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General (07)You don't often get email from Learn why this is important From: Be ve rl y Paras < Se nt: Thursday, January 1, 2026 6:23 PM To: City Cl e rk <ci tycl e rk@anaheim.net> Cc: The re sa Bass <TBass@anahe i m.ne t> Subje ct: [EXTERN AL] Re que st f or Re view and Comment Submi ssi on Warning: This email originated from outside the City of Anaheim. Do not click links or open attachments unless you recogniz e the sender and are expecting the message. Dear Anaheim City Co uncil Memb ers and City Clerk, My name is Beverly P aras , and I am an Orange Co unty resident invo lved in a c ommunity effo rt to imp ro ve how c ities are ab le to address p ublic safety concerns involving urb an coyo tes. We have sub mitted a p etitio n to the Califo rnia Fish and Game Commission to mo d ernize s tate wild life language to formally rec o gnize urb an coyo tes. The Co mmis s io n has acc ep ted the petitio n and p lac ed it o n their agenda. I will b e speaking before the Co mmis s io n o n February 12, and Orange Co unty residents are c urrently s ubmitting p ublic c o mments in sup p o rt o f these changes . Even a brief s tatement from California c ities s uc h as “We s upport P etitio n 2025-16” would help tremendous ly. At the same time, we have as ked the Co unty of Orange to spons o r and adop t a Title 10 s tyle animal ordinanc e. T his type o f ordinanc e wo uld give c ities clearer authority and p ractical tools while remaining c os t neutral and c o ns is tent with exis ting law. A sho rt email to the County expressing s upport for adopting a T itle 10 type o rd inanc e would als o b e very helpful. I have attac hed a c o mp lete copy of the Title 10 p ro p o s al and the Title 14 petitio n. The pho tos inc luded in b o th proposals are intentionally the same, as they s erve the same p urpose of illus trating urban c o yote behavior and p ublic safety concerns . To make review eas ier, I am als o includ ing a p lain language s ummary for T itle 10 s o there is no need to read the full ordinanc e or the 86 p ages o f sup p o rting material, along with the c os t s heet. F o r Title 14, I have attac hed the S tate’s o fficial acc ep tance letter c o nfirming the petition has been ac c ep ted and p lac ed o n the Co mmis s io n’s agenda. If the City of Anaheim finds value in this work, your sup p o rt would strengthen c o o rd inatio n at the c ity, c ounty, and state level and ultimately help us help loc al go vernments . Thank yo u fo r yo ur time and fo r yo ur s ervic e to the community. Res p ectfully, Beverly Paras Orange County Resident State of California – Fish and Game Commission PETITION TO THE CALIFORNIA FISH AND GAME COMMISSION FOR REGULATION CHANGE FGC 1 (Rev 06/19) Page 1 of 2 Tracking Number: (__________) To request a change to regulations under the authority of the California Fish and Game Commission (Commission), you are required to submit this completed form to: California Fish and Game Commission, (physical address) 1416 Ninth Street, Suite 1320, Sacramento, CA 95814, (mailing address) P.O. Box 944209, Sacramento, CA 94244-2090 or via email to FGC@fgc.ca.gov. Note: This form is not intended for listing petitions for threatened or endangered species (see Section 670.1 of Title 14). Incomplete forms will not be accepted. A petition is incomplete if it is not submitted on this form or fails to contain necessary information in each of the required categories listed on this form (Section I). A petition will be rejected if it does not pertain to issues under the Commission’s authority . A petition may be denied if any petition requesting a functionally equivalent regulation change was considered within the previous 12 months and no information or data is being submitted beyond what was previously submitted. If you need help with this form, please contact Commission staff at (916) 653- 4899 or FGC@fgc.ca.gov. SECTION I: Required Information. Please be succinct. Responses for Section I should not exceed five pages 1. Person or organization requesting the change (Required) Name of primary contact person: Beverly Paras Address: 13452 Sorrell Dr, Garden Grove CA 92843 Telephone number: 714-458-7049 Email address: parasinspection@yahoo.com 2. 3. Overview (Required): Request amendment to Title 14 §472 to modernize coyote rules, limit unsafe methods, address feeding, and support prevention. 4. Rationale (Required): Current rules cause confusion and safety issues in cities. Updating §472 improves safety, reduces conflicts, and aligns with science. SECTION II: Optional Information 5. Date of petition: November 17, 2025 6. Category of Proposed Change ☐ Sport Fishing ☐ Commercial Fishing ☒ Hunting ☒ Other, please specify: Nongame Mammals / Urban Coyote Management Fish and Game Code Sections 200, 202, and 203 grant the Commission authority to regulate the taking of nongame mammals and to amend Title 14 Section 472. State of California – Fish and Game Commission PETITION TO THE CALIFORNIA FISH AND GAME COMMISSION FOR REGULATION CHANGE FGC 1 (Rev 06/19) Page 2 of 2 7. The proposal is to: Amend Title 14, Section 472 ☒ Amend Title 14 Section(s): 472 ☐ Add New Title 14 Section(s): Click here to enter text. ☐ Repeal Title 14 Section(s): Click here to enter text. 8. If the proposal is related to a previously submitted petition that was rejected, specify the tracking number of the previously submitted petition Click here to enter text. ☒ Not applicable. 