LAFCO
"Final Countywide Fire MSR/SOI Update. Adopted 9.11.25"
Read the report at Local Agency Formation Commissions ↗
Sutter Local Agency Formation Commission
1201 Civic Cente r Blvd.
Yuba City, CA 95993
Municipal Service Review and
Sphere of Influence Update
Fire Protection & Emergency Medical Service Providers
Sutter County
Final
Adopted on September 11, 2025
Resolution No. 2025-07
Sutter LAFCO
MSR and SOI Update | Countywide Fire Protection and EMS
September 11, 2025 Final
TABLE OF CONTENTS
ACKNOWLEDGEMENTS ......................................................................................................... X
EXECUTIVE SUMMARY .......................................................................................................... 1
Key Premises, Assumptions, and Benchmarks ..............................................................................1
Summary of Recommendations ....................................................................................................3
City of Live Oak Fire Department .......................................................................................... 3
City of Yuba City Fire Department ........................................................................................ 3
County Service Area C ........................................................................................................... 4
County Service Area D ........................................................................................................... 4
County Service Area F ............................................................................................................ 5
County Service Area G ........................................................................................................... 5
Meridian Fire Protection District ............................................................................................. 6
Robbins Sutter Fire Protection District .................................................................................... 6
Other Recommendations ....................................................................................................... 7
Summary of Determinations ...........................................................................................................9
Service Provision Determinations ........................................................................................... 9
Sphere of Influence Determinations ................................................................................... 15
LOCAL AGENCY FORMATION COMMISSIONS ................................................................... 18
Legal Requirements and Purpose .............................................................................................. 18
LAFCO Responsibilities .................................................................................................................. 18
Sutter County LAFCO Commission ...................................................................................... 19
Sphere of Influence ...................................................................................................................... 20
Disadvantaged Unincorporated Communities................................................................. 21
Sphere of Influence Updates and LAFCO Policy .............................................................. 23
Municipal Service Review (MSR) Requirements ....................................................................... 24
SUTTER COUNTY AND LOCAL FIRE & EMS RESPONSE .......................................................... 26
Emergency Medical Services .............................................................................................. 27
Public Safety Answering Point Systems ............................................................................... 33
PURPOSE OF THIS MSR AND SCOPE OF WORK .................................................................... 35
Methodology .......................................................................................................................... 35
AGENCY SERVICE REVIEWS ................................................................................................ 47
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Sutter LAFCO
MSR and SOI Update | Countywide Fire Protection and EMS
September 11, 2025 Final
CITY OF LIVE OAK FIRE DEPARTMENT ................................................................................. 49
Jurisdictional Boundary & Sphere of Influence ......................................................................... 49
Demographics ............................................................................................................................... 51
Age Distribution & Income ................................................................................................... 52
Governance and Staffing............................................................................................................ 54
Municipal Services ........................................................................................................................ 56
Service Demands and Capacity......................................................................................... 57
Service Performance ............................................................................................................. 59
Fiscal Health ................................................................................................................................... 59
Revenues & Expenditures ..................................................................................................... 60
SOI/Boundary & Other Recommendations – City of Live Oak Fire Department ................. 62
MSR & SOI Determinations – City of Live Oak Fire Department.............................................. 64
Service Provision Determinations ......................................................................................... 64
Sphere of Influence Determinations ................................................................................... 69
CITY OF YUBA CITY FIRE DEPARTMENT................................................................................ 71
Jurisdictional Boundary & Sphere of Influence ......................................................................... 71
Bogue Stewart Master Plan .................................................................................................. 71
Demographics ............................................................................................................................... 74
Population & Housing ............................................................................................................ 74
Age Distribution & Income ................................................................................................... 76
Governance and Staffing .................................................................................................... 78
Municipal Services ................................................................................................................. 80
Service Demands and Capacity......................................................................................... 84
Service Performance ............................................................................................................. 85
Fiscal Health ................................................................................................................................... 90
Revenues & Expenditures ..................................................................................................... 90
SOI/Boundary & Other Recommendations – City of Yuba City Fire Department ............... 93
MSR & SOI Determinations – City of Yuba City Fire Department............................................ 95
Service Provision Determinations ......................................................................................... 96
Sphere of Influence Determinations ................................................................................. 101
COUNTY SERVICE AREA C ................................................................................................ 103
Jurisdictional Boundary & Sphere of Influence ....................................................................... 103
Demographics ............................................................................................................................. 105
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Sutter LAFCO
MSR and SOI Update | Countywide Fire Protection and EMS
September 11, 2025 Final
Population & Housing .......................................................................................................... 105
Age Distribution & Income ................................................................................................. 107
Governance and Staffing .................................................................................................. 109
Municipal Services ............................................................................................................... 111
Service Demands and Capacity....................................................................................... 113
Service Performance ........................................................................................................... 114
Fiscal Health ................................................................................................................................. 115
Revenues & Expenditures ................................................................................................... 115
SOI/Boundary & Related Recommendations – County Service Area C ............................ 118
MSR & SOI Determinations – County Service Area C ............................................................. 120
Service Provision Determinations ....................................................................................... 120
Sphere of Influence Determinations ................................................................................. 124
COUNTY SERVICE AREA D ................................................................................................ 126
Jurisdictional Boundary & Sphere of Influence ....................................................................... 126
Sutter Pointe.......................................................................................................................... 128
Demographics ............................................................................................................................. 132
Population & Housing .......................................................................................................... 132
Age Distribution & Income ................................................................................................. 134
Governance and Staffing .................................................................................................. 136
Municipal Services ............................................................................................................... 138
Service Demands and Capacity....................................................................................... 140
Service Performance ........................................................................................................... 140
Fiscal Health ................................................................................................................................. 141
Revenues & Expenditures ................................................................................................... 141
SOI & Related Recommendations – County Service Area D ............................................... 143
MSR & SOI Determinations – County Service Area D ............................................................. 146
Service Provision Determinations ....................................................................................... 146
Sphere of Influence Determinations ................................................................................. 151
COUNTY SERVICE AREA F ................................................................................................. 153
Jurisdictional Boundary & Sphere of Influence ....................................................................... 153
Demographics ............................................................................................................................. 155
Population & Housing .......................................................................................................... 155
Age Distribution & Income ................................................................................................. 157
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Sutter LAFCO
MSR and SOI Update | Countywide Fire Protection and EMS
September 11, 2025 Final
Governance and Staffing .................................................................................................. 159
Municipal Services ............................................................................................................... 161
Service Demands and Capacity....................................................................................... 163
Service Performance ........................................................................................................... 164
Fiscal Health ................................................................................................................................. 165
Revenues & Expenditures ................................................................................................... 165
SOI/Boundary & Other Recommendations – County Service Area F ................................. 168
MSR Determinations – County Service Area F ........................................................................ 171
Service Provision Determinations ....................................................................................... 171
Sphere of Influence Determinations ................................................................................. 175
COUNTY SERVICE AREA G ................................................................................................ 177
Jurisdictional Boundary & Sphere of Influence ....................................................................... 177
Bogue Stewart Master Plan ................................................................................................ 177
Demographics ............................................................................................................................. 180
Population & Housing .......................................................................................................... 180
Age Distribution & Income ................................................................................................. 181
Governance and Staffing .................................................................................................. 183
Municipal Services ............................................................................................................... 184
Service Demands and Capacity....................................................................................... 185
Service Performance ........................................................................................................... 185
Fiscal Health ................................................................................................................................. 185
Revenues & Expenditures ................................................................................................... 185
SOI/Boundary & Other Recommendations – County Service Area G ................................ 188
MSR Determinations – County Service Area G ....................................................................... 190
Service Provision Determinations ....................................................................................... 190
Sphere of Influence Determinations ................................................................................. 194
MERIDIAN FIRE PROTECTION DISTRICT .............................................................................. 196
Jurisdictional Boundary & Sphere of Influence ....................................................................... 196
Demographics ............................................................................................................................. 198
Population & Housing .......................................................................................................... 198
Age Distribution & Income ................................................................................................. 200
Governance and Staffing .................................................................................................. 202
Municipal Services ............................................................................................................... 203
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Sutter LAFCO
MSR and SOI Update | Countywide Fire Protection and EMS
September 11, 2025 Final
Service Demands and Capacity....................................................................................... 205
Service Performance ........................................................................................................... 206
Fiscal Health ................................................................................................................................. 207
Revenues & Expenditures ................................................................................................... 207
SOI/Boundary & Other Recommendations – Meridian Fire Protection Fire Department . 209
MSR & SOI Determinations – Meridian Fire Protection District ............................................... 212
Service Provision Determinations ....................................................................................... 212
Sphere of Influence Determinations ................................................................................. 216
ROBBINS SUTTER BASIN FIRE PROTECTION DISTRICT ......................................................... 218
Jurisdictional Boundary & Sphere of Influence ....................................................................... 218
Demographics ............................................................................................................................. 220
Population & Housing .......................................................................................................... 220
Age Distribution & Income ................................................................................................. 222
Governance and Staffing .................................................................................................. 224
Municipal Services ............................................................................................................... 225
Service Demands and Capacity....................................................................................... 227
Service Performance ........................................................................................................... 228
Fiscal Health ................................................................................................................................. 229
Revenues & Expenditures ................................................................................................... 229
SOI/Boundary & Other Recommendations – Meridian Fire Protection Fire Department . 232
MSR & SOI Determinations – Meridian Fire Protection District ............................................... 235
Service Provision Determinations ....................................................................................... 235
Sphere of Influence Determinations ................................................................................. 239
APPENDIX 1 – PUBLIC COMMENTS RECEIVED ................................................................... 241
APPENDIX 2 – SUTTER LAFCO RESOLUTION NO. 2025-07 .................................................. 300
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Sutter LAFCO
MSR and SOI Update | Countywide Fire Protection and EMS
September 11, 2025 Final
TABLE OF FIGURES
Figure 1: Regional DUC Map................................................................................................................. 22
Figure 2: Recent Sutter County Fires by Acreage .............................................................................. 26
Figure 3: EMS Response Time Standards in Sutter County ................................................................ 30
Figure 4: Bi-County Ambulance Responses in Yuba City .................................................................. 31
Figure 5: Bi-County Ambulance Responses in Sutter Rural ............................................................... 32
Figure 6: Engine Typing Standards ....................................................................................................... 42
Figure 7: NFPA 1710 Response Time Standards .................................................................................. 44
Figure 8: NFPA 1720 Staffing and Response Time............................................................................... 45
Figure 9: Regional Map .......................................................................................................................... 48
Figure 10: Live Oak’s Jurisdictional Boundary and SOI Map ............................................................ 50
Figure 11: Live Oak’s Resident Population .......................................................................................... 51
Figure 12: Live Oak’s Housing Characteristics .................................................................................... 52
Figure 13: Live Oak’s Age Distribution .................................................................................................. 53
Figure 14: Live Oak’s Income Characteristics ..................................................................................... 54
Figure 15: Live Oak’s Fire Department Historical Staff ....................................................................... 55
Figure 16: Live Oak’s Fire Station(s) Assignments as FY 2023............................................................. 57
Figure 17: Live Oak’s Service Demands between FY 2020 and FY 2023 ......................................... 58
Figure 18: Cash Flow – Live Oak Fire Department.............................................................................. 61
Figure 19: Yuba City Jurisdictional Boundary and SOI Map ............................................................. 73
Figure 20: Yuba City’s Resident Population ........................................................................................ 75
Figure 21: Yuba City’s Housing Characteristics .................................................................................. 76
Figure 22: Yuba City’s Age Distribution ................................................................................................ 77
Figure 23: Yuba City’s Income Characteristics ................................................................................... 78
Figure 24: Yuba City Fire Department Historical Staffing .................................................................. 79
Figure 25: Yuba City’s Fire Station(s) Assignments as FY 2023........................................................... 84
Figure 26: Yuba City’s Service Demands between FY 2019 and FY 2023 ....................................... 85
Figure 27: Yuba City Fire Department Average Response Times (2023) ......................................... 86
Figure 28: Cash Flow – Yuba City Fire Department ............................................................................ 91
Figure 29: Tax Allocations – Yuba City Fire Department ................................................................... 92
Figure 30: CSA C Jurisdictional Boundary and SOI Map ................................................................. 104
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Sutter LAFCO
MSR and SOI Update | Countywide Fire Protection and EMS
September 11, 2025 Final
Figure 31: CSA C’s Resident Population ............................................................................................ 106
Figure 32: CSA C’s Housing Characteristics ...................................................................................... 107
Figure 33: CSA C’s Age Distribution .................................................................................................... 108
Figure 34: CSA C’S Income Characteristics ...................................................................................... 109
Figure 35: CSA C’s Historical Budgeted Staffing............................................................................... 110
Figure 36: CSA C’s Fire Station(s) Assignments as FY 2023 ............................................................. 113
Figure 37: CSA C and CSA D’s Service Demands between FY 2022 and FY 2023 ...................... 114
Figure 38: Cash Flow – CSA C ............................................................................................................. 116
Figure 39: CSA D Jurisdictional Boundary and SOI Map ................................................................. 127
Figure 40: Sutter Pointe Specific Plan Area ....................................................................................... 129
Figure 41: CSA D’s Resident Population ............................................................................................ 133
Figure 42: CSA D’s Housing Characteristics ...................................................................................... 134
Figure 43: CSA D’s Age Distribution .................................................................................................... 135
Figure 44: Income Characteristics ...................................................................................................... 136
Figure 45: CSA D’s Historical Budgeted Staff .................................................................................... 137
Figure 46: CSA D’s Fire Station(s) Assignments .................................................................................. 139
Figure 47: Cash Flow – CSA D ............................................................................................................. 142
Figure 48: CSA F Jurisdictional Boundary and SOI Map .................................................................. 154
Figure 49: CSA F’s Resident Population ............................................................................................. 156
Figure 50: CSA F’s Housing Characteristics ....................................................................................... 157
Figure 51: CSA F’s Age Distribution ..................................................................................................... 158
Figure 52: CSA F’s Income Characteristics ........................................................................................ 159
Figure 53: CSA F’s Historical Budgeted Staff ..................................................................................... 160
Figure 54: CSA F’s Fire Station(s) Assignments as FY 2023 ................................................................ 163
Figure 55: CSA F’s Service Demands between FY 2020 and FY 2023 ............................................ 164
Figure 56: CSA F’s Average Response Times as of FY 2023 ............................................................. 165
Figure 57: Cash Flow – CSA F .............................................................................................................. 167
Figure 58: CSA G Jurisdictional Boundary and SOI Map ................................................................. 179
Figure 59: CSA G’s Resident Population ............................................................................................ 180
Figure 60: CSA G’s Housing Characteristics ...................................................................................... 181
Figure 61: CSA G’s Age Distribution ................................................................................................... 182
Figure 62: CSA G’s Income Characteristics ...................................................................................... 183
Figure 63: Cash Flow – CSA G ............................................................................................................. 187
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Sutter LAFCO
MSR and SOI Update | Countywide Fire Protection and EMS
September 11, 2025 Final
Figure 64: Meridian FPD Jurisdictional Boundary and SOI Map ..................................................... 197
Figure 65: Resident Population ........................................................................................................... 199
Figure 66: Housing Characteristics ..................................................................................................... 200
Figure 67: Meridian FPD’s Age Distribution ........................................................................................ 201
Figure 68: Income Characteristics ...................................................................................................... 202
Figure 69: Meridian’s FPD’s Budgeted Staff ...................................................................................... 203
Figure 70: Meridian FPD’s Fire Station(s) Assignments as FY 2023 ................................................... 205
Figure 71: Meridian FPD’s Service Demands for FY 2023 ................................................................. 206
Figure 72: Cash Flow – Meridian FPD ................................................................................................. 208
Figure 73: Sutter Basin FPD Jurisdictional Boundary and SOI Map ................................................. 219
Figure 74: Resident Population ........................................................................................................... 221
Figure 75: Housing Characteristics ..................................................................................................... 222
Figure 76: Age Distribution ................................................................................................................... 223
Figure 77: Income Characteristics ...................................................................................................... 224
Figure 78: Robbins Sutter Basin FPD’s Budgeted Staff ..................................................................... 225
Figure 79: Robbins Sutter Basin FPD’s Fire Station(s) Assignments as FY 2023 ............................... 227
Figure 80: Robbins Sutter Basin FPD Demands in FY 2023 ................................................................ 228
Figure 81: Cash Flow – Sutter Basin FPD ............................................................................................. 231
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Sutter LAFCO
MSR and SOI Update | Countywide Fire Protection and EMS
September 11, 2025 Final
LIST OF ABBREVIATIONS USED
ALS Advanced Life Support
BCA Bi-County Ambulance
BLS Basic Life Support
CAL FIRE California Department of Forestry and Fire Protection
CFD Community Financing District
CKH Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000
CSA County Service Area
DUC Disadvantaged Unincorporated Community
EMS Emergency Medical Service
EMT Emergency Medical Technician
FRA Federal Responsibility Area
ICS Incident Command System
ISO Insurance Services Office
JPA Joint Powers Authority
LAFCO Local Agency Formation Commission
LEMSA Local Emergency Medical Services Agency
MSR Municipal Service Review
NFPA National Fire Protection Association
PSAP Public Safety Answering Point
SAFER Staffing for Adequate Fire and Emergency Response
SCO State Controller’s Office
SOI Sphere of Influence
SORC Standard of Response Coverage
SRA State Responsibility Area
ZIB Zone of Increased Benefit
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Sutter LAFCO
MSR and SOI Update | Countywide Fire Protection and EMS
September 11, 2025 Final
ACKNOWLEDGEMENTS
RSG Inc., Planwest Partners and Sutter County Local Agency Formation Commission
(“LAFCO”) gratefully acknowledges the time and effort of officials and staff with the
affected local fire and emergency medical agencies in assisting in the preparation of this
report. This includes – but is not limited to – the following individuals:
Peter H. Daley III, Consultant Specialist
Richard Epperson, Sutter County Interim Fire Chief
Carlos Del Rio, Sutter County Fire Battalion Chief
Marty Vinson, CSA C and CSA D Volunteer Fire Chief
Jesse Alexander, Yuba City Fire Chief
Marty Creel, Former Sutter Basin FPD Fire Chief
Matt Lichenstein, Sutter Basin FPD Assistant Fire Chief
Jason Cooper, Meridian FPD Fire Chief
Alex Bumpus, Bi-County Ambulance President/CEO
John Poland, S-SV EMS Regional Executive Director
Patrick Comstock, S-SV EMS Deputy Director of Operations
Kristy Harlan, S-SV EMS Contracts Compliance Manager
Steve Smith, Sutter County Administrator
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Sutter County Municipal Service Review and Sphere Update
Countywide Fire and EMS
September 11, 2025, Final
EXECUTIVE SUMMARY
The Sutter County Local Agency Formation Commission (“Sutter LAFCO” or “Commission”)
is preparing a Municipal Service Review (“MSR”) and Sphere of Influence (“SOI”) update
for all fire agencies in Sutter County. The report has been prepared by RSG, Inc. (“RSG”)
and Planwest Partners, Inc. (“Planwest”) on behalf of Sutter LAFCO with the scope of work
approved by the Executive Officer and the Commission.
The overall intent with the report is to provide an independent assessment of the eight (8)
affected agencies that provide fire protection and emergency medical services to
residents within Sutter County as required under both statute and LAFCO policy. This
includes evaluating the current and future relationship between the availability and
adequacy of fire protection and emergency medical services within the County.
KEY PREMISES, ASSUMPTIONS, AND BENCHMARKS
It is assumed Sutter County LAFCO will revisit the MSR and key findings on a regular five-
year basis consistent with the timetable set by the Legislature and further memorialized
under adopted LAFCO policy. Doing so will allow the Commission to assess the accuracy
of earlier projections and make appropriate amendments to the approach as needed
for future MSRs and/or studies.
This MSR assesses the service delivery of eight (8) affected agencies: (1) City of Live Oak
Fire Department; (2) City of Yuba City Fire Department; (3) CSA C; (4) CSA D; (5) CSA F;
(6) CSA G; (7) Meridian Fire Protection District; and (8) Robbins Sutter Basin Fire Protection
District.
The period for collecting data to inform the Commission’s analysis and related projections
on population growth, service demands, and finances has been set to cover the five-
year fiscal period from 2019 to 2023. The timeframe for the MSR, specific to projections
(with limited exceptions) has been augmented to cover the next five-year period through
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Sutter County Municipal Service Review and Sphere Update
Countywide Fire and EMS
September 11, 2025, Final
2028 with the previous five years serving as the baseline analysis contemplated under
State law. This timeframe syncs with the five-year cycle prescribed for MSRs and the
expectation therein to inform all related SOI and boundary changes.
The historical, current, and future population figures for residents within the agencies’
jurisdictional boundary is estimated using data generated by ESRI and their mapping
analyses of census tracts. Other demographic data gathered from ESRI involve housing,
employment rates, and household income. Various benchmarks and financial data are
used to assess and make related determinations on each agency’s fiscal health and
performance.
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Sutter County Municipal Service Review and Sphere Update
Countywide Fire and EMS
September 11, 2025, Final
SUMMARY OF RECOMMENDATIONS
At the end of each agency profile, RSG and Planwest Partners describe the various
recommendations pertaining to each fire protection and emergency medical services
providers’ sphere of influence (“SOI”), in addition to any other relevant
recommendations. Key recommendations are highlighted below:
CITY OF LIVE OAK FIRE DEPARTMENT
- Sutter LAFCO should proceed to affirm the City of Live Oak’s sphere of
influence with respect to the delivery of fire protection and emergency
medical services.
- The City of Live Oak may consider the establishment of a permanent funding
source, such as a special assessment or parcel tax to ensure the long-term
operational sustainability of fire and emergency medical services. The City’s
fire-specific revenues have not been sufficient to cover the rising cost of
services associated with its contract with Sutter County Fire.
CITY OF YUBA CITY FIRE DEPARTMENT
- Sutter LAFCO may consider adopting a “Fire/EMS Only” Sphere of Influence
for the CSA G area to formalize and solidify the City of Yuba City’s contract
position to deliver of fire protection and emergency medical services to the
CSA G service area.
- The Yuba City Fire Department may consider establishing a permanent
funding source, such as a special assessment or parcel tax, to maintain its
current staffing levels and avoid potential disruptions to service delivery. This
funding source should also consider costs associated with the new staffing
required for the projected additional apparatus at Station No. 1.
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Sutter County Municipal Service Review and Sphere Update
Countywide Fire and EMS
September 11, 2025, Final
COUNTY SERVICE AREA C
- Sutter LAFCO may proceed to re-affirm CSA C’s sphere of influence with
respect to the delivery of fire protection and emergency medical services.
- Sutter LAFCO may also consider proceeding with the approval of the
consolidation of County Service Areas (“CSA”) C, D, and F upon receipt of
a completed change of organization application due to the comparatively
lower call volume of CSA C and D, in addition to the administrative duties
performed by CSA F. A merger could streamline operations, improve service
efficiency, and optimize resource allocation.
- CSA C currently receives its share of the 1% property tax allocation; however,
CSA C may also consider the establishment of a permanent funding source,
such as a special assessment or parcel tax to ensure the long-term
operational sustainability of fire and emergency medical services.
COUNTY SERVICE AREA D
- Sutter LAFCO may proceed to re-affirm CSA D’s sphere of influence with
respect to the delivery of fire protection and emergency medical services.
- Sutter LAFCO may also consider proceeding with the approval of the
consolidation of County Service Areas (“CSA”) C, D, and F upon receipt of
a completed change of organization application due to the comparatively
lower call volume of CSA C and D, in addition to the administrative duties
performed by CSA F. A merger could streamline operations, improve service
efficiency, and optimize resource allocation.
- Sutter LAFCO may consider proceeding with the approval of the
establishment of a County Service Area (“CSA”) or Zone of Increased Benefit
(“ZIB”) for the Sutter Pointe Specific Plan Area (“Plan area”) upon receipt of
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Sutter County Municipal Service Review and Sphere Update
Countywide Fire and EMS
September 11, 2025, Final
a completed change of organization application to provide a structured
and sustainable funding mechanism for the ongoing delivery of fire
protection and emergency medical services in the Plan area and ensure the
service area receives an enhanced level of service delivery due to its high
population density and planned uses.
- CSA D currently receives its share of the 1% property tax allocation; however,
CSA D may also consider the establishment of a permanent funding source,
such as a special assessment or parcel tax to ensure the long-term
operational sustainability of fire and emergency medical services.
COUNTY SERVICE AREA F
- Sutter LAFCO may proceed to re-affirm the CSA F sphere of influence with
respect to the delivery of fire protection and emergency medical services.
- CSA F may consider increasing its special assessment via a voter-approved
ballot initiative to maintain staffing levels and avoid potential future
disruptions to service delivery.
- Sutter LAFCO may also consider proceeding with the approval of the
consolidation of County Service Areas (“CSA”) C, D, and F upon receipt of
a completed change of organization application due to the comparatively
low call volume of CSA C and D, in addition to the administrative duties
performed by CSA F. A merger could streamline operations, improve service
efficiency, and optimize resource allocation.
COUNTY SERVICE AREA G
- Sutter LAFCO may proceed to affirm CSA G’s sphere of influence with
respect to the delivery of fire protection and emergency medical services.
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Sutter County Municipal Service Review and Sphere Update
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September 11, 2025, Final
- Sutter County could consider establishing a County Service Area Zone of
Increased Benefit (“ZIB”) for the CSA G service area. A ZIB can provide a
structured and sustainable funding mechanism for the ongoing delivery of
fire protection and emergency medical services and ensure the service area
receives an enhanced level of service delivery due to its comparatively
higher population density.
- CSA G currently receives its share of the 1% property tax allocation; however,
CSA G may consider the establishment of a permanent funding source, such
as a special assessment or parcel tax to cover the entire cost of contracted
fire and emergency medical services with the Yuba City Fire Department.
MERIDIAN FIRE PROTECTION DISTRICT
- Sutter LAFCO may proceed to re-affirm the Meridian Fire Protection District’s
sphere of influence with respect to the delivery of fire protection and
emergency medical services.
- Sutter LAFCO may consider future consolidation of the Meridian Fire
Protection District with Sutter County Fire due to the District’s difficulty
maintaining duty officer coverage, recruiting and retaining volunteers, and
its comparatively low call volume.
- The Meridian FPD may consider the establishment of a permanent funding
source, such as a special assessment or parcel tax to ensure the long-term
operational sustainability of fire and emergency medical services.
ROBBINS SUTTER FIRE PROTECTION DISTRICT
- Sutter LAFCO may proceed to re-affirm the Robbins Sutter Basin Fire
Protection District’s sphere of influence with respect to the delivery of fire
protection and emergency medical services.
