Tree Removal Streamlining Guidelines for High and Very High Fire Hazard Severity Zones

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June 10, 2026

Martina Davis,
Planning Division Manager
San Jose

Re: Tree removal streamlining guidelines for High and Very High Fire Hazard Severity Zones

As the City of San José considers streamlining tree removal permits in High and Very High Fire Hazard Severity Zones, we recommend retaining discretionary review for removals involving trees or sites that provide significant ecological, riparian, slope stabilization, habitat, or canopy benefits.

Large, healthy trees are often among the most fire-resilient components of the landscape and can help reduce wildfire intensity by providing shade, retaining soil moisture, and slowing wind speeds. Because these trees provide important ecological and community benefits, we recommend that the streamlined process exclude the following:

  • Large native oaks and other native heritage trees, including Coast Live Oak, Valley Oak, Blue Oak, and Black Oak above a specified size threshold (for example, 24 inches DBH or greater),

  • Riparian trees located within creek corridors, wetlands, riparian habitat, or required stream setbacks,

  • Trees located on steep slopes (for example, slopes exceeding 20-25 percent) where root systems help stabilize soils and reduce erosion,

  • Projects proposing removal of multiple trees, such as projects proposing removal of more than three protected trees, and

  • Projects resulting in substantial canopy loss, such as removal of more than 25 percent of existing tree canopy on a parcel.

In addition, streamlined approvals should be limited to removals that are certified by a qualified arborist or registered professional forester as necessary to comply with state law.

These safeguards would help ensure that any streamlined process is used for legitimate wildfire-risk reduction purposes and not for unrelated tree removals. They would also maintain protection for the City's most environmentally valuable trees, riparian resources, wildlife habitat, urban canopy, and erosion-prone areas while allowing appropriate wildfire-risk reduction measures to proceed efficiently.
 

Thank you for your consideration,

Shani Kleinhaus, Environmental Advocate
Santa Clara Valley Bird Alliance

Katja Irvin
Guadalupe Group Conservation Chair
Sierra Club Loma Prieta Chapter

Alice Kaufman, Policy and Advocacy Director
Green Foothills