FIELD NOTE · SUPPLEMENTAL SET
Cedar gone grey: what a Bungalow Heaven reroof is allowed to be
ISSUEDJULY 11, 2026DRAWN BY THE NIGHTLY SWEEP
The roofs coming off Pasadena's Craftsman bungalows are split cedar and redwood shake, grey and split along the grain, and the document deciding what goes back on is thirteen months old. The Bungalow Heaven Landmark District Conservation Plan was adopted on June 16, 2025, and its first page states that it replaces in its entirety the plan adopted October 5, 1993. Thirty-one years between them. Nothing in the new plan attaches a review to a reroof. Everything attaches to the material and to the pattern it is laid in, which is the part of the specification a roofer in this district is least free to choose.
Health and Safety Code 13132.7(j), reproduced verbatim inside CBC 1505.6, bars any wood roof covering material from sale or application in this state except on two conditions. The State Fire Marshal must have listed it, and it must have "passed at least five years of the 10-year natural weathering test," run against standard 15-2 of the 1994 Uniform Building Code at a testing facility the State Fire Marshal recognizes. What excludes untreated wood is a clock, not a rating.
The Building Code keeps a narrow door open anyway, because a note to Table 1505.1 permits No. 1 cedar or redwood shakes and shingles on buildings not more than two stories above grade plane, with not more than 6,000 square feet of projected roof area. The same note sets a minimum 10-foot fire-separation distance from the leading edge of the roof to a lot line on all sides except street fronts and public ways, and Section 1505.7 puts 5/8-inch Type X gypsum under the sheathing. Ten feet to the line on all sides is a lot condition, not a roofing condition.
CBC 1.1.7.3.1 provides that a detached one- or two-family dwelling may be designed under that code or the California Residential Code but not both, which leaves the Residential Code as the ordinary path for a detached Craftsman bungalow. Chapter 9 of the 2025 Residential Code carries no counterpart to the Table 1505.1 note and none to Section 1505.7, so on that path there is no cedar, no redwood, no 6,000 square feet and no Type X. That door is in the Building Code only.
CBC 1505.1.2 runs to three limbs and the trade quotes one of them, which is where the rolling-year reading comes from. The entire roof covering of every existing structure where more than 50 percent of the total roof area is replaced within any one-year period must be a fire-retardant roof covering of at least Class C fire classification. The section then reaches every new structure and "any roof covering applied in the alteration, repair or replacement of the roof of every existing structure," a third limb carried word for word in 2025 CRC R902.1.2 and in Health and Safety Code 13132.7(b). A 40 percent section replacement does not escape the class floor.
Class C is the statewide minimum and it is not the Pasadena minimum, because PMC 14.04.110 amends CBC 1505.1 to require that all roof assemblies and roof coverings be of not less than Class B. PMC 14.04.315 adds Section R902.1.1.1 to the Residential Code, putting roof covering materials in other zones at Class A or B, and its operative text is unchanged from Ordinance 7355 of 2019. A Bungalow Heaven roof cannot lawfully be Class C on either code path.
The ordinance on the November 3, 2025 council agenda repealed and replaced Chapter 14.04 in its entirety and applies to building permit applications from January 1, 2026, and the two zone lists inside 14.04.315 are not the same length. All roofing material in the very-high and moderate fire hazard severity zones must be Class A, while no wood roof covering material may be installed on any structure in the very high, high and moderate zones as identified by the Pasadena Fire Department. Three zones for the wood ban, two for Class A.
One exception survives, and it sits in the moderate zone, where the fire code official may, upon a showing of good cause and necessity, approve the use of fire-resistive wood as part of Class A listed assemblies for the repair or maintenance of an existing structure. That is the only route by which wood returns to a mapped Pasadena roof.
Class A flame spread in a material property table and Class A in Chapter 15 are not the same finding. CBC 1505.2 requires Class A roof assemblies and roof coverings to be listed and identified as Class A by an approved testing agency, tested in accordance with ASTM E108 or UL 790. A specifier who writes Class A into the submittal and stops has not specified anything yet.
Standard 6 of the Secretary of the Interior's Standards for Rehabilitation enters Pasadena's review at PMC 17.62.090.E.4.b as a finding the approval has to rest on, and it requires a replacement feature to match the old "in composition, design, color, texture, and other visual properties, and, where possible, materials." Brief 16 supplies the harder half, that where the original varies subtly in color and texture the substitute should be similarly varied "so that it is not conspicuous by its uniformity." Prefabricated products, it warns, may offer limited, if any, choice of unit size. The coursing follows the product.