9. Effective date: Earliest operative date available. No emergency requested. 10. Supporting documentation: See attached packet. 11. Economic or Fiscal Impacts: No significant fiscal impacts expected. 12. Forms: None. Click here to enter text. SECTION 3: FGC Staff Only Date received: Click here to enter text. FGC staff action: ☐ Accept - complete ☐ Reject - incomplete ☐ Reject - outside scope of FGC authority Tracking Number Date petitioner was notified of receipt of petition and pending action: _______________ Meeting date for FGC consideration: ___________________________ FGC action: ☐ Denied by FGC ☐ Denied - same as petition _____________________ Tracking Number ☐ Granted for consideration of regulation change Cover Letter Dear California Fish and Game Commission, Please accept this petition to modernize Title 14 §472 to address urban coyote conflicts, clarify regulatory language, and support prevention-focused management. The attached materials include the rationale, proposed language, and supporting documentation. Letter Explaining the Reason for Modernizing Title 14 §472 California's urban and suburban regions are experiencing a significant increase in habituated coyote behavior. Current regulatory language in Title 14 §472 was created decades ago for rural and wildland contexts, not today’s densely populated neighborhoods. As a result, residents, municipalities, and enforcement agencies face confusion, inconsistent responses, and an absence of clear guidance for preventing and addressing urban coyote conflicts. Modernization is needed for four primary reasons: 1. Outdated Language The current regulation contains no definitions, no explanation of purpose, and no distinction between rural coyote behavior and repeated conflict behavior occurring in neighborhoods, parks, and residential streets. 2. No Feeding or Attractant Provisions Unregulated intentional and unintentional feeding — including unmanaged feral-cat feeding stations — leads directly to habituation. The current regulation provides no tools to address or prevent this. 3. No Urban-Conflict Framework There is no structure for determining when a coyote’s behavior transitions from normal wildland behavior to urban conflict behavior requiring intervention, such as yard entry, stalking pets, or repeated daylight boldness. 4. Lack of Prevention Requirements Modern wildlife management emphasizes prevention first. Updated language supporting attractant control, community education, and reporting creates consistent statewide standards. Updating Title 14 §472 does not increase lethal control; it improves clarity, transparency, safety, and science-based prevention. Cities, counties, and residents need regulatory language that reflects today’s urban realities. Petition Summary This petition requests amendments to Title 14 §472 to improve clarity, safety, and management tools for urban environments experiencing increased habituated coyote behavior. Proposed Urban Language Overview • Add definitions for urban area, habituation, attractants, feeding, and conflict behavior. • Add clear purpose statement applicable to populated regions. • Add feeding prohibition and attractant rules. • Distinguish between normal wildland behavior and urban conflict behavior. • Provide structured intervention criteria for conflict situations. • Support prevention through community education and attractant mitigation. Photo Documentation Section (Photos Attached Separately) Photos to be added separately illustrate habituated coyote behavior in residential environments. Captions will describe patterns such as reliance on food attractants, alley and yard movement, daylight exposure, reduced flight distance, and interactions with domestic animals and humans. Side-by-Side Reference: Current Language vs. Hypothetical Modernized Urban Language Current Title 14 §472 Hypothetical Modernized Urban Language No stated purpose or urban context.Adds clear purpose for managing and preventing coyote conflicts in populated areas. No definitions provided.Adds key definitions: urban area, conflict behavior, habituation, attractants, feeding, domestic animal protection. No feeding prohibition.Adds explicit feeding prohibition including negligent attractant placement and unmanaged feral-cat feeding sites in active conflict zones. No distinction between rural and urban behavior.Creates two behavioral categories: normal wildland behavior and urban conflict behavior requiring intervention. Depredation allowed without modern structure.Allows intervention only when documented conflict behavior exists, paired with a simple review or verification process. No prevention or mitigation requirements.Adds prevention requirements: attractant removal, securing areas, and basic community education. No domestic-animal protection language.Adds domestic-animal protections and required responses for repeated yard entry, stalking, or