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Sutter County Municipal Service Review and Sphere Update
Countywide Fire and EMS
September 11, 2025, Final
- The District may consider the establishment a permanent funding source,
such as a special assessment or parcel tax, to ensure the long-term
operational sustainability of fire and emergency medical services.
- Sutter LAFCO may consider future consolidation of the Robbins Sutter Basin
Fire Protection District’s with Sutter County Fire due to the District’s difficulty
recruiting and retaining volunteers, in addition to its comparatively low call
volume.
OTHER RECOMMENDATIONS
- The County’s exclusive ambulance transport service provider, Bi-County
Ambulance (“BCA”), has been in compliance with its response time
standards for both the Yuba City and Sutter Rural responses zones for every
year out of the five years reviewed. However, it may be beneficial for Sutter
County, through its participation in the Sierra-Sacramento Valley EMS
Agency, to initiate a competitive bid process for the ambulance transport
provider agreement at the conclusion of BCA’s existing contract on
December 31, 2026. A competitive bid process can promote greater
transparency and facilitate opportunities for enhanced cost efficiencies and
service capabilities, in addition to allowing for an opportunity to assess
alternative service providers. It could also help solidify that the current
service provider remains the most effective option or could help identify
areas for improvement.
- It is encouraged that the four Public Safety Answering Point Systems
(“PSAPs”) in Sutter and Yuba County continue to collaborate and work
toward the consolidation of the four dispatch centers into the Yuba County
Sheriff’s facility, as recommended in Federal Engineering Inc.’s 2023
Consolidation Study Report, to enhance service efficiency, improve cost
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Sutter County Municipal Service Review and Sphere Update
Countywide Fire and EMS
September 11, 2025, Final
effectiveness, and alleviate potential challenges related to staff recruitment
and retention.
- While this report recommends that Sutter LAFCO consider the near-term
consolidation of County Service Areas (“CSA”) C, D, and F, in addition to
considering future consolidation of the Meridian and Robbins Sutter Basin Fire
Protection District with Sutter County Fire, it is also recommended that a
broader, countywide consolidation of all fire protection service providers in
the County be explored in the long term.
To inform countywide consolidation, it is recommended that all fire
protection service providers within the County participate in a
comprehensive Standards of Response Coverage (“SORC”) study. This
analysis should evaluate response times, station locations and coverage,
staffing, wages, benefits including pensions, and a forecast of past, current,
and future service delivery needs. Importantly, the study should also assess
the financial feasibility of a consolidated fire protection system.
Countywide consolidation may offer several long-term benefits to fire
protection services in Sutter County, including enhanced operational
efficiency, improved coordination of resources, elimination of service
redundancies, and more equitable delivery of fire protection services across
service areas. Given the fiscal and staffing constraints faced by many of its
existing service providers, consolidation may serve as a strategic pathway to
strengthen service reliability, ensure consistent standards of training and
equipment, and improve long-term fiscal sustainability.
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Sutter County Municipal Service Review and Sphere Update
Countywide Fire and EMS
September 11, 2025, Final
SUMMARY OF DETERMINATIONS
Sutter LAFCO’s pertinent determinations, as required by Government Code Section 56425
and 56430, for each fire protection and emergency medical services provider can be
found at the end of each agency profile. Key determinations can be found below:
SERVICE PROVISION DETERMINATIONS
1. Growth and Population Projections
There are approximately 99,626 residents in Sutter County as of 2024. The County’s
resident population is forecasted to reach 99,795 residents by 2029. This accounts
for an annual growth rate of approximately 0.03%. County Service Area C is
expected to have the lowest annual population growth rate from 2024 to 2029 with
an annual decrease of (0.3%), reducing the population from 1,443 residents in 2024
to 1,425 residents in 2029. The City of Live Oak is expected to experience the highest
annual population growth rate from 2024 to 2029 with an annual increase of 0.4%,
increasing the population from 9,354 residents in 2024 to 9,541 residents in 2029.The
Sutter Pointe Specific Plan will add 17,500 residential units and a population of
approximately 47,00 residents over the next 30 years. The Bogue Stewart Master
Plan will add 2,500 residential units and approximately 6,720 residents over the next
20 years.
2. Location and Characteristics of Disadvantaged Unincorporated Communities within or
Contiguous to SOI
According to Sutter LAFCO’s policies, there are six (6) disadvantaged
unincorporated communities (“DUCs”), including four (4) severely disadvantaged
unincorporated communities, located in Sutter County. County Service Area F, the
Yuba City Fire Department, and the Sutter Basin Fire Protection District are the
primary fire protection and emergency medical services providers to these DUCs.
A map showing the location of these DUCs can be found in Figure 1.
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3. Present and Planned Capacity of Facilities, Adequacy of Public Services, and
Infrastructure Needs and Deficiencies in any Disadvantaged Unincorporated
Communities within or Contiguous to SOI
Nearly all of the fire protection and emergency medical service providers have the
adequate capacity, infrastructure and availability to continue to provide fire
protection and emergency medical services to their residents now and into the
foreseeable future. Additional key details are noted below:
- While County Service Area (“CSA”) D has adequate capacity to deliver fire
protection and emergency medical services to existing residents with its
boundary, its service area will be heavily impacted by the sharp increase in
resident population in the Sutter Pointe Specific Plan area.
- The initial phase of the Sutter Pointe Specific Plan area will require the
construction of a temporary fire facility until permanent fire facilities are
constructed, which will be vital for the Plan area due to its distance from
other capable fire protection resources.
- The Yuba City Fire Department indicated that the Department’s Station No.
1 is in poor condition and the station does not have the current capacity to
accommodate existing call volume due to limited space for fire personnel in
living quarters, in addition to inadequate space for the Department’s
modern apparatus and equipment. According to Department staff, Station
No. 1 will need to acquire an additional apparatus with appropriate staffing
in the near future in order to address the anticipated increase in service
demand levels out of the station.
- CSA F staff noted that while the Oswald Tudor Station No. 8—located near
the southeast perimeter of CSA F at 1280 Barry Road—is functional, the CSA
would benefit from moving this station approximately six (6) miles south
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towards the southern perimeter of the CSA’s jurisdictional boundary.
Proposed relocation of Oswald Tudor Station No. 8 should be evaluated,
such as through a Standards of Response Coverage (SORC) study and
discussed with the Yuba City Fire Department to determine the benefits and
challenges of service delivery to both agencies.
- The Meridian Fire Protection District’s Station No. 65 is in good condition but
is undersized for the District’s needs according to District staff. The District
noted that it would be difficult to accommodate future facility
improvements because the station is located in a designated floodplain.
- The Robbins Station No. 48 is in fair condition. However, the station is not
large enough to accommodate all of the District’s apparatus equipment.
One (1) of the District’s apparatus must be stored at the District’s auxiliary
building, while the District’s water tender is stored at the John Deere
dealership approximately a quarter mile from Robbins Station No. 48.
4. Financial Ability to Provide Services
Most of the fire protection and emergency medical service providers reviewed
have the financial ability to provide fire and emergency medical services to
existing residents. However, it is unclear whether the majority of these service
providers will have the financial capacity to continue providing these services at
existing service levels in the future. It is recommended that all of the service
providers reviewed in this report consider the establishment of a permanent
funding source, such as a special assessment or parcel tax, in order to fiscally
sustain the future delivery of fire protection and emergency medical services.
Additional key details are noted below:
- The City of Live Oak recently renewed its contract with Sutter County Fire for
a five-year term beginning January 1, 2024, which included an increase to
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total contract costs. The City of Live Oak is exploring the establishment of a
permanent funding source, such as a parcel tax, in order to fiscally sustain
the City’s fire protection and emergency medical services through its existing
contract with Sutter County Fire.
- Yuba City Fire Department staff indicated that there is an approximate
$400,000 annual cost deficit for the Department’s existing contract with
County Fire to provide fire protection and emergency medical services to
CSA G.
- The Yuba City Fire Department is currently relying on its 2021 Staffing for
Adequate Fire and Emergency Response (SAFER) Grant to maintain existing
staffing levels. The Department may face budgeting challenges within the
next two (2) years to maintain these staffing levels according to Department
staff.
- CSA F is the only CSA in the County Fire system with a special fire tax. The tax
has not had a cost-of-living adjustment since its adoption. Cost of living
adjustments, or annual inflation rates, are common best practices when
adopting special taxes.
- CSA F staff indicated that the Department did not receive a recent award
for the Staffing for Adequate Fire and Emergency Response (SAFER) Grant.
As a result, the Department will have to review staff capacity, and determine
if current staffing levels can be maintained, or if a reduction in staffing is
necessary.
- CSA F has increasingly relied on County General Fund dollars to supplement
its annual budget as a result of Sutter County providing equity adjustments
and one-time lump sum payments to CSA staff beginning in FY 2022. In FY
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2023, CSA F received approximately $799,300 from the County’s General
Fund.
- Based on the two fiscal years of data available (FY 2022 and FY 2023), CSA
G has maintained little or no financial surplus, demonstrating limited flexibility
to absorb unanticipated costs or economic fluctuations.
- While the Meridian Fire Protection maintained a surplus in two of the five
years reviewed, the District’s recurring deficits indicate potential financial
instability, emphasizing the need for strategic fiscal management to ensure
long-term sustainability.
- The Robbins Sutter Basin Fire Protection District’s expenses have risen at an
unsustainable pace between the two fiscal years reviewed (FY 2022 and FY
2023).
- With the unknown cost increases of service delivery, including but not limited
to insurance, fuel, apparatus and equipment costs, and personnel salary,
benefits and retirement that may outpace revenues, all agencies may face
fiscal challenges with sustaining the future delivery of fire protection and
emergency medical services.
5. Opportunities for Shared Facilities
Several existing and potential opportunities for shared facilities were identified as
part of this MSR, including the following:
- The City of Live Oak contracts with Sutter County Fire to provide fire
protection and emergency medical services to residents within city limits.
Sutter County Fire utilizes the City of Live Oak’s Station No. 5 and City-owned
apparatus to provide these services to the City of Live Oak.
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- The City of Yuba City is the contracted fire protection and emergency
medical service provider to CSA G.
- County Service Area C shares one (1) volunteer Fire Chief and one (1)
volunteer Assistant Chief with County Service Area D.
- CSA F manages and oversees the day-to-day administrative duties for CSA
C and CSA D finances.
- There is an opportunity for consolidation between CSA C, CSA D, and CSA F
given the low call volume and the existing administrative role of CSA F for
both CSA C and CSA D. Concurrent with consolidation efforts, the County
would need to address the special fire tax in CSA F.
- Given the Meridian Fire Protection District’s and Robbins Sutter Basin Fire
Protection District’s difficulty recruiting and retaining volunteers, in addition
to the Districts’ low call volume, there may be opportunity for future
consolidation between Sutter County Fire and the Districts.
6. Accountability for Community Service Needs, including Governmental Structure and
Operational Efficiencies
All fire protection and emergency medical service providers hold regular and
accessible meetings. Some of the fire protection and emergency medical service
providers release comprehensive public information including audits and budgets.
Additional determinations regarding accountability for community service needs
can be found below:
- Meridian FPD’s financial audits were difficult to obtain because the District
only keeps hard copies of audits on file. The District should ensure it maintains
digital copies of its financial audits, in addition to hard copies.
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- Robbins Sutter Basin FPD’s financial audits were difficult to obtain. While the
District is not required to complete an annual audit pursuant to Government
Code Section 26909(b), the County Auditor-Controller’s office was unable to
provide the County’s policy on this requirement upon request.
7. Any Other Matter Related to Effective or Efficient Service Delivery as Required by
Commission Policy
Other matters related to effective or efficient service delivery as required by LAFCO
policy were not identified.
SPHERE OF INFLUENCE DETERMINATIONS
1. Present and Planned Land Uses
- Approximately 87% of land in Sutter County is dedicated to agricultural uses, with
the remaining land allocated to open space and residential uses at 12% and 1%,
respectively. Public, commercial, industrial, transportation, and vacant land uses
each account for less than 1% of land uses in the County.
- The Bogue Stewart Master Plan area will result in over 2,500 residential units, almost
1.2 million square feet of non-residential space, and 84 acres of parks, open space,
and public facilities. At build-out, the Plan area will result in an additional 6,720
residents and 1,894 employees.
- The Sutter Pointe Specific Plan is a master-planned, mixed-use community that will
support approximately 17,500 dwelling units and approximately 50 million square
feet in employment uses. The Plan area will also add 47,000 residents and provide
jobs for approximately 63,000 employees at build out. The first phase of
development is expected to begin in the fall of 2025.
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2. Present and Probable Need for Public Facilities and Services
The majority of fire protection and emergency medical service providers’ spheres
of influence define the agencies’ current boundary and service area for fire
protection and emergency medical services. Additionally, most public facilities are
adequate to meet the current level of fire and emergency medical services now
and into the foreseeable future. Additional considerations are provided below:
- Yuba City Fire Department staff indicated Station No. 1 will need to acquire
an additional apparatus in the near future in order to address the
anticipated increase in service demand levels out of the station.
- At present, CSA G’s jurisdictional boundary follows a roughly square shape
bound by Eager Road to north, North Township Road to the west, the Feather
River to the east, and Reed Road to the south, which may not accurately
reflect actual population densities and service demands.
- It is unlikely CSA D will have the necessary capacity to provide fire protection
and emergency medical services for the rapidly increasing service demand
that will result from the Sutter Pointe Specific Plan area.
3. Present Capacity and Adequacy of Public Facilities
With the exceptions noted in this report, all of the fire protection and emergency
medical service providers have sufficient capacity and adequate infrastructure
and related facilities to continue to provide fire protection and emergency
medical services to its residents now and in the future.
4. Presence of Social or Economic Communities of Interest
No social or economic communities of interest were identified as part of this MSR.
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5. Present and Probable Need for Public Services of any Disadvantaged Unincorporated
Communities (“DUCs”)
According to Sutter LAFCO’s policies, there are six (6) disadvantaged
unincorporated communities (“DUCs”), including four (4) severely disadvantaged
unincorporated communities, located in Sutter County. At present, the fire
protection and emergency medical service providers evaluated in this report have
sufficient capacity and adequate infrastructure to continue to provide fire
protection and emergency medical services to these areas.
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LOCAL AGENCY FORMATION COMMISSIONS
LEGAL REQUIREMENTS AND PURPOSE
The Cortese-Knox-Hertzberg Local Government
Reorganization Act of 2000, Government Code Section 56430
et. seq., (“CKH”) requires LAFCOs to regularly prepare reviews
of services provided by most local agencies and provides
discretion on the manner in which a commission undertakes
these reviews. The reviews are instrumental in making
determinations on jurisdictional and sphere of influence
boundaries, as well as informing commissions, affected
agencies, and the general public of opportunities for
improving service delivery.
LAFCO RESPONSIBILITIES
CKH directs LAFCOs to discourage urban sprawl, encourage the orderly formation and
development of cities and special districts, and to preserve agricultural land. LAFCOs act
as the county-wide oversight agency that is responsible for considering logical and timely
changes in local governmental boundaries, including annexations and detachments of
territory, incorporations of cities, formations of special districts, and consolidations,
mergers, and dissolutions of districts. In this manner, LAFCOs play an important role in
assuring the thoughtful, appropriate, and efficient reorganization, simplification, and
streamlining of quality local governmental services.
As part of these objectives, LAFCOs establish and periodically review spheres of influence
for local agencies through a process known as a municipal service review (“MSR”) and
sphere of influence (“SOI”) update.
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SUTTER COUNTY LAFCO COMMISSION
Sutter LAFCO is governed by a 12-member “Commission” comprised of county, city,
special district, and public members. The Commission is divided between seven regular
or voting members and four alternates. All Commissioners are elected officials with the
exception of two public members. Sutter LAFCO Commissions holds regular meetings on
the second Thursday of every other month at the City Council Chambers at 1201 Civic
Center Blvd., in Yuba City. LAFCO Commission meetings begin at 2 pm. Recordings of
meetings are available online at https://www.sutterlafco.org/meeting-recordings.
The Sutter County LAFCO Commission roster as of August 2025 is as follows:
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SPHERE OF INFLUENCE
Since 1971, LAFCOs in California have been responsible for determining and overseeing
the sphere of influence (“SOI”) for local government agencies. A SOI is defined as “a plan
for probable physical boundaries and service area of a local agency, as determined by
the Commission.” Consistent with Commission SOI policies, an SOI can be (a) coterminous
to agency boundaries as the ultimate foreseen configuration of the agency in
anticipation of no future growth, (b) extended beyond the agency boundaries in
anticipation of future growth, (c) be smaller, indicating the need to detach areas from
the agency boundaries, or (d) be designated a “zero sphere”, which indicates a potential
dissolution of the agency. In order to amend the sphere of influence boundaries, formal
approval from the Commission is required. Factors considered in a SOI include current
and future land use, capacity needs, and any relevant areas of interest such as
geographical terrain, location, and any other aspects that would influence the level of
service.
Per Government Code Section 56425, a SOI shall consider and prepare a written
statement of its determinations of the following factors:
1. Present and planned land use in the area, including agricultural and open space
lands.
2. Present and probable need for public facilities and services in the area.
3. Present capacity of public facilities and adequacy of public services that the
agency provides or is authorized to provide.
4. Existence of any social or economic communities of interest in the area.
5. Present and need for those public facilities and services of any disadvantaged
unincorporated communities within the existing sphere of influence.
The purpose of a SOI is to ensure efficient services while discouraging urban sprawl and
the premature conversion of agricultural and open space lands by preventing
overlapping jurisdictions and duplication of services. On a regional level, LAFCOs
consider the orderly development of a community by reconciling differences between
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different agency plans. This is intended to ensure the most efficient urban service
arrangements are created for the benefit of area residents and property owners.
DISADVANTAGED UNINCORPORATED COMMUNITIES
As part of the MSR, RSG and Planwest considered the impact of the SOI relative to
Disadvantaged Unincorporated Communities (“DUC”) and Severely Disadvantaged
Unincorporated Communities (“SDUC”). A DUC is defined by Government Code Section
56033.5 as an area of inhabited territory located within an unincorporated area of a
county within a “disadvantaged community.” A disadvantaged community is defined in
Water Code Section 79505.5(a) as a community with an annual median household
income which is less than 80 percent of the statewide median household income.
Furthermore, a severely disadvantaged unincorporated community is defined in Public
Resources Code Section 75005(g) as a community with a median household income less
than 60% of the statewide average. Government Code Section 56046 defines “inhabited”
as territory within which there are 12 or more registered voters.
Sutter LAFCO refers to Government Code Section 56033,5, Water Code Section
79505.5(a), and Government Code Section 56046, for determining the presence and
location of DUCs in Sutter County. RSG and Planwest utilized 2019-2023 American
Community Survey Census data for identifying DUCs and SDUCs, which establishes an
annual statewide median household income of $95,521. As a result, throughout this
report, a disadvantaged unincorporated community refers to any unincorporated area
wherein the median household income is less than $76,416.80, while a severely
disadvantaged unincorporated community refers to any unincorporated area wherein
the median household income is less than $57,312.60.
Figure 1 provides a regional map of DUCs located in Sutter County.
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Figure 1: Regional DUC Map
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SPHERE OF INFLUENCE UPDATES AND LAFCO POLICY
A sphere of influence (“SOI”) may be modified as determined by LAFCO; the procedures
for making sphere amendments are outlined in CKH, and in some cases, further refined
by the Commission’s own guidelines. Pursuant to Government Code Section 56430, the
Commission must first conduct a municipal services review prior to updating or amending
a SOI.
Per Government Code Section 56425, a SOI shall consider and prepare a written
statement of its determinations of the following factors:
1. Present and planned land use in the area, including agricultural and open
space lands.
2. Present and probable need for public facilities and services in the area.
3. Present capacity of public facilities and adequacy of public services that the
agency provides or is authorized to provide.
4. Existence of any social or economic communities of interest in the area.
5. Present and need for those public facilities and services of any disadvantaged
unincorporated communities within the existing sphere of influence.
The Sutter LAFCO Commission adopted a “Sphere of Influence Policy” in May 2019 with
amendments made in January 2024, which provides a framework for SOI updates for both
cities and special districts. LAFCO’s policy provides the following two types of SOIs as
detailed below.
- Areas of Concern: A geographical area extending beyond the sphere of influence
in which land use decisions or other governmental actions of one local agency
(“Acting Agency”) impact directly or indirectly upon another local agency
(“Concerned Agency”).
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- Zero and Minus Spheres: A SOI for a city or special district that includes no territory.
LAFCO adopts a Zero SOI if the service functions of the agency are either non-
existent, no longer needed, or should be reallocated to another service provider.
Adoption of a “zero” sphere of influence is an indication the agency should be
dissolved.
RSG analyzes the spheres in the “SOI Recommendations” section of this MSR.
MUNICIPAL SERVICE REVIEW (MSR) REQUIREMENTS
Section 56425(g) of CKH requires that LAFCOs evaluate a given SOI every five years, as
necessary; the vehicle for doing this is known as a Municipal Service Review (“MSR”). Prior
to or in conjunction with SOI reviews, a MSR must be prepared pursuant to Government
Code Section 56430. MSRs are conducted to assist in the SOI review process by providing
information regarding the ability of agencies to provide public services. Pursuant to
Government Code Section 56430, MSRs are to make determinations considering the
seven required topics based on CKH. These seven areas include:
1. Growth and population projections for the affected area.
2. Location and characteristics of any disadvantaged unincorporated
communities within or contiguous to the sphere of influence(s).
3. Present and planned capacity of public facilities, adequacy of public services,
infrastructure needs, or deficiencies related to sewers, municipal and industrial
water, and structural fire protection in any disadvantaged, unincorporated
communities within or contiguous to the sphere of influence.
4. Financial ability of agencies to provide services.
5. Status of, and opportunities for, shared facilities.
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6. Accountability for community service needs, including government structure
and operational efficiencies.
7. Any other matter related to effective or efficient service delivery, as required
by LAFCO Policy.
The focus of this MSR is to describe how municipal services are being carried out and to
determine if the residents of the community are receiving the highest level of fire
protection and emergency medical service possible, while also discouraging urban
sprawl and the premature conversion of agricultural lands. If an MSR determines that
certain services are not being carried out to an adequate standard, LAFCO can
recommend changes such as sphere changes as well as consolidation or dissolution of
service providers to provide the best service possible to the population.
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SUTTER COUNTY AND LOCAL FIRE & EMS RESPONSE
Sutter County (“County”) is geographically the 53rd largest county in California with a
607 square mile jurisdictional boundary. With respect to population, Sutter County is the
37th largest county in California with a total resident population of 99,626 as of FY 2024.1
The County primarily consists of agricultural uses, followed by residential, commercial,
and industrial uses.2
As a whole, the County has experienced only two major wildland fire incidents between
FY 2019 and FY 2023, demonstrating an insignificant number of fire incidents in most
recent years as compared to other neighboring counties. Figure 2 below shows the most
recent fires in Sutter County over the last five-years as measured in total acreage burned.
Figure 2: Recent Sutter County Fires by Acreage
Incident County Date Started Acres
West Butte Fire Sutter 6/8/19 1,350
River Fire Sutter 4/19/21 80
Source: California Department of Forestry and Fire Protection (CAL FIRE)
Eight (8) fire protection and emergency medical service providers across the County
respond to calls in their service area, in addition to responding to automatic and mutual
aid responses outside of each agencies’ jurisdictional boundary. The fire protection
service providers in the County include fire protection districts, city fire departments, and
community service areas.
Unlike the vast majority of counties in the state, Sutter County does not have any land
designated as State Responsibility Areas (“SRAs”). However, Sutter County has – at a very
1 Source: ESRI Business Analyst
2 Source: Sutter County 2030 General Plan
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minimal level - land designated as Federal Responsibility Areas (“FRAs”).3 SRAs refer to
land in which the California Department of Forestry and Fire Protection (“CAL FIRE”) is
primarily responsible for wildfire prevention and suppression, while FRAs are federally
managed lands wherein federal agencies are responsible for fire protection. As a result,
firefighting resources in the County are largely dependent on local fire agencies, which
requires strong local fire departments, proactive fire prevention efforts, and effective
coordination between neighboring agencies to mitigate fire risk.
EMERGENCY MEDICAL SERVICES
Emergency medical services (“EMS”) are emergency services that provide urgent pre-
hospital treatment and stabilization for serious illness and injuries, including transport to
definitive care, such as a hospital.4 EMS is commonly broken up into two different levels
of care:
1. Basic Life Support (“BLS”): BLS services are typically the first line of response
to medical emergencies, focusing on the provision of immediate, on-scene
care to stabilize and support vital functions until the victims of illness or injury
can be provided full medical care by an advanced life support provider or
hospital.5 Most fire protection service providers require personnel to be
trained as Emergency Medical Responders (“EMR’s”) or Emergency Medical
Technicians (“EMTs”) to provide BLS services. Fire protection service providers
are usually the first to arrive at the scene of a medical emergency, requiring
firefighter EMR’s and/or EMTs to fulfill an essential role in stabilizing victims
prior to transport by an ambulance transport service provider.
2. Advanced Life Support (“ALS”). Advanced Life Support services include a
higher level of care, such as advanced airway management, intravenous
(“IV”) access, and medication administration. While some firefighters are
3 The Sutter National Wildlife Refuge is the only Federal Responsibility Area in the County, which covers approximately 4.0 square
miles according to the U.S. Fish and Wildlife Service.
4 Source: www.ems.gov
5 Source: American Red Cross
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trained as paramedics and can deliver ALS services on-scene, paramedic
certification is not typically required for fire protection service personnel. As
a result, ALS services are often provided by specialized ambulance agencies
or hospital-based personnel, who work in coordination with first responders
to ensure comprehensive patient care. The fire departments detailed in this
MSR are not licensed or certified currently to provide ALS services.
Local Emergency Medical Services Agency
Pursuant to California Government Code Section 6500, et seq. and California Health &
Safety Code Section 1797.200, the Sierra-Sacramento Valley EMS Agency (“S-SV EMS”)
serves as the designated local emergency medical service agency (“LEMSA”) in Sutter
County. S-SV EMS was formed in 1975 as a Joint Powers Agency (“JPA”). The JPA
Governing Board consists of a County Supervisor for each S-SV EMS member county. S-SV
EMS is responsible for the planning, development, implementation and oversight of all
EMS components for all ten (10) counties under its jurisdiction, including EMS system
design, the qualification, accreditation, and authorization of all prehospital care
personnel, and compliance with local and state EMS statutes and regulations.