What the plan carries instead is Section VI.A.2, the items requiring city staff review where visible from the public right-of-way, and item d reads "Changes to roofing, including materials and changes to installation pattern of roofing shingles or tiles." Material or pattern. A roofer who matches the cedar and changes the exposure stands before staff on the same footing as one who swaps cedar for composite. The note under that list adds that certificates for this category of work are issued upon approval by staff and that staff may at its discretion refer applications to the Historic Preservation Commission, so the staff route is a default rather than a guarantee.
5 years OF THE 10-YEAR NATURAL WEATHERING TEST A WOOD ROOF COVERING MUST PASS BEFORE CALIFORNIA ALLOWS ITS SALE, HSC 13132.7(J) 50 percent OF ROOF AREA REPLACED IN A YEAR PULLS THE ENTIRE COVERING UP TO THE CLASS FLOOR, CBC 1505.1.2 10 feet MINIMUM FIRE-SEPARATION DISTANCE UNDER THE UNTREATED CEDAR AND REDWOOD NOTE, CBC TABLE 1505.1
The plan puts the material and the installation pattern on the review list, which makes the specification itself the thing under review. That is why reroof filings out of Pasadena's landmark districts are where a roofing contractor shapes a specification rather than pricing one somebody else wrote.
Wood shake, nonclassified as it arrives
Section 1505.5 of the 2025 California Building Code defines nonclassified roofing as approved material not listed as Class A, B or C, and the trade shorthand that puts a fire rating between cedar and a Pasadena roof has the mechanism backwards. Section 1505.6 defines fire-retardant-treated wood shakes and shingles as wood "impregnated by the full-cell vacuum-pressure process with fire-retardant chemicals, and which have been qualified by UBC Standard 15-2 or ASTM E108 or UL 790 for use on Class A, B or C roofs." Treated shake reaches Class A.Health and Safety Code 13132.7(j), reproduced verbatim inside CBC 1505.6, bars any wood roof covering material from sale or application in this state except on two conditions. The State Fire Marshal must have listed it, and it must have "passed at least five years of the 10-year natural weathering test," run against standard 15-2 of the 1994 Uniform Building Code at a testing facility the State Fire Marshal recognizes. What excludes untreated wood is a clock, not a rating.
The Building Code keeps a narrow door open anyway, because a note to Table 1505.1 permits No. 1 cedar or redwood shakes and shingles on buildings not more than two stories above grade plane, with not more than 6,000 square feet of projected roof area. The same note sets a minimum 10-foot fire-separation distance from the leading edge of the roof to a lot line on all sides except street fronts and public ways, and Section 1505.7 puts 5/8-inch Type X gypsum under the sheathing. Ten feet to the line on all sides is a lot condition, not a roofing condition.
CBC 1.1.7.3.1 provides that a detached one- or two-family dwelling may be designed under that code or the California Residential Code but not both, which leaves the Residential Code as the ordinary path for a detached Craftsman bungalow. Chapter 9 of the 2025 Residential Code carries no counterpart to the Table 1505.1 note and none to Section 1505.7, so on that path there is no cedar, no redwood, no 6,000 square feet and no Type X. That door is in the Building Code only.
CBC 1505.1.2 runs to three limbs and the trade quotes one of them, which is where the rolling-year reading comes from. The entire roof covering of every existing structure where more than 50 percent of the total roof area is replaced within any one-year period must be a fire-retardant roof covering of at least Class C fire classification. The section then reaches every new structure and "any roof covering applied in the alteration, repair or replacement of the roof of every existing structure," a third limb carried word for word in 2025 CRC R902.1.2 and in Health and Safety Code 13132.7(b). A 40 percent section replacement does not escape the class floor.
Class C is the statewide minimum and it is not the Pasadena minimum, because PMC 14.04.110 amends CBC 1505.1 to require that all roof assemblies and roof coverings be of not less than Class B. PMC 14.04.315 adds Section R902.1.1.1 to the Residential Code, putting roof covering materials in other zones at Class A or B, and its operative text is unchanged from Ordinance 7355 of 2019. A Bungalow Heaven roof cannot lawfully be Class C on either code path.
The ordinance on the November 3, 2025 council agenda repealed and replaced Chapter 14.04 in its entirety and applies to building permit applications from January 1, 2026, and the two zone lists inside 14.04.315 are not the same length. All roofing material in the very-high and moderate fire hazard severity zones must be Class A, while no wood roof covering material may be installed on any structure in the very high, high and moderate zones as identified by the Pasadena Fire Department. Three zones for the wood ban, two for Class A.
One exception survives, and it sits in the moderate zone, where the fire code official may, upon a showing of good cause and necessity, approve the use of fire-resistive wood as part of Class A listed assemblies for the repair or maintenance of an existing structure. That is the only route by which wood returns to a mapped Pasadena roof.
Old growth, out of the supply
National Park Service Preservation Brief 16, revised in 2023, finds that commercial supplies no longer provide the denser, decay-resistant wood of old-growth forests, so careful matching to species will not yield a replacement equal in performance to the historic material, and old-growth stock is likely to be very expensive if it can be found at all. The original roof is not waiting on the other side of the statute. Brief 16 lists code-required performance among the circumstances where substitution is appropriate, which is the preservation literature conceding the swap and then setting its own conditions.Composite shake, uniform out of the crate
For a wood shingle roof the brief names the substitutes as fiber cement, mineral/polymer composite, wood fiber/polymer composite, pre-cast concrete and metal, and it separates the two composites on how they behave rather than on how they look. Mineral/polymer composite shingles carry Class 4 impact resistance and, in the brief's words, "flame spread ratings ranging from Class A to Class C depending on the specific product," with integral color that may be subject to fading and more thermally-driven movement than slate or wood. Cellulose fiber/polymer composite runs the other way, with minimal thermal movement, Class 4 impact resistance and Class A flame spread, and a 50-year limited warranty is typical of both.Class A flame spread in a material property table and Class A in Chapter 15 are not the same finding. CBC 1505.2 requires Class A roof assemblies and roof coverings to be listed and identified as Class A by an approved testing agency, tested in accordance with ASTM E108 or UL 790. A specifier who writes Class A into the submittal and stops has not specified anything yet.
Standard 6 of the Secretary of the Interior's Standards for Rehabilitation enters Pasadena's review at PMC 17.62.090.E.4.b as a finding the approval has to rest on, and it requires a replacement feature to match the old "in composition, design, color, texture, and other visual properties, and, where possible, materials." Brief 16 supplies the harder half, that where the original varies subtly in color and texture the substitute should be similarly varied "so that it is not conspicuous by its uniformity." Prefabricated products, it warns, may offer limited, if any, choice of unit size. The coursing follows the product.
A changed material, and the review that follows
PMC 17.62.090.A names this district directly, providing that projects within the Bungalow Heaven, Garfield Heights and Banbury Oaks Landmark Districts are processed in accordance with the review thresholds in the respective Conservation Plan. The chapter's own exemption list at 17.62.090.B.6 carries the sentence "reroofing (except for a change of material)," and a contractor who reads that and stops has read the wrong document. Subsection 17.62.090.B.7 provides that where an adopted conservation plan conflicts with the chapter's procedures the plan prevails, subject only to the Appeal and Call for Review procedures of Chapter 17.72. Bungalow Heaven has an adopted plan, and it carries no reroofing exemption.What the plan carries instead is Section VI.A.2, the items requiring city staff review where visible from the public right-of-way, and item d reads "Changes to roofing, including materials and changes to installation pattern of roofing shingles or tiles." Material or pattern. A roofer who matches the cedar and changes the exposure stands before staff on the same footing as one who swaps cedar for composite. The note under that list adds that certificates for this category of work are issued upon approval by staff and that staff may at its discretion refer applications to the Historic Preservation Commission, so the staff route is a default rather than a guarantee.
5 years OF THE 10-YEAR NATURAL WEATHERING TEST A WOOD ROOF COVERING MUST PASS BEFORE CALIFORNIA ALLOWS ITS SALE, HSC 13132.7(J) 50 percent OF ROOF AREA REPLACED IN A YEAR PULLS THE ENTIRE COVERING UP TO THE CLASS FLOOR, CBC 1505.1.2 10 feet MINIMUM FIRE-SEPARATION DISTANCE UNDER THE UNTREATED CEDAR AND REDWOOD NOTE, CBC TABLE 1505.1
The plan puts the material and the installation pattern on the review list, which makes the specification itself the thing under review. That is why reroof filings out of Pasadena's landmark districts are where a roofing contractor shapes a specification rather than pricing one somebody else wrote.