pet attacks. No reporting requirements.Adds annual reporting of sightings, conflicts, interventions, and feeding-related hotspots. Broad daylight, a habituated coyote standing calmly in the open even with people nearby, acting like the neighborhood is his. Broad-daylight fence patrol. This is what really happens after a coyote is hazed out of a backyard it doesn’t run, it doesn’t show fear. It simply strolls away, calm and unfazed, then circles back when the person is gone. This is the behavior of a fully habituated coyote. Day-long lingering = this coyote is hubicthated. A coyote so habituated it now sleeps inches from an occupied home— curled beneath a family’s front window as if the yard were its den. This is no wildlife passing through. This is wildlife moving in.” Coyote out in broad daylight, completely at ease.” Coyotes relaxing in broad daylight at Floral Park are a classic example of habituation. This dog is recovering from a severe coyote attack that happened in the owner’s backyard.” Coyotes are habituated, hunting in groups, moving in and out of our yards, and comfortable staying in the front yard after a kill.” He killed a cat, stood his ground, and watched people watching him. Daylight. No fear. This is what happens when coyotes lose their fear of humans. Coyote carrying someone’s pet in broad daylight. This behavior shows habituation because the coyote is comfortable moving openly around people and homes with no fear.” This is all we can show. The rest was too heartbreaking. A cat’s remains were found at Eastgate Park the collar is the only shareable part. California Natural Resources Building 715 P Street, 16th Floor, Sacramento, California 95814 Commissioners Erika Zavaleta, President Santa Cruz Samantha Murray, Vice President La Jolla Jacque Hostler-Carmesin, Member McKinleyville Eric Sklar, Member Saint Helena Darius W. Anderson, Member Kenwood STATE OF CALIFORNIA Gavin Newsom, Governor Fish and Game Commission Melissa A. Miller-Henson Executive Director P.O. Box 944209 Sacramento, CA 94244-2090 (916) 653-4899 fgc@fgc.ca.gov www.fgc.ca.gov Wildlife Heritage and Conservation Since 1870 December 3, 2025 Beverly Paras Sent via email to Re: Petition for regulation change (Tracking Number 2025-16) Dear Ms. Paras: Thank you for submitting your petition for regulation change to the California Fish and Game Commission (Commission). Your petition has been assigned tracking number 2025-16. Commission staff reviewed your petition for completeness per Section 662(b), Title 14, California Code of Regulations, and it has been accepted as complete. Your petition will be received by the Commission at its December 10-11, 2025 meeting. Commission action on your request (to deny or grant for further consideration in a future rulemaking) will be scheduled for the Commission’s February 11-12, 2026 meeting. While it is not necessary, you are welcome to attend either meeting and provide comment. Meeting agendas and other details, including instructions on how to watch or participate in the meeting, are available on the Commission's website at http://www.fgc.ca.gov/meetings/2025. Meeting materials are posted to the website a few days before the meeting. If you have any questions about your petition, please feel free to contact me or Commission staff at (916) 653-4899 or fgc@fgc.ca.gov, and please reference your tracking number. Sincerely, H. David Thesell Deputy Executive Director Orange County Title 10 Sponsorship Packet Prepared for Supervisor Janet Nguyen Prepared by: Beverly Paras On behalf of the Nextdoor Wildlife Safety Coalition of Orange County Attachment A – Sponsorship Request Letter Supervisor Janet Nguyen Orange County Board of Supervisors First District Dear Supervisor Nguyen My name is Beverly Paras and I am an Orange County resident living in Garden Grove. I am submitting this packet on behalf of the Nextdoor Wildlife Safety Coalition of Orange County. I am respectfully asking you to sponsor an agenda item for the Board of Supervisors to consider adopting a countywide Title 10 style ordinance that gives cities real enforcement tools to address wildlife attractants chronic feeding and coyote habituation that crosses city boundaries every day. Right now cities in Orange County do not have a consistent countywide standard for preventive authority. State regulation under California Code of Regulations Title 14 Section 472 allows a landowner or licensed person to take a coyote at any time and in any number once a conflict already exists. This is reactive and does not provide cities with practical proactive tools for early prevention such as enforcing chronic feeding rules or reducing attractants across shared wildlife corridors. A Title 10 style ordinance would finally allow consistent early intervention before wildlife becomes fully habituated or repeatedly returns to neighborhoods where conflicts are already taking place. Attachment B in this packet includes a conceptual countywide map showing the major wildlife corridors linking Garden Grove Westminster Huntington Beach Fountain Valley and every city connected through central west south and east county zones. These corridors demonstrate why a city by city