Pursuant to Government Code Section 1797.224, a LEMSA has the authority to create one
or more exclusive operating areas, which refer to specific geographic regions where a
single ambulance provider has been granted the exclusive right to operate if a
competitive process is utilized to select the provider. However, no competitive process is
required if the local EMS agency develops a local plan that continues the use of existing
providers operating in the manner and scope in which the services have been provided
without interruption since January 1, 1981.6
6 California Government Code Section 1797.224
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Bi-County Ambulance
Bi-County Ambulance (“BCA”) is the exclusive contract ambulance transport service
provider in both Sutter and Yuba County. BCA has been the sole ambulance transport
service provider in Sutter County since 1980 without any interruptions. As a result, BCA’s
contract with S-SV EMS is not required to go out to competitive bid at the end of each
contract period.
BCA’s current contract with S-SV EMS became effective on January 1, 2024, and expires
on December 31, 2026. Historically, BCA’s contract term was five years; however, it was
shortened in its most recent award to enable more frequent performance evaluations.
The current contract requires BCA provide 24/7 prehospital emergency medical care and
transport services to emergency medical calls within Sutter and Yuba County. This
includes a minimum of 120 ALS ambulance unit hours on a daily basis within BCA’s
combined Sutter and Yuba County exclusive operating areas.
EMS Response Time Standards
EMS response times are calculated from the time of call receipt by the contracted
ambulance transport service provider to the time of arrival of a fully equipped and staffed
authorized ambulance. In Sutter County, EMS response time standards are established by
S-SV EMS, which require ambulance transport service providers to meet the adopted
standards as a condition of their ambulance transport provider agreements. S-SV EMS’s
current response time standards became effective December 1, 2023 and will be
reassessed in January 2027. Figure 3 shows the current EMS response time standards
established for Yuba City and the Sutter County Rural region, which encompasses all
areas outside of Yuba City in the County.
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Figure 3: EMS Response Time Standards in Sutter County
Compliance
Ambulance Response Zone Time (MM:SS)
Requirement
Yuba City - City Limits 90% 8:00
Sutter County Rural 20 90% 20:00
Sutter County Wilderness N/A ASAP
Source: S-SV EMS Policy Manual (Section 415)
As a result, Bi-County Ambulance operates under the established response time
standards adopted by S-SV EMS in both Yuba City and the Sutter County Rural region. It
should be noted that the response time standards adopted for Yuba City are more
stringent than the majority of jurisdictions within the S-SV EMS 10-County Region, where
10-minute or greater response time standards are typical. Only three counties under the
oversight of S-SV EMS have 8-minute response time zones established for emergency
ambulance response.7 Bi-County Ambulance serves two of those three counties,
including Sutter and Yuba County.
Bi-County Ambulance is required to report its response time measurements on a monthly
basis to S-SV EMS, which is then published regularly on S-SV EMS’s website. In accordance
with the ambulance response zone and response time standards shown in Figure 3, S-SV
EMS compliance data is provided by each ambulance response zone in Sutter County.
Figure 4 provides an overview of ambulance responses in Yuba City from 2019 to 2023.
7 Source: S-SV EMS Policy Manual (Section 415)
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Figure 4: Bi-County Ambulance Responses in Yuba City
Average Late Median Late
Year Total Calls On-Time Calls % On-Time Late Calls % Late Call Response Call Response
Time (MM:SS) Time (MM:SS)
2019 7,523 7,115 94.6% 408 5.4% 9:31 8:57
2020 7,164 6,833 95.4% 331 4.6% 9:59 9:17
2021 8,032 7,635 95.1% 397 4.9% 10:30 9:35
2022 8,279 7,698 93.0% 581 7.0% 9:58 9:13
2023 7,818 7,283 93.2% 535 6.8% 9:44 9:07
Average 7,763 7,313 94.2% 450 5.8% 9:56 9:13
Source: S-SV EMS, Bi-County Ambulance
On average, Bi-County Ambulance responded to 7,763 calls annually in Yuba City - or
approximately 21 calls daily - during the report period. Bi-County Ambulance’s peak
demand in Yuba City was recorded in 2022 at 8,279 calls annually - or approximately 23
calls daily. Based on the data provided from S-SV EMS, Bi-County Ambulance was in
compliance with its response time standards for every year out of the five years reviewed
with an average on-time response rate of 94.2% across the report period.
To determine the extent of late call arrivals in Yuba City, average and median late call
response times were also analyzed. Bi-County ambulance had an average late call
response of 9 minutes and 56 seconds and a median late call response of 9 minutes and
13 seconds. This means that Bi-County Ambulance’s average and median late call
response times were still within the 10-minute response time standard used by the majority
of jurisdictions within the S-SV EMS 10-County Region, including the cities of Chico,
Oroville, Grass Valley, Lincoln, and Redding. While late calls accounted for less than 6.0%
of calls across the reporting period, the average late call response time suggests that
there are occasional calls for service that experience longer delays and skew the
average upward past the median late call response time of 9 minutes and 13 seconds.
Bi-County Ambulance’s responses were also analyzed in the Sutter Rural region, which
encompasses all areas outside of Yuba City in the County. Figure 5 provides an overview
of Bi-County Ambulance’s responses in Sutter Rural.
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Figure 5: Bi-County Ambulance Responses in Sutter Rural
Year Total Calls On-Time Calls % On-Time Late Calls % Late
2019 1,545 1,535 99.4% 10 0.6%
2020 1,546 1,540 99.6% 6 0.4%
2021 2,008 1,995 99.4% 13 0.6%
2022 2,068 2,051 99.2% 17 0.8%
2023 2,009 1,988 99.0% 21 1.0%
Average 1,835 1,822 99.3% 13 0.7%
Source: SSV-EMS
On average, Bi-County Ambulance responded to 1,835 calls annually in Sutter Rural - or
approximately 5.0 calls daily - during the reporting period. Bi-County Ambulance’s peak
demand in Sutter Rural was recorded in 2022 at 2,068 calls annually - or approximately
5.7 calls daily. According to the data provided by S-SV EMS, Bi-County Ambulance was
in compliance with its response time standards for every year out of the five years
reviewed with an average on-time response rate of 99.3% across the reporting period.
Due to the low volume of late calls recorded for the Sutter Rural region, average and
median late calls were not analyzed since a few outliers could significantly shift the
average and median.
Mentioned previously, BCA’s contract with S-SV EMS is not required to go out to
competitive bid since BCA’s ambulance transport services have been provided without
interruption since January 1, 1981. While Bi-County Ambulance has been in compliance
with its response time standards for both the Yuba City and Sutter Rural responses zones
for every year out of the five reviewed, it may be beneficial for Sutter County, through its
participation in the Sierra-Sacramento Valley EMS Agency, to initiate a competitive bid
process for the ambulance transport provider agreement at the conclusion of BCA’s
existing contract on December 31, 2026.
While Sutter County Administrator staff indicated the Department conducted a thorough
review of BCA’s service delivery prior to the renewal of BCA’s existing contract,
formalizing this process through a competitive bid process can promote greater
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transparency and facilitate opportunities for enhanced cost efficiencies and service
capabilities. Lastly, in addition to the competitive bid process allowing for an opportunity
to assess alternative service providers, it could also help solidify that the current service
provider remains the most effective option or could help identify areas for improvement.
PUBLIC SAFETY ANSWERING POINT SYSTEMS
Public Safety Answering Point Systems (“PSAPs”), also known as 9-1-1 Call Centers, refer
to public agency facilities equipped and staffed with call takers which receive 9-1-1 calls
for a defined geographic area and process those calls and events according to a
specific operational policy.8 While PSAPs are not under LAFCO jurisdiction, PSAPs work
closely with local fire departments and ambulance transport service providers to ensure
the efficient delivery of emergency services.
There are two PSAPs that provide emergency dispatch services to residents within Sutter
County, including the Sutter County Sheriff’s Office and the City of Yuba City Police
Department. Sutter County’s dispatch services are provided from the Sutter County
Sheriff’s Office headquarters located at 1077 Civic Center Blvd, Yuba City, CA, while the
City of Yuba City Police Department’s dispatch services are provided from the Yuba City
Police Department headquarters at 1545 Poole Blvd, Yuba City, CA.
PSAP Consolidation
In 2023, the City of Yuba City contracted with a consultant, Federal Engineering Inc., for
a study considering the feasibility of consolidating or regionalizing public safety
emergency communications resources of the four primary PSAPs in both Sutter and Yuba
County. The study included the Sutter County Sheriff’s Office, the City of Yuba City Police
Department, the City of Marysville Police Department, and the Yuba County Sheriff’s
Department.
8 California Governor’s Office of Emergency Services 9-1-1 Operations Manual Glossary
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The study recommended the consolidation of the four dispatch centers into the Yuba
County Sheriff’s facility in order to provide policy and procedure continuity, facilitate
interoperability between all Sutter and Yuba County law and fire agencies, in addition to
allow dispatcher recruiting and hiring without competing with three other agencies.
Consolidation of the four dispatch centers can decrease delays to call processing and
response dispatch, as emergency 9-1-1 calls received by one dispatch center do not
have to be transferred to another dispatch center with response jurisdiction. A single
dispatch center would allow multiple agencies interoperability of communications, and
aid in closest unit dispatched to the call location. The study also recommended a joint
powers agency as a governance model, in which the agencies have control of the
dispatch center budget and policies and allow for a more cost-efficient option for the
JPA to contract with one or more agencies for human resources, finance, and payroll
functions.
As of the date of this report, no additional updates have been provided to RSG and
Planwest Partners regarding progress made towards the recommendations proposed in
the study. However, it is encouraged that the four PSAPs continue to collaborate to
enhance service efficiency, improve cost effectiveness, and alleviate potential
challenges related to staff recruitment and retention.
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PURPOSE OF THIS MSR AND SCOPE OF WORK
The MSR’s underlying purpose is to produce an independent assessment of the municipal
services provided by the fire protection and emergency medical service providers in
Sutter County historically and over the next few years, consistent with the Commission’s
regional growth management duties and interests. The Commission will use the
information collected as part of the report in (a) guiding sphere of influence updates, (b)
informing of potential boundary changes and out-of-agency services, and if merited, (c)
initiating government reorganization, such as special district formations, consolidations,
and/or dissolutions.
METHODOLOGY
RSG worked in coordination with Sutter LAFCO staff throughout the development of this
MSR. Key tasks and activities in the completion of this MSR include data collection, the
Advisory Committee meetings, interviews with agency staff, agency profile development,
determination analysis, public review of MSR, and the adoption of the final MSR.
Data Collection
To fully understand key factors and current issues involving the Fire Agencies in Sutter
County, RSG conducted an initial working session with Sutter LAFCO staff to determine
the project scope and formalize overall MSR objectives, schedules, policy and fiscal
criteria, service standards, and roles and responsibilities.
The MSR began with a complete and thorough review of publicly available data and
documents. Adopted budgets, annual comprehensive financial reports, and capital
improvement plans were assessed to develop a comprehensive overview of the County
and of a given agency. In addition, various other reports and documents were utilized
from the California State Controller’s Office, Census Bureau, LAFCO, and ESRI Business
Analyst.
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Advisory Committee
RSG and Planwest facilitated a series of Advisory Committee (“Ad Hoc”) meetings
focused on identifying challenges and opportunities for sustaining emergency fire and
rescue services delivered by local fire agencies within Sutter County.
The first Ad Hoc meeting was held in September 2024 to inform of the MSR process and
identify key regional and local issues. A second Ad Hoc meeting was held in January 2025
to discuss general findings from the agency interviews and identify major challenges and
opportunities alongside the Ad Hoc Committee. The third Ad-Hoc meeting was held in
May 2025 to receive commentary on the Public Review MSR draft.
Interviews
In coordination with Sutter LAFCO, during the months of November 2024 through February
2025, RSG and Planwest met with executive leadership and governing board members of
the eight (8) fire protection and emergency medical service providers in the County. RSG
and Planwest collected information on the overall operation of the departments,
including staffing, quality of service, financial conditions, and resources, among other
aspects. The interviews presented a unique opportunity for agency representatives to
provide insights into service areas that extend into territories that are not covered by an
existing fire service provider or within the SOI of an existing service provider. The interviews
also allowed for the discussion of any nuances or key considerations in the completion of
this MSR - including but not limited to - the delivery of fire protection and emergency
medical services to the Sutter Pointe Specific Plan area, opportunities for consolidation
between fire protection service providers, and the delivery of advanced life support
(“ALS”) medical services in Yuba City, which will be discussed later in this report.
Agency Profiles
RSG developed agency profiles based on the data collected and information gathered
from the agency interviews and done so as required under statute. This includes key
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characteristics including services offered, staffing levels, station locations, population
and growth, infrastructure and financial condition, and boundary areas and maps.
Agency profiles can be found in the following sections of this MSR.
Financial audits were difficult to obtain from some of the fire agencies. Some fire agencies
only kept hard copies of financial audits on file, while others did not complete yearly
audits. Pursuant to Government Code Section 26909, a special district may, by unanimous
request of the governing board of the special district and with unanimous approval of
the County Board of Supervisors, conduct audits at a lesser frequency as established by
the County Auditor-Controller’s office. However, County Auditor-Controller personnel did
not have these established requirements readily available upon request.
As a result, RSG and Planwest relied on various sources for financial data across the
reporting period, including Agency budgets, audited financial statements, and data
obtained from the California State Controller’s Office (“SCO”). Fire agencies in California
are required by Government Code Section 53891 to provide the State Controller’s Office
with an annual report of all financial transactions. According to the SCO, the purpose of
this report is to collect and compile statewide financial and statistical data on as uniform
a basis as possible. The reported balances and transactions are derived from audited
financial statements prepared in accordance with generally accepted accounting
principles.
The data collected is published on the SCO’s “By the Numbers” website and in raw data
format. The raw dataset reports general revenues, functional tax revenues, and other
revenue sources, including charges for services, special benefit assessments, use of
money, and intergovernmental revenues. The dataset provides current expenditures by
department and operating expenditures (salaries and wages, retirement benefits,
materials and supplies, contract services, debt service, and capital outlay).
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For some agencies, RSG utilized the SCO’s raw data to review historical operating
revenues and expenditures. From this data, RSG can generalize an agency’s fiscal health,
including tax revenue and expenditure trends.
County Service Areas
There are several County Service Areas (“CSAs”) that have formed within Sutter County.
County Service Area C (“East Nicolaus Fire District”) was formed in 1963 to provide fire
protection services in the southeast portion of Sutter County and includes the
communities of Nicolaus and East Nicolaus. County Service Area D (“Pleasant Grove Fire
District”) was also formed in 1963 to provide fire protection services in the southern portion
of Sutter County, including the area south of Striplin Road and north of the Sacramento
County line. CSA F, the largest CSA by square mileage in Sutter County, was established
in 1996 to provide fire protection services to areas in the northern and eastern portion of
Sutter County. Lastly, CSA G was formed in May 2001 to provide fire protection services
within the former Walton Fire Protection District area in the east-central portion of Sutter
County, which surrounds the City of Yuba City.
Analysis and Criteria Sources
Insurance Services Office Fire Protection Class Rating
The Insurance Services Office (“ISO”) creates ratings for fire departments and the
communities these departments serve. ISO gives overall fire protection class ratings
ranging from 1 to 10 with a rating of 1 being the best and a rating of 10 means the
department does not meet the ISO’s minimum requirements. ISO calculates a
community’s overall fire protection class rating by evaluating the community on a 0 to
105.5 point scale using the following criteria:
- 50 points of the rating are derived from the quality of the local fire department.
Activities that are monitored include maintenance and testing of department
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equipment according to NFPA 1901, staffing levels, type and extent of training
provided to department personnel, and proximity of stations to its residents.
- 40 points of the rating are based on the community’s water supply. Determinations
for water supply are based on whether there is a sufficient water supply for fire
suppression beyond daily maximum consumption, surveying all components of the
water supply, review hydrant inspections and frequency of flow testing, and the
number of fire hydrants that are no more than 1,000 feet from the representative
location.
- 10 points of the rating are based on the quality of emergency communications
within a community. ISO determine the quality of emergency systems by evaluating
the emergency reporting system, communication centers including the number of
telecommunicators, computer-aided dispatch facilities, and the dispatch circuits
and how the center notifies firefighters about the location of the emergency.
- 5.5 points of the rating are based on community risk reduction. This portion of the
rating gives incentives to communities who strive to proactively reduce fire severity.
The areas of community risk reduction evaluated are fire prevention activities, fire
safety education, and fire investigations.
Some fire departments have a “split” rating (e.g., 3/3X) where the first rating number
refers to the classification of properties within 5 road miles of a fire station and within 1,000
feet of a creditable water supply and the second number followed by either the X or Y
designation, applies to properties within 5 road miles of a fire station but beyond 1,000
feet of a creditable water supply. The X and Y classifications replace the former 9 and 8B
portions of a split classification, respectively. For example, a community formerly graded
as a split 6/9 was changed to a split 6/6X. Similarly, a community formerly graded as a
split 6/8B classification was changed to a split 6/6Y classification. A Class 8B, or “Y”, is
applied to communities that provide superior fire protection services and fire alarm
facilities, but the water supply is not capable of the minimum Fire Suppression Rating
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System fire flow criteria of 250 gallons per minute for 2 hours. A Class 9 fire department is
dispatched by a creditable communications system, the fire department has an
adequate first alarm response and initial attack, but there is no creditable water supply.
A department with a Class 10 rating typically will lack an adequate first alarm response
for an initial attack structure fire and have no credible water supply in a geographic area.
A department that has a split ISO listing such as a 6/10 may carry an ISO rating that was
established prior to the X/Y upgraded listing. As mentioned previously, the secondary
number rating is typical for areas of the response jurisdiction that are more than five miles
from the station and lack a credible water supply. This can often occur in the far reaches
of a rural jurisdiction, where apparatus response times are long due to travel distances,
and long travel times/distances to a water supply to refill water tenders and engines with
a long return time prevents the department from maintaining an effective fire flow on
scene. This ongoing, uninterrupted water shuttle exercise was referred to by ISO as a
“Rural 8” in the past, and was a measure of the ability of the jurisdiction to effectively
maintain water supply and fight fire in a remote location of the district.
Insurance companies may use these ratings to determine the home insurance rates that
will be charged to homeowners in the respective district. Insurance companies may
charge higher premiums to communities with ratings closer to 10 and lower insurance
premiums to communities with ratings closer to 1. Not all insurance companies rely on ISO
ratings and may use their own criteria for determining insurance premiums.
Engine Standards
The National Wildfire Coordinating Group has developed a set of minimum performance
requirements for structure and wildland engine resource types. These standards, provided
in
Figure 6 below, are also adopted and used by both the Firefighting Resources of
California Organized for Potential Emergencies (FIRESCOPE) Field Operations Guide and
the National Incident Management System (NIMS) as the standard within the Incident
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Command System (“ICS”), a response structure utilized by public agencies to manage
emergencies, to assess equipment capability.
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Figure 6: Engine Typing Standards
Requirements Type 1 Type 2 Type 3 Type 4 Type 5 Type 6 Type 7
Tank minimum capacity 300 300 500 750 400 150 50
(gal)
Pump minimum flow 1,000 500 150 50 50 50 10
(gal/min)
At rated pressure (psi) 150 150 250 100 100 100 100
Hose: 2½-inch 1,200 1,000 N/A N/A N/A N/A N/A
Hose: 1½-inch 500 500 1,000 300 300 300 N/A
Hose: 1-inch N/A N/A 500 300 300 300 200
Ladders per NFPA 1901 Yes Yes N/A N/A N/A N/A N/A
Master stream (500 gal/min.) Yes N/A N/A N/A N/A N/A N/A
Pump and roll N/A N/A Yes Yes Yes Yes Yes
Maximum GVWR (lbs.) N/A N/A N/A N/A 26,000 19,500 14,000
Personnel (minimum) 4 3 3 2 2 2 2
Source: National Wildfire Coordinating Group
Notes:
1. Types 1 and 2 are structure; Types 3-7 are wildland.
2. All types shall meet federal, state and agency requirements for motor vehicle safety standards, including all
gross vehicle weight ratings when fully loaded.
3. Type 3 engines and tactical water tenders shall be equipped with a foam proportioner system.
4. All water tenders and engine types 3 through 6 shall be able to prime and pump water from a 10-foot lift.
5. Personnel shall meet the qualification requirements of NWCG Standards for Wildland Fire Position
Qualifications, PMS 310-1.
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Staffing & Response Time Standards
The National Fire Protection Association provides nationally recognized staffing and
response time standards for both career and volunteer fire departments within NFPA 1710
and 1720, respectively.
NFPA 1710, Standards for the Organization and Deployment of Fire Suppression
Operations, Emergency Medical Operations, and Special Operations to the Public by
Career Fire Departments, addresses the structure and operation of organizations
providing emergency response services, including industry recognized standards for the
response to fire and medical emergencies. For a typical one- or two-story single-family
dwelling of 2,000 square feet or small commercial structure (low to medium hazard), NFPA
1710 sets the standard for the initial full alarm response at 16 firefighters or 17 if an aerial
device is used. This level of response typically includes a duty officer to take command,
and 4-5 fire engines staffed with 3-4 fire personnel per unit to carry out the necessary tasks
on a fire that must happen simultaneously. These tasks include search and rescue, fire
attack, ventilation, water supply, a RIT (rapid intervention team as required by OSHA 29
CFR 1910.134(g)(4)), incident command, and other tasks the incident requires.
Commercial structures (medium to high hazard structures) require an even more involved
level of response, due to the typically larger building area, and the fuel load of stored
items within. For a typical open air strip mall with a size between 13,000 and 196,000
square feet, NFPA 1710 sets a standard that a jurisdiction must be able to provide a
minimum of 27 fire personnel on scene (28 if an aerial device is used) to complete the
tasks necessary to mitigate the incident.
Additionally, NFPA 1710 provides response time standards for career fire departments and
can be seen in Figure 7. NFPA 1710 provides standards for dispatch call answering and
processing to incident tone out. Turnout times, the time it takes fire personnel to don the
correct level of personal protective equipment (PPE) for the call type, and roll out from
their station or location, are provided for both EMS calls and fire/other calls. Fire calls
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allow additional time for the donning of full structural PPE or wildland PPE. Time of arrival
on scene represents the total recommended response time from the unit leaving the
station to arrival on scene. The difference in the full response arrival stems from a larger
number of units typically dispatched to a larger, high hazard incident.
All paid career fire departments should work to align their response time standard with
the times listed in NFPA 1710.
Figure 7: NFPA 1710 Response Time Standards
Staffing and response time standards for volunteer fire departments and districts are
found in NFPA 1720, Standard for the Organization and Deployment of Fire Suppression
Operations, Emergency Medical Operations, and Special Operations to the Public by
Volunteer Fire Departments. The staffing and response time standards found in NFPA 1720
differ from the standards found in NFPA 1710 in that the staffing recommendations are
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listed based upon the type of area that the fire department has to cover and respond
to, rather than driven by type of occupancy. NFPA 1720 provides response standards for
staffing and response times based on the number of people per square mile within each
response area and referred to as the “Demand Zone.” The minimum staffing levels and
response time objectives in NFPA 1720 are based upon structural firefighting in a low
hazard occupancy, such as a 2,000 square foot, two-story single-family home without
basement or exposure problems (other buildings located close that could also catch fire).
These levels are depicted in Figure 8.
Figure 8: NFPA 1720 Staffing and Response Time
It should be noted that the same number of staff on scene (15) is recommended for
volunteer fire departments in an Urban Area, which matches the standard for career
departments, with only the response time objective being longer for the volunteer
department. NFPA 1720 provides further guidelines on the fire department by setting the
objective that upon arrival of the necessary resources on scene, the fire department shall
have the capability to safely commence an initial attack of the fire within 2 minutes of
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arrival 90% of the time. Departments shall have the capability for sustained operations at
an emergency scene, through their own personnel and equipment and automatic and
mutual aid for fire attack, search and rescue, forcible entry, ventilation, and preservation
of property, accountability of on scene personnel, ability to assign and deploy a rapid
intervention crew (RIC), and the ability to support an incident beyond initial attack.
All volunteer fire departments should work to align their response standards with those
provided in NFPA 1720.
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AGENCY SERVICE REVIEWS
The next section of this report covers the municipal service reviews of the eight (8) fire
protection and emergency medical service providers within Sutter County which are as
follows.
- City of Live Oak Fire Department
- City of Yuba City Fire Department
- County Service Areas C, D, F and G
- Meridian Fire Protection District
- Robbins Sutter Fire Protection District
Figure 9 provides a regional map of the fire protection and emergency medical service
providers reviewed in this report.
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Figure 9: Regional Map
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CITY OF LIVE OAK FIRE DEPARTMENT
The Town of Live Oak was originally settled in 1866 by A.M. McGrew and with the
California-Oregon Railroad’s arrival in the 1870’s, the area further expanded leading up
to its incorporation as a general law city in January 1947. The City of Live Oak (“Live Oak”
or “City”) is situated along the Highway 99 corridor between Yuba City and Chico with
direct access to Sacramento and San Francisco.
The City of Live Oak Fire Department (“Live Oak” or “Department”) is authorized to
provide fire protection and emergency medical services within the City’s 3.1 square mile
jurisdictional boundary. The City contracts with Sutter County Fire to provide fire
protection and emergency medical services to residents within the city limits. The latter
arrangement was established in 1996. Prior to this arrangement, the City of Live Oak Fire
Department provided fire protection and emergency medical services to its service area.
The City’s contract was renewed on January 1, 2024, and extends through December 31,
2029.
JURISDICTIONAL BOUNDARY & SPHERE OF INFLUENCE
The City of Live Oak’s (“Live Oak” or “City”) current jurisdictional boundary spans an area
of approximately 3.11 square miles with an expanded sphere of influence designation.
The City of Live Oak’s SOI currently spans 12.0 square miles and was last updated in 2012.
The City’s fire service area is coterminous with its existing boundary and sphere of
influence.
As of FY 2024, the total assessed value (land and structures) within Live Oak is
approximately $707.8 million which translates to a per capita value of approximately
$75,700 based on the current 2024 resident service population.
Figure 10 presents Live Oak’s sphere in relation to its jurisdictional boundary.
