The Palisades and Eaton fires claimed 31 lives and destroyed more than 16,000 structures. They also triggered a cascade of regulatory and policy updates that every California city, county, utility, and special district needs to understand now.
If your jurisdiction's emergency plans haven't been reviewed since before January 2025, you are likely already out of compliance with new federal and state requirements—and at risk of losing access to critical grant funding when the next disaster strikes.
The Regulatory Landscape Shifted in 2025
Within weeks of the fires, federal and state regulators began updating the standards governing local emergency preparedness. Three major policy changes took effect in 2025 that directly affect California local governments:
The Federal Emergency Management Agency released Version 2.1 of its Hazard Mitigation Assistance (HMA) Program and Policy Guide, effective January 20, 2025—the same week the LA fires reached their peak. This updated guide governs eligibility for four critical funding programs: the Hazard Mitigation Grant Program (HMGP), HMGP Post Fire, the Building Resilient Infrastructure and Communities (BRIC) program, and Flood Mitigation Assistance (FMA). Any major disaster declaration issued on or after January 20, 2025 is governed by the new Version 2.1 standards.
On April 11, 2025, FEMA's updated Local Mitigation Planning Policy Guide took effect. This is the foundational document that defines what must be included in a Local Hazard Mitigation Plan (LHMP) for FEMA approval. The updated guide reflects lessons from recent catastrophic wildfire events and includes heightened expectations around wildfire-specific risk assessments, integration with community wildfire protection plans, and equity considerations in mitigation strategies.
Cal OES has published a comparison document detailing the changes from the 2022 guidance to the 2025 standards. If your LHMP was approved under the 2022 framework and is due for a 5-year update, it must now meet the 2025 requirements.
FEMA released an updated Local Mitigation Planning Handbook in June 2025—the first comprehensive revision of the handbook since 2013. The handbook provides the step-by-step process for developing and updating LHMPs. It emphasizes early stakeholder engagement, deeper integration with existing community planning documents (General Plans, Capital Improvement Plans), and ongoing plan implementation—not just plan adoption.
What This Means If You Don't Act
The stakes are not abstract. Under 44 CFR Part 201 and the Disaster Mitigation Act of 2000, local governments must have a current, FEMA-approved hazard mitigation plan to access non-emergency federal disaster assistance. This includes HMGP funds, Public Assistance for permanent work, and FMAG-related grants.
A plan that was approved in 2020 or 2021 expires five years after adoption. If your plan lapses before you renew it, your jurisdiction loses grant eligibility—even retroactively for an open application. The LA fires opened a substantial HMGP funding window through FEMA Disaster Declaration 4856. Jurisdictions in Los Angeles County and neighboring areas that lack a current, approved LHMP cannot access those dollars.
Additionally, California Assembly Bill 2140 (2006) allows counties and cities that have adopted a FEMA-approved LHMP into the Safety Element of their General Plan to qualify for additional state cost-sharing on eligible Public Assistance projects. Many California jurisdictions have not taken this step—and are leaving state dollars on the table.
Who Is Affected
These requirements apply broadly:
- Cities and towns in all 58 California counties, particularly those in Southern California, the Bay Area, and other high wildfire-risk zones
- Counties that serve as Operational Area leads under California's Standardized Emergency Management System (SEMS)
- Special districts, including water agencies, utility districts, school districts, and fire districts that participate in multi-jurisdictional LHMPs
- Utilities serving high-risk wildfire areas that must demonstrate emergency preparedness under both regulatory and grant eligibility frameworks
If your jurisdiction participates in a multi-jurisdictional LHMP (common in smaller cities), you still need to verify that your annex meets the 2025 requirements individually. Cal OES's Annex Review Tool (ART) specifies elements each jurisdiction must address on its own—regardless of the lead agency's overall plan status.
Four Steps to Get Into Compliance Before Your Next Audit Cycle
- Confirm Your Plan's Current Status and Expiration Date Pull your current LHMP and check the FEMA approval date. Plans are valid for five years. If you're within 18 months of expiration—or already past it—the update process needs to start now. Cal OES and FEMA both require lead time for review before a plan lapses. Submit updates to Cal OES at least 90 days before your planned adoption date.
- Conduct a Gap Analysis Against the 2025 Standards Compare your existing plan against the April 2025 FEMA Local Mitigation Planning Policy Guide using Cal OES's Plan Review Tool (PRT). Key areas that frequently fail the 2025 review include: wildfire-specific risk assessments, documentation of underserved and access-and-functional-needs populations, and evidence that mitigation actions have been implemented (not just listed).
- Review and Update Your Emergency Operations Plan (EOP) The Los Angeles County After-Action Review released in September 2025, conducted by the McChrystal Group, identified critical failures in evacuation warning systems, interoperable communications, and command structure clarity during the January fires. Under California AB 580, counties are required to submit their EOPs to Cal OES upon any update. Even if you are a city, the AAR's findings offer a direct blueprint for where California EOPs commonly fail.
- Align Your Plan With the FEMA Funding Window With FEMA Disaster Declaration 4856 still open, there is an active HMGP Post Fire funding opportunity for jurisdictions in affected areas. Eligible mitigation projects include defensible space programs, home hardening, early warning systems, and evacuation route improvements. A current, FEMA-approved LHMP is a prerequisite to apply. The window will not stay open indefinitely.
The Bottom Line
The January 2025 LA fires changed the conversation in Sacramento and in Washington. FEMA updated its mitigation planning standards. Cal OES is actively reviewing county plans. Grants are available—but only to jurisdictions that have done the planning work.
Local government emergency managers who wait for the next disaster to audit their plans will find themselves scrambling to update compliance documentation while simultaneously managing an active response. That is not a position any agency should be in.
The time to act is now, while the regulatory updates are recent and the funding windows are open.