approach cannot succeed. Wildlife moves freely across every boundary while each city operates under different rules and without shared standards. A countywide Title 10 ordinance would fix this by providing one uniform framework for all cities. Attachment C introduces verified photo evidence of repeated visits daytime presence and bold behavior from coyotes that have already become resident animals in neighborhoods. These images show what happens when there is no countywide prevention standard. A consistent Title 10 framework is a more humane and effective system because it reduces the conditions that cause wildlife to become dependent on human areas in the first place. This packet is not a complaint. It is a solution. I am asking you to take the next step by sponsoring the discussion so Orange County can reduce conflicts protect residents and pets and apply one countywide standard that supports early effective wildlife management. Thank you for your time and consideration. Sincerely Attachment B – Countywide Wildlife Corridor Map North Central Corridor Garden Grove Westminster Huntington Beach Fountain Valley Straight north to south movement through neighborhoods parks and drainage channels. West OC Urban Coastal Seal Beach Los Alamitos Cypress La Palma Movement along river corridors and coastal routes. Central OC Park Channel Santa Ana Orange Tustin Irvine Travel through connected park systems major channels and green spaces. South OC Foothill Lake Forest Mission Viejo Rancho Santa Margarita Laguna Niguel San Juan Capistrano San Clemente Wildlife entering neighborhoods from foothills and open space. East OC Canyons Silverado Modjeska Trabuco Canyon Wildlife originating in the canyons and moving toward residential corridors. These overlapping zones show why a city by city approach fails. Wildlife travels freely across boundaries while enforcement authority does not. A countywide Title 10 ordinance creates one unified standard for prevention and intervention. Attachment C – Key Los Angeles County Title 10 Language Clean Summary 1. Countywide Authority and Enforcement Title 10 applies countywide including unincorporated areas and cities that contract into county enforcement. 2. Definition of Wild Animals Wild animals include nondomestic mammals hybrids wild birds reptiles and similar species. 3. Corrective Action Authority Officers may issue warnings citations corrective orders and address unsafe conditions. 4. Feeding and Attractant Prohibitions LA County prohibits feeding wild animals and prohibits conditions that create attractants including unsecured food trash and shelter structures. 5. Public Nuisance Classification Wildlife attractants are treated as public nuisances subject to citations and required correction. 6. Graduated Penalties Enforcement includes verbal warnings written warnings and administrative citations and only severe or repeat cases escalate. 7. City Collaboration Structure Contract cities adopt County Title 10 for unified enforcement across multiple jurisdictions. Attachment D – Prevention and Photo Evidence The following pages contain the photographic evidence referenced for prevention and habituation concerns described in this packet. These photos document repeated visits daytime presence bold behavior and the clear progression of habituation in multiple Orange County neighborhoods. Broad daylight, a habituated coyote standing calmly in the open even with people nearby, acting like the neighborhood is his. Broad-daylight fence patrol. Coyote out in broad daylight, completely at ease.” This is what really happens after a coyote is hazed out of a backyard it doesn’t run, it doesn’t show fear. It simply strolls away, calm and unfazed, then circles back when the person is gone. This is the behavior of a fully habituated coyote. A coyote so habituated it now sleeps inches from an occupied home— curled beneath a family’s front window as if the yard were its den. This is no wildlife passing through. This is wildlife moving in.” Day-long lingering = this coyote is hubicthated. This dog is recovering from a severe coyote attack that happened in the owner’s backyard.” Coyotes are habituated, hunting in groups, moving in and out of our yards, and comfortable staying in the front yard after a kill.” He killed a cat, stood his ground, and watched people watching him. Daylight. No fear. This is what happens when coyotes lose their fear of humans. This is all we can show. The rest was too heartbreaking. A cat’s remains were found at Eastgate Park the collar is the only shareable TITLE 10 – COYOTE-SPECIFIC AUTHORITIES (Complete Synopsis) This document summarizes all Title 10 provisions that directly apply to coyotes, based on the modern Los Angeles County Title 10 framework, which is widely regarded as the strongest municipal animal-control and wildlife-safety code in California. 1. Coyote Classification Under Title 10 Coyotes are classified as “wild animals,” giving municipalities clear authority to regulate, control, remove, or take coyotes under multiple public-safety sections. 