"Appendix 1, Fire MSR/SOI Update, Comment Memorandum"

Date: September 5, 2025 To: Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION From: RSG, Inc. Planwest Partners, Inc. SUBJECT: PUBLIC REVIEW DRAFT MSR COMMENT MEMORANDUM RSG, Inc. (“RSG”) and Planwest Partners Inc (“Planwest”) were retained by the Sutter Local Agency Formation Commission (“LAFCO”) to prepare a Countywide Fire and Emergency Medical Services Municipal Services Review (“MSR”) and Sphere of Influence (“SOI”) Update. LAFCO staff posted the Public Review Draft MSR and SOI Update to LAFCO’s website in June 2025 as required by Cortese-Knotz-Hertzberg Local Government Reorganization Act of 2000 (“CKH”) Section 56427. This memorandum summarizes the comments received from affected service providers, other agencies, and the public during the 21-day public review period and RSG will revise the Public Review Draft MSR as outlined below. The purpose of this memorandum is to memorialize each comment received as well as establish concurrence with LAFCO staff on response to the comments. LAFCO COMMISSION MEMBER: MARC BOOMGAARDEN (Received via email on June 24, 2025 and June 26, 2025) Commissioner Comment: It seems that the report has numerous references to “staff” provided info. Is it a responsibility of the MSR authors to validate this information as provided or just report it as provided by each respective agency?  Response or Comment: The MSR relies on information provided directly by agency staff through surveys, interviews, and supporting documentation. While RSG makes every effort to review materials for accuracy, consistency, and completeness, the MSR is intended to reflect the data and input as provided by each agency. The goal is to present this information in a clear and objective manner that enables LAFCO to make informed statutory determinations, while acknowledging any limitations in available data where applicable. Commissioner Comment: A fundamental benchmark of any fire department that is providing fire and life safety services is its response times. Based upon the information provided, plus my own observations /assumptions there are some response times being reported that could be questionable. Was there a common understanding amongst all agencies regarding what response times consist of? Response time includes the time component of Call Taking (measured as the time the 911 call is received at the Dispatch Center until the fire department is notified) – Turnout Time (measured as the time from when the Fire Department receives the call from the Dispatch Center to the time the responding unit begins its travel to the emergency) and Travel Time ( measured as the time from when the responding unit begins its travel to the emergency to the time it arrives at the emergency). This should be a standard under which the MSR is reporting so that response times are accurately being monitored and reported.  Response or Comment: These standards were communicated to all agencies to ensure a uniform understanding of the response time framework. However, response time data for fire protection service providers was limited across jurisdictions and was only provided by the Yuba City Fire Department and CSA F. Accordingly, the MSR is constrained by the availability and quality of the Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 2 data submitted. Variations or gaps in reported response times may reflect differences in local data tracking and reporting practices. The MSR can be updated to include a footnote for response time data provided to include the following: “The response time data presented in this table was provided directly by the respective fire protection service provider. RSG relies on the accuracy of the information submitted and is unable to independently verify the data.” Commissioner Comment: Why are the references to both Sutter County ‘s and Yuba City’s failed revenue measures? There really isn’t any relevancy to either of these measures on service delivery in the past or going forward since they both failed  Response or Comment: Pursuant to Government Code Section 56430, LAFCO is required to make determinations regarding the financial ability of agencies to provide adequate services. Although both the Sutter County and Yuba City revenue measures ultimately failed, they were intended, in part, to enhance funding for fire protection services. Discussion of the failed ballot measures provides context for the agencies’ fiscal health and highlights ongoing challenges in securing sustainable funding, which is relevant to LAFCO’s statutory determinations related to service adequacy and long-term viability. Additionally, it can help inform future LAFCO Commissions, County and City governments, and agencies themselves by providing a historical timestamp within the MSR of when such funding measures were attempted. Commissioner Comment: There were references to consolidation of County Service Areas but no reference or even mention of consolidation of all fire services within Sutter County (Cities, County, Dependent and Independent Special Districts. This should be at least mentioned.  Response or Comment: The MSR includes references to the potential consolidation of County Service Areas, as well as prospective consolidation efforts between independent special fire districts and the CSAs based on discussions with agency staff and reflect existing coordination efforts that have already occurred within the County Service Areas. However, RSG acknowledges that the future consolidation of all fire protection service providers could also be explored at a later date. The MSR will be updated to include a recommendation to further explore this consolidation effort. Furthermore, this will also include a recommendation for the fire protection service providers to conduct a Standards of Response Coverage (SORC) study to analyze response times, station locations and coverage, staffing, wages and benefits including pensions, and a fiscal review and forecast of past, current, and future needs, including the ability of the combined organization to adequately fund the proposed organization and operation to further inform these future consolidation decisions. Commissioner Comment: There are several tables attributed to ESRI Business Analyst that seem to show that Sutter County Housing Units will decline by over 60,000 between 2010 and 2029. This is confusing to me…  Response or Comment: The Housing Characteristics tables incorrectly referenced the population of Sutter County in 2010, as opposed to the number of housing units. These references will be updated throughout the report. The number of housing units in Sutter County is expected to increase from 33,858 housing units in 2010 to 34,853 housing units in 2029. It is important to note that these figures do not account for the increased housing development anticipated as a result of the planned development of the Bogue Stewart Master Plan or Sutter Pointe Specific Plan. Commissioner Comment: There is no mention of reciprocity between fire departments as they support emergency response within Sutter County. If imbalance occurs (it does I understand) then that places a burden on the fire department that is providing the “extra help” This needs to be discussed. Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 3  Response or Comment: During interviews with fire agency staff, several agencies referenced the use of “move and cover” procedures as well as participation in automatic and mutual aid agreements. However, no specific concerns were raised, nor was data provided regarding the frequency or geographic distribution of such responses. RSG acknowledges that mutual aid demands may be disproportionate in certain areas of the County, particularly where call volumes are high, incidents are more complex, or staffing levels are insufficient to meet operational needs. In such cases, the burden of response may fall more heavily on neighboring agencies. Because no specific concerns were raised by the service providers, RSG does not intend to include references to the potential imbalance referenced in the Commissioner’s comment. If any of the affected service providers can provide data to evidence the imbalance, RSG will update the MSR accordingly. Commissioner Comment: The City of Yuba City should be collecting the data regarding its response in to CSA G.  Response or Comment: The Yuba City Fire Department indicated that the Department does not consistently track its call volume in CSA G. The Department indicated that it can be challenging to separate CSA G calls from the Department’s total call volume since the location of each service call would have to be manually evaluated by Department staff on a call-by-call basis. As a result, the MSR recommends that the Department consistently track call volume in the CSA G service area. Commissioner Comment: There really is no discussion on the burden experienced by all County Fire Departments experience when their personnel must accompany Bi- County Ambulance to the hospital This affects on duty staffing and ability to respond. We should know how often it happens and how long on average the personnel are outside of their respective jurisdictions.  Response or Comment: During interviews with agency staff, the issue of fire personnel accompanying Bi-County Ambulance to the hospital was not identified as a significant or high-priority concern by the fire agencies included in this MSR. The primary concern raised in connection to providing service alongside Bi-County Ambulance was related to extended response times to the scene by Bi-County Ambulance. RSG collected and reviewed ambulance response time data, including average and median late-call response times, in coordination with Bi-County Ambulance and the Sierra-Sacramento Valley Emergency Medical Services Agency (S-SV EMS), the designated Local Emergency Medical Services Agency (LEMSA) for the region. S-SV EMS confirmed that Bi-County Ambulance is meeting required response time standards. While data regarding the frequency and duration of instances in which fire personnel accompany ambulances to the hospital—thereby rendering apparatus temporarily unavailable—could offer valuable insight into the operational impacts on fire departments, such information was not requested as part of this MSR. Without access to detailed incident-level data, estimates provided by agency staff remain anecdotal and cannot be independently verified. Commissioner Comment: There really is no discussion of what each respective service provider should establish at their response time goals and staffing levels. This is a significant issue within the County for all Fire Departments. More rural areas may demand/request a certain level of service (staffing levels, response times) in comparison to more populated areas. This is unrealistic in regards to ability to pay. This should be discussed  Response or Comment: RSG will update the MSR to include response time recommendations based on NFPA 1710 and NFPA 1720, which provide national standards for career and volunteer/staffed combination fire departments, respectively. These standards establish benchmarks for response Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 4 times, staffing levels, and deployment models appropriate to both urban and rural service environments. Commissioner Comment: ISO rating is mentioned as a benchmark throughout the report. While ISO rating is an item worth mentioning it does have limitations. While it is mentioned that a lower rating MAY result in lower insurance premiums to homeowners and commercial properties, ISO has historically been reluctant to quantify what the lowered percentage or cost might be. Additionally, not all insurance providers consider ISO ratings when establishing premiums. A more comprehensive, and therefore more likely meaningful assessment of the risks a fire department is responsible for protecting and that particular fire department’s service delivery standards and objectives (staffing, response times etc.) A Standards of Coverage provides significant analysis and provides for data driven decision making. There are numerous examples of this type of study utilized by Fire Departments throughout Northern California. I would strongly suggest that the MSR suggest/recommend a Standards of Cover study be performed for Sutter County Fire’s CSA’s as well as the two city’s and the independent Special Districts.  Response or Comment: While ISO ratings are not utilized by all insurance providers in determining policy premiums, they remain a nationally recognized metric for evaluating a jurisdiction’s fire protection capabilities. In the context of an MSR and CKH, benchmarks like ISO ratings are useful in evaluating an agency’s ability to provide effective and efficient services. ISO assessments consider key factors such as fire department operations, water supply systems, and emergency communications, providing a general benchmark of service readiness and infrastructure support. However, RSG acknowledges the limitations of ISO ratings, particularly the lack of transparency in how ratings translate to insurance premium reductions and the inconsistency in their use among insurers. A Standards of Response Coverage (SORC) study offers a more comprehensive and operationally relevant analysis. Unlike ISO ratings, a SORC evaluates risk levels, response time objectives, deployment strategies, station placement, staffing models, and service demand. As previously noted, RSG will update the MSR include a recommendation for the fire protection service providers to conduct a Standards of Response Coverage (SORC) study to analyze response times, station locations and coverage, staffing, wages and benefits including pensions, and a fiscal review and forecast of past, current, and future needs, to further inform future consolidation decisions. Commissioner Comment: As CSA G is still under legislative control by Sutter County (not day to day operational control) I would also suggest that any review/implementation of revenue generation for that Sutter County undertakes for CSA C, CSA D, & CSA F also include CSA G.  Response or Comment: RSG will update the MSR accordingly. Commissioner Comment: Lastly (I think for now) There are references about the “fragile” nature of the financial ability for all departments to continue to deliver services into the future yet the report also indicates they have the ability to provide current levels of service as well as into the future. This statement in and of itself seems inconsistent. If they (Fire Department’s) are or are going to be in trouble in needs to be stated now.  Response or Comment: The determinations have been updated to reflect the financial challenges faced by several service providers, including the City of Live Oak, CSA F, and CSA G. While the report notes that agencies are generally able to maintain current service levels in the near term, it also highlights concerns about long-term sustainability due to limited revenue growth and increasing service demands. The updated language will clarify that, while agencies are currently meeting existing service demands, their ability to sustain these levels over the long term is uncertain. The revisions will address previous inconsistencies and more accurately reflect the financial vulnerabilities identified. Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 5 Commissioner Comment: In a county of with a population of approximately 99,000 it seems reasonable that some level of discussion regarding consolidating the 8 different jurisdictions into one fire agency be mentioned. I am aware of the different nature of the risks covered (urban, semi-urban, residential, commercial, ag land etc.) in the entire county but these are a combination of risks that exist and are covered by fire agencies across the US and specifically within California.  Response or Comment: Mentioned previously, the MSR includes references to the potential consolidation of County Service Areas, as well as prospective consolidation efforts between independent special fire districts and the CSAs based on discussions with agency staff and reflect existing coordination efforts that have already occurred within the County Service Areas. However, RSG acknowledges that the future consolidation of all fire protection service providers could also be explored at a later date. The MSR will be updated to include a recommendation to further explore this consolidation effort. Furthermore, this will also include a recommendation for the fire protection service providers to conduct a Standards of Response Coverage (SORC) study to analyze response times, station locations and coverage, staffing, wages and benefits including pensions, and a fiscal review and forecast of past, current, and future needs, including the ability of the combined organization to adequately fund the proposed organization and operation to further inform these future consolidation decisions. Commissioner Comment: There is mention of the possibility of moving Sutter County’s Station 8 six miles to the south. Such a move would likely assist coverage issues that currently exist within Sutter County, and may increase with the proposed development of Sutter Pointe. It would likely affect auto and mutual aid agreements between Yuba City and Sutter County. These would likely include response times as well as availability of on scene staffing for in progress emergencies. As such this should be mentioned. Additionally, if such a move is undertaken Yuba City will then need to consider its response time performance to the south west portion of its Sphere of Influence as well as CSA G territory.  Response or Comment: The reference to the potential relocation of Sutter County Fire Station 8 emerged from discussions with representatives from the Yuba City Fire Department and CSA F. Both agencies noted that the current location of Station 8—positioned near the southern Yuba City boundary—may result in overlapping coverage that is potentially redundant. RSG recommends that any station relocation should be considered within the framework of a comprehensive Standards of Response Coverage (SORC) and/or consolidation study. Such an analysis would provide the data necessary to evaluate optimal station placement, assess coverage impacts, and inform future resource deployment. Additionally, if Station 8 is relocated, Yuba City may need to re-evaluate its response time performance to the southwestern portion of its Sphere of Influence and adjacent CSA G territory to ensure continued service effectiveness. The MSR will be updated to reflect this information. Commissioner Comment: Yuba City has a Standards of Coverage document that should be reviewed and refreshed. Not sure the authors of the MSR were made aware of this as there is no mention of it within the Draft MSR.  Response or Comment: RSG requested a copy of this document from the Yuba City Fire Chief on July 29, 2025. On August 1, 2025, the Yuba City Fire Chief stated that he has been unable to locate any Standards of Cover plan. The only document that he was able to locate was a Strategic Plan from 2002 that corresponded to a Standards of Cover course/training that occurred in 2002. Commissioner Comment: Page 66 & 67 – There are several “infill residential projects currently underway and several more that have been approved. Hard to believe that the population as reported in 2024 would be the same in 2029 (Figure 18) Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 6  Response or Comment: Population estimates presented in the MSR, including those in Figure 18, are based on data obtained from ESRI Business Analyst, a widely used demographic and market analysis platform. ESRI projections rely on U.S. Census data, American Community Survey (ACS) results, and other national and regional datasets to generate population forecasts. While this provides a consistent and standardized basis for analysis, it may not fully account for the most recent local development activity, such as newly approved or ongoing infill residential projects, which may not yet be reflected in real-time permitting or construction data. It is also important to note that these population figures for Yuba City do not account for the increased resident population anticipated as a result of the planned development of the Bogue Stewart Master Plan that is expected to be built out over the next 20 years with an added resident population of 6,720. Commissioner Comment: As mentioned in a previous memo Figure 19 (and others seem to indicate a diminishing number of housing units. Between 2010 and 2029.  Response or Comment: The Housing Characteristics tables incorrectly referenced the population of Sutter County in 2010, as opposed to the number of housing units. These references will be updated throughout the report. The number of housing units in Sutter County is expected to increase from 33,858 housing units in 2010 to 34,853 housing units in 2029. It is important to note that these figures do not account for the increased housing development anticipated as a result of the planned development of the Bogue Stewart Master Plan or Sutter Pointe Specific Plan. Commissioner Comment: Page 70 & 71-- Councilmembers are elected by District since 2022. Chief Hubbard is verifying the current staffing numbers.  Response or Comment: RSG will update the MSR accordingly. Commissioner Comment: Page 71 – Don’t believe a discussion about Measure D is even relevant given its failure.  Response or Comment: Pursuant to Government Code Section 56430, LAFCO is required to make determinations regarding the financial ability of agencies to provide adequate services. Although both the Sutter County and Yuba City revenue measures ultimately failed, they were intended, in part, to enhance funding for fire protection services. Discussion of the failed ballot measures provides context for the agencies’ fiscal health and highlights ongoing challenges in securing sustainable funding, which is relevant to LAFCO’s statutory determinations related to service adequacy and long-term viability. Additionally, it can help inform future LAFCO Commissions, County and City governments, and agencies themselves by providing a historical timestamp within the MSR of when such funding measures were attempted. Commissioner Comment: Page 73 – Discussed the condition of Fire Stations with Chief Hubbard. My understanding is he will be providing updates regarding current conditions.  Response or Comment: RSG received updated fire station conditions from Chief Hubbard on June 30, 2025. The MSR has been updated accordingly. Commissioner Comment: Page 74 - Appreciate the mention of diesel exhaust gas removal systems as they represented a commitment and investment to the health of the firefighters, not sure of its relevance since they already exist.  Response or Comment: The inclusion of references to diesel exhaust gas removal systems in the MSR is intended to inform the LAFCO Board and members of the public who may not be familiar with the health and safety benefits associated with such systems. While some agencies have already implemented these systems, documenting their presence—and identifying where they may still be Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 7 needed—provides a comprehensive assessment of current facility conditions. This information can also serve as a supporting reference for agencies seeking grants or other funding opportunities to address equipment or facility improvements. Commissioner Comment: Do appreciate the mention of lack of automatic fire sprinklers at Fire Station 7. This is an item that not only protects the lives of firefighters but the facility as well.  Response or Comment: RSG has received this comment. Commissioner Comment: Page 75 – Yuba City and therefore the Yuba City Fire Department does have a Vehicle Replacement Plan.  Response or Comment: RSG requested a copy of this document from the Yuba City Fire Chief on July 29, 2025. On August 1, 2025, the Yuba City Fire Chief stated the City does not have a City Vehicle Replacement Plan in place in the format of a description or program. However, they do have accounts set up that money is allocated to in the format of funding to be used for specific equipment/response vehicles. They have a spreadsheet to document the funds and allocation to various city vehicles and City emergency response vehicles. RSG has updated the MSR accordingly to reflect this information. Commissioner Comment: Page 75 – Yuba City Fire has an Aerial Apparatus (Ladder Truck) at Fire Station 3. It serving as both an engine (water tank with pump) and aerial device. Not sure but it may be the only such piece of equipment within the County. It is staffed by 4 personnel.  Response or Comment: RSG will request additional information regarding this apparatus including year of the truck and ladder length and will update the MSR accordingly. Commissioner Comment: Page 76 – As the largest Fire Department in Sutter County (and the Bi-County region) it receives frequent requests for automatic aid and mutual aid from neighboring fire departments as well as the State through the Master Mutual Aid System. These requests, when filled, do have an impact on the Departments response ability within its own jurisdiction. These requests for aid should be reported within their Service Demand Needs. Reciprocity is also a data point that should be considered as mentioned in a previous memo.  Response or Comment: During interviews with agency staff, the impact of fulfilling automatic and mutual aid requests—particularly as it relates to the department’s ability to respond within its own jurisdiction—was not identified as a significant or high-priority concern by the fire agencies included in this MSR. Additionally, data regarding the frequency, duration, or operational impact of providing or receiving mutual and automatic aid was not provided by the fire agencies reviewed in this MSR. As a result, the MSR is limited by the availability and completeness of the data submitted. If the affected agency provides information supporting this concern, RSG will update the MSR accordingly. Commissioner Comment: Page 76 – CSA G calls for service should be tracked as well as the cost of providing response to this contracted area.  Response or Comment: RSG has received and responded to this comment above. Commissioner Comment: Page 77 – See previous memo for discussion on ISO and Standards of Coverage.  Response or Comment: RSG has received and responded to this comment above. Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 8 Commissioner Comment: Page 79 – Priority Dispatch is in place and being monitored. Chief Hubbard will provide more info.  Response or Comment: RSG requested a status update on Priority Dispatch from the Yuba City Fire Chief on July 29, 2025. On August 1, 2025, the Yuba City Fire Chief stated that priority Dispatch (Pro QA) is live and being utilized by Yuba City Dispatch. This occurred on 6/17/2025. Currently dispatch is trained on the program, the system is built out and in place, and the dispatchers are going through each element for every Fire/EMS call received. The Fire Department has not flipped the switch to categorize calls for response at this point and we are currently responding to all calls, but will look to implement in the near future. RSG updated the MSR accordingly. Commissioner Comment: Page 86 – I do believe there will be population growth within the City by the year 2029. This is based upon current and forecasted residential construction.  Response or Comment: RSG has received and responded to this comment above. Commissioner Comment: Page 88 – Regarding the item of Fire Station 1 needing additional apparatus, additional staffing will also be required to respond on the apparatus.  Response or Comment: RSG will update the MSR accordingly. Commissioner Comment: Yuba City Fire is an active member of several Regional Teams. These all affect response, staffing and budget and therefore likely require some discussion:  Members of the local law enforcement SWAT response. YCFD firefighters participate as the Tactical Emergency Medical Support (TEMS) in this capacity they respond to SWAT incidents within Yuba City as well as the Bi-County region. Personal must stay current with certifications and continuing education requirements.  Hazardous Material Response Team – Members of the Yuba City Fire Department serve on the regional Hazardous Materials response team. Yuba City Fire houses the response vehicle. Personal must stay current with certifications and continuing education requirements. Personal must stay current with certifications and continuing education requirements.  Water Rescue – Members of the Yuba City Fire Department support the Bi-County region with response to requests for water rescue. The Department houses a boat and personal watercraft. Personal must stay current with certifications and continuing education requirements.  Statewide Master Mutual Aid – Yuba City Fire Department provides ‘all risk” support for incident when requested by the State of California . Yuba City Fire Department houses a State owned fire engine to facilitate response. Personal must stay current with certifications and continuing education requirements.  Response or Comment: RSG will update the MSR accordingly to include this information. AGENCY: YUBA CITY FIRE DEPARTMENT (Received via email from Chief Hubbard on June 30, 2025) Agency Comment: Page 70 – Update the Fire Chief position to reflect my name, effective July 1, 2025.  Response or Comment: RSG will update the MSR accordingly. Agency Comment: Page 70 – At the end of FY 2023, we had 59 full-time employees, not 56. Over the last five years (FY 2019 to FY 2023), the Yuba City Fire Department has increased staffing by 3 members, reflecting an overall positive change of 5.36%, not a decrease of 2 or -3.4%. Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 9  Response or Comment: RSG will update the MSR accordingly. Agency Comment: Page 71 – The chart should be updated to show 59 personnel for both 2022 and 2023, with an average of 58.4 and a trend increase of 5.36%. This should be noted in both the “Paid Position” area and the “Total” area.  Response or Comment: RSG will update the MSR accordingly. Agency Comment: Page 73 – Station 2 should be listed in good condition following upgrades and expansion, which include new dorms, bathrooms, workout room, laundry room, PPE storage, and previously completed kitchen and day room upgrades.  Response or Comment: RSG will update the MSR accordingly. Agency Comment: Page 73 – Station 3 should be listed in moderate to good condition, reflecting recent kitchen and dining room upgrades. However, the addition of a fourth firefighter has required doubling up in one room, which may still justify a classification of lacking modern accommodations.  Response or Comment: RSG will update the MSR accordingly. Agency Comment: Page 74 – At the end of the paragraph on vehicle exhaust systems, add that the Department has also installed PPE storage facilities at all stations through our Cancer Task Force. This addition helps limit exhaust and carcinogen exposure from contaminated PPE.  Response or Comment: RSG will update the MSR accordingly. Agency Comment: Page 75 – The Department has an apparatus replacement policy.  Response or Comment: RSG will request a copy of this document and update the MSR accordingly. Agency Comment: Page 75 – Chart should reflect Rescue Boat and 2 jet skis at Station 1, under station 3 instead of Type 1 use Ladder Truck, under station 3 the last Type 1 listed is a 2007 not 2000, under station 7there is only 1 Type which is a 2000, under station 7 we have an SCBA air unit (2018)  Response or Comment: RSG will update the MSR accordingly. Agency Comment: Page 88 - Station 1 bullet point to reflect the need for additional personnel to staff that additional piece of equipment in the future.  Response or Comment: RSG will update the MSR accordingly. Agency Comment: Page 88 - Station 2 in moderate to good condition following upgrades that will be completed in the next 1-2 weeks.  Response or Comment: RSG will update the MSR accordingly. Agency Comment: Page 88 - Station 3 in moderate to good condition as stated above.  Response or Comment: RSG will update the MSR accordingly. STAKEHOLDER: PLEASANT GROVE FIREMAN’S ASSOCIATION (Letter received via email from Kingsley Bogard Attorneys at Law on July 7, 2025) Comment: The MSR relies on fiscal data from 2019–2023 to project service needs through 2028. This Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 10 limited timeframe does not reflect recent developments or operational changes that impact CSA C and D today and in the near future.  Response or Comment: Pursuant to Government Code 56425, LAFCOs are required to review and update each Sphere of Influence (SOI) at least every five years. In conjunction with this, Government Code 56430 requires that a Municipal Service Review (MSR) be conducted prior to or in coordination with an SOI update. Because these reviews follow a five-year cycle, the MSR evaluates conditions based on the preceding five fiscal years, FY 2019 to 2023. This timeframe ensures consistency with the statutory review period and reflects the most recent complete data available at the time of the report. While more recent developments may not be captured, the MSR provides a snapshot of service trends and capacity to inform planning over the next five years. RSG and LAFCO welcome any updated information or documentation regarding recent developments or operational changes to help inform future MSR updates or SOI determinations. RSG and LAFCO will work together to determine the appropriate action based on this information. Comment: The suggestion to consolidate CSA C and D with CSA F is primarily based on reported “low call volumes.” However, no benchmarks or comparative data are provided to justify this claim. Clearer metrics and justification are necessary before such a significant conclusion can be reached. Furthermore, the call volumes included in the MSR are not accurate and are significantly lower than the call volume (calls responded to by CSA C and D). Furthermore, the call volumes included in the MSR are not accurate and are significantly lower than the call volume (calls responded to by CSA C and D).  Response or Comment: RSG will coordinate with LAFCO staff and County Fire Chief Daley to understand whether additional updates to the discussion about CSAs C, D and F are warranted. Comment: The MSR briefly references alternatives like forming a new CSA or establishing a Zone of Increased Benefit (“ZIB”), but it does not explore the practical or fiscal implications of these options in any depth.  Response or Comment: As mentioned, the MSR includes a high-level discussion of governance alternatives in CSA D such as the formation of a new County Service Area (CSA) or the establishment of a Zone of Increased Benefit (ZIB), consistent with the requirements of Government Code 56430, which states that LAFCO may assess various alternatives for improving efficiency and affordability of infrastructure and service delivery within and contiguous to the sphere of influence. However, detailed fiscal or operational analyses of these alternatives are outside the scope of the MSR process. Comment: CSA C and D already share a volunteer Fire Chief and Assistant Chief, while CSA F handles limited administrative duties such as purchasing supplies. The day-to-day operations of CSAs C and D are overseen by their own volunteer Fire Chief. These existing arrangements are evidence that administrative roles are already shared. In short, the CSA’s have already addressed inefficiencies and evidence that there are opportunities for administrative streamlining without the need for full consolidation.  Response or Comment: RSG will review this comment with LAFCO staff and consult with County Fire Chief Daley to gain an understanding of whether any additional changes to the MSR are warranted. Comment: Any discussion of consolidation should first address the implications of CSA F’s special fire tax. Proceeding without resolving this issue could create fiscal inequities across the newly combined areas.  Response or Comment: The MSR currently includes this information. The MSR states that “the County can ensure collaboration and careful financial planning in order to preserve the fiscal health of each County Service Area. A potential cost sharing agreement may help preserve the financial resources of each service area by establishing a fair funding allocation process and create a County Service Area Zone of Increased Benefit to preserve CSA F’s existing special fire tax.” Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 11 Comment: Current public safety infrastructure is sufficient to meet the fire and EMS needs of CSA C and D. With the anticipated funding from the Sutter Pointe development (through a new CSA or ZIB), station coverage and staffing can be significantly improved—negating the need for structural consolidation at this time.  Response or Comment: RSG will review this comment with LAFCO staff and consult with County Fire Chief Daley to gain an understanding of whether any additional changes to the MSR are warranted. Comment: Despite RSG and LAFCO’s efforts to gather input for the MSR, Pleasant Grove Fire’s CSAs had limited contact and only email survey input. Pleasant Grove Fire was not an active participant in this process. Unfortunately, this lack of engagement excluded vital on-the- ground perspectives and undermines the validity of the MSR findings.  Response or Comment: RSG and LAFCO worked closely with Sutter County Fire Consultant Specialist Peter Daley, as well as Interim Sutter County Fire Chief Richard Epperson, during the preparation of this MSR. Chief Daley was responsible for coordinating, gathering, and submitting data for the CSAs. Comment: Pleasant Grove Fire’s CSAs were not informed about Advisory Committee (“Ad Hoc”) meetings hosted by RSG and Planwest. As a result, Pleasant Grove Fire was denied an opportunity to contribute to critical discussions that directly affect CSA C and D.  Response or Comment: RSG and LAFCO worked closely with Sutter County Fire Consultant Specialist Peter Daley, as well as Interim Sutter County Fire Chief Richard Epperson, during the preparation of this MSR. Peter Daley and Chief Epperson represented CSAs C, D, F and G in Advisory Committee meetings. Comment: Between November 2024 and February 2025, RSG and Planwest conducted interviews with fire and EMS agencies countywide. CSA C and D were not included, despite being directly impacted by the MSR recommendations.  Response or Comment: RSG interviewed Sutter County Fire Consultant Specialist Peter Daley, Interim Sutter County Fire Chief Richard Epperson, and Sutter County Chief Administrative Officer Steve Smith as part of the data collection efforts for this MSR. Peter Daley and Chief Epperson represented CSA C, D, F, and G. Comment: The MSR includes agency profiles developed from interviews and collected data. Since Pleasant Grove Fire’s CSAs were not interviewed, the profiles include inaccuracies that skew the report’s conclusions.  Response or Comment: RSG interviewed Sutter County Fire Consultant Specialist Peter Daley, Interim Sutter County Fire Chief Richard Epperson, and Sutter County Chief Administrative Officer Steve Smith as part of the data collection efforts for this MSR. Peter Daley and Chief Epperson represented CSA C, D, F, and G. Comment: Currently there are already shared administrative functions that CSA C and D pay CSA F to perform. The only inefficiency identified in the MRS is that CSA F must either pay for CSA C's expenses up front and reimburse itself, or process payments from CSA C’s budget. This inefficiency does not mandate a full structural merger, but instead could be facilitated through improved financial coordination.  Response or Comment: The MSR does not mandate a full structural merger as the comment suggests. The data collection and analysis for this MSR indicated that consolidation may be a viable option to consider. The MSR states that a “merger could streamline operations, improve service efficiency, and optimize resource allocation.” Further data collection, analysis, and a completed change of application organization would be required for LAFCO to move forward with a change of organization. Comment: CSA C currently has a shared volunteer Fire Chief and Assistant Chief (with CSA D), one Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 12 shared Extra-Help Fire Engineer, and 20 volunteer firefighters. In 2024, a second Extra-Help Firefighter was added to meet growing needs. With additional funding from the Sutter Pointe CSA or ZIB, staffing levels can be increased further to provide adequate coverage for the expanded area.  Response or Comment: RSG has received this comment and will work with LAFCO and County Fire Chief Daley to determine if changes to the MSR are warranted. AGENCY: SUTTER COUNTY ADMINISTRATOR’S OFFICE (Received via email from Steve Smith on July 7, 2025) Comment: Page 22 (333 of 231 in pdf) states “adequacy of public services” twice  Response or Comment: RSG will update the MSR accordingly. Comment: Page 23 (34) has grammatical error  Response or Comment: RSG will update the MSR accordingly. Comment: Page 38 (50) odd spacing of paragraph  Response or Comment: RSG will update the MSR accordingly. Comment: Page 43 (53) states Live Oak sphere is 135.9 miles. Maybe 13.59?  Response or Comment: The City of Live Oak’s sphere of influence is approximately 12.0 sq. mi. The MSR will be updated accordingly. Comment: Page 67 (78) couple missing words in sentence  Response or Comment: RSG will update the MSR accordingly. Comment: Page 70 (81) lists current fire chief that has subsequently resigned  Response or Comment: RSG will update the MSR accordingly. Comment: Page 76 (87) Figures seem incorrect, at least for number of “Fire” calls that goes from7,168 in 2022 to 371 in 2023  Response or Comment: RSG will contact the Yuba City Fire Department to clarify the significant decrease from 2022 to 2023. Comment: Page 78 (89) Change percentage to percent  Response or Comment: RSG will update the MSR accordingly. Comment: Page 139 (150) CSA F was formed in mid-1990’s not 1963. Also, the square miles numbers don’t match each other.  Response or Comment: RSG will update the MSR accordingly. Comment: Page 147 (158) Also mentions formation in 1963  Response or Comment: RSG will update the MSR accordingly. Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 13 Comment: Page 152 (163) States expenses are in four categories, but only lists three. States General Fund support has increased from 2019-2023, but it has not. Other funding sources were primarily used such as CARES and ARPA. States service population of 18,705, but previously stated 9, 424 on page 141 (152)  Response or Comment: RSG will update the MSR accordingly. Comment: Page 153 (164) states the department has adequate staffing levels into the foreseeable future. It does not. We barely avoided six layoff beginning July 1, 2025, due to $1 million from Sutter Pointe developers, but those positions will transfer to Sutter Pointe within 18 months, leaving CSA F short six staff and either browning out stations intermittently or going to 1-0 staffing.  Response or Comment: RSG will coordinate with LAFCO staff, Sutter County Fire Consultant Specialist Peter Daley, and Interim Sutter County Fire Chief Richard Epperson to gain a better understanding of this comment and will update the MSR accordingly. Comment: Page 157 (168) again mentions General Fund dollars should be ARPA funding.  Response or Comment: RSG will update the MSR accordingly. Comment: Page 158 (169) again mentions adequate staffing into the future.  Response or Comment: RSG will coordinate with LAFCO staff, Sutter County Fire Consultant Specialist Peter Daley, and Interim Sutter County Fire Chief Richard Epperson to gain a better understanding of this comment and will update the MSR accordingly. Comment: Not sure what is meant by specific information should be made available to enhance transparency. Made available to whom? The state controller, the public via website, the Board via public meeting?  Response or Comment: CSA F does not maintain a website. To enhance accountability and transparency for its public constituents, the CSA should accessible information regarding the Fire Department’s range of fire protection and emergency medical services, governance structure, compensation details, annual budgets, reserve fund policy, and the current and historical annual financial reports provided to the State Controller’s Office. RSG will update the MSR accordingly to clarify this information. Comment: Page 166-167 (177-178) States CSA G is governed by Board of Supervisors. It is not, it is simply a pass through of funding to the City, which oversees all operations. Again, mentions former Yuba City Fire Chief.  Response or Comment: RSG will update the MSR accordingly to clarify CSA G’s governance structure. Comment: Page 174 (185) States the district has surplus revenue four out of the last five years, then states that two fiscal years of data are available, and the district’s financial position is fragile.  Response or Comment: Only two fiscal years of data were available for CSA G. RSG will remove the statement regarding CSA G’s surplus revenue four out of the last five years. Comment: Page 176 (187) states CSA G has no other planned developments as part of MSR. Just checking if this means except for Bogue Stewart, which was discussed in the study.  Response or Comment: The Bogue Stewart Master Plan should be identified in the referenced section. RSG will update the MSR accordingly. Comment: Page 207 (218) grammatical error Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 14  Response or Comment: RSG will update the MSR accordingly. Comment: Page 213 (224) grammatical error  Response or Comment: RSG will update the MSR accordingly. STAKEHOLDER: JANE VANDENHOFF (Comments received via email on July 10, 2025) Comment: I am writing in opposition to any action that would consolidate or re-draw boundaries for CSA's C and D with CSA F.  Response or Comment: RSG’s recommendations regarding district boundaries are outlined in the summary of recommendations. For CSA C, CSA D, and CSA F, RSG recommends re-affirming the sphere of influence with respect to the delivery of fire protection and emergency medical services. RSG also recommends that consolidation of the CSA C, CSA D, and CSA F may improve service delivery, subject to submittal of a completed change of organization application. Comment: It was disappointing to read this Draft which did not mention businesses that are served within the CSA's. It appeared to be solely population driven.  Response or Comment: The MSR is designed to meet the requirements of CKH, including a determination with respect to the “growth and population projections for the affected area,” using the best available information. RSG does not have reliable business or employment forecasts at the district- level. RSG has obtained detailed population estimates and forecasts at the district-level for each of the fire and emergency medical service providers in Sutter County, and supplements this information with estimates of known commercial development (such as the Sutter Pointe Specific Plan) when available. Comment: It also failed to mention that the CSA's not only provide services to residents (and businesses), but ever-increasingly to accidents and incidents that occur on the roads and highways within the CSA's. The roads within our C and D communities have become thoroughfares and cut-throughs for traffic en route to and from Placer and Yuba County.....a situation that is becoming worse by the year with the increasing residential and commercial building in the East.  Response or Comment: When available, RSG presented vehicle accident calls for service or responses. District data collection varies significantly from one service provider to the next, and consistent information on vehicle accident calls for service or responses is not always available. Typically, vehicle accident responses require emergency medical response, which RSG and Planwest described within the MSR with respect to every service provider. Comment: East Nicolaus and Pleasant Grove Fire Department (CSA's C & D) were created by community members in the 60's.....a truly community-driven undertaking. According to the report, they are financially sound. Our communities are proud of our Fire Departments. The report simply states that "they were created in the 60's.) To ignore the historical significance is short-sighted.  Response or Comment: RSG is aiming to provide factual information in the MSR, and intends to avoid using subjective terminology. If additional factual information about the formation of CSA C or CSA D was presented, RSG would include this information in the MSR. STAKEHOLDER: MARTY VINSON (Comments received via email on July 10, 2025) Comment: Page X Martin, the first name should be Marty.  Response or Comment: RSG updated the MSR accordingly. Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 15 Comment: Page 1, inconsistent LAFCO year studies. Where is the last one 2019 to 2023 and what was 2017- on the web site, outcome or where is it?  Response or Comment: It’s unclear what this comment is referring to. The statement on Page 1 of the MSR is designed to provide readers with background information about the scope of the MSR. The last MSRs completed for each fire protection service provider are as follows: City of Live Oak (none completed to date), City of Yuba City (2020), County Service Areas (2017), Meridian FPD and Robbins Sutter Basin FPD (2012). Comment: Statements on page 3/4 service area C and D are in accurate, incorrect data provided.  Response or Comment: It is unclear what this comment is referring to. The statements on pages 3 and 4 of the MSR regarding CSA C and CSA D are summaries of RSG’s recommendations based on the information presented in the MSR, rather than information that could be deemed correct or incorrect. Comment: page 4, CSA D, why is it the new development needs a enhanced level of service over the other CSA’s?  Response or Comment: With substantial new development expected in CSA D, RSG suggested that an enhanced level of service will be necessary. The enhanced level of service is with respect to current service levels. In order to maintain current service levels to new development, CSA D will need to significantly enhance service levels. Comment: Page 5, CSA F, there is no discussion on a county wide tax just for Fire service, why just CSA F, why not include them all?  Response or Comment: RSG is expanding the discussions about revenue generation to all service providers. Comment: Page 6 why no permanent funding source recommendation for C and D?  Response or Comment: RSG is extending the topic of revenue generation from CSA D to all service providers. Comment: Page 12, statement of CSA F managing and overseeing CSA C & D is a false statement and how did you come to that conclusion?  Response or Comment: According to County Fire, CSA F is providing administrative services to CSA C and D. Comment: Page 13, #7, explain what policies were not identified and why not?  Response or Comment: CKH specifies that a municipal service review must address “any other matter related to effective or efficient service delivery as required by Commission policy.” Based on RSG’s review of Commission policies, Sutter LAFCO has not adopted additional policies that must be addressed within the MSR. Comment: How many times if any? did you meet in person with other CSA,s not including C or D and who were they?  Response or Comment: RSG met with County Fire on several occasions to discuss the operations, finances, and services provided by the County Service Areas. Comment: Are there any current applications filed for a new service area in South Sutter? Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 16  Response or Comment: RSG is not aware of any current applications to designate a new service area in South Sutter. County and/or LAFCO staff may be able to address this question. Comment: Page 14, typo? Build-out vrs Build out?  Response or Comment: RSG updated the MSR to be consistent with this terminology. Comment: Page 14, sec 2 it states, It’s unlikely D will have the necessary capacity to provide fire protection and emergency services, where is the data for this comment? then on page 15 sec 3 states, with exceptions- what are they and or where are they located?  Response or Comment: RSG’s determinations for CSA D are based on the information provided between pages 114 and 137. The developer of Sutter Pointe and Sutter County are currently in the process of determining how to provide services to the Sutter Pointe Specific Plan area during construction and at buildout. Comment: typo? states meeting begins at 2:00 pm?  Response or Comment: It is unclear what this comment is in reference to. RSG searched the document for “2:00,” “pm,” and “p.m.” and was unable to determine what this comment is referring to. Comment: Typo, Page, 87, Built out?  Response or Comment: RSG updated the MSR to be consistent with this terminology. Comment: Page 93, sec 2 Jurisdictional- As of FY 2023- no notation of where this information came from, please explain where it came from?  Response or Comment: RSG updated the MSR to include a footnote referencing the source of the assessed value information. Comment: Typo, Page, 95, build out?  Response or Comment: RSG updated the MSR to be consistent with this terminology. Comment: Page 95, where did the population count come from, ESRI Business Ansalyst?  Response or Comment: RSG obtained population estimates from ESRI Business Analyst. ESRI utilizes the latest information from the US Census and American Community Survey to make population estimates based on custom-defined geographies, such as fire and emergency medical service provider boundaries. Comment: Is ESRI a paid subcontractor and if so how is the public supposed to confirm this information without buying into the company plan or program?  Response or Comment: RSG subscribes to ESRI for demographic information, and verification of this data by the public would be difficult without a subscription and GIS mapping capabilities. Comment: Where are the rules and laws that govern CSAs?  Response or Comment: County Service Areas are governed by Government Code Sections 25210 through 25217.4, known as the County Service Area Law. Comment: Page 95, where is the figure or graph portion of the final data given by ESRI for paragraph 1? Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 17  Response or Comment: The figures provided in the MSR represent data provided by ESRI. RSG supplements this information anecdotally with data about development projects in the pipeline, such as the Sutter Pointe Specific Plan. Comment: Page 96, what happened to the years 21,22,23 in figure 29?  Response or Comment: Figure 29 presents resident population at key points in time: the 2010 census, the 2020 census, an estimate of population in 2024 (the best available information during the preparation of the MSR), and a forecast of the population in 2029. The population estimates are intended to provide a high level understanding of how the population has changed since 2010 and is expected to change in the next 5 years. Annual population change is not considered material to the findings of the MSR. Comment: Why is there unaccounted data for the inbetween years, some data goes from 2010 to 2024.  Response or Comment: RSG presented the best available information at the time of the preparation of the MSR. Demographic data, for example, is best understood in terms of long term trends, while calls for service/response data is best understood in terms of annual change. Comment: How much of the report was generated by AI?  Response or Comment: RSG’s report was not generated by artificial intelligence. The MSR is the product of over a year of data collection, analysis, and interviews with service providers. Because RSG evaluated several service providers concurrently, portions of the MSR may appear duplicative because the same findings and determinations must be addressed for each service area. Comment: Page 102 the last paragraph, in addition to a new F550 is not accurate. We purchased a type 6 for each dept and the chassis was a F550.  Response or Comment: RSG will update the MSR accordingly. Comment: page 103 service demand records.  Response or Comment: It is unclear what this comment is in reference to. Comment: What is CSA C and D tax revenue return percentage?  Response or Comment: CSA C received $278,000 in property tax revenues in 2022-23 (Page 105), while CSA D received $335,000 in property tax revenues in 2022-23 (Page 129). Comment: Why hasn’t there been any town Hall meetings about LAFCO.  Response or Comment: Sutter LAFCO meets at 1:00 pm on the second Thursday every other month (Jan, Mar, May, Jul, Sep, Nov). The public is welcome to provide general comments or questions at any Commission meeting during the public comment portion of the agenda, or about specific topics during public hearings. Comment: If the service area D has the new building happening in its service are. Why hasn’t the developer discussed anything with CSA D?  Response or Comment: It is RSG’s understanding that the developer has discussed the new development and planned services with Sutter County. Comment: Does the money just given to service area F for personnel belong to service area D, if not why not. Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 18  Response or Comment: RSG assumes this comment is referring to the reimbursement paid to CSA F for administrative services. AGENCY: CITY OF LIVE OAK (Received via email from City Manager Benjamin Moody on August 6, 2025) Comment: Did Sutter County provide this [in reference to Live Oak’s service demands between FY 2020 and 2023]? Does Live Oak need to follow up to provide?  Response or Comment: Sutter County Fire provided call data for calls for service within the City of Live Oak. No additional information is needed for the MSR. Comment: Is it the sphere of influence the city limits for service boundary?  Response or Comment: California Government Code Section 56076 defines “sphere of influence” as a plan for the probable physical boundaries and service area of a local agency, as determined by the LAFCO commission. The City of Live Oak has an expanded sphere of influence that extends beyond City limits. Comment: Also if a new statement could be added underneath this one: With a new five year service contract in place beginning 1/1/2024, with costs increase 43% FY 25/FY 23, evaluate options to increase revenues and analyze service cost reductions for sustainability  Response or Comment: RSG has updated the MSR accordingly. Comment: Is Sutter County paying to support CSA F via the 15% call volume? Or the population calculation via Live Oak/County service agreement for the sphere area outside city limits?  Response or Comment: RSG did not receive a copy of the City of Live Oak’s contract with Sutter County Fire and is unable to independently verify this information. Comment: Not sure this is real. Built 1 SFR in 24/25. Is the growth rate from ESRI/Gov. forecasts or did the city provide it?  Response or Comment: Population estimates presented in the MSR are based on data obtained from ESRI Business Analyst, a widely used demographic and market analysis platform. ESRI projections rely on U.S. Census data, American Community Survey (ACS) results, and other national and regional datasets to generate population forecasts. While this provides a consistent and standardized basis for analysis, it may not fully account for the most recent local development activity, such as newly approved or ongoing infill residential projects, which may not yet be reflected in real-time permitting or construction data. Comment: Isn't Live Oak via contract serving the 2 on the north?  Response or Comment: CSA F is the primary fire protection service provider to the disadvantaged unincorporated communities located contiguous to the City of Live Oak. RSG did not receive a copy of the City of Live Oak’s contract with Sutter County Fire and is unable to independently verify whether the contract includes these service areas. Comment: What is the population of CSA F that is in L.O. sphere?  Response or Comment: As of the date of this Comment Memorandum, the population of the unincorporated portion of the City of Live Oak’s SOI is 835. RSG has updated the MSR to include this information. Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 19 Comment: Add a statement about Live Oak after this one: New service contract with Sutter County, cost currently exceed Fire Revenues collected via CFD 2004-1  Response or Comment: RSG has updated the MSR accordingly. Comment: Is that accurate, seems low? [in reference to Sutter County land use percentages]  Response or Comment: RSG and Planwest relied upon GIS data to the distribution of land use in Sutter County. Comment: With Live Oak's slow growth rate and existing facilities, is the existing capacity adequate?  Response or Comment: RSG determined that the City of Live Oak has the adequate capacity and infrastructure to continue providing fire protection and emergency medical services to its current and future residents through its contract with Sutter County Fire. Comment: Is this the state or county annual median household income? [in reference to the annual median household income used to determine DUCs in Sutter County]  Response or Comment: The statewide annual median household income is $95,521. RSG has updated the report to clarify this information. Comment: What is the requirement for city of Live Oak? [in reference to EMS Response Time Standards in Sutter County]  Response or Comment: The City of Live Oak falls under the Sutter County Rural 20 ambulance response zone, which establishes a 20-minute response time standard 90% of the time. Comment: Missing a period. [p.37]  Response or Comment: RSG has updated the MSR accordingly. Comment: Fix this gap. [p.38]  Response or Comment: RSG has updated the MSR accordingly. Comment: 136 seems too big compared to city limits [in reference to the City of Live Oak’s sphere of influence size]  Response or Comment: RSG has updated the MSR accordingly to reflect that the City of Live Oak’s sphere of influence spans 12.0 square miles. Comment: I've heard closer to 2,700 - did the county assessor or Live Oak provide a basis for data? [in reference to the number of housing units in the City of Live Oak]  Response or Comment: Housing estimates presented in the MSR are based on data obtained from ESRI Business Analyst, a widely used demographic and market analysis platform. ESRI projections rely on U.S. Census data, American Community Survey (ACS) results, and other national and regional datasets to generate population forecasts. While this provides a consistent and standardized basis for analysis, it may not fully account for the most recent local development activity, such as newly approved or ongoing infill residential projects, which may not yet be reflected in real-time permitting or construction data. Comment: Maybe delete sentence with the slow build/growth. Internal: ask Karen how many homes over the past 5 years (referencing the annual number of housing units added in the last decade). I don’t understand Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 20 current (referencing the ratio of housing units to residents). With housing costs I see it going up, not down (referencing the forecasted average household size in 2029).  Response or Comment: RSG removed the sentence “this creates a ratio of 0.5 housing units for every 1 new resident.” Comment: This is an error [in reference to Sutter County housing unit information presented in Figure 10]  Response or Comment: The Housing Characteristics tables incorrectly referenced the population of Sutter County in 2010, as opposed to the number of housing units. These references will be updated throughout the report. The number of housing units in Sutter County is expected to increase from 33,858 housing units in 2010 to 34,853 housing units in 2029. Comment: Does not match the % up above [in reference to percentage change of median age reflected in Figure 11]  Response or Comment: RSG has updated the MSR accordingly. Comment: 95,521 Page 19 [in reference to the median household income reported for Sutter County]  Response or Comment: The 2024 median household annual income for Sutter County is $70,700 based on estimates from ESRI Business Analyst. The median statewide annual household income is $95,521 based on five-year estimates obtained from the U.S. Census Bureau for 2019-2023. Comment: Even thought not a DNC, do we need to call out disadvantaged community being less than 80% AMI  Response or Comment: California Government Code Section 56425 mandates that in determining the sphere of influence of a city that provides structural fire protection services, the commission shall consider and prepare a written statement of its determinations, including the present and probable need for public facilities and services of any disadvantaged unincorporated communities within the existing sphere of influence. Comment: Does this match housing/pop data from page 46  Response or Comment: RSG has addressed this comment previously. Comment: Delete [in reference to Richard Epperson’s title as “Interim” Fire Chief  Response or Comment: RSG has updated the MSR accordingly. Comment: In 2024 we had a significant staffing increase, this should be included in the MSR  Response or Comment: RSG cannot retroactively compile 2024 data for the preparation of this MSR. The MSR provides a snapshot of service trends and capacity to inform planning over the next five years. Comment: Is the chief included? In the 24 contact we have B.C. + 6 + volunteers + chief ? [in reference to Figure 13] Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 21  Response or Comment: The staffing figures reported in Figure 13 were obtained directly from Sutter County Fire. The staffing figures include the Sutter County Fire Chief under paid positions. The MSR’s report period covers the years 2019 through 2023. Comment: Including Live Oak [in reference to S-SV EMS designating Bi-County Ambulance as the exclusive ambulance transport provider in Sutter County]  Response or Comment: The City of Live Oak is implied in this statement. RSG has updated this statement to clarify. Comment: It is located in the central part of the city [in reference to the Station No. 5 location]  Response or Comment: RSG has updated the MSR accordingly. Comment: 5 [in reference to Station No. 1]  Response or Comment: RSG updated the MSR accordingly. Comment: Confirm what Live Oak owns and what Live Oak maintains  Response or Comment: RSG updated the MSR accordingly. Comment: Live Oak/Sutter County contract maintenance: Type 1, Type 3, water tender, utility. [“LO” label added next to Type 1, Type 2 and Type 6 apparatus in Figure 14]  Response or Comment: RSG updated the MSR accordingly. Comment: [In reference to an average of 2,046 dispatched calls annually] is this within City limits or area code?  Response or Comment: Call data reported for the City of Live Oak is based on calls for service within City limits. Comment: [In reference to a placeholder] Chief Epperson to answer.  Response or Comment: RSG has updated the MSR accordingly. Comment: Work has been completed [in reference to improvements at Station No. 5]  Response or Comment: RSG has updated the MSR accordingly. Comment: 2019 data needs to be added, it should show a decrease from 2019 to 2020 [in reference to Figure 15]  Response or Comment: The MSR currently reflects that Information for FY 2019 is not readily available due to County Fire changing its incident reporting system. As a result, RSG is unable to incorporate this information into the report. Comment: What call types are defined as "Other Rescue"  Response or Comment: “Other Rescue” calls refer to any rescue-type call that does not have a specific category in the system (the “300” series of calls). This includes, but is not limited to, service calls such as water rescues, extrications from vehicles, electrical rescues, medical aids and medical assists, Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 22 trench rescue or confined space rescue, and lock-in calls. RSG has included the definition of “Other Rescue” calls in the MSR. Comment: Confirming 11.8% decrease in fire protection calls, but 33% reduction in overall calls since 2020?  Response or Comment: RSG updated the MSR accordingly. The 11.8% decrease corresponds solely to fire calls for service, whereas the 33% reduction refers to the total calls for services (fire, EMS, etc) Comment: Regarding Figure 15 (Live Oak Service Demands between FY 2020 and FY 2023), is this by city limits or area code?  Response or Comment: The City of Live Oak’s service demands reflect calls for service within City limits. Comment: If call volume decreased and staffing increased, is Live Oak overstaffed  Response or Comment: RSG determined that the City of Live Oak has the adequate capacity and infrastructure to continue providing fire protection and emergency medical services to its current and future residents through its contract with Sutter County Fire. Comment: According to Calfire's fire hazard severity zone (FHSZ), Live Oak has no fire hazard severity zones  Response or Comment: RSG has received this comment. Comment: Is this confirmation from Sutter County? [in reference to the County Fire’s ISO rating in the City of Live Oak]  Response or Comment: County Fire confirmed the City of Live Oak’s ISO rating. Comment: Is this a thing? How do I find or recommend establishing? [in reference to Sutter County Fire’s response time standards in the City of Live Oak]  Response or Comment: RSG has included additional information regarding NFPA 1710 in the Methodology section of the report. Comment: Fire protection specific. The special assessment is $135K/year + 2004 CFD component  Response or Comment: RSG has updated the MSR accordingly. Comment: Remove dash after $84,000. Should be special assessment 2004 CFD.  Response or Comment: RSG has updated the MSR accordingly. Comment: [In reference to 33.1% change in calls for services from 2020 to 2023] in 2024?  Response or Comment: RSG cannot retroactively compile 2024 data for the preparation of this MSR. The MSR provides a snapshot of service trends and capacity to inform planning over the next five years. Comment: [In reference to emergency medical services listed under the City’s Financial Ability to Provide Services] with Bi-County.  Response or Comment: RSG has updated the MSR accordingly. Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 23 Comment: [In reference to Live Oak reimbursing “up to 85%” of Sutter County’s operational costs] approximately.  Response or Comment: RSG will update the MSR accordingly Comment: [In reference to figures $305,000 and $928,000] James confirm.  Response or Comment: RSG updated the MSR accordingly, based on data provided by the City. Comment: [In reference to “overall decrease of 28.9%”] I don’t understand the decrease  Response or Comment: The Live Oak Cash Flow Figure indicates that Live Oak’s annual Fire Department expenditures decreased from $1,392,429 in 2019 to $990,587 in 2023, which is a 28.9% decrease. No changes were made to the MSR based on this comment. Comment: [In reference to Live Oak’s financial ability to provide fire protection and emergency medical services now and into the foreseeable future.] need to update; I want a more conservative statement that costs rise over revenues. $1.3 cost vs $300k revenue. Need to consider additional revenues or reduction in service.  Response or Comment: RSG revised the MSR accordingly. Comment: 991,000 [in reference to Live Oak’s total expenditures at the end of FY 2023]  Response or Comment: RSG has updated the MSR accordingly. Comment: What do they need to see, we can provide desired data upon request [in reference to the report stating that this analysis does not account for potential revenues from the City’s General Fund, such as property or sales taxes]  Response or Comment: RSG’s analysis does not require additional information. Comment: Impact fees are not available for operating expenditures. Source appears to be from ACFR's. These amount match the actual amounts.  Response or Comment: RSG has received this comment. Comment: Live Oak in the city limits, utilize Bi county across the SOI  Response or Comment: RSG has received this comment. Comment: 1 residential unit was added in 2024, and 2025 will be a similar number  Response or Comment: RSG has addressed this comment previously. Comment: ? This is not the case? [in reference to the statement regarding a surplus of housing production in the City]  Response or Comment: This statement is based upon the rate of new housing units vs. the rate of population growth in the City based on information from ESRI Business Analyst. RSG has updated the MSR to include the word “potential” in this sentence. Comment: Live Oak is a DAC Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 24  Response or Comment: Mentioned previously, California Government Code Section 56425 mandates that in determining the sphere of influence of a city that provides structural fire protection services, the commission shall consider and prepare a written statement of its determinations, including the present and probable need for public facilities and services of any disadvantaged unincorporated communities within the existing sphere of influence. Comment: CSA F revenue increases to help offset costs to Sutter County residents outside of City limits [in reference to the Service Provision Determinations].  Response or Comment: No changes were made to the MSR based on this comment. Comment: Does Sutter Country provide this information to the city? [in reference to the City of Live Oak making information public regarding fire protection services provided by Sutter County]  Response or Comment: RSG encourages the City of Live Oak and Sutter County Fire to exchange information in order to making information more readily accessible, regarding the Fire Department’s range of fire protection and emergency medical services, governance structure (including an organizational chart), compensation details, annual budgets, reserve fund policy, and the current and historical annual financial reports provided to the State Controller’s Office. AGENCY: CITY OF LIVE OAK (Comments received from Ben Moody via email on August 26, 2025) Comment: 2-4 with platoon setup [pg. 57, regarding staff assignments to Station No. 5]  Response or Comment: RSG will updated the MSR accordingly. Comment: Mr. Moody provided labels next to each apparatus indicating ownership.  Response or Comment: RSG updated the MSR accordingly. Comment: 3,014 page 64 [pg. 52, referring to a typo indicating the number of Live Oak housing units will increase to 9,541 in 2029]  Response or Comment: RSG will update the MSR accordingly. Comment: Confirm seems to high? Unemployment rate ~ 9%, sometimes double digits [pg 53 in reference to the 2024 employment level of 97.5%]  Response or Comment: RSG reviewed the data underlying these tables and made one correction to the way the employment rate is calculated. Additionally, RSG’s figures are representative of the employment and unemployment rates for the prime working age group (ages 25 to 64). RSG’s review of the underlying data indicates that the age groups 16-24 and 65+ have higher unemployment rates – 11.0 and 9.2%, respectively. Comment: Currently 2025 – Fire Assessment - $135k, - 2004 CFD – 18% FIRG – 140K; annual; 1996 speical; historic; with no mechanism to adjust for inflation; 305/255 ~ 19.6%; James – why 2019 $1.4 m - is that due to one time fire truck purchase? Something is wrong can’t have an average of $768k with a end FY 23 high of 980k. The average is off and or the 2019 figure [pg. 60]  Response or Comment: RSG updated the MSR accordingly. Comment: strike – without ARPA funding there has not been strong growth [pg 62. Referring to the statement that “while the City has demonstrated strong revenue growth…”] Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 25  Response or Comment: RSG updated the MSR accordingly. Comment: page 51 said 0.5% (pg. 64 referring to the annual population growth rate of 0.4%)  Response or Comment: RSG updated the MSR accordingly. Comment: something wrong see page 60; this # has been flat 1996 special assessment – no inflation; 2004 CFD – nad not been increased 2007-2025. [pg 66]  Response or Comment: RSG’s figures are shown in Figure 18: Cash Flow – Live Oak Fire Department, and the $305,000 total revenue figure includes impact fees, miscellaneous income, interest, and unrealized gains in addition to special assessment and CFD revenues. Regarding the figure on page 60, RSG reviewed and revised the total average annual expenses to $928,000 to align with the figures presented in Figure 18. SERVICE PROVIDER: ROBBINS SUTTER BASIN FIRE PROTECTION DISTRICT (Comments received from Chief Greg Pote via email on September 1, 2025) Comment: The biggest error I see in current draft is that the study refers to Robbins Sutter Basin Fire Station as "Station 45". The correct identifier should be Station 48.  Response or Comment: RSG updated the MSR accordingly. Comment: The current draft LAFCO document states Robbins Sutter Basin is looking to hire a part time Fire Chief. That position is now filled.  Response or Comment: RSG updated the MSR accordingly If there are any questions, comments, or concerns with this memorandum as drafted please do not hesitate to contact Brandon Fender at 714-316-2106 or at bfender@rsgsolutions.com. Attachment 1: LAFCO Commissioner Marc Boomgaarden email (June 24, 2025) Attachment 2: LAFCO Commissioner Marc Boomgaarden email (June 26, 2025) Attachment 3: Yuba City Fire Department email (July 1, 2025) Attachment 4: Kingsley Bogard Attorneys at Law letter (July 7, 2025) Attachment 5: Sutter County Administrator Steve Smith Attachment received via email (July 7, 2025) Attachment 6: Jane Vandenhoff email (July 10, 2025) Attachment 7: Marty Vinson email (July 10, 2025) Attachment 8: City of Live Oak comments (August 7, 2025) Attachment 9: City of Live Oak comments (August 26, 2025) Attachment 10: Robbins Sutter Basin Fire Protection District (September 1, 2025) Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 26 Attachment 1 : LAFCO Commissioner Marc Boomgaarden email (June 24, 2025) Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 27 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 28 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 29 Attachment 2: LAFCO Commissioner Marc Boomgaarden email (June 26, 2025) Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 30 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 31 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 32 Attachment 3: Yuba City Fire Department email (July 1, 2025) Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 33 Attachment 4: Kingsley Bogard Attorneys at Law letter (July 7, 2025) Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 34 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 35 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 36 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 37 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 38 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 39 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 40 Attachment 5: Sutter County Administrator Steve Smith Attachment (July 7, 2025) Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 41 Attachment 6: Jane Vandenhoff email (July 10, 2025) Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 42 Attachment 7: Marty Vinson email (July 10, 2025) Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 43 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 44 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 45 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 46 Attachment 8: City of Live Oak comments (August 7, 2025). Note: additional comments were provided by the City of Live Oak in a PDF copy of the MSR, which are not pictured in this Attachment. Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 47 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 48 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 49 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 50 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 51 Attachment 9: City of Live Oak comments (August 26, 2025) Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 52 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 53 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 54 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 55 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 56 Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 57 Attachment 10: Robbins Sutter Basin Fire Protection District (September 1, 2025) Doug Libby, Executive Officer SUTTER LOCAL AGENCY FORMATION COMMISSION Page 58