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Figure 10: Live Oak’s Jurisdictional Boundary and SOI Map
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DEMOGRAPHICS
The City of Live Oak’s (“Live Oak” or “City”) total current resident population within its
jurisdictional boundary (fire protection and emergency medical service area) is
estimated at 9,354 as of FY 2024. This amount represents 9.4% of the countywide
population total. As of the date of this MSR, the unincorporated portion of the City of Live
Oak’s sphere of influence, which excludes the portion located within the City limits, has
a population of 835, which represents 4.5% of the population in CSA F. The estimated
resident population in the City of Live Oak has risen overall by 8.2% - or approximately 712
residents since 2010 - demonstrating an upward trend.9 The current resident population
produces a population density of 0.12 residents for every acre and underlies the overall
rural characteristic of the City’s jurisdictional boundary. The City of Live Oak primarily
consists of residential uses, with the remaining land uses in the City being commercial,
industrial, civic land uses, and small number of public uses.10
The City’s population is expected to grow by approximately 0.4% annually over the next
five-years reaching 9,541 residents by 2029 and reflects an overall increase of 187
residents.11 This growth is similar to the anticipated annual population growth countywide
which is expected to grow 0.5% annually, reaching 99,795 residents by 2029. Figure 11
summarizes the City of Live Oak and the County’s past, present and future population
growth.
Figure 11: Live Oak’s Resident Population
9 Source: ESRI Business Analyst
10 Source: City of Live Oak Land Use Element
11 Source: ESRI Business Analyst
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An estimated 2,952 housing units are within the City’s boundary as of FY 2024. This amount
accounts for an overall increase of 371 units – or 14.4% - since 2010 for an annual change
of 27 housing units. Furthermore, it is expected the City’s total number of housing units will
reach 3,014 by FY 2029, accounting for an estimated 2.0% increase.
Of the total number of current housing units in the City, more than one-half – or 60.5% -
are owner-occupied. The remainder of housing units are divided between 36.0% being
renter-occupied and 3.6% being vacant. Further, the average household size in the City
for 2024 is 3.25. This amount reflects a decrease of (5.0%) since 2010 wherein the average
household size was 3.42. Figure 12 includes additional details regarding the City’s housing
characteristics.
Figure 12: Live Oak’s Housing Characteristics
AGE DISTRIBUTION & INCOME
Compared to the County as a whole, the population of the City of Live Oak’s service
area has been relatively younger. The median age of residents in the City is 35.7 and
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reflects an increase of 8.4% from 32.7 in 2010. The current median age in the City remains
slightly lower than the countywide median age of 37.5 demonstrating a younger resident
population.
Similarly, 96.3% of residents within the prime working age group (between the ages of 25-
64) are employed while the remaining 3.7% are unemployed, reflecting a stable
workforce within the City’s jurisdictional boundary.12 Additional details regarding the City
of Live Oak’s age distribution and employment rates are provided in Figure 13.
Figure 13: Live Oak’s Age Distribution
The median household income in the City of Live Oak is $66,163 which is approximately
6.9% lower than the County’s median household income of $70,700. This amount confirms
households in the City are receiving moderately less pay over the report period
compared to the county as whole. Furthermore, the City has a poverty level rate of 17.4%,
which is approximately 24.1% higher than the County’s poverty level rate of 13.2%,
suggesting residents within the City may have a lower standard of living and less access
to resources.13
According to Sutter LAFCO’s policies, there is one Disadvantaged Unincorporated
Community (“DUC”) located contiguous to the eastern boundary of the City’s limits and
12 The prime working age group does not include individuals between the ages of 16-25 nor 65 and above given residents within
these age groups are typically in school or nearing/in retirement.
13 Federal poverty levels are determined annually by the U.S. Census Bureau which uses a set of money income thresholds that
vary by family size and composition to determine who is in poverty.
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one Severely Disadvantaged Community (“SDUC”) located contiguous to the western
boundary of the City’s limits. A DUC is defined as any unincorporated area wherein the
median household income is less than $76,416.80, while an SDUC is defined as any
unincorporated area wherein the median household income is less than $57,312.60.14
Sutter County Fire is the primary fire protection and emergency medical service provider
to both of these areas. Figure 1 shows the location of these areas in relation to the County
as a whole. Figure 14 provides an overview of income characteristics in the City and
County.
Figure 14: Live Oak’s Income Characteristics
GOVERNANCE AND STAFFING
The City of Live Oak’s (“Live Oak” or “City”) operates under a council-manager system,
where the City Council sets policies and the City Manager has the administrative authority
to implement such policies. The City of Live Oak’s Fire Department is governed by the City
Council which consists of a Mayor, Vice Mayor and three councilmembers. Each member
of the council is elected at-large and serve four-year terms whereas the Mayor and Vice
Mayor serve one-year terms. The City Council regularly meets on the first and third
Wednesday of every month in the Council Chambers in the City Hall located at 9955 Live
Oak Boulevard in Live Oak.
14 Source: Government Code Section 56033.5 and 56046, Water Code Section 79505.5(a), Public Resources Code Section
75005(g), American Community Survey Census 2019-2023 data
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The current CSA F Fire Chief – Richard Epperson – was appointed in May 2024 and is
currently serving as the Department’s Fire Chief. Live Oak’s fire protection, emergency
medical, and ambulance services are primarily dependent on the Department’s own
staffing arrangements and headlined by its existing contract with Sutter County Fire. Live
Oak’s total fire services staff at the end of FY 2023 totaled 6.0 fulltime employees including
1.0 Battalion Chief, in addition to 9.0 of volunteers. Over the last five years between FY
2019 and FY 2023, Live Oak’s Fire Department has increased its staffing by 8 additional
members – or 114.3%. According to CSA F staff, volunteers receive a shift stipend of $50
per shift, $11 per training, and $9 per call.
Figure 15 below summarizes the Departments total staff over the report period.
Figure 15: Live Oak’s Fire Department Historical Staff
Fiscal Year 2019 2020 2021 2022 2023 Average Trend
Type:
Paid Positions 6 6 6 6 6 6 0.0%
Volunteer Positions 1 3 13 9 9 7 800.0%
Total 7 9 19 15 15 13 114.3%
Per 100 residents 0.5 0.6 1.3 1.0 1.0 0.9 121.1%
Source: Sutter County Fire
Training
Sutter County Fire personnel conduct regular weekly trainings. In previous years, trainings
for Sutter County Fire personnel assigned to the Live Oak Station were conducted at the
Live Oak Station No. 5. In April 2024, the Live Oak City Council approved a new training
center located at 9633 N St in the City of Live Oak. The training facility is centrally located
within City limits and will provide fire personnel with hands-on training, including a
container-based burn structure to simulate real-world fire conditions.15
15 Source: https://www.appeal-democrat.com/news/live-oak-council-approves-new-firefighting-training-center/article_778ba5c4-
010a-11ef-859a-eb946a82c419.html
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MUNICIPAL SERVICES
The City of Live Oak (“Live Oak” or “City”) established formal fire protection service
following the City’s incorporation in 1947. As granted under Government Code Section
38600 et. seq., the City of Live Oak is authorized to provide a full range of municipal
services, most notably including fire protection and emergency medical services.
Through its contract with Sutter County Fire, Live Oak’s fire protection services include
responses to structural fires, hazardous materials conditions, vehicle extrications, in
addition to prevention, public education, and emergency preparedness and mitigation.
The Department’s emergency medical services are classified as basic life support (“BLS”).
The Sierra-Sacramento Valley EMS Agency designates (“S-SV EMS”) Bi-County Ambulance
(“BCA”) as the exclusive ambulance transport provider in Sutter County, including the
City of Live Oak.
The City of Live Oak’s fire station (“Live Oak Station No. 5”) is staffed by Sutter County Fire
personnel, including one (1) Battalion Chief, three (3) full-time Captains, three (3) full-time
Engineers, and two (2) to three (3) volunteer firefighters. The Live Oak Station No.5 is
staffed by three rotating platoons on a 48/96 schedule in which fire personnel work for 48
consecutive hours followed by 96 hours off before the next duty period begins. The station
is continuously staff by five (5) to six (6) public safety personnel, including two (2) to (3)
volunteer firefighters, two (2) full-time Captains and/or Engineers, and one (1) Battalion
Chief. The current fire station details follow.
- The Live Oak Station No. 5 is located near the center of City limits at 2745 Fir Street
in Live Oak. The station was built over one hundred (100) years ago and is owned
by the City of Live Oak. The station is in moderate condition and recently
completed dormitory and living room work. A total of two (2) to four (4) public
safety staff are assigned to Station No. 5 at any given time.
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The Live Oak Station No. 5 currently houses seven (7) apparatus. Sutter County Fire owns
four (43) of the apparatus, including the Type 3 engine, Water Tender and two (2)
Command Vehicles. The City of Live Oak owns three (3) apparatus, including a Type 1,
Type 2, and Type 6 engine. All fire engines are stored within the Station No. 5’s apparatus
bay. Figure 16 summarizes the Department’s station staffing and apparatus conditions as
of FY 2023.
Figure 16: Live Oak’s Fire Station(s) Assignments as FY 2023
Station No.5
Fire Engines Type 1 (2018)
Type 2 (2005)
Type 3 (2009)
Type 6 (2007)
Water Tender Water Tender (1995)
Command Vehicles Utility Vehicle (2004)
Utility Vehicle (2021)
Total 7
Source: County Fire
County Fire also supplements its fire protection and emergency medical services within
the City of Live Oak by maintaining reciprocal automatic/mutual aid agreements with
neighboring jurisdictions. This includes agreements with Butte County Fire, CAL FIRE, and
the Yuba City Fire Department.
SERVICE DEMANDS AND CAPACITY
Overall service demands for fire protection and emergency medical services from County
Fire within Live Oak city limits between FY 2020 and FY 2023 have averaged 2,046
dispatched calls annually - or 5.61 calls per day.16 (Information for the first year – FY 2019
– is not readily available due to County Fire changing its incident reporting system). Live
Oak’s largest single source of onsite responses involved emergency medical incidents
16 Information for FY 2019 was not readily available.
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necessitating Basic Life Support service which accounted for 91.4% of all service calls for
at the end of the report period (FY 2023). Further, onsite arrivals necessitating fire
protection services averaged 143 calls between FY 2020 and FY 2023, and account for
an overall decrease of 15 responses to fire calls for service annually – or a decrease of
(11.8%) fire calls for service. Live Oak’s peak demand was recorded in FY 2020 which
reflected a daily onsite response of 7.0 calls for service. According to CSA F staff, the City
of Live Oak experienced a high volume of “Other Rescue” calls in FY 2020 due to the
impacts of COVID-19.17 Overall, Live Oak’s total onsite responses decreased between FY
2020 and FY 2023 from 2,552 to 1,708 reflecting an overall decrease of (33.1%) for all on-
site responses.
Considering the limited growth in housing and population within city limits, the decrease
in onsite responses for the Department may be more attributable to the inherent
characteristics of a rural environment rather than improvements in fire prevention efforts.
However, while service demands are falling over time, Live Oak and by extension County
Fire, must remain prepared for any sporadic or high-impact events (such as a wildfire or
large accidents) that can occur despite the low response volume. Figure 17 below
summarized Live Oak’s fire protection and emergency medical demands during FY 2020
– FY 2023.
Figure 17: Live Oak’s Service Demands between FY 2020 and FY 2023
Existing Service Demands 2019 2020 2021 2022 2023 Average Trend
Category
Fire N/A 127 171 161 112 1 43 -11.8%
EMS-BLS N/A 1,224 1,479 1,469 1,561 1,433 27.5%
EMS-ALS N/A - - 1 - 0 N/A
Vehicle Extracations N/A 4 7 1 0 1 2 8 200.0%
Other Rescue N/A 1,195 596 2 4 2 3 4 60 -98.1%
Hazardous Condition/Materials Calls N/A 2 2 5 - 2 -100.0%
Total Onsite Responses N/A 2,552 2,255 1,670 1,708 2,046 -33.07%
Source: County Fire
17 “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, trench rescue or confined space rescue, and lock-in calls.
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SERVICE PERFORMANCE
With respect to Live Oak’s capacities to meet existing and future demands, County Fire
– as measured by staffing, equipment, and historical call volume trends – appear
sufficiently sized to readily accommodate the existing demands within the City limits
through the timeframe of this report. Live Oak and Sutter County Fire utilizes automatic
aid and mutual aid for large incidents or periods of multiple simultaneous calls. Other key
performance measures follow.
- Live Oak’s most recent evaluation of structural fire protection capabilities from the
Insurance Services Office (ISO) was completed in 2023 and resulted in a Class 4
rating for the Department. The ISO score is a measure of the capability of the fire
department to protect the community and is rated on a scale of 1 to 10, with 1
being the highest rating. ISO evaluates the fire department for apparatus and
equipment, weight of response (number of firefighters arriving on scene), training,
water supply and distribution, emergency communications systems, and fire
prevention/community risk reduction efforts.
- County Fire follows NFPA 1710 response time standards for the City of Live Oak.
Given the City of Live Oak’s population density and existing service demands, NFPA
1710 is a reasonable standard for ensuring the timely and effective delivery of fire
and emergency medical responses.
FISCAL HEALTH
The sections that follow evaluate the City of Live Oak’s Fire Department’s (“Live Oak” or
“Department”) fiscal health, inclusive of revenue sources and major expenditure
categories.
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REVENUES & EXPENDITURES
Live Oak’s total annual average fire protection specific revenues between FY 2019 and
FY 2023 totaled $255,000. Historically, the largest single source of the Department’s
revenue is from the 1996 Special Fire Assessments which account for about $131,000 or
42.9% of all revenues for the Department as of FY 2023. The 1996 Special Fire Assessment
does not have a built-in mechanism to adjust for inflation in the future. The remainder of
revenues for the Department are derived from income from fees, interest, and its 2004
community financing district (“CFD”). At the end of FY 2023, Live Oak’s total revenues
amounted to $305,000 and reflect an overall increase of $84,000 or 38.1% since 2019
(about $221,000).
The City of Live Oak reimburses CSA F up to 85.0% of its operational costs associated with
providing fire protection and emergency medical services to the City of Live Oak. Live
Oak’s total average annual expenses over the report period have been $928,000. The
District’s expenses are further broken down into three categories: (a) Service & Supplies;
(b) Debt & Contingency; and (c) Capital Outlay. The Department’s costs associated with
Service & Supplies account for nine-tenths– or 90.2% - of Department’s expenditures, at
$893,000 as of FY 2023.
Live Oak’s total expenditures at the end of the report period (FY 2023) totaled $990,600
accounting for an overall decrease of $402,000 - or (28.9%). The drop in expenditures can
be largely attributed to a decrease in costs associated with the Departments debts.
However, City staff indicated that the City recently renewed its contract with Sutter
County Fire for a five-year term beginning January 1, 2024, which included an increase
to the total contract costs.
RSG’s analysis reveals a consistent deficit in each fiscal year of the report period,
indicating that revenues are insufficient to cover the costs of fire services. However, this
analysis does not account for potential revenues from the City’s General Fund, such as
property or sales taxes, due to limited financial information provided in the Department’s
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financial reports. However, given that costs associated with the City’s contract with Sutter
County Fire have recently increased, it is essential that the City evaluate its option for
increasing its revenue base and/or analyze opportunities for cost savings.
According to City staff, the City is exploring the establishment of a permanent funding
source, such as a parcel tax, in order to fiscally sustain the City’s fire protection and
emergency medical services through its existing contract with Sutter County Fire.
Additional details regarding Live Oak’s total revenues and expenditures are provided in
Figure 18.
Figure 18: Cash Flow – Live Oak Fire Department
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SOI/BOUNDARY & OTHER RECOMMENDATIONS – CITY OF LIVE OAK
FIRE DEPARTMENT
The following recommendations by RSG and Planwest Partners call for specific action
from Sutter LAFCO and pertain to the City of Live Oak sphere of influence (“SOI”)
amendments, boundary changes, and any other recommendations:
1. Sutter LAFCO should proceed to affirm the City of Live Oak’s sphere of influence
with respect to the delivery of fire protection and emergency medical services. The
City of Live Oak’s sphere of influence demarks the City’s current and/or probable
future boundary and service area for all municipal services provided, including fire
protection and emergency medical services.
2. The City of Live Oak may consider the establishment of a permanent funding
source, such as a special assessment or parcel tax to ensure the long-term
operational sustainability of fire and emergency medical services. The City’s net
income has declined over time. A permanent funding source, such as a special
assessment or parcel tax, would offer greater financial stability, enabling the City
to continue contracting with Sutter County Fire for fire protection and emergency
medical services.
3. Sutter LAFCO may also consider exploring a broader, countywide consolidation of
all fire protection service providers in the County in the long term. Countywide
consolidation may offer several long-term benefits to fire protection and
emergency services in Sutter County, including enhanced operational efficiency,
improved coordination of resources, elimination of service redundancies, and
more equitable delivery of fire protection and emergency medical services across
service area. Given the fiscal and staffing constraints faced by several of its existing
providers, consolidation may serve as a strategic pathway to strengthen service
reliability, ensure consistent standards of training and equipment, and improve
long-term fiscal sustainability.
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To inform future decision making regarding countywide consolidation, it is
recommended that all fire protection service providers within the County
participate in a comprehensive Standards of Response Coverage (“SORC”) study.
This analysis should evaluate response times, station locations and coverage,
staffing, wages, benefits including pensions, and a forecast of past, current, and
future service delivery needs. Importantly, the study should also assess the financial
feasibility of a consolidated fire protection system.
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MSR & SOI DETERMINATIONS – CITY OF LIVE OAK FIRE DEPARTMENT
Sutter County LAFCO is directed to prepare written determinations to address the various
governance factors enumerated under Government Code Section 56430 whenever it
prepares a municipal service review. These determinations serve as independent
statements derived from the information collected, analyzed, and presented in the report
by RSG and Planwest. The purpose of the determinations is to provide an independent
assessment to the City of Live Oak’s ability to provide fire protection and emergency
medical services to residents within its jurisdictional boundary now and in the near future.
SERVICE PROVISION DETERMINATIONS
1. Growth and Population Projections
- There are approximately 9,354 residents in the City of Live Oak as of 2024. RSG
estimates the City of Live Oak has added approximately 712 new residents since
2010.
- The City of Live Oak has added approximately 371 new housing units since 2010.
This new development accounts for an annual increase of 27 new units each year.
- Since 2010, the growth rate of new housing units has outpaced the population
growth rate, indicating a potential surplus of housing production within the City
limits.
- The City of Live Oak resident population is forecasted to reach 9,541 residents by
2029. This accounts for an annual growth rate of approximately 0.40%.
- The number of housing units in the City of Live Oak is expected reach 3,014 housing
units by 2029. This accounts for an annual growth rate of approximately 2.0%.
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2. Location and Characteristics of Disadvantaged Unincorporated Communities within or
Contiguous to SOI
According to Sutter LAFCO’s policies, there is one Disadvantaged Unincorporated
Community (DUC) located contiguous to the eastern boundary of the City of Live
Oak’s city limits and one Severely Disadvantaged Community (SDUC) located
contiguous to western boundary of the City of Live Oak’s city limits. Sutter County
Fire is the primary fire protection and emergency medical service providers to both
of these areas.
3. Present and Planned Capacity of Facilities, Adequacy of Public Services, and
Infrastructure Needs and Deficiencies in any Disadvantaged Unincorporated
Communities within or Contiguous to SOI
The following statements apply to the City of Live Oak’s Fire Department with
respect to the availability, adequacy, and performance of its fire protection and
emergency medical services available under Government Code Section 38611.
These statements serve to confirm RSG and Planwest Partner’s determination that
Live Oak has adequate capacity, infrastructure and availability to continue to
provide fire protection and emergency medical services to its residents now and
into the foreseeable future.
- The City of Live Oak provides fire protection and emergency medical
services by way of a formal contract with CSA F (“Sutter County Fire”) out of
one fire station – Live Oak Station No. 5 located at 2745 Fir Street in Live Oak
- with a total staffing of nine (9) public safety personnel as of the end of the
report period (FY 2023).
- Live Oak Station No. 5 is in average condition and is currently undergoing
dormitory and living room improvements.
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- Overall demands for fire protection and emergency medical services from
Live Oak during FY 2020 through FY 2023 have averaged 2,046 dispatched
calls annually or 5.6 dispatched calls per day. Overall calls for service from
2020 to 2023 have decreased by 33.1%.
4. Financial Ability to Provide Services
The City of Live Oak has the financial ability to provide contracted fire services with
Sutter County and contracted emergency medical services with Bi-County
Ambulance to existing residents through its contract with Sutter County Fire.
However, the long-term financial sustainability of this arrangement remains
uncertain. The Department appears to rely, at least in part, on General Fund
allocations to fund the City’s existing contract with Sutter County Fire. Given other
potential demands on the General Fund, it is unclear whether the City can
continue to provide these contracted services at current levels over time.
Additional information is provided below.
- The City of Live Oak reimburses Sutter County Fire approximately 85.0% of its
operational costs associated with providing fire protection and emergency
medical services to the City of Live Oak.
- At the end of FY 2023, the City of Live Oak’s total revenues for providing fire
protection and emergency medical services amounted to about $305,000
and reflect an overall increase of 38.1% since the beginning of the report
period (FY 2023).
- Live Oak’s total expenditures for providing fire protection and emergency
medical services at the end of the FY 2023 totaled about $990,600,
representing an overall decrease of (28.9%) since the beginning of the report
period.
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- The City of Live Oak’s financial reports indicate the City uses fire-specific
revenue and the City’s General Fund to fund Department operations.
- The City is exploring the establishment of a permanent funding source, such
as a parcel tax, in order to fiscally sustain the City’s fire protection and
emergency medical services through its existing contract with Sutter County
Fire.
- The City of Live Oak has the financial ability to provide existing fire protection
and emergency medical services to residents; however, because costs
generally rise faster than revenues, it is unclear whether this level of service
can be sustained in the long term.
5. Opportunities for Shared Facilities
The City of Live Oak contracts with Sutter County Fire to provide fire protection and
emergency medical services to residents within city limits. Sutter County Fire utilizes
the City of Live Oak’s Station No. 5 and City-owned apparatus to provide these
services to the City of Live Oak. No other opportunities for shared facilities were
identified as part of this MSR.
6. Accountability for Community Service Needs, including Governmental Structure and
Operational Efficiencies
The Live Oak City Council holds regular public meetings on the first and third
Wednesday of every month. To enhance accountability and transparency, the City
of Live Oak may consider 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.
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7. Any Other Matter Related to Effective or Efficient Service Delivery as Required by
Commission Policy
Other matters related to effective or efficient service delivery as required by LAFCO
policy were not identified.
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Sutter County LAFCO is also directed to prepare a written statement of determinations in
determining the sphere of influence of each local agency enumerated under
Government Code Section 56425 whenever it prepares a sphere of influence update. The
purpose of the determinations is to provide an independent assessment to the City of Live
Oak’s ability to provide fire protection and emergency medical services to residents
within its sphere of influence now and in the near future.
SPHERE OF INFLUENCE DETERMINATIONS
1. Present and Planned Land Uses
Most land within the City of Live Oak sphere of influence consists of residential uses,
followed by commercial, industrial, civic, and public land uses. No other major
planned developments were identified as part of this MSR.
2. Present and Probable Need for Public Facilities and Services
The City of Live Oak’s sphere of influence defines the City’s current and probable
future boundary and service area for all municipal services provided, including fire
protection and emergency medical services. The City’s public facilities are
adequate to meet the current level of fire and emergency medical services now
and into the foreseeable future.
3. Present Capacity and Adequacy of Public Facilities
The City of Live Oak has sufficient capacity and adequate infrastructure and
related facilities to continue to provide fire protection and emergency medical
services to its residents now and in the future through its contract with Sutter County
Fire (“CSA F”). The comprehensive review of the Sutter County Fire capacity and
demands on page 57 in this report supports these claims.
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4. Presence of Social or Economic Communities of Interest
The City of Live Oak’s sphere of influence does not include any social or economic
communities of interests.
5. Present and Probable Need for Public Services of any Disadvantaged Unincorporated
Communities (“DUCs”)
According to Sutter LAFCO’s policies, there is one Disadvantaged Unincorporated
Community (DUC) located contiguous to the eastern boundary of the City of Live
Oak’s city limits and one Severely Disadvantaged Community (SDUC) located
contiguous to western boundary of the City of Live Oak’s city limits. Sutter County
Fire, specifically CSA F, is the primary fire protection and emergency medical
service providers to both of these areas.
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CITY OF YUBA CITY FIRE DEPARTMENT
The City of Yuba City was founded in 1849 by John A. Sutter, Pierson B. Reading, Henry
Cheever and Samuel Brannan who held the initial title to four square miles in the City.18 In
1856, Yuba City became the permanent Sutter County seat and was incorporated as a
California City on January 23, 1908.19 The City of Yuba City is situated in eastern Sutter
County on the western banks of the Feather River. The City is authorized to provide a
broad range of municipal services including planning, law enforcement, parks and
recreation, potable water, wastewater and fire protection.
The City of Yuba City Fire Department (“City” or “Department”) was established in 1909
to provide fire protection services to the City of Yuba City. In 2001, the City began
contracting with Sutter County to provide fire protection services to residents within CSA
G.
JURISDICTIONAL BOUNDARY & SPHERE OF INFLUENCE
The City’s current jurisdictional boundary spans an area of approximately 15 square miles
with an expanded sphere of influence designation. The City’s SOI currently spans
approximately 25 square miles and was established in 2021.
As of FY 2024, the total assessed value (land and structures) within Yuba City is
approximately $7.6 billion which translates to a per capita value of approximately
$108,800 based on the current resident service population.
BOGUE STEWART MASTER PLAN
In 2021, the City of Yuba City annexed approximately 741 acres, known as the Bogue
Stewart Master Plan area, located at the southern boundary of city limits. The Bogue
18 Sutter County Historical Society
19 Sutter County History website
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Stewart Master Plan area (“Plan area”) will include over 2,500 residential units, almost 1.2
million square feet of non-residential space, and 84 acres of parks, open space, and
public facilities. At build-out, the Plan area will result in an additional 6,720 residents and
1,894 employees. The project will be constructed in three distinct phases in which
development will initially occur along Highway 99 and then generally spread further to
the east and west.20
Figure 19 presents Yuba City’s sphere of influence in relation to its jurisdictional boundary.
20 Source: Bogue Stewart Master Plan (May 2019)
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Figure 19: Yuba City Jurisdictional Boundary and SOI Map
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DEMOGRAPHICS
POPULATION & HOUSING
The City’s total current resident population within its jurisdictional boundary is estimated
at 70,171 as of 2024. This amount represents 70.4% of the countywide population total.
The estimated resident population in the City has risen overall by 6.2% - or approximately
4,079 residents - since 2010, demonstrating an upward trend.21 The current resident
population produces a population density of 1.2 residents for every acre and underlies
the overall rural characteristic of the City’s jurisdictional boundary. The City primarily
consists of residential uses, which make up approximately 65.0% of land uses in the City.
