retrofit cost burdens on homeowners in high‑risk zones without specifying assistance or regulatory mechanisms.

The Safe System and 25‑year timelines push jurisdictions toward long‑range execution but assume steady funding and political will; the law creates accountability tools (reports, consultation, submittals) but not the revenue streams to realize the plans.

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