2. Nuisance Animal Criteria Coyotes meet the Title 10 definition of “nuisance animals” when they: • Enter yards • Harass or stalk pets • Approach people • Ignore hazing • Appear in daylight frequently • Display habituation • Cause repeated neighborhood complaints Under this section, cities may initiate hazing, targeted response, trapping, or removal before an attack occurs. 3. Potentially Dangerous Coyote A coyote becomes “potentially dangerous” when it: • Stalks, menaces, or chases a person or pet • Breaks into an enclosure • Circles or follows people • Exhibits fearless daylight behavior • Shows repeated stalking patterns • Harasses children or elderly individuals Title 10 authorizes: • Capture • Removal • Euthanasia (after determination) • Increased patrols • Public safety alerts 4. Dangerous Coyote – Mandatory Removal A coyote is “dangerous” if it: • Attacks or bites a human • Kills or injures a pet • Attempts to enter a home • Charges or corners a person • Returns repeatedly after aggression Under this section, the city must remove the animal. Options include: • Immediate lethal force • Capture and euthanasia • Contracted wildlife removal teams • Police or animal control intervention 5. Immediate Threat Provision Title 10 authorizes immediate lethal force without permits or hearings if a coyote is: • Actively attacking or about to attack • Holding or killing a pet • Charging a person • Behaving aggressively on school grounds • Cornering or threatening an individual 6. Authority to Take Coyotes “Take” includes capture, kill, trap, remove, pursue, or euthanize. Cities may take coyotes when: • They pose any threat • Display habituation • Cause repeated complaints • Are linked to prior attacks • Meet nuisance, potentially dangerous, or dangerous definitions 7. Nuisance Wildlife Teams Title 10 authorizes deployment of: • Animal control officers • Police officers • Contract wildlife trappers • USDA Wildlife Services These teams may perform trapping, targeted removal, hazing, and surveillance. 8. Coyote Trapping Authority Title 10 prohibits: • Steel-jaw traps • Poison • Glue traps • Leg-holds But authorizes humane cage traps for: • Dangerous wildlife • Nuisance wildlife • Depredating coyotes Captured coyotes may be euthanized for public safety. 9. Required City Response to Coyote Incidents Cities must respond to: • Bites and attacks • Pets killed or injured • Daylight aggression • Repeated sightings in a small area • Coyotes carrying pets • Stalking behavior around children • Home-entry attempts 10. Sensitive Area Protections Coyotes in: • Schools • Parks • Daycares • Playgrounds • Senior centers may be removed or lethally dispatched immediately if they pose risk. 11. Public Safety Supremacy Title 10 states human safety overrides wildlife considerations. Municipal authority applies even when state agencies are slow or unavailable. 12. Reporting and Tracking Title 10 requires: • Incident tracking • Complaint systems • Escalation protocols • Public notifications 13. Coordination with Agencies Cities may coordinate with: • CDFW • USDA Wildlife Services • Police/Sheriff • County animal control 14. Summary Title 10 provides: • Clear removal authority • Lethal force authority • Preventative intervention • Trapping powers • Escalation structure • Protection for schools and neighborhoods This framework is essential for meaningful coyote management and is the model currently used by Los Angeles County and other proactive jurisdictions. Title 10 Financial Benefits Proven Cost Savings • No New Tax Burden • Nearly 20 Years of Success For almost 20 years, Los Angeles has operated under a Title 10 wildlife-safety framework with no extra taxpayer burden and a clear record of reducing city costs. Title 10 is a preventative, education-based model that addresses human-caused habituation, the root source of most urban coyote conflicts. 1. Lower Emergency Response Costs Cities save money because Title 10 reduces: • repeated animal control dispatch • police and fire responses to wildlife calls • neighborhood panic calls caused by feeding hot spots Prevention means fewer expensive call-outs. 2. Eliminates Most Reactive “Removal” Costs Without prevention laws, cities rely on costly options such as trapping or private wildlife contractors. Title 10 reduces the need for these reactive measures, saving thousands annually. 3. Reduces Liability and Risk Exposure Title 10 gives cities a clear, consistent standard for wildlife safety. This reduces legal exposure, insurance risk, and municipal liability, which are major budget concerns for every city. 4. No New Staff, No New Programs, No New Taxes Title 10 requires: • no new departments • no new employees • no new funding Existing city staff work more efficiently because they finally have a clear ordinance that addresses attractants and feeding. 5. Community-Driven Education Reduces Costs Further Public education grows organically through community groups, online networks, neighborhood coalitions, and volunteer-driven outreach — not city budgets. Summary Title 10 is a low-cost, high-impact, proven model that lowers city expenses while improving safety for residents, pets, and wildlife. Orange County cities can adopt this approach with zero new tax burden, just as Los Angeles has successfully done for nearly two decades.