The remaining land uses in the City include open space, commercial, and industrial uses.22
The City’s population is not expected to change over the next five-years. This growth is
slightly lower than the anticipated annual population growth countywide which is
expected to grow 0.03%, reaching 99,795 residents by 2029.
It is 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.
Figure 20 summarizes the City and the County’s past, present and future population
growth.
21 Source: ESRI Business Analyst
22 Source: Yuba City Land Use Element
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Figure 20: Yuba City’s Resident Population
There are an estimated 24,147 housing units within the City’s boundary as of FY 2024. This
amount accounts for an overall increase of 515 units – or 2.2% - since 2010 for an annual
change of 37 housing units. This creates a ratio of 0.13 housing units for every 1 new
resident. Furthermore, it is expected that the City’s total number of housing units will reach
24,243 housing units, an estimated 0.4% increase, by the year 2029.
Of the total number of current housing units in the City, approximately 55.1% are owner-
occupied. The remainder of housing units are divided between 41.1% being renter-
occupied and 3.7% being vacant. Further, the average household size in the City for 2024
is 2.99. This amount reflects an increase of 0.3% since 2010 wherein the average household
size was 2.98.
It is important to note, that these housing figures for Yuba City do not account for the
increased housing units anticipated as a result of the planned development of the Bogue
Stewart Master Plan community that is expected to consist of over 2,500 new housing
units within the 20 years.
Figure 21 includes additional details regarding Yuba City’s housing characteristics.
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Figure 21: Yuba City’s Housing Characteristics
AGE DISTRIBUTION & INCOME
Relative to the County as a whole, the population of the Yuba City service area has been
somewhat younger. The median age of residents in Yuba City is 36.8 and reflects an
increase of 10.5% from 33.3 since 2010. The current median age in Yuba City remains
slightly lower than the countywide median age of 37.5 demonstrating a younger resident
population.
Similarly, 91.9% - of residents within the prime working age group (between the ages of
25-64) are employed while the remaining 8.1% are unemployed, reflecting a stable
workforce within the City’s jurisdictional boundary.23 Additional details regarding Yuba
City’s age distribution and employment rates are provided in Figure 22
23 The prime working age group does not include individuals between the ages of 16-25 nor 65 and above given residents within
these age groups are typically in school or nearing/in retirement.
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Age Distribution City of Yuba City Sutter County
2010 Median Age 33.3 34.6
2024 Median Age 36.8 37.5
% Change (2010-2024) 9.5% 7.7%
2024 Employment Levels (Ages 25-64) 91.9% 92.5%
2024 Unemployment Levels (Ages 25-64) 8.1% 7.5%
Source: ESRI Business Analyst
.
Figure 22: Yuba City’s Age Distribution
Age Distribution City of Yuba City Sutter County
2010 Median Age 33.3 34.6
2024 Median Age 36.8 37.5
% Change (2010-2024) 9.5% 7.7%
2024 Employment Levels (Ages 25-64) 91.9% 92.5%
2024 Unemployment Levels (Ages 25-64) 8.1% 7.5%
Source: ESRI Business Analyst
The median household income of Yuba City is $66,687 which is approximately 6.0% lower
than the County’s median household income of $70,700. This amount confirms households
in Yuba City are receiving moderately less pay over the report period compared to the
county as whole. Furthermore, Yuba City has a poverty level rate of 13.7%, which is
approximately 3.6% higher than the County’s poverty level rate of 13.2%.24
According to Sutter LAFCO’s policies, there are three Severely Disadvantaged
Unincorporated Communities (SDUCs) contiguous to Yuba City’s corporate boundary. All
three SDUCs are located within County Service Area (CSA) G. An SDUC is defined as any
24 Federal poverty levels are determined annually by the U.S. Census Bureau which uses a set of money income thresholds that
vary by family size and composition to determine who is in poverty.
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unincorporated area wherein the median household income is less than $57,312.60.25
Figure 23 provides an overview of income characteristics in Yuba City and County.
Figure 23: Yuba City’s Income Characteristics
Income Characteristics City of Yuba City Sutter County
2024 Median Household Income $66,687 $70,700
2024 Median Household Income Per $31,607 $32,860
Poverty Level (2018-2022) 13.7% 13.2%
Source: ESRI Business Analyst
GOVERNANCE AND STAFFING
The City of Yuba City operates under a council-manager system, where the City Council
sets policies and the interim City Manager – Robert Bendorf – has the administrative
authority to implement such policies.26 The City of Yuba City’s Fire Department is governed
by the City Council which consists of a Mayor, Vice Mayor and three councilmembers.
Each member of the council is elected by district and serve four-year terms whereas the
Mayor and Vice Mayor serve one-year terms. The City Council regularly meets on the first
and third Tuesday of every month in the Council Chambers in the City Hall located at
1201 Civic Center Boulevard in Yuba City.
The Council appoints a Fire Chief to oversee the day-to-day operations of the District. The
current Fire Chief – Josh Hubbard – was appointed in July 2025. Yuba City’s total fire
services staff at the end of FY 2023 totaled 56.0 fulltime employees with no volunteers and
3 Fire Chiefs. Over the last five years between FY 2019 and FY 2023, Yuba City’s Fire
Department has decreased its staffing by 2 members, reflecting an overall change of
(3.4%). Yuba City Fire Department utilizes a three-platoon rotating system on a 48/96
25 Source: Government Code Section 56033.5 and 56046, Water Code Section 79505.5(a), Public Resources Code Section
75005(g), American Community Survey Census 2019-2023 data
26 Robert Bendorf was appointed interim City Manager in March 2025.
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schedule in which fire personnel work for 48 consecutive hours followed by 96 hours off
before the next duty period begins.
Figure 24 below summarizes the Departments total staff over the report period.
Figure 24: Yuba City Fire Department Historical Staffing
The Department employs two fire safety inspectors who work under the direction of the
Department’s Fire Marshal and focus on the fire prevention services of the Department.
The Department also employs two administrative positions who assist with overseeing the
day-to-day administrative tasks associated with the Department. These positions are
reflected in the total paid positions figure for FY 2023.
Department staff noted that while the Department currently has adequate staffing levels
to maintain its current level of services now and into the foreseeable future, the
Department may face budgeting challenges within the next two years to maintain its
current level of staffing. Discussed further in the Financials section of this Agency Profile,
the Department would have received a portion of the revenues collected from Measure
D—a 1% sales tax measure that failed when it went to the voters in November 2024—to
maintain existing fire department staffing levels after short-term grants expire.
Department staff indicated that while the Department can utilize its approximate $1.2
million award from the 2021 Staffing for Adequate Fire and Emergency Response (SAFER)
Grant to maintain a daily operational staffing of seventeen (17) personnel, the Grant is
not a permanent source of funding. However, the Yuba City City Council has the authority
to maintain a daily staffing level of seventeen (17) personnel after the SAFER grant period
ends.
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Training
The Yuba City Fire Department offers comprehensive training opportunities for its fire
safety personnel. Fire safety personnel are also required to maintain up-to-date
certifications and complete ongoing training for the Department’s specialized teams,
including its roles as Tactical Emergency Medical Support (“TEMS”) for local law
enforcement SWAT operations, the Department’s Hazardous Materials team, and the
Department’s water rescue team. The Department provides relevant information related
to its training procedures, including completed training courses, Department-wide
training hours, and training goals in its Annual Report that is published annually on its
website. According to the Department’s 2023 Annual Report, each Department member
completed an average of 299.6 training hours during the 2023 calendar year.
Trainings are conducted at the Department’s administrative building on a monthly basis.
The Department is also in the process of building a full training facility at the Department’s
Station No. 4 located at 150 Ohleyer Road. Department staff noted that the Department
invites neighboring districts to attend classroom-style trainings a few times a year.
MUNICIPAL SERVICES
The City of Yuba City established formal fire protection service in 1909 following the City’s
incorporation in 1908. As granted under Government Code Section 38600 et. seq., the
City of Yuba City is authorized to provide a full range of municipal services, most notably
including fire protection and emergency medical services.
Yuba City’s fire protection, rescue, and emergency medical services functions represent
the Department’s primary activity. Yuba City’s fire protection services include pre-
hospital emergency medical services, fire suppression, hazardous materials, technical
rescue, and water rescue. The emergency medical function is classified as basic life
support. The Sierra-Sacramento Valley EMS Agency designates Bi-County Ambulance as
the exclusive ambulance transport provider in Sutter County.
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The Yuba City Fire Department’s five (5) stations are staffed on a 48/96 schedule in which
fire personnel work for 48 consecutive hours followed by 96 hours off before the next duty
period begins. The Department’s fire stations are continuously staffed by a total of 17
public safety personnel across all five (5) stations. The current fire station details follow.
- Station No. 1 is located near the center of Yuba City city limits at 824 Clark Avenue.
The station was built in 1961 and is in poor condition due to its age and undersized
facilities for modern apparatus and equipment according to Department staff. The
station does not have the current capacity to accommodate existing call volume
due to limited space for fire personnel in living quarters. The station also only has
two (2) showers, which presents challenges for fire personnel when performing
decontamination procedures. Lastly, the station has structural deficiencies,
including leaks that occur in the station’s roof, according to Department staff.
- Station No. 2 is located towards the northern perimeter of Yuba City at 1641 Gray
Avenue. The station was built in 1979 and is expected to be in good condition
following a series of ongoing upgrades and expansions, which include new dorms,
bathrooms, a workout room, laundry room, and PPE storage. Kitchen and day room
upgrades have also been recently completed for this station.
- Station No. 3 is located towards the southeast perimeter of Yuba City at 795 Lincoln
Road. The station was built in 1993 and is in good to moderate condition according
to Department staff. The station recently underwent kitchen and dining room
upgrades. However, Department staff also indicated that the addition of a fourth
firefighter at the station has required two personnel to share a single sleeping
quarters, suggesting that the station’s living accommodations are undersized and
do not align with modern standards, which typically include private sleeping areas
for each firefighter.
- Station No. 4 is located outside of the southwest perimeter of Yuba City at 150
Ohleyer Road. The station is located outside of City limits in CSA G, which falls within
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the City’s sphere of influence. The station was built in 2009 and is in very good
condition according to Department staff. The Department is in the process of
building a full training facility at this station.
- Station No. 7 is located towards the northwest perimeter of Yuba City at 2855
Buttehouse Road. The station was built in 1993 and is in good to moderate condition
according to Department staff. Additionally, the station has adequate capacity to
meet modern standards.
- The Department also has a Fire Administration building that was built in 2002. The
building contains a training classroom and training tower for scheduled
Department trainings. According to Department staff, the building is in good
condition.
All five (5) of the Department’s fire stations have exhaust removal systems for the
apparatus bay floors. This is beneficial to staff, as diesel exhaust emissions were
designated as a carcinogen in 1998. Ongoing exposure to diesel exhaust has been linked
to lung cancer and bladder cancer, and a suspected cause of other types of cancer.
The National Fire Protection Association (NFPA) 1500: Standard on Fire Department
Occupational Safety, Health and Wellness Program section 10.1.5 specifies “The fire
department shall prevent exposure to firefighters and contamination of living and
sleeping areas to exhaust emissions through the use of direct or source capture systems.”
Though a station may have a door between the apparatus bay and the living and
sleeping quarters, the door alone will not prevent diesel exhaust emissions from entering
and remaining in other locations of the facility. Exhaust removal systems capture the
emissions at the tailpipe of the apparatus and typically remove the emissions to the
exterior of the building.
It should also be noted that the Department installed Personal Protective Equipment
(“PPE”) storage facilities at all of its station through the Department’s Cancer Task Force.
This addition helps limit exhaust and carcinogen exposure from contaminated PPE.
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Additionally, with the exception of Station No. 7, the Department’s fire stations, and Fire
Administration building are equipped with automatic fire sprinkler systems. An automatic
fire sprinkler system is activated by temperature rise from the fire; the sprinkler head(s)
closest to the fire activate when their heat-rated fusible link melts, releasing water to
suppress the flames. Facilities protected by an automatic sprinkler system reduce the
chance of loss of the facility in the event of a fire starting within the building by slowing
the fire’s growth or extinguishing the fire completely. The sprinkler system protects the
apparatus and equipment housed within, and most importantly, they allow personnel
stationed within the facility to evacuate safely in the event of a fire within, and begin an
attack of the fire.
The Department currently has a total of nineteen (19) fire apparatus. The Department
does not have an apparatus replacement policy; however, it follows the National Fire
Protection Association (“NFPA”) recommendation of a 20-year life expectancy with 10
years as a first-out apparatus.27 Department staff indicated that due to projected service
demands increasing for Station No.1, the Department will need to purchase an additional
apparatus in the near future in order to address the anticipated increase in service
demand levels, which will also require additional personnel to staff the engine.
Figure 25 summarizes the Department’s station staffing and apparatus conditions as of FY
2023.
27 The City of Yuba City does not have a City Vehicle Replacement Plan in the format of a description or program. Instead, the
City has financial accounts set up where money is allocated in the format of funding to be used for specific equipment and
response vehicles. The City maintains a spreadsheet to document the funds and allocation to various city vehicles and City
emergency response vehicles.
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Figure 25: Yuba City’s Fire Station(s) Assignments as FY 2023
Yuba City also supplements its fire protection and emergency medical services by
maintaining reciprocal automatic/mutual aid agreements with neighboring jurisdictions.
Specifically, the Department has automatic and mutual aid agreements with Sutter
County Fire and the Marysville Fire Department in Yuba County. The Department also has
mutual aid agreements with the Linda Fire Protection District in Yuba County, in addition
to an agreement with the Beale Air Force Base also located in Yuba County. In addition
to these local agreements, the Department participates in California’s statewide mutual
aid system, enabling it to both provide and receive assistance during large-scale
emergencies when local resources are exceeded.
The Department also supports specialized regional response capabilities, such as its
participation as a Tactical Emergency Medical Support (“TEMS”) provider in the local law
enforcement Special Weapons and Tactics (“SWAT”) response team. Department
personnel respond to these incidents within Yuba City and throughout the broader Bi-
County region.
SERVICE DEMANDS AND CAPACITY
Overall demands for fire protection and emergency medical services for the City of Yuba
City during the FY 2019 to FY 2023 reporting period have averaged 11,055 dispatched
calls annually or 30.3 calls daily. Onsite arrivals necessitating fire protection services
averaged 341 calls between FY 2019 and FY 2023. Annual onsite incident demands slightly
increased during FY 2019 to FY 2023 with an overall change of 1.97%. The Department’s
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peak demand was recorded in FY 2022 which reflected a daily onsite response of 31.2
calls for service. Figure 26 below summarized Yuba City’s fire protection and emergency
medical demands during FY 2019 – FY 2023
Figure 26: Yuba City’s Service Demands between FY 2019 and FY 2023
Department staff indicated that the call volume provided in Figure 26 also reflects calls
for service in CSA G where the Department is contracted to provide fire protection and
emergency medical services. Department staff noted that it can be challenging to
separate CSA G calls from the Department’s total call volume since each service call’s
location would have to be evaluated on a call-by-call basis. However, in 2022, the
Department attempted to track its calls for service in the CSA G service area and
estimates that it responded to approximately 1,078 calls in CSA G that calendar year. This
equates to approximately 9.4% of the Department’s total call volume in 2022.
SERVICE PERFORMANCE
With respect to the Yuba City Fire Department’s ability to meet existing fire protection
and emergency medical service demands within its service area, the Department – as
measured by staffing and equipment – appears sufficiently sized to readily
accommodate the existing demands within its jurisdictional boundary through the
timeframe of this report. The Department also appears sufficiently sized to accommodate
the existing demands within the CSA G service area. Additional details regarding the
Department’s service performance can be found below:
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- The Department’s most recent evaluation of structural fire protection capabilities
from the Insurance Services Office (ISO) resulted in a Class 2 rating for the
Department.28 This rating indicates the Department provides robust fire protection
services for residents within its service area. The ISO score is a measure of the
capability of the fire department to protect the community and is rated on a scale
of 1 to 10, with 1 being the highest rating. ISO evaluates the fire department for
apparatus and equipment, weight of response (number of firefighters arriving on
scene), training, water supply and distribution, emergency communications
systems, and fire prevention/community risk reduction efforts. Department staff
noted that the Department’s limiting factor for improving its ISO rating is the
Department’s dispatch center—the Yuba City Police Department dispatch
center—which only has two (2) dispatch positions on at any given time to process
9-1-1 incoming calls, dispatch calls for service, and support radio communications
on two separate radio frequencies for police and fire.
- The City of Yuba City’s adopted internal response time standard for fire protection
and emergency medical calls is arrival within six (6) minutes of the 9-1-1 call being
received, 90 percent of the time. Figure 27 details the Department’s average
response times in FY 2023.29
Figure 27: Yuba City Fire Department Average Response Times (2023)
Call Type Average Response Time
Structure Fires 5 minutes 9 seconds
Emergency Medical Services 5 minutes 29 seconds
All Calls 5 minutes 45 seconds
Source: Yuba City Fire Department Annual Report (2023)
28 The ISO classifications are ranked between 1 and 10 and are designed to assess a fire service providers ability to protect local
communities based on uniform measurements. The data is used by fire departments to help measure the effectiveness of their fire
protection services whereas insurance companies use it when establishing premiums for fire insurance. A Class 1 rating typically
reflects superior property fire protections and can help lower the insurance premiums within a community.
29 The response time data presented in this table was provided directly by the respective fire protection service provider. RSG and
Planwest rely on the accuracy of the information submitted and is unable to independently verify this data.
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According to Department staff, the Department was in the 91st percentile for its six (6)
minute response time standard for all service calls. As a result, the Department was in
compliance with its established internal response time standards for FY 2023.
Emergency Medical Services in Yuba City
As shown in Figure 26, the Yuba City Fire Department is responsible for a relatively high
volume of service calls within its service area, with the vast majority of its service calls
resulting from calls for emergency medical services. While local fire agencies are usually
the first to arrive on-scene for EMS calls, the Yuba City Fire Department relies on the
designated ambulance transport provider in Sutter County - Bi-County Ambulance - to
provide essential advanced life support (“ALS”) medical services to critical patients. While
Bi-County Ambulance has consistently met its response time standards during the
reporting period for service calls within Yuba City, Department staff indicated that there
may be potential opportunities to further enhance EMS services and provide the highest
standard of care. Potential opportunities include the implementation of a Community
Paramedicine Program or the implementation of priority dispatching to better allocate
paramedic resources:
- Community Paramedicine Programs: Health and Safety Code Section 1840 enables
local EMS agencies to develop community paramedicine programs or triage to
alternate destination programs in which paramedics provide healthcare services
in non-emergency settings or transport 911 callers to non-emergency facilities.30
While these programs are relatively new and evolving in the state of California, the
goal of community paramedicine programs is to reduce unnecessary 911 calls,
reduce emergency room visits, and improve services provided to frequent EMS
users. At present, there is limited information available regarding the successful
30 Community paramedicine or triage to alternate destination program must be consistent with the Emergency Medical Services
Authority’s regulations and the provisions of the Health and Safety Code and submit evidence of compliance with the
requirements of Section 1841 and Sections 1842 and 1843, as applicable, to the Emergency Medical Services Authority (EMSA) for
approval pursuant to Section 1835.
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implementation of these programs in California, however, Department staff noted
that similar programs have been successfully implemented in the state of
Colorado. For instance, the Colorado Springs Fire Department established a
Community Assistance, Referral & Education Services (CARES) program in 2012. The
CARES program provides intensive outreach, case management, and care
navigation for vulnerable populations including people experiencing
homelessness, high-risk inmates, frequent EMS users, and at-risk seniors.31
To evaluate the feasibility of implementing one of these programs, the Yuba City
Fire Department could coordinate closely with S-SV EMS to assess community needs
and identify populations who frequently use EMS services. This coordination could
also include reviewing relevant state guidance, examining successful models from
other jurisdictions, and developing a collaborative framework for program design,
approval, and oversight.
- Priority Dispatching: In addition to a community medicine or triage to alternate
destination program, the implementation of priority dispatching could also
enhance emergency medical services in Yuba City. Priority dispatching refers to a
structured dispatch system that relies on protocols developed and researched by
the International Academies of Emergency Dispatch to give dispatchers guidelines
and priorities for how incidents should be prioritized and handled. This means
categorizing 911 medical calls by severity and urgency, which can improve
resource allocation by ensuring critical calls receive faster and specialized care.
As of June 2025, the Yuba City Dispatch Center has initiated the implementation
of priority dispatch protocols. Dispatch personnel have completed priority dispatch
training and the system infrastructure has been fully developed and deployed.
Dispatch personnel are currently applying the established criteria to each Fire/EMS
call received. While the Yuba City Fire Department has not yet activated the call
31 Source: City of Colorado Springs website
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categorization function to determine response levels, activation of this feature is
anticipated in the near future.
Lastly, some local fire agencies could also implement ALS capabilities on one or more fire
engines to improve service performance measures within their service area. These
programs can offer significant benefits, including faster access to advanced medical
care, improved patient outcomes, and more efficient use of emergency medical
resources—allowing fire-based ALS units to stabilize patients while ambulance transport
units focus on the most critical cases. However, the implementation of ALS programs
involves substantial initial and ongoing investments. These include higher personnel costs
due to the need for certified paramedics, increased training and certification
requirements, heightened regulatory compliance, and the acquisition and maintenance
of specialized medical equipment and supplies. The City of Richmond, for example,
recently completed a draft Advanced Life Support First Responder Feasibility Study and
estimated approximately $7.8 million in costs associated with the creation of an ALS
program over the first 67 months.32
While the current Ambulance Transport Provider agreement between the Sierra-
Sacramento Valley EMS Agency (“S-SV EMS”) and Bi-County Ambulance establishes an
exclusive operating area for ambulance transport services in Sutter County, S-SV EMS
requirements do not prevent several service providers from providing ALS services within
the established exclusive operating area, on either a full-time or part-time basis as ALS
staffing allowed. However, the decision to implement ALS capabilities would require
careful consideration of the substantial costs associated with program development,
including personnel, training, regulatory compliance, equipment, and ongoing
operations.
32 Source: Agenda Report - Draft Advanced Life Support (ALS) First Responder Feasibility Study - https://pub-
richmond.escribemeetings.com/filestream.ashx?DocumentId=57829&ref=grandviewindependent.com.
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FISCAL HEALTH
The sections that follow evaluate the City of Yuba City’s Fire Department’s (“Yuba City”
or “Department”) fiscal health, inclusive of revenue sources and major expenditure
categories.
REVENUES & EXPENDITURES
Yuba City’s total average revenues between FY 2019 and FY 2023 totaled $1.33 million.
The largest single source of the Department’s revenue is from its Fire Services Contract to
provide services to CSA G which account for $928,000 – or 72.3% - of all revenues for the
Department as of FY 2023. The remainder of revenues for the Department are derived
from income from fees, emergency response, and special services. At the end of FY 2023,
Yuba City’s total revenues amounted to $1.28 million and reflect an overall increase of
$88,000 – or 7.4%.
With respect to expenditures, Yuba City’s total average annual expenses over the report
period have been $12.4 million. The Department’s expenses are further broken down into
two categories: (a) Administrative; and (b) Operation. The Department’s costs associated
with Operation account for nearly nine-tenths– or 88.6% - of Department’s expenditures,
at $13.1 million as of FY 2023. Department staff also indicated that there is an approximate
$400,000 cost shortage for the Department’s existing contract with County Fire to provide
fire protection and emergency medical services to CSA G.
Yuba City’s total expenditures at the end of FY 2023 totaled $14.8 million, accounting for
an overall increase of $3.3 million since FY 2019. This amount translates to a per capita
cost of $210 based on an estimated resident service population of 70,218 as of FY 2023.
Furthermore, mentioned previously, Measure D—a Yuba citywide 1% sales tax measure—
did not pass when it went to the voters in November 2024. A portion of the revenue
measure would have contributed to maintaining existing fire department staffing levels,
in addition to improvements to the Department’s Fire Station No.1. Department staff
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indicated that while the Department can utilize its approximate $1.2 million award from
the 2021 Staffing for Adequate Fire and Emergency Response (SAFER) Grant to maintain
a daily operational staffing on seventeen (17) personnel, the Grant is not a permanent
source of funding. However, the Yuba City City Council has the authority to maintain a
daily staffing level of seventeen (17) personnel after the SAFER grant period ends.
Additional details regarding Yuba City’s total revenues and expenditures are provided in
Figure 28.
Figure 28: Cash Flow – Yuba City Fire Department
Yuba City Fire Revenues (Actuals) 2019 2020 2021 2022 2023 Average Trend
Category:
Permit fees $ 9 5,084 $ 133,517 $ 82,046 $ 106,017 $ 135,099 $ 110,353 42.1%
Special services 5 ,618 5,577 170 16,487 25,696 10,710 357.4%
Emergency response 2 98,625 49,099 640,987 571,876 186,171 349,352 -37.7%
Fire service contract 7 87,572 844,968 838,155 880,481 928,169 855,869 17.9%
Mitigation Fees 2 27 3,413 1,505 4,389 863 2,079 280.2%
Total Revenue $ 1 ,186,899 $ 1,033,161 $ 1,561,358 $ 1,574,861 $ 1,275,135 $ 1,326,283 7.4%
Per capita $ 1 6.97 $ 14.68 $ 22.21 $ 22.41 $ 18.16 $ 18.89 7.0%
Yuba City Fire Expenses (Actuals) 2019 2020 2021 2022 2023 Average Trend
Category:
Admin $ 1 ,651,496 $ 1,750,724 $ 1,107,926 $ 1,265,224 $ 1,677,330 $ 1,490,540 1.6%
Operation 9 ,844,521 9,884,668 10,160,617 11,513,467 13,082,672 10,897,189 32.9%
Total Expenses $ 1 1,496,017 $ 11,635,392 $ 11,268,543 $ 12,778,691 $ 14,760,002 $ 12,387,729 28.4%
Per capita $ 1 64.39 $ 165.37 $ 160.26 $ 181.86 $ 210.20 $ 176.42 27.9%
Surplus/(deficit) $ (10,309,118) $ (10,602,231) $ (9,707,185) $ (11,203,830) $ (13,484,867) $ (11,061,446) 30.8%
Source: Yuba City's Annual Budget FY 2019 - 2023
It is important to note that while the City of Yuba City’s financial reports reveal a
consistent revenue shortfall in each fiscal year of the report period, the gap is likely
covered by the City’s General Fund. While RSG was unable to confirm the additional
sources of revenues that offset costs incurred from fire-related services, RSG identified
certain allocations from taxes the City receives within the Department’s annual budgets
that are assumed to recover costs associated with fire-related activities for the City.
Additional details regarding these tax allocations are provided in Figure 29.
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Figure 29: Tax Allocations – Yuba City Fire Department
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SOI/BOUNDARY & OTHER RECOMMENDATIONS – CITY OF YUBA
CITY FIRE DEPARTMENT
The following recommendations call for specific action from Sutter LAFCO, Yuba City, and
the Yuba City Fire Department, and pertain to the City of Yuba City’s sphere of influence
(“SOI”) amendments, boundary changes, and any other recommendations:
1. Sutter LAFCO may consider adopting a “Fire/EMS Only” Sphere of Influence for the
CSA G area to formalize and solidify the City of Yuba City’s contract position to
deliver of fire protection and emergency medical services to the CSA G service
area dating back to the establishment of CSA G in 2001. By formally adopting a
“Fire/EMS Only” Sphere of Influence, Sutter LAFCO could also clarify boundaries
and responsibilities for service provision to the CSA G area. At present, the CSA G
jurisdictional boundary follows a roughly square shape bound by Eager Road to
north, North Township Road to the west, the Feather River to the east, and Reed
Road to the south, which may not accurately reflect actual population densities,
locations of fire stations, and service demands. By aligning the potential “Fire/EMS
Only” Sphere of Influence more closely with actual service needs and area, Sutter
LAFCO could ensure that the Yuba City Fire Department’s existing and future
delivery of fire protection and emergency medical services to the CSA G area are
accurately reflected by way of a formalized sphere of influence.
Yuba City provides several other municipal services, including law enforcement,
wastewater services, and parks and recreation, among others. As an alternative to
establishing a Fire/EMS Only SOI, Sutter LAFCO may consider reviewing Yuba City’s
SOI and municipal services holistically at a later date, and establishing a new SOI
at that time, with the knowledge that the existing SOI and CSA G boundary may
not accurately reflect the City’s fire and emergency medical service area.
2. The Yuba City Fire Department may consider separately tracking calls for service
in the CSA G service area. While Department staff noted challenges with tracking
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calls for service in the area since each call’s location would have to be evaluated
on a call-by-call basis, it would allow the Department to better understand existing
service demands and trends in the area, improve resource allocation, and ensure
long-term financial sustainability of providing services to the area. Department staff
indicated that there is an approximate $400,000 annual cost shortage for the
Department’s existing contract with Sutter County to provide fire protection and
emergency medical services to CSA G. By better understanding the amount of
service calls attributable to only the CSA G area, the Department can develop a
more accurate picture of costs associated with providing fire protection and
emergency medical services in the future to ensure that contract amounts
adequately cover the cost of providing services to CSA G service area.
3. The Yuba City Fire Department may consider establishing a permanent funding
source, such as a special assessment or parcel tax, to ensure the long-term
operational sustainability of fire and emergency medical services. The Department
is utilizing its 2021 Staffing for Adequate Fire and Emergency Response (“SAFER”)
Grant to maintain a daily staffing level of seventeen (17) personnel, however, the
Department may face budgeting challenges within the next two (2) years to
maintain these staffing levels once the grant period ends. Measure D, a citywide
1% sales tax measure, would have gone towards maintaining existing fire
department staffing levels at the Department, but it failed to pass on the November
2024 ballot. However, the need for stable, dedicated funding for fire, rescue, and
emergency medical services remains as the Department continues to face
increasing demand for fire protection and emergency medical services. A
permanent funding source would offer greater financial stability, enabling the
Department to plan for future staffing needs, training, and the acquisition of new
equipment.
4. Sutter LAFCO may also consider exploring a broader, countywide consolidation of
all fire protection service providers in the County in the long term. Countywide
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consolidation may offer several long-term benefits to fire protection and
emergency services in Sutter County, including enhanced operational efficiency,
improved coordination of resources, elimination of service redundancies, and
more equitable delivery of fire protection and emergency medical services across
service area. Given the fiscal and staffing constraints faced by several of its existing
providers, consolidation may serve as a strategic pathway to strengthen service
reliability, ensure consistent standards of training and equipment, and improve
long-term fiscal sustainability.
To inform future decision making regarding countywide consolidation, it is
recommended that all fire protection service providers within the County
participate in a comprehensive Standards of Response Coverage (“SORC”) study.
This analysis should evaluate response times, station locations and coverage,
staffing, wages, benefits including pensions, and a forecast of past, current, and
future service delivery needs. Importantly, the study should also assess the financial
feasibility of a consolidated fire protection system.
MSR & SOI DETERMINATIONS – CITY OF YUBA CITY FIRE
DEPARTMENT
Sutter County LAFCO is directed to prepare written determinations to address the various
governance factors enumerated under Government Code Section 56430 whenever it
prepares a municipal service review. These determinations serve as independent
statements derived from the information collected, analyzed, and presented in the report
by RSG and Planwest. The purpose of the determinations is to provide an independent
assessment to the City of Yuba City’s ability to provide fire protection and emergency
medical services to residents within its jurisdictional boundary now and in the near future.
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SERVICE PROVISION DETERMINATIONS
1. Growth and Population Projections
- There are approximately 70,171 residents in the City of Yuba City as of 2024. The
city of Yuba City added approximately 4,079 new residents since 2010.
- The City of Yuba City added approximately 515 new housing units since 2010. This
new development accounts for an annual increase of 37 new units each year.
- Since 2010, the rate of new housing units has outpaced the population growth rate,
indicating a surplus of housing production within the City limits.
- The City of Yuba City resident population is not projected to experience any growth
by the year 2029, not including population growth attributed to the Bogue Stewart
Master Plan development. The Bogue Stewart Master Plan development will add
approximately 6,700 residents to the City’s resident population at build out.
- The number of housing units in the City of Yuba City is expected reach 24,243
housing units by 2029, not including housing growth attributed to the Bogue Stewart
Master Plan development. This accounts for an annual growth rate of
approximately 0.4%. The Bogue Stewart Master Plan will separately add over 2,500
new housing units at built out.
2. Location and Characteristics of Disadvantaged Unincorporated Communities within or
Contiguous to SOI
According to Sutter LAFCO’s policies, there are three Severely Disadvantaged
Unincorporated Communities (SDUCs) contiguous to Yuba City corporate limits. All
three SDUCs are located within County Service Area (CSA) G. The Yuba City Fire
Department is the primary fire protection and emergency medical services
provider to these SDUCs.
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3. Present and Planned Capacity of Facilities, Adequacy of Public Services, and
Infrastructure Needs and Deficiencies in any Disadvantaged Unincorporated
Communities within or Contiguous to SOI
The following statements apply to the City of Yuba City’s Fire Department (“Yuba
City” or “Department”) with respect to the availability, adequacy, and
performance of its fire protection and emergency medical services available
under Government Code Section 38611. These statements serve to confirm RSG
and Planwest Partner’s determination that Yuba City has adequate capacity,
infrastructure and availability to continue to provide fire protection and
emergency medical services to its residents now and into the foreseeable future
with the exception of issues identified with one of its fire stations detailed below.
- Yuba City provides fire protection and emergency medical services by way
of a formal contract with CSA G (“Sutter County Fire”) out of its five (5) fire
stations with a total public safety staffing of 56.0 full time equivalent
personnel as of the end of the FY 2023.
- Four (4) of the fire stations are located within City limits, while one (1) fire
station (Station No.4) is located within CSA G. The Department also has a Fire
Administration building that is utilized for administrative personnel and
Department training sessions.
- Department staff indicated that the Department’s Station No.1 is in poor
condition. The station does not have the current capacity to accommodate
existing call volume due to limited space for fire personnel in living quarters,
in addition to inadequate space for the Department’s modern apparatus
and equipment.
- Department staff indicated Station No. 1 will need to acquire an additional
apparatus in the near future in order to address the anticipated increase in
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service demand levels out of the station. This acquisition will also necessitate
additional personnel to adequately staff the apparatus.
- The Department’s Station No. 2 is expected to be in good condition following
a series of ongoing upgrades and expansions, which include new dorms,
bathrooms, a workout room, laundry room, and PPE storage. Kitchen and
day room upgrades have also been recently completed for this station.
- The Department’s Station No. 3 is in moderate to good condition and
recently underwent kitchen and dining room upgrades. However, the station
has shared sleeping quarters and, as a result, does not meet modern
accommodation standards.
- The Department’s Station No. 4 is in very good condition. The Department is
in the process of building a full training facility at this station.
- The Department’s Station No. 7 is in good to fair condition according to
Department staff. Additionally, the station has adequate capacity to meet
modern standards.
- The Department also has a Fire Administration building that was built in 2002.
The building contains a training classroom and training tower for scheduled
Department trainings.
- Overall demands for fire protection and emergency medical services for the
City of Yuba City and CSA G during FY 2019 through FY 2023 have averaged
11,055 dispatched calls annually or 30.3 calls daily. Overall demands during
the report period have increased slightly by 2.0%.
4. Financial Ability to Provide Services
The City of Yuba City has the financial ability to provide fire and emergency
medical services to its existing residents within City limits, in addition to CSA G.
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However, continued service to both of these areas will require ongoing evaluation
of the City’s fiscal capacity, including the long-term availability of General Fund
revenues, growth in service demands, and the cost of maintaining adequate
staffing, equipment, and infrastructure. Additional details can be found below.
- At the end of FY 2023, the City of Yuba City’s total fire-specific revenues
amounted to $1.28 million and reflect an overall increase of 7.4% since FY
2019.
- The Department’s total expenditures for fire protection and emergency
medical services at the end of FY 2023 totaled $14.8 million, representing an
overall increase of $3.3 million since the beginning of FY 2019.
- Department staff indicated that there is an approximate $400,000 annual
cost deficit for the Department’s existing contract with County Fire to
provide fire protection and emergency medical services to CSA G.
- The Department is currently utilizing its 2021 Staffing for Adequate Fire and
Emergency Response (SAFER) Grant to maintain existing staffing levels. The
Department may face budgeting challenges within the next two (2) years to
maintain these staffing levels once the grant period ends.
- The City of Yuba City’s financial reports indicate the City uses fire-specific
revenue and the City’s General Fund to fund Department operations.
5. Opportunities for Shared Facilities
The City of Yuba City is the contracted fire protection and emergency medical
service provider to CSA G. The Department also maintains reciprocal
automatic/mutual agreements with Sutter County Fire, the City of Marysville Fire
Department in Yuba County, the Linda Fire Protection District in Yuba County, in
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addition to an agreement with the Beale Air Force Base in Yuba County. No other
opportunities for shared facilities were identified as part of this MSR.
6. Accountability for Community Service Needs, including Governmental Structure and
Operational Efficiencies
The Yuba City City Council holds regular public meetings on the first and third
Tuesday of every month. The Yuba City Fire Department updates its website
regularly and posts relevant information related to the Department’s services. The
Department also publishes an Annual Report that is posted on its website and
provides comprehensive information including, but not limited to, the
Department’s organizational chart, historical call volume, training information, and
response times.
7. Any Other Matter Related to Effective or Efficient Service Delivery as Required by
Commission Policy
Other matters related to effective or efficient service delivery as required by LAFCO
policy were not identified.
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Sutter County LAFCO is also directed to prepare a written statement of determinations in
determining the sphere of influence of each local agency enumerated under
Government Code Section 56425 whenever it prepares a sphere of influence update. The
purpose of the determinations is to provide an independent assessment to the City of
Yuba City’s ability to provide fire protection and emergency medical services to residents
within its sphere of influence now and in the near future.
SPHERE OF INFLUENCE DETERMINATIONS
1. Present and Planned Land Uses
Most land within the City of Yuba City sphere of influence consists of residential
uses, followed by open space, commercial, and industrial uses. The City annexed
approximately 741 acres in 2021, known as the Bogue Stewart Master Plan area.
The Bogue Stewart Master Plan area will include over 2,500 residential units, almost
1.2 million square feet of non-residential space, and parks, open space, and public
facilities. No other major planned developments were identified as part of this MSR.
2. Present and Probable Need for Public Facilities and Services
The City of Yuba City’s sphere of influence defines the City’s current and probable
future boundary and service area for all municipal services provided, including fire
protection and emergency medical services. The City’s public facilities are
adequate to meet the current level of fire and emergency medical services now
and into the foreseeable future.
3. Present Capacity and Adequacy of Public Facilities
The City of Yuba City has sufficient capacity and adequate infrastructure and
related facilities to continue to provide fire protection and emergency medical
services to its residents now and in the future within City limits and CSA G. However,
Department staff indicated Station No. 1 will need to acquire an additional
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apparatus in the near future in order to address the anticipated increase in service
demand levels out of the station.
4. Presence of Social or Economic Communities of Interest
The City of Yuba City’s sphere of influence does not contain any social or
economic communities of interest.
5. Present and Probable Need for Public Facilities and Services of any Disadvantaged
Unincorporated Communities (“DUCs”)
According to Sutter LAFCO’s policies, there are three Severely Disadvantaged
Unincorporated Communities (SDUCs) contiguous to Yuba City corporate
boundary. All three SDUCs are located within the City of Yuba City’s sphere of
influence in County Service Area (CSA) G. At present, the Department has sufficient
capacity and adequate infrastructure to continue to provide fire protection and
emergency medical services to these areas. However, Department staff indicated
it will need to purchase an additional apparatus in the near future in order to
address the anticipated increase in service demand levels out of its Station No.1.
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COUNTY SERVICE AREA C
County Service Area C (“CSA C”) – also referred to as the East Nicolaus Fire Department
- is a dependent special district formed in 1963 and is legally authorized to provide fire
protection and emergency medical services in the southeast portion of Sutter County.
CSA C’s jurisdictional boundary currently spans approximately 62 square miles and is
anchored by Robbins Sutter Basin Fire Protection District and County Service Area F to the
west, Yuba County to the north, Placer County to the east, and County Service Area D
to the south.
JURISDICTIONAL BOUNDARY & SPHERE OF INFLUENCE
CSA C’s current jurisdictional boundary spans an area of approximately 62 square miles
with a coterminous sphere of influence designation. The District’s sphere was last updated
in 2017.
As of FY 2023, the total assessed value (land and structures) within CSA C is approximately
$470.1 million, or a per capita value of approximately $325,772 based on the current
resident population of 1,443.
Figure 30 presents CSA C’s sphere in relation to its jurisdictional boundary.
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Figure 30: CSA C Jurisdictional Boundary and SOI Map
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DEMOGRAPHICS
POPULATION & HOUSING
CSA C’s total current resident population within its jurisdictional boundary is estimated at
1,443 as of 2024. This amount represents 1.4% of the countywide population total. The
estimated resident population in CSA C has decreased overall by (8.9%) - or
approximately 141 residents - since 2010, demonstrating a downward trend.33 Similarly,
CSA C experienced a loss of 12 residents each year since 2020, from 1,492 to 1,443 in
2024. The current resident population produces a population density of 0.4 residents for
every acre and underlies the overall rural characteristic of CSA C’s jurisdictional
boundary. The CSA C jurisdictional boundary primarily consists of residential uses,
agricultural and public land uses.34 While not located in the CSA C jurisdictional boundary,
the Sutter Pointe Specific Plan is a master-planned, mixed-use community located in the
nearby CSA D jurisdictional boundary that will include a combination of residential,
employment, service, open space, and public uses. The Plan area will support
approximately 17,500 dwelling units, 47,000 residents, and provide jobs for approximately
63,000 employees at build out. The first phase of the Sutter Pointe Specific Plan area is
expected to begin in the fall of 2025.
CSA C’s population is expected to decline by approximately (0.25%) annually over the
next five-years, falling to 1,425 residents by 2029 and reflects an overall decrease of 18
residents.35 On the contrary, the countywide population is expected to grow 0.03%,
reaching 99,795 residents by 2029. Figure 31 summarizes CSA C’s and the County’s past,
present and future population growth.
33 Source: ESRI Business Analyst
34 Source: Sutter County 2030 General Plan
35 Source: ESRI Business Analyst
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Figure 31: CSA C’s Resident Population
There are an estimated 613 housing units within CSA C’s boundary as of FY 2024. This
amount accounts for an overall decrease of 36 units – or (5.5%) - since 2010 for an annual
change of 3 housing units. The CSA’s total number of housing units are expected to
remain the same over the next five years.
Of the total number of current housing units in CSA C, approximately 60.2% are owner-
occupied. The remainder of housing units are divided between 29.9% being renter-
occupied and 10% being vacant. Further, the average household size in CSA C for 2024
is 2.61. This amount reflects a decrease of (3.7%) since 2010 wherein the average
household size was 2.71. Figure 32 includes additional details regarding CSA C’s housing
characteristics.
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Figure 32: CSA C’s Housing Characteristics
AGE DISTRIBUTION & INCOME
Relative to the County as a whole, the population of the CSA C service area has been
somewhat older. The median age of residents in CSA C is 42.7 and reflects a decrease of
(2.8%) from 42.7 since 2010. The current median age in CSA C remains slightly higher than
the countywide median age of 37.5 demonstrating an aging resident population.
Similarly, 95.6% - of residents within the prime working age group (between the ages of
25-64) are employed while the remaining 4.4% are unemployed, reflecting a stable
workforce within the District’s jurisdictional boundary.36 Additional details regarding CSA
C’s age distribution and employment rates are provided in Figure 33.
36 The prime working age group does not include individuals between the ages of 16-25 nor 65 and above given residents within
these age groups are typically in school or nearing/in retirement.
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Figure 33: CSA C’s Age Distribution
Age Distribution CSA C Sutter County
2010 Median Age 43.9 34.6
2024 Median Age 42.7 37.5
% Change (2010-2024) -2.8% 7.7%
2024 Employment Levels (Ages 25-64) 95.6% 92.5%
2024 Unemployment Levels (Ages 25-64) 4.4% 7.5%
Source: ESRI Business Analyst
The median household income within CSA C is $104,211 which is approximately 32.2%
higher than the County’s median household income of $70,700. This amount suggests
households in CSA C are receiving more pay over the report period compared to the
county as whole. Furthermore, CSA C has a poverty level rate of 11.8%, which is
approximately (11.9%) lower than the County’s poverty level rate of 13.2%.
According to Sutter LAFCO’s policies, there is one (1) Disadvantaged Unincorporated
Communities (“DUCs”) contiguous to the western boundary of CSA C in the Sutter Basin
Fire Protection District. The Sutter Basin Fire Protection District is the primary fire protection
and emergency medical services provider to this DUC. A DUC is defined as any
unincorporated area wherein the median household income is less than $76,416.80.37
Figure 34 provides an overview of income characteristics in CSA C and County.
37 Source: Government Code Section 56033.5 and 56046, Water Code Section 79505.5(a), Public Resources Code Section
75005(g), American Community Survey Census 2019-2023 data
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Figure 34: CSA C’S Income Characteristics
Income Characteristics CSA C Sutter County
2024 Median Household Income $104,211 $70,700
2024 Median Household Income Per $50,734 $32,860
Poverty Level (2018-2022) 11.8% 13.2%
Source: ESRI Business Analyst
GOVERNANCE AND STAFFING
The County Service Area C (“CSA C”) operates as a county-dependent special district
under the County Service Area Law and codified under Government Code Section 25210
et seq. The act empowers CSA districts to provide a range of municipal services in the
county upon approval by LAFCOs - including but not limited to – water, wastewater,
police protection, and fire protection. CSA C is currently authorized by Sutter LAFCO to
provide fire protection and emergency medical services within unincorporated Sutter
County. The remaining service functions (i.e., powers) enumerated under the principal
act are deemed latent, meaning they are authorized by statute but would need to be
formally activated by Sutter LAFCO at a noticed public hearing and would be subject to
conducting authority proceedings. Similarly, CSA C may not divest itself from any of its
authorized service functions without LAFCO approval.
CSA C is governed by the County Board of Supervisors which consists of five-members
that represent an area of the County, known as a Supervisorial District. Each member of
the Board is elected by registered voters to four-year terms. The Board of Supervisors
regularly meets on every Tuesday at the Yuba City Council Chambers at City Hall located
at 1201 Civic Center Boulevard in Yuba City. The meetings are recorded and live
streamed on internet for the public. CSA C has a separate Fire Board, in addition to a
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501c3. CSA C provides access to public information through Facebook and town hall
meetings.
While CSA C operates separately from other County Service Areas in the County in terms
of day-to-day duties, all of the CSAs operate under the County Fire system. The Board of
Supervisors appoints an at-will County Fire Chief - Richard Epperson - to oversee the
administrative operations of all County Service Areas. With respect to day-to-day
operations of CSA C, CSA C’s volunteer Fire Chief oversees a budgeted staff of 22,
including one shared volunteer Fire Chief and Assistant Chief with CSA D, one shared
Extra-Help Fire Engineer with CSA D and 20 Volunteer Fire Fighters. Budgeted staffing has
slightly increased between FY 2019-2023 with an overall change among volunteer
positions at 100.0% from 10 to 20.
Figure 35 below summarizes the District’s total budgeted staff over the report period.
Figure 35: CSA C’s Historical Budgeted Staffing
Fiscal Year 2019 2020 2021 2022 2023 Average Trend
Type:
Paid Positions 1 1 0 0 2 0.67 0.0%
Volunteer Positions 10 15 13 14 20 15.7 53.8%
Total 11 16 13 14 22 16.3 100.0%
Per 100 residents 0.7 1.1 0.9 1.0 1.5 1.1 103.4%
Source: CSA C
The volunteer Fire Chief receives a $600 total travel stipend for managing both CSA C
and CSA D. Volunteer firefighters receive $50 per 24-hour shift and $25 per 12-hour shift.
Volunteer firefighters also receive $9 per service call and $11 per training session. CSA C
staff indicated there is a need to increase volunteer compensation in order to establish
24-hour staffing.
Training
CSA C fire personnel conduct weekly trainings on Tuesday nights at the Department’s
East Nicolaus Station 85. Department staff indicated that the CSA trains with CSA F on an
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annual basis for yearly refresher trainings. CSA C also periodically trains with the
Sacramento Fire Department, CAL FIRE, in addition to private companies. CSA C staff
noted that the CSA trains in accordance with State Fire Marshal regulations and trains at
a higher emergency medical services standard due to extended waiting periods for the
designated ambulance transport provider.
MUNICIPAL SERVICES
CSA C was established to provide formal fire protection service in 1963. As granted under
Government Code Section 25213, CSA C is authorized to provide a full range of municipal
services, most notably including fire protection and emergency medical services.
CSA C’s fire protection and emergency medical service functions represent the CSA’s
primary activity. CSA C’s fire protection services include responses to structural fires,
hazardous materials conditions, vehicle extrications, in addition to prevention, public
education, and emergency preparedness and mitigation. CSA C’s emergency medical
services are classified as basic life support. The Sierra-Sacramento Valley EMS Agency
designates Bi-County Ambulance as the exclusive ambulance transport provider in Sutter
County.
CSA C has one (1) fire station that is staffed by two (2) to four (4) fire personnel during
operating hours. The station is staffed from Monday through Friday from 8am to 4pm. The
CSA also owns an additional building that is used for storage purposes. The current fire
station details follow.
- The East Nicolaus Station 85 is located near the western boundary of CSA C at 1988
Nicolaus Avenue in East Nicolaus. According to CSA staff, the station was built
around 1963. The station experienced water damage in 2021 and was subsequently
remodeled, which included the addition of sleeping quarters for fire personnel. CSA
staff indicated that the facility is large enough to accommodate the CSA’s modern
equipment and current staffing levels. However, the station is not equipped with
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an exhaust removal system. An exhaust removal system is vital for firefighter health
and wellness, as diesel exhaust emissions were designated as a carcinogen in 1998.
Ongoing exposure to diesel exhaust has been linked to lung cancer and bladder
cancer, and a suspected cause of other types of cancer that commonly affect
firefighters. The National Fire Protection Association (NFPA) 1500: Standard on Fire
Department Occupational Safety, Health and Wellness Program section 10.1.5
specifies “The fire department shall prevent exposure to firefighters and
contamination of living and sleeping areas to exhaust emissions through the use of
direct or source capture systems.” Though a station may have a door between the
apparatus bay and the living and sleeping quarters, the door alone will not prevent
diesel exhaust emissions from entering and remaining in other locations of the
facility. Exhaust removal systems capture the emissions at the tailpipe of the
apparatus and remove the emissions to the exterior of the building.
- CSA C also owns a building located at 176 Pleasant Grove Road in Rio Oso. The
building primarily consists of metal materials and is used as a storage facility for
some of CSA C’s apparatus and equipment. According to CSA C, the building is
being slowly updated on an as-needed basis.
CSA C owns its own apparatus and equipment. The Department currently has a total of
eight (8) apparatus. Department staff noted that the Department was able to upgrade
to newer equipment in recent years. The Department recently purchased two (2) new
Type 6 Engines in 2024, in addition to a new F550 4WD utility vehicle. The Department is
expecting to purchase an additional Type 3 Engine in 2025. Figure 36 summarizes the
Department’s station staffing and apparatus conditions as of FY 2023.
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Figure 36: CSA C’s Fire Station(s) Assignments as FY 2023
Station No. 85
Fire Engines Type 1 (2003)
Type 1 (2015)
Type 3 (1988)
Type 6 (2007)
Type 6 (2023)
Water Tenders Water Tender (1994)
Water Tender (2021)
Other Fleet Vehicles Water Rescue Vehicle (2018)
Total 8
Source: CSA C
CSA C also supplements its fire protection and emergency medical services by
maintaining reciprocal mutual aid agreements with neighboring jurisdictions. This includes
agreements with the Sutter County Fire, Sacramento Metropolitan Fire District, CAL FIRE,
Wheatland Fire Authority, and the Linda Fire Protection District. The CSA is also working
on a written agreement with the Sacramento International Airport.
SERVICE DEMANDS AND CAPACITY
Response data for CSA C is compiled with response data for CSA D given the two
agencies shared staffing resources. Overall demands for fire protection and emergency
medical services for CSA C and CSA D between FY 2022 to FY 2023 have averaged 622
dispatched calls annually or 1.7 calls daily.38 Annual onsite incident demands increased
from FY 2022 to FY 2023 with an overall change of 7.5%. CSA C and CSA D’s peak demand
was recorded in FY 2023 which reflected a daily onsite response of 1.8 calls. Figure 37
below summarizes CSA C’s and CSA D’s fire protection and emergency medical
demands during FY 2022 – FY 2023.39
38 Information for FY 2019 – FY 2021 was not readily available and call type categories were not provided for FY 2022 - FY 2023.
39 Service demands for FY 2019 through FY 2021 was not made available upon request.
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Figure 37: CSA C and CSA D’s Service Demands between FY 2022 and FY 2023
CSA C and CSA D receive lower call volumes when compared to CSA F as a whole. In
2023, CSA F responded to 3,003 calls for service, reflecting significantly higher service
demands and a larger response area. Given the lower service demand in CSA C and D,
Sutter County could consider consolidating these County Service Areas with CSA F. This
merger could streamline operations, improve service efficiency, and optimize resource
allocation.
SERVICE PERFORMANCE
With respect to CSA C’s capacities to meet existing service demands, the Department –
as measured by staffing and equipment – appear sufficiently sized to readily
accommodate the existing demands within its jurisdictional boundary through the
timeframe of this report. However, it will be critical to monitor the impact of the Sutter
Pointe Specific Plan on both CSA C’s and CSA D’s ability to respond to calls for service
both within and outside its jurisdictional boundary in a timely and efficient manner. Given
the CSA C’s East Nicolaus Station No. 85 and CSA D’s Pleasant Grove Station No. 9 are
not staffed on a 24-hour basis, their ability to consistently respond to an increased level
of service calls in CSA D may be limited. Other key performance measures follow.
- The Department’s most recent evaluation of structural fire protection capabilities
from the Insurance Services Office (ISO) resulted in a Class 8b/10 rating for the
Department. This rating is considered typical for a largely rural service area where
response travel distances can be long, and credible water sources readily
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accessed by the fire department are limited. The ISO score is a measure of the
capability of the fire department to protect the community and is rated on a scale
of 1 to 10, with 1 being the highest rating. ISO evaluates the fire department for
apparatus and equipment, weight of response (number of firefighters arriving on
scene), training, water supply and distribution, emergency communications
systems, and fire prevention/community risk reduction efforts.
- CSA C does not have adopted response time standards for fire protection and
emergency medical calls. However, according to CSA C staff, the CSA maintained
an average response time of four minutes and 31 seconds in 2023 across both CSA
C and CSA D given their joint responses to service calls.40
FISCAL HEALTH
The sections that follow evaluate County Service Area C’s (“CSA C”) fiscal health,
inclusive of revenue sources and major expenditure categories during the report period
(FY 2019 through FY 2023).
REVENUES & EXPENDITURES
CSA C’s total average revenues over the last five years totaled $290,000. The largest single
source of the CSA’s revenue is property taxes which account for $278,000 – or 96.7% - of
all revenues for the District. The remainder of revenues for the CSA are derived from
income from interest, intergovernmental revenues and charges from services with the
latter involving mutual assistance with other fire service providers in the region. At the end
of FY 2023, CSA C’s total revenues amounted to $287,000 and reflect an overall increase
of $34,000 – or 13.4%. The CSA has maintained a surplus in four out of the five fiscal years
40 The response time data was provided directly by the respective fire protection service provider. RSG and Planwest rely on the
accuracy of the information submitted and is unable to independently verify this data.
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reviewed suggesting the CSA maintains enough revenues to cover the CSA’s associated
costs.
With respect to expenditures, CSA C’s total average annual expenses over the report
period have been $228,000. The CSA’s expenses are further broken down into three
categories: (a) Services & Supplies; (b) Other; and (c) Capital Assets. The District’s costs
associated with Services and Supplies account for nearly two-fifths – or 39.1% - of CSA
expenditures, at $81,000 as of FY 2023.
CSA C’s total expenditures at the end of the report period (FY 2023) totaled $207,000,
accounting for an overall increase of $100,000 - or 94.1%. This translates to a per capita
cost of $142.38 based on a resident service population of 1,455 as of FY 2023.
While there was a deficit in FY 2021, the District’s average net income over the last five
years totaled $610,000 and remained in a surplus for four out the five years reviewed.
Additional details regarding CSA C’s total revenues and expenditures are provided in
Figure 38.
Figure 38: Cash Flow – CSA C
Lastly, although CSA C maintains a separate budget from other County Services Areas
under Sutter County Fire, CSA F manages and oversees the day-to-day administrative
duties for CSA C’s finances. For instance, when making a purchase, CSA F must either pay
for CSA C’s expenditures from its own financial accounts and then reimburse itself, or CSA
F personnel must process these expenditures directly from CSA C’s separate financial
account. The consolidation of CSA C and CSA D with CSA F could enhance administrative
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efficiency by streamlining existing purchasing processes and reducing the administrative
burden on CSA F.
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SOI/BOUNDARY & RELATED RECOMMENDATIONS – COUNTY
SERVICE AREA C
The following recommendations pertain to Sutter County and CSA C’s sphere of influence
(“SOI”) amendments, boundary changes, and any other recommendations:
1. Sutter LAFCO may proceed to re-affirm CSA C’s sphere of influence with respect
to the delivery of fire protection and emergency medical services. CSA C’s sphere
of influence demarks the CSA’s current boundary and service area for fire
protection and emergency medical services. CSA C’s sphere of influence also
appropriately reflects the existing and relevant social and economic communities
of interests.
2. Sutter LAFCO may also consider proceeding with the approval of the consolidation
of County Service Areas (“CSA”) C, D, and F upon receipt of a completed change
of organization application. CSA C and CSA D receive comparatively lower call
volumes due to their smaller service populations, while CSA F experiences
significantly higher service demands and services a larger response area.
Additionally, at present, CSA F personnel perform several administrative oversight
duties for both CSA C and D, which could be streamlined through consolidation.
This merger could thus streamline operations, improve service efficiency, and
optimize resource allocation. However, the County may ensure collaboration and
careful financial planning in order to preserve the fiscal health of each County
Service Area. A potential cost sharing agreement could help preserve the financial
resources of each service area by ensuring a fair funding allocation process, and
the County may establish a County Service Area Zone of Increased Benefit to
preserve CSA F’s existing special fire tax.
3. Sutter LAFCO may also consider exploring a broader, countywide consolidation of
all fire protection service providers in the County in the long term. Countywide
consolidation may offer several long-term benefits to fire protection and
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emergency services in Sutter County, including enhanced operational efficiency,
improved coordination of resources, elimination of service redundancies, and
more equitable delivery of fire protection and emergency medical services across
service areas. Given the fiscal and staffing constraints faced by several of its
existing providers, consolidation may serve as a strategic pathway to strengthen
service reliability, ensure consistent standards of training and equipment, and
improve long-term fiscal sustainability.
To inform future decision making regarding countywide consolidation, it is
recommended that all fire protection service providers within the County
participate in a comprehensive Standards of Response Coverage (“SORC”) study.
This analysis should evaluate response times, station locations and coverage,
staffing, wages, benefits including pensions, and a forecast of past, current, and
future service delivery needs. Importantly, the study should also assess the financial
feasibility of a consolidated fire protection system.
4. CSA C currently receives its share of the 1% property tax allocation; however, CSA
C may also consider the establishment of a permanent funding source, such as a
special assessment or parcel tax, to ensure the long-term operational sustainability
of fire and emergency medical services. While the CSA remained in a surplus for
four out the five years reviewed, the District’s net income has declined over time.
A permanent funding source, such as a special assessment or parcel tax, would
offer greater financial stability, enabling the CSA to sustain its current level of fire
protection and emergency medical services into the future.
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MSR & SOI DETERMINATIONS – COUNTY SERVICE AREA C
Sutter County LAFCO is directed to prepare written determinations to address the various
governance factors enumerated under Government Code Section 56430 whenever it
prepares a municipal service review. These determinations serve as independent
statements derived from the information collected, analyzed, and presented in the report
by RSG and Planwest. The purpose of the determinations is to provide an independent
assessment to the ability of CSA C to provide fire protection and emergency medical
services to residents within its jurisdictional boundary now and in the near future.
SERVICE PROVISION DETERMINATIONS
1. Growth and Population Projections
- There are approximately 1,443 residents in County Service Area (“CSA”) C as of
2024. CSA C added approximately 141 new residents since 2010.
- CSA C has lost approximately 36 new housing units since 2010. This represents an
annual decrease of about 3 units each year.
- The CSA C resident population is projected to grow to 1,425 residents by 2029. This
accounts for an annual growth rate of approximately (0.3%).
- The number of housing units in CSA C is not expected to change through 2029.
2. Location and Characteristics of Disadvantaged Unincorporated Communities within or
Contiguous to SOI
According to Sutter LAFCO’s policies, there is one (1) Disadvantaged
Unincorporated Communities (“DUCs”) contiguous to the western boundary of CSA
C in the Sutter Basin Fire Protection District. The Sutter Basin Fire Protection District
is the primary fire protection and emergency medical service provider to this DUC.
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3. Present and Planned Capacity of Facilities, Adequacy of Public Services, and
Infrastructure Needs and Deficiencies in any Disadvantaged Unincorporated
Communities within or Contiguous to SOI
CSA C provides fire protection and emergency medical services to residents
located within its jurisdictional boundary. CSA C has adequate capacity to deliver
fire protection and emergency medical services to residents within its existing
boundary.
- Fire protection and emergency medical services are provided from one (1)
fire station, the East Nicolaus Station No. 85, located at 1988 Nicolaus
Avenue in the unincorporated community of East Nicolaus, CA. CSA staff
indicated that the facility is large enough to accommodate the CSA’s
modern equipment and current staffing levels.
- CSA C also owns a building located at 176 Pleasant Grove Road in the
unincorporated community of Rio Oso, CA. The building is used as a storage
facility for surplus apparatus and equipment.
- The Fire Department currently has eight (8) apparatuses, including five (5)
fire engines, two (2) water tenders, and one (1) water rescue vehicle. CSA C
owns its own apparatus and equipment.
- Overall demands for fire protection and emergency medical services from
CSA C and CSA D during FY 2022 through FY 2023 averaged 622 dispatched
calls annually or 1.7 calls daily.
- CSA C has sufficient capacity and related infrastructure to meet the
community’s needs now and in the near future.
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4. Financial Ability to Provide Services
CSA C has the financial ability to provide fire and emergency medical services to
its existing residents located within its jurisdictional boundary. However, while the
CSA remained in a surplus for four out the five years reviewed, the District’s net
income has declined over time. As a result, it is unclear whether the CSA can
continue to provide its existing service levels over time. Additional details can be
found below.
- At the end of FY 2023, CSA C total revenues amounted to about $228,000
and reflect an overall increase of 13.4% since FY 2019.
- CSA C’s total expenditures at the end of the FY 2023 totaled about $228,000,
representing an overall increase of 94.1% since the beginning of the report
period.
- The District’s average net income over the last five years totaled about
$610,000 and remained in a surplus for four out the five years reviewed.
- At present, CSA F manages and oversees the day-to-day administrative
duties for CSA C finances. To enhance administrative efficiency, County Fire
could consolidate CSA C, CSA D, and CSA F to streamline existing financial
processes and reduce the existing administrative burden placed on CSA F.
5. Opportunities for Shared Facilities
County Service Area C shares one (1) volunteer Fire Chief and one (1) Assistant
Chief with County Service Area D. Department staff indicated that CSA C staff train
with CSA F staff on an annual basis. There is an opportunity for consolidation
between CSA C, CSA D, and CSA F given the comparatively lower call volume and
the existing administrative inefficiencies mentioned above.
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6. Accountability for Community Service Needs, including Governmental Structure and
Operational Efficiencies
The Board of Supervisors regularly meets every Tuesday. The meetings are recorded
and live streamed on the internet for the public. CSA C has a separate Fire Board,
in addition to a 501c3 non-profit. CSA C provides access to public information
through Facebook and town hall meetings.
7. Any Other Matter Related to Effective or Efficient Service Delivery as Required by
Commission Policy
Other matters related to effective or efficient service delivery as requires by LAFCO
policy were not identified.
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Sutter County LAFCO is also directed to prepare a written statement of determinations in
determining the sphere of influence of each local agency enumerated under
Government Code Section 56425 whenever it prepares a sphere of influence update. The
purpose of the determinations is to provide an independent assessment to the ability of
CSA C to provide fire protection and emergency medical services to residents within its
sphere of influence now and in the near future.
SPHERE OF INFLUENCE DETERMINATIONS
1. Present and Planned Land Uses
Most land within the CSA C sphere of influence primarily consists of agricultural
uses. While there are no significant developments planned within the CSA C
jurisdictional boundary, the Sutter Pointe Specific Plan area is a master-planned,
mixed-use community located in CSA D’s jurisdictional boundary that will include
a combination of residential, employment, service, open space, and public uses.
The Plan area will break ground in the fall of 2025 and may result in significant
increases in call volume for CSA C.
2. Present and Probable Need for Public Facilities and Services
The CSA C sphere of influence demarks the City’s current service area for fire
protection and emergency medical services provided. CSA C supports the present
and probable service needs for fire protection and emergency medical services
within the CSA’s SOI.
3. Present Capacity and Adequacy of Public Facilities
CSA C has sufficient capacity and adequate infrastructure and related facilities to
continue to provide fire protection and emergency medical services to its residents
now and in the future. However, the consolidation of CSA C, D, and F could
enhance service delivery to the CSA C service area by improving coordination and
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optimizing efficiencies between the three agencies. It will be critical to monitor the
impacts of the Sutter Pointe Specific Plan on the Department to ensure timely and
efficient responses to service calls. The comprehensive review of CSA C capacity
and demands in this report supports these claims.
4. Presence of Social or Economic Communities of Interest
The CSA C sphere of influence does not include any social or economic
communities of interests.
5. Present and Probable Need for Public Services of any Disadvantaged Unincorporated
Communities (“DUCs”)
According to Sutter LAFCO’s policies, there is one (1) Disadvantaged
Unincorporated Communities (“DUCs”) contiguous to the western boundary of CSA
C in the Sutter Basin Fire Protection District. The Sutter Basin Fire Protection District
is the primary fire protection and emergency medical services provider to this DUC.
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COUNTY SERVICE AREA D
County Service Area (“CSA D”) – also referred to as the Pleasant Grove Fire Department
- is a dependent special district formed in 1963 and is legally authorized to provide fire
protection and emergency medical services in the southwest portion of Sutter County.
CSA D’s jurisdictional boundary currently spans approximately 71 square miles and is
anchored by Robbins Sutter Basin Fire Protection District to the west, County Service Area
C to the north, Placer County to the east, and Sacramento and Yolo County to the south.
The CSA’s SOI is coterminous with its service boundary.
JURISDICTIONAL BOUNDARY & SPHERE OF INFLUENCE
CSA D’s current jurisdictional boundary spans an area of approximately 71 square miles
with a coterminous sphere of influence designation. The District’s sphere was last updated
in 2017.
As of FY 2023, the total assessed value (land and structures) within CSA D is approximately
$698.7 million, a per capita value of approximately $733,193 based on the current resident
population of 953.
Figure 39 presents CSA D’s sphere in relation to its jurisdictional boundary.
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Figure 39: CSA D Jurisdictional Boundary and SOI Map
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SUTTER POINTE
The Sutter Pointe Specific Plan is a master-planned, mixed-use community located in CSA
D’s jurisdictional boundary that was approved by the Sutter County Board of Supervisors
on June 30, 2009. The community includes a combination of residential, employment,
service, open space, and public uses. The Plan area will support approximately 17,500
dwelling units and approximately 50 million square feet in employment uses. The Plan
area will also add 47,000 residents and provide jobs for approximately 63,000 employees
at build out. The Sutter Pointe Specific Plan is proposed to be built in four phases of
residential/mixed-use development and four separate phases for its employment village
development. The first phase of development, referred to as Lakeside at Sutter Pointe, is
expected to begin in the fall of 2025 and will establish approximately 3,402 single-family
and 399 multi-family homes.41
Figure 40 presents the Sutter Pointe Specific Plan area in relation to CSA D’s jurisdictional
boundary.
41 Source: Sutter Pointe Specific Plan & Sutter County website
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Figure 40: Sutter Pointe Specific Plan Area
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Proposed Plan for Fire and Emergency Medical Services
The Developer and Sutter County are currently in the process of exploring the
establishment of an additional County Service Area in order to provide a wide range of
municipal services, including fire protection and emergency medical services, to the Plan
area. Throughout all phases of the project, Sutter County Fire will be responsible for
providing fire protection, suppression, emergency medical services, and hazardous
materials management to the Plan area. According to the Public Facilities Financing Plan
for the Plan area, the initial Lakeside development will require the construction of a
temporary fire facility until permanent fire facilities are constructed, which will be vital for
the Plan area due to its distance from other capable fire protection resources.
At buildout, the Sutter Pointe Specific Plan will include three fire stations, including one
(1) master fire station and two (2) substations. County Fire staff estimate that a total of 39
uniformed personnel, 4 support staff, and 16 vehicles are needed to service the Plan
area.42 Buildout of the Lakeside project will require the construction of one of the two
substations, while the remaining Plan area development will require the construction of
the second substation and master fire station, as well as acquisition of required
equipment, support vehicles and land. Both temporary and permanent fire facilities may
be shared with law enforcement facilities.43
The estimated costs for fire protection and emergency medical services in the Plan area
will amount to $22.9 million at buildout, including $5.6 million for the initial Lakeside
development and $17.2 million during the remaining phases. While developer funding will
be utilized to fund the temporary facilities needed in early development phases to house
initial fire operations, a New Sutter Pointe Fee Program will fund improvements associated
with the delivery of fire protection and emergency medical services in the Plan area.
Additional discussion between the developer and the County regarding the
42 Source: Sutter Pointe Specific Plan Public Facilities Financing Plan (prepared by EPS)
43 Source: Sutter Pointe Specific Plan Public Facilities Financing Plan (prepared by EPS)
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administration of the Fee Program will be required in order to determine details such as
whether the Fee Program will be administered privately or publicly.44
Proposed Response Time Standards
According to the Sutter Pointe Specific Plan Public Facilities Financing Plan, County Fire’s
fire suppression resources will be deployed to provide for the arrival of an engine
company within a 6-minute response time 90 percent of the time. The Facilities Financing
Plan also states the timing of construction and staffing of each fire station will be
completed in a manner that maintains these standards.
Industry Standards
NFPA 1710, Standards for the Organization and Deployment of Fire Suppression
Operations, Emergency Medical Operations, and Special Operations to the Public by
Career Fire Departments, addresses the structure and operation of organizations
providing emergency response services, including industry recognized standards for the
response to emergencies. For a typical one- or two-story single-family dwelling of 2,000
square feet, NFPA 1710 sets the standard for the initial full alarm response at 16 firefighters
or 17 if an aerial device is used. This level of response typically includes a duty officer to
take command, and 4-5 fire engines staffed with 3-4 fire personnel per unit to carry out
the necessary tasks on a fire that must happen simultaneously. These tasks include search
and rescue, fire attack, ventilation, water supply, a RIT (rapid intervention team as
required by OSHA 29 CFR 1910.134(g)(4)), incident command, and other tasks the
incident requires.
Commercial structures require an even more involved level of response, due to the
typically larger building area, and the fuel load of stored items within. For a typical open
air strip mall with a size between 13,000 and 196,000 square feet, NFPA 1710 sets a
standard that a jurisdiction must be able to provide a minimum of 27 fire personnel on
44 Source: Sutter Pointe Specific Plan Public Facilities Financing Plan (prepared by EPS)
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scene (28 if an aerial device is used) to complete the tasks necessary to mitigate the
incident.
While a temporary fire station may be built during the first phase of the project, the first
residential or commercial structure built within the Plan area will require the level of
response described above by NFPA 1710. Additionally, it is unlikely CSA D will have the
necessary capacity to provide fire protection and emergency medical services for the
rapidly increasing service demand that will result from the Plan area, even in the first
phase of construction. Furthermore, responses to calls for service from the fire stations of
Community Service Areas C, D, & F may require a long response time for emergency
services to the Plan area. As a result, comprehensive fire and emergency medical
responses must be incorporated into the development plan early and at the beginning
of construction, rather than at the end of the first phase.
DEMOGRAPHICS
POPULATION & HOUSING
CSA D’s total current resident population within its jurisdictional boundary is estimated at
953 as of 2024. This amount represents 1.0% of the countywide population total. The
estimated resident population in CSA D has decreased overall by (1.4%) - or
approximately 14 residents - since 2010, demonstrating a downward trend.45 More
recently, CSA D has experienced a reduction of 3 residents each year over the last 4
years, from 964 in 2020 to 953 in 2024. The current resident population produces a
population density of 0.02 residents for every acre and underlies the overall rural
characteristic of CSA D’s jurisdictional boundary. The Sutter County 2030 General Plan
does not specify the exact percentages of land use types within CSA D; however, the
area consists of a mix of residential and agricultural land uses.
45 Source: ESRI Business Analyst
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CSA D’s population is expected to decrease by approximately (0.17%) annually over the
next five-years reducing to 945 residents by 2029 and accounts for an overall decrease
of 8 residents.46 In contrast, the countywide population is expected to grow 0.03% and
reach 99,795 residents by 2029.
It is important to note, that these population figures for CSA D do not account for the
increased resident population anticipated as a result of the planned development of the
Sutter Pointe community that is expected to be built out over the next 20 to 30 years with
an added resident population of 47,000. This would increase CSA D’s total population to
47,953 by FY 2055.
Figure 41 summarizes CSA D’s and the County’s past, present and future population
growth.
Figure 41: CSA D’s Resident Population
There are an estimated 382 housing units within CSA D’s boundary as of FY 2024. This
amount accounts for an overall decrease of 37 units – or 8.8% - since 2010 for an annual
change of 3 housing units. It is expected that the District’s total number of housing units
will remain unchanged through the year 2029.
Of the total number of current housing units in CSA D, approximately 62.6% are owner-
occupied. The remainder of housing units are divided between 28.0% being renter-
occupied and 9.4% being vacant. Further, the average household size in CSA D for 2024
46 Source: ESRI Business Analyst
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is 2.75. This amount reflects an increase of 2.6% since 2010 wherein the average household
size was 2.75.
It is important to note, that these housing figures for CSA D do not account for the
increased housing units anticipated as a result of the planned development of the Sutter
Pointe community that is expected to be consist of 17,500 new housing units within the
next 20 to 30 years. This would increase CSA D’s total housing units to 17,882 by FY 2055.
Figure 42 includes additional details regarding CSA D’s housing characteristics.
Figure 42: CSA D’s Housing Characteristics
AGE DISTRIBUTION & INCOME
Relative to the County as a whole, the population of the CSA D service area has been
somewhat older. The median age of residents in CSA D is 44.6 and reflects an increase of
3.0% since 2010. The current median age in CSA D remains slightly higher than the
countywide median age of 37.5 demonstrating an older resident population.
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Similarly, 90.9% - of residents within the prime working age group (between the ages of
25-64) are employed while the remaining 9.1% are unemployed, reflecting a stable
workforce within the District’s jurisdictional boundary.47 Additional details regarding CSA
D’s age distribution and employment rates are provided in Figure 43.
Figure 43: CSA D’s Age Distribution
Age Distribution CSA D Sutter County
2010 Median Age 43.3 34.6
2024 Median Age 44.6 37.5
% Change (2010-2024) 2.9% 7.7%
2024 Employment Levels (Ages 25-64) 90.9% 92.5%
2024 Unemployment Levels (Ages 25-64) 9.1% 7.5%
Source: ESRI Business Analyst
The median household income of CSA D is $71,060 which is approximately 0.5% higher
than the County’s median household income of $70,700. This amount confirms households
in CSA D are receiving nominally more pay over the report period compared to the
county as whole. Furthermore, CSA D has a poverty level rate of 12.9%, which is
approximately (2.3%) lower than the County’s poverty level rate of 13.2%.
According to Sutter LAFCO’s policies, there is one (1) Disadvantaged Unincorporated
Communities (“DUCs”) contiguous to the western boundary of CSA D in the Sutter Basin
Fire Protection District. The Sutter Basin Fire Protection District is the primary fire protection
and emergency medical services provider to this DUC. A DUC is defined as any
unincorporated area wherein the median household income is less than $76,416.80.48
Figure 44 provides an overview of income characteristics in the CSA D and County.
47 The prime working age group does not include individuals between the ages of 16-25 nor 65 and above given residents within
these age groups are typically in school or nearing/in retirement.
48 Source: Government Code Section 56033.5 and 56046, Water Code Section 79505.5(a), Public Resources Code Section
75005(g), American Community Survey Census 2019-2023 data
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Figure 44: Income Characteristics
Income Characteristics CSA D Sutter County
2024 Median Household Income $71,060 $70,700
2024 Median Household Income Per $41,353 $32,860
Poverty Level (2018-2022) 12.9% 13.2%
Source: ESRI Business Analyst
GOVERNANCE AND STAFFING
The County Service Area D (“CSA D”) operates as a county-dependent special district
under the County Service Area Law and codified under Government Code Section 25210
et seq. The act empowers CSA districts to provide a range of municipal services in the
county upon approval by LAFCOs - including but not limited to – water, wastewater,
police protection, and fire protection. CSA D is currently authorized by Sutter LAFCO to
provide fire protection and emergency medical services within unincorporated Sutter
County. The remaining service functions (i.e., powers) enumerated under the principal
act are deemed latent, meaning they are authorized by statute but would need to be
formally activated by Sutter LAFCO at a noticed public hearing and would be subject to
conducting authority proceedings. Similarly, CSA D may not divest itself from any of its
authorized service functions without LAFCO approval.
CSA D is governed by the County Board of Supervisors which consists of five-members
that represent an area of the County, known as a Supervisorial District. Each member of
the Board is elected by registered voters to four-year terms. The Board of Supervisors
regularly meets on every Tuesday at the Yuba City Council Chambers at City Hall located
at 1201 Civic Center Boulevard in Yuba City. The meetings are recorded and live
streamed on internet for the public.
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While CSA D operates separate from other County Service Areas in the County in terms
of day-to-day duties, all of the CSAs operate under the County Fire system. The Board of
Supervisors appoints an at-will County Fire Chief - Richard Epperson - to oversee the
administrative operations of all County Service Areas. With respect to day-to-day
operations of CSA D, CSA D’s volunteer Fire Chief oversees a budgeted staff of 19,
including one shared volunteer Fire Chief and Assistant Chief with CSA C, one shared
Extra-Help Fire Engineer with CSA D and 17 Volunteer Fire Fighters. Budgeted staffing has
slightly increased between FY 2019-2023 with an overall change among volunteer
positions at 5.6% from 17 to 19.
Figure 45 below summarizes the Departments total budgeted staff over the report period.
Figure 45: CSA D’s Historical Budgeted Staff
Fiscal Year 2019 2020 2021 2022 2023 Average Trend
Type:
Paid Positions 1 1 0 0 0 0 -100.0%
Volunteer Positions 17 18 20 19 19 19.3 11.8%
Total 18 19 20 19 19 19.3 5.6%
Per 100 residents 1.9 2.0 2.1 2.0 2.0 2.0 6.2%
Source: Sutter County Budgets FY 2019 - 2023 & CSA D
The volunteer Fire Chief receives a $600 total travel stipend for managing both CSA C
and CSA D. Volunteer firefighters receive $50 per 24-hour shift and $25 per 12-hour shift.
Volunteer firefighters also receive $9 per service call and $11 per training session. CSA D
staff indicated there is a need to increase volunteer compensation in order to establish
24-hour staffing.
Training
CSA D fire personnel conduct weekly trainings on Tuesday nights at the Department’s
Pleasant Grove Station No. 9. Department staff indicated that the CSA trains with CSA F
on an annual basis for yearly refresher trainings. CSA D also periodically trains with the
Sacramento Fire Department, CAL FIRE, in addition to private companies. CSA D staff
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noted that the CSA trains in accordance with State Fire Marshal regulations and trains at
a higher emergency medical services standard due to extended waiting periods for the
designated ambulance transport provider.
MUNICIPAL SERVICES
CSA D was established to provide formal fire protection service in 1963. As granted under
Government Code Section 25213, CSA D is authorized to provide fire protection and
emergency medical services in Sutter County. CSA D’s emergency medical services are
classified as basic life support. The Sierra-Sacramento Valley EMS Agency designates Bi-
County Ambulance as the exclusive ambulance transport provider in Sutter County.
CSA D has one (1) fire station that is staffed by two (2) to four (4) fire personnel during
operating hours. The station is staffed from Monday through Friday from 8am to 4pm. The
CSA also owns an additional building that is used for storage purposes. The current fire
station details follow.
- The Pleasant Grove Station No. 9 is located near the eastern boundary of CSA D at
3100 Howsley Road in the community of Pleasant Grove. According to CSA staff,
the station was built in the 1960’s. CSA staff indicated that the facility is large
enough to accommodate the CSA’s modern equipment and current staffing
levels. However, the station is not equipped with an exhaust removal system. This is
vital for firefighter health and wellness, as diesel exhaust emissions were designated
as a carcinogen in 1998. Ongoing exposure to diesel exhaust has been linked to
lung cancer and bladder cancer, and a suspected cause of other types of cancer
that commonly affect firefighters. The National Fire Protection Association (NFPA)
1500: Standard on Fire Department Occupational Safety, Health and Wellness
Program section 10.1.5 specifies “The fire department shall prevent exposure to
firefighters and contamination of living and sleeping areas to exhaust emissions
through the use of direct or source capture systems.” Though a station may have
a door between the apparatus bay and the living and sleeping quarters, the door
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alone will not prevent diesel exhaust emissions from entering and remaining in other
locations of the facility. Exhaust removal systems capture the emissions at the
tailpipe of the apparatus and remove the emissions to the exterior of the building.
- CSA D also owns a building located at 3479 Sankey Road in the community of
Pleasant Grove. The building is used as a storage facility for some of CSA D’s
apparatus and equipment.
CSA D owns its own apparatus and equipment. The Department currently has a total of
nine (9) apparatus. Department staff noted that the Department was able to upgrade to
newer equipment in recent years. The Department hopes to purchase a new Type 1
Engine in the FY 2026 budget. The Department is expecting to purchase an additional
Type 3 in 2025.
Figure 46 summarizes the Department’s station staffing and apparatus conditions as of FY
2023.
Figure 46: CSA D’s Fire Station(s) Assignments
Station No. 9
Fire Engines Type 1 (2004)
Type 1 (2015)
Type 1 (2001)
Type 3 (2007)
Type 3 (1984)
Type 6 (2023)
Water Tenders Water Tender (1994)
Water Tender (2021)
Other Fleet Vehicles Chief Vehicle (2003)
Total 9
Source: CSA D
CSA D also supplements its fire protection and emergency medical services by
maintaining reciprocal mutual aid agreements with neighboring jurisdictions.
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SERVICE DEMANDS AND CAPACITY
CSA C and CSA D combine their historical call volume data due to shared staffing
resources. As a result, please refer to CSA C’s Agency Profile beginning on Page 113 for
an overview of the service demands and capacity in CSA D.
SERVICE PERFORMANCE
With respect to CSA D’s capacities to meet existing service demands, the Department –
as measured by staffing and equipment – appear sufficiently sized to readily
accommodate the existing demands within its jurisdictional boundary through the
timeframe of this report. In regard to CSA D’s service demands in the future, the service
area will be heavily impacted by the sharp increase in resident population in the Sutter
Pointe Specific Plan area. It will be critical to monitor the impact of the Sutter Pointe
Specific Plan on the Department’s ability to respond to calls for service both within and
outside its jurisdictional boundary in a timely and efficient manner. Given the East
Nicolaus Station 85 is not staffed on a 24-hour basis, its ability to consistently respond to
an increased level of service calls in CSA D may be limited. Other key performance
measures follow.
- The Department’s most recent evaluation of structural fire protection capabilities
from the Insurance Services Office (ISO) resulted in a Class 8b/10 rating for the
Department. This rating is considered typical for a largely rural service area where
response travel distances can be long, and credible water sources readily
accessed by the fire department are limited. The ISO score is a measure of the
capability of the fire department to protect the community and is rated on a scale
of 1 to 10, with 1 being the highest rating. ISO evaluates the fire department for
apparatus and equipment, weight of response (number of firefighters arriving on
scene), training, water supply and distribution, emergency communications
systems, and fire prevention/community risk reduction efforts.
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- CSA D does not have adopted response time standards for fire protection and
emergency medical calls. However, according to CSA D staff, the CSA maintained
an average response time of four minutes and 31 seconds in 2023 across both CSA
C and CSA D given their joint responses to service calls.49
FISCAL HEALTH
The sections that follow evaluate County Service Area D’s (“CSA D” or “District”) fiscal
health, inclusive of revenue sources and major expenditure categories during the report
period (FY 2019 through FY 2023).
REVENUES & EXPENDITURES
CSA D’s total average revenues over the last five years totaled $423,000. The largest single
source of the District’s revenue is property taxes which account for $335,000 – or 57.9% -
of all revenues for the District. The remainder of revenues for the District are derived from
income from interest, intergovernmental revenues and charges from services with the
latter involving mutual assistance with other fire service providers in the region. At the end
of FY 2023, CSA D’s total revenues amounted to $578,000 and reflect an overall increase
of $178,000 – or 44.6%. The District has maintained a surplus in four out of the five fiscal
years reviewed suggesting the District maintains enough revenues to cover the District’s
associated costs.
With respect to expenditures, CSA D’s total average annual expenses over the report
period have been $351,000. The District’s expenses are further broken down into three
categories: (a) Services & Supplies; (b) Other; and (c) Capital Assets. The District’s costs
associated with Services and Supplies account for nearly one-third – or 29.8% - of District
expenditures, at $162,000 as of FY 2023.
49 The response time data was provided directly by the respective fire protection service provider. RSG and Planwest rely on the
accuracy of the information submitted and is unable to independently verify this data.
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CSA D’s total expenditures at the end of the report period (FY 2023) totaled $543,000,
accounting for an overall increase of $317,000 – or 140.7%. The spike in expenditures can
be largely attributed to an increase in costs associated with the acquisition of new
apparatus equipment according to CSA staff.
While there was a deficit in FY 2021, the District’s average net income over the last five
years totaled $72,000 and remained in a surplus for four out the five years reviewed.
Additional details regarding CSA D’s total revenues and expenditures are provided in
Figure 47.
Figure 47: Cash Flow – CSA D
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SOI & RELATED RECOMMENDATIONS – COUNTY SERVICE AREA
D
The following recommendations call for specific action from Sutter LAFCO and Sutter
County and pertain to the CSA D sphere of influence (“SOI”) amendments, boundary
changes, and any other recommendations:
1. Sutter LAFCO may proceed to re-affirm CSA D’s sphere of influence with respect to
the delivery of fire protection and emergency medical services. CSA D’s sphere of
influence demarks the CSA’s current boundary and service area for fire protection
and emergency medical services.
2. Sutter LAFCO may also consider proceeding with the approval of the consolidation
of County Service Area (“CSA”) C, D, and F upon receipt of a completed change
of organization application. CSA C and CSA D receive the lowest call volumes in
the County Fire system due to their small service populations, while CSA F
experiences significantly higher service demands and services a larger response
area. Additionally, at present, CSA F personnel perform several administrative
oversight duties for both CSA C and D, which could be streamlined through
consolidation. This merger could thus streamline operations, improve service
efficiency, and optimize resource allocation. However, 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.
3. Sutter LAFCO may also consider exploring a broader, countywide consolidation of
all fire protection service providers in the County in the long term. Countywide
consolidation may offer several long-term benefits to fire protection and
emergency services in Sutter County, including enhanced operational efficiency,
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improved coordination of resources, elimination of service redundancies, and
more equitable delivery of fire protection and emergency medical services across
service areas. Given the fiscal and staffing constraints faced by several of its
existing providers, consolidation may serve as a strategic pathway to strengthen
service reliability, ensure consistent standards of training and equipment, and
improve long-term fiscal sustainability.
To inform future decision making regarding countywide consolidation, it is
recommended that all fire protection service providers within the County
participate in a comprehensive Standards of Response Coverage (“SORC”) study.
This analysis should evaluate response times, station locations and coverage,
staffing, wages, benefits including pensions, and a forecast of past, current, and
future service delivery needs. Importantly, the study should also assess the financial
feasibility of a consolidated fire protection system.
4. CSA D currently receives its share of the 1% property tax allocation; however, CSA
D may also consider the establishment of a permanent funding source, such as a
special assessment or parcel tax to ensure the long-term operational sustainability
of fire and emergency medical services. While the CSA remained in a surplus for
four out the five years reviewed, the District’s net income has declined over time.
A permanent funding source, such as a special assessment or parcel tax, would
offer greater financial stability, enabling the CSA to sustain its current level of fire
protection and emergency medical services into the future.
5. Lastly, Sutter LAFCO may consider proceeding with the approval of the
establishment of a County Service Area (“CSA”) or Zone of Increased Benefit (“ZIB”)
for the Sutter Pointe Specific Plan Area (“Plan area”) upon receipt of a completed
change of organization application. The establishment of a CSA or ZIB can provide
a structured and sustainable funding mechanism for the ongoing delivery of fire
protection and emergency medical services in the Plan area and ensure the
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service area receives an enhanced level of service delivery due to its high
population density and planned uses. A CSA or ZIB can also increase local
accountability and control over service provision, ensuring that residents and
property owners in the Plan area have a direct stake in the funding and delivery of
critical emergency services.
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MSR & SOI DETERMINATIONS – COUNTY SERVICE AREA D
Sutter County LAFCO is directed to prepare written determinations to address the various
governance factors enumerated under Government Code Section 56430 whenever it
prepares a municipal service review. These determinations serve as independent
statements derived from the information collected, analyzed, and presented in the report
by RSG and Planwest. The purpose of the determinations is to provide an independent
assessment to the ability of CSA D to provide fire protection and emergency medical
services to residents within its jurisdictional boundary now and in the near future.
SERVICE PROVISION DETERMINATIONS
1. Growth and Population Projections
- There are approximately 953 residents in County Service Area (“CSA”) D as of 2024.
The CSA D population declined by approximately 14 residents since 2010.
- The CSA D housing inventory declined by approximately 37 housing units since
2010. This represents an annual decrease of 3 units each year.
- The CSA D resident population is projected to amount to 945 residents by 2029, not
including population growth attributed to the Sutter Pointe Specific Plan
development. This accounts for an annual growth rate of approximately (0.2%). The
Sutter Pointe Specific Plan is expected to separately add approximately 47,000
residents at built out in the next 20 to 30 years.
- The number of housing units in CSA D is expected to remain the same through 2029,
not including housing growth as a result of the Sutter Pointe Specific Plan. The first
phase of the Sutter Pointe Specific Plan is expected to begin in the fall of 2025 and
will establish approximately 3,402 single-family and 399 multi-family homes. At build
out, the Plan area will result in 17,500 new housing units in the next 20 to 30 years.
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2. Location and Characteristics of Disadvantaged Unincorporated Communities within or
Contiguous to SOI
According to Sutter LAFCO’s policies, there is one (1) Disadvantaged
Unincorporated Communities (“DUCs”) contiguous to the western boundary of CSA
D in the Sutter Basin Fire Protection District. The Sutter Basin Fire Protection District is
the primary fire protection and emergency medical services provider to this DUC.
3. Present and Planned Capacity of Facilities, Adequacy of Public Services, and
Infrastructure Needs and Deficiencies in any Disadvantaged Unincorporated
Communities within or Contiguous to SOI
CSA D provides fire protection and emergency medical services to residents
located within its jurisdictional boundary. While CSA D has adequate capacity to
deliver fire protection and emergency medical services to existing residents with its
boundary, its service area will be heavily impacted by the sharp increase in
resident population in the Sutter Pointe Specific Plan area. It will be critical to
monitor the impact of the Sutter Pointe Specific Plan and the Department’s ability
to respond to calls for service both within and outside its jurisdictional boundary in
a timely and efficient manner.
- Fire protection and emergency medical services are provided from one (1)
fire station, Pleasant Grove Station No. 9, located at 3100 Howsley Road in
the unincorporated community of Pleasant Grove. CSA staff indicated that
the facility is large enough to accommodate the CSA’s modern equipment
and current staffing levels.
- CSA D also owns a building located at 3479 Sankey Road in the community
of Pleasant Grove. The building is used as a storage facility for some of CSA
D’s apparatus and equipment.
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- The initial phase of the Sutter Pointe Specific Plan area, known as the
Lakeside development, will require the construction of a temporary fire
facility until permanent fire facilities are constructed, which will be vital for
the Plan area due to its distance from other capable fire protection
resources.
- At buildout, the Sutter Pointe Specific Plan will include three fire stations,
including one (1) master fire station and two (2) substations.
- The Fire Department currently has nine (9) apparatus, including six (6) fire
engines, two (2) water tenders, and one (1) Chief vehicle. CSA D owns its
own apparatus and equipment.
- Overall demands for fire protection and emergency medical services from
CSA C and CSA D during FY 2022 through FY 2023 have averaged 622
dispatched calls annually or 1.7 calls daily.
- CSA D has sufficient capacity and related infrastructure to meet the
community’s needs now and in the near future; however, it will be critical to
monitor the impacts of the Sutter Pointe Specific Plan on the Department to
ensure timely and efficient responses to service calls.
4. Financial Ability to Provide Services
CSA D has the financial ability to provide fire and emergency medical services to
its existing residents located within its jurisdictional boundary. However, while the
CSA remained in a surplus for four out the five years reviewed, the District’s net
income has declined over time. As a result, it is unclear whether the CSA can
continue to provide its existing service levels over time. Additional details can be
found below. Additional details can be found below.
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- At the end of FY 2023, the CSA D’s total revenues amounted to
approximately $578,000 and reflect an overall increase of 44.6% since FY
2019.
- CSA D’s total expenditures at the end of the FY 2023 totaled about $543,000,
representing an overall increase of 140.7% since FY 2019.
- The District’s average net income over the last five years totaled $72,000 and
remained in a surplus for four out the five years reviewed.
- At present, CSA F manages and oversees the day-to-day administrative
duties for CSA D’s finances. To enhance administrative efficiency, County
Fire could consolidate County Service Areas (“CSA”) C, D, and F to
streamline existing financial processes and reduce the administrative burden
placed on CSA F.
5. Opportunities for Shared Facilities
County Service Area D shares one (1) volunteer Fire Chief and one (1) Assistant
Chief with County Service Area C. Department staff indicated that CSA staff train
with CSA F on an annual basis. There may be an opportunity for consolidation
between County Service Area C, D, and F, given CSA C and CSA D’s comparatively
lower call volume and the existing administrative inefficiencies mentioned above.
6. Accountability for Community Service Needs, including Governmental Structure and
Operational Efficiencies
The Board of Supervisors regularly meets every Tuesday. The meetings are recorded
and live streamed on internet for the public. CSA D has a separate Fire Board, in
addition to a 501c3 non-profit. CSA D provides access to public information
through Facebook and town hall meetings.
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7. Any Other Matter Related to Effective or Efficient Service Delivery as Required by
Commission Policy
Other matters related to effective or efficient service delivery as required by LAFCO
policy were not identified.
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Sutter County LAFCO is also directed to prepare a written statement of determinations in
determining the sphere of influence of each local agency enumerated under
Government Code Section 56425 whenever it prepares a sphere of influence update. The
purpose of the determinations is to provide an independent assessment to the ability of
CSA D to provide fire protection and emergency medical services to residents within its
sphere of influence now and in the near future.
SPHERE OF INFLUENCE DETERMINATIONS
1. Present and Planned Land Uses
Most land within CSA D’s sphere of influence primarily consists of agricultural and
residential uses. The Sutter Pointe Specific Plan area will include a combination of
residential, employment, service, open space, and public uses. The Plan area will
support approximately 17,500 dwelling units and approximately 50 million square
feet in employment uses. The Plan area will add approximately 47,000 residents
and provide jobs for approximately 63,000 employees at build out.
2. Present and Probable Need for Public Facilities and Services
CSA D’s sphere of influence demarks the CSA’s current boundary and service area
for fire protection and emergency medical services. However, it is unlikely CSA D
will have the necessary capacity to provide fire protection and emergency
medical services for the rapidly increasing service demand that will result from the
Plan area. As a result, it is recommended that Sutter LAFCO proceed with the
approval of the establishment of a County Service Area (“CSA”) or Zone of
Increased Benefit (“ZIB”) for the Sutter Pointe Specific Plan Area (“Plan area”) upon
receipt of a completed change of organization application to reflect the
enhanced service delivery required by the service area.
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3. Present Capacity and Adequacy of Public Facilities
CSA D has sufficient capacity and adequate infrastructure and related facilities to
provide fire protection and emergency medical services to its current residents.
However, it will be critical to monitor the impacts of the Sutter Pointe Specific Plan
on the Department to ensure timely and efficient responses to service calls. The
comprehensive review of the Sutter County Fire capacity and demands in this
report supports these claims.
4. Presence of Social or Economic Communities of Interest
The CSA D sphere of influence does not include any social or economic
communities of interests.
5. Present and Probable Need for Public Services of any Disadvantaged Unincorporated
Communities (“DUCs”)
According to Sutter LAFCO’s policies, there is one (1) Disadvantaged
Unincorporated Communities (“DUCs”) contiguous to the western boundary of CSA
D in the Sutter Basin Fire Protection District. The Sutter Basin Fire Protection District is
the primary fire protection and emergency medical services provider to this DUC.
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COUNTY SERVICE AREA F
County Service Area F (“CSA F”) is a dependent special district formed in 1996 and is
legally authorized to provide fire protection and emergency medical services in the
eastern portion of Sutter County. CSA F’s jurisdictional boundary currently spans
approximately 222 square miles and is anchored by Meridian Fire Protection District and
Sutter Basin Fire Protection District to the west, County Service Area C to the south, and
Yuba to the east. The District’s SOI is coterminous with its service boundary.
JURISDICTIONAL BOUNDARY & SPHERE OF INFLUENCE
CSA F’s current jurisdictional boundary spans an area of approximately 222 square miles
with a coterminous sphere of influence designation. The District’s sphere was last updated
in 2017.
As of FY 2023, the total assessed value (land and structures) within CSA F is approximately
$2.7 billion, a per capita value of approximately $142.132 based on the current resident
population of 18,778.
Figure 48 presents CSA F’s sphere in relation to its jurisdictional boundary.
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Figure 48: CSA F Jurisdictional Boundary and SOI Map
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DEMOGRAPHICS
POPULATION & HOUSING
CSA F’s total current resident population within its jurisdictional boundary is estimated at
9,424 as of 2024. This amount represents 9.5% of the countywide population total. The
estimated resident population in CSA F has risen overall by 0.5% - or approximately 50
residents - since 2010, demonstrating an upward trend.50 Between 2020 and 2024, CSA F
has experienced an increase of 11 residents per year going from 9,380 residents in 2020
to 9,424 residents by 2024. The latter produces a population density of 0.07 residents for
every acre and underlies the overall rural characteristic of CSA F’s jurisdictional boundary.
The Sutter County 2030 General Plan does not specify the exact percentages of land use
types within CSA D; however, the area consists of a mix of residential and agricultural
land uses. While not located in the CSA F jurisdictional boundary, the Sutter Pointe
Specific Plan is a master-planned, mixed-use community located in the nearby CSA D
jurisdictional boundary that will include a combination of residential, employment,
service, open space, and public uses. The Plan area will support approximately 17,500
dwelling units, 47,000 residents, and provide jobs for approximately 63,000 employees at
build out. The first phase of the Sutter Pointe Specific Plan area is expected to begin in
the fall of 2025.
CSA F’s population is expected to grow by approximately 0.13% annually over the next
five-years reaching 9,485 residents by 2029 and reflects an overall increase of 61
residents.51 This growth is slightly higher than the anticipated annual population growth
countywide which is expected to grow 0.03%, reaching 99,795 residents by 2029. Figure
49 summarizes CSA F’s and the County’s past, present and future population growth.
50 Source: ESRI Business Analyst
51 Source: ESRI Business Analyst
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Figure 49: CSA F’s Resident Population
2010 2020 2024 2029 Annual Change Annual Change
Resident Population
Estimate Estimate Estimate Projection (2010-2020) (2024 - 2029)
CSA F 9,374 9,380 9,424 9,485 0.0% 0.1%
Sutter County 94,737 99,633 99,626 99,795 0.5% 0.0%
Source: ESRI Business Analyst
There are an estimated 3,564 housing units within CSA F’s boundary as of 2024. This
amount accounts for an overall increase of 58 units – or 1.7% - since 2010 and an annual
change of 4 housing units. This creates a ratio of 1.16 housing units for every 1 new
resident. Furthermore, it is expected that CSA’s total number of housing units will continue
to grow and reach 3,567 housing units by 2029, reflecting an overall increase of 0.1%.
Of the total number of current housing units in CSA F, approximately 71.1% are owner-
occupied. The remainder of housing units are divided between 28.9% being renter-
occupied and 5.4% being vacant. Further, the average household size in CSA F for 2024
is 2.84. This amount reflects a decrease of (1.4%) since 2010 wherein the average
household size was 2.88. Figure 50 includes additional details regarding CSA F’s housing
characteristics.
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Figure 50: CSA F’s Housing Characteristics
AGE DISTRIBUTION & INCOME
Relative to the County as a whole, the population of the CSA F service area has been
somewhat older. The median age of residents in CSA F is 40.5 and reflects an increase of
1.5% from 39.9 since 2010. The current median age in CSA F remains slightly higher than
the countywide median age of 37.5 demonstrating an older resident population.
Similarly, 92.0% - of residents within the prime working age group (between the ages of
25-64) are employed while the remaining 8.0% are unemployed, reflecting a stable
workforce within the District’s jurisdictional boundary.52 Additional details regarding CSA
F’s age distribution and employment rates are provided in Figure 51.
52 The prime working age group does not include individuals between the ages of 16-25 nor 65 and above given residents within
these age groups are typically in school or nearing/in retirement.
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Figure 51: CSA F’s Age Distribution
Age Distribution CSA F Sutter County
2010 Median Age 39.9 34.6
2024 Median Age 40.5 37.5
% Change (2010-2024) 1.5% 7.7%
2024 Employment Levels (Ages 25-64) 92.0% 92.5%
2024 Unemployment Levels (Ages 25-64) 8.0% 7.5%
Source: ESRI Business Analyst
The median household income of CSA F is $89,041 which is approximately 20.6% higher
than the County’s median household income of $70,700. This amount confirms households
in CSA F are receiving moderately more pay over the report period compared to the
county as whole. Furthermore, CSA F has a poverty level rate of 8.5%, which is
approximately (55.3%) lower than the County’s poverty level rate of 13.2%.
According to Sutter LAFCO’s policies, there is one (1) Disadvantaged Unincorporated
Communities (“DUCs”) contiguous to the southwestern boundary of CSA F in the Sutter
Basin Fire Protection District. The Sutter Basin Fire Protection District is the primary fire
protection and emergency medical services provider to this DUC. Additionally, there is
one (1) DUC and one (1) SDUC located contiguous the City of Live Oak city limits. CSA F
is the primary fire protection and emergency medical service provider to these areas. A
DUC is defined as any unincorporated area wherein the median household income is less
than $76,416.80, while an SDUC is defined as any unincorporated area wherein the
median household income is less than $57,312.60.53 Figure 52 provides an overview of
income characteristics in the CSA F and County.
53 Source: Government Code Section 56033.5 and 56046, Water Code Section 79505.5(a), Public Resources Code Section
75005(g), American Community Survey Census 2019-2023 data
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Figure 52: CSA F’s Income Characteristics
Income Characteristics CSA F Sutter County
2024 Median Household Income $89,041 $70,700
2024 Median Household Income Per Capita $38,099 $32,860
Poverty Level (2018-2022) 8.5% 13.2%
Source: ESRI Business Analyst
GOVERNANCE AND STAFFING
The County Service Area F (“CSA F”) operates as a county-dependent special district
under the County Service Area Law and codified under Government Code Section 25210
et seq. The act empowers CSA districts to provide a range of municipal services in the
county upon approval by LAFCOs - including but not limited to – water, wastewater,
police protection, and fire protection. CSA F is currently authorized by Sutter LAFCO to
provide fire protection and emergency medical services within unincorporated Sutter
County. The remaining service functions (i.e., powers) enumerated under the principal
act are deemed latent, meaning they are authorized by statute but would need to be
formally activated by Sutter LAFCO at a noticed public hearing and would be subject to
conducting authority proceedings. Similarly, CSA F may not divest itself from any of its
authorized service functions without LAFCO approval.
CSA F is governed by the County Board of Supervisors which consists of five-members that
represent an area of the County, known as a Supervisorial District. Each member of the
Board is elected by registered voters to four-year terms. The Board of Supervisors regularly
meets every Tuesday at the Yuba City Council Chambers at City Hall located at 1201
Civic Center Boulevard in Yuba City. The meetings are recorded and live streamed on
the internet for the public.
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The Board of Supervisors appoints an at-will Fire Chief to oversee the day-to-day
operations of the District. The current Fire Chief – Richard Epperson – was selected to
serve as the Interim Fire Chief in May 2024 and oversees a budgeted staff of 49.0
employees which includes two (2) Battalion Chiefs, nine (9) captains, five (5) Engineers,
six (6) Engineers (SAFER Grant paid), and twenty-seven (27) Volunteers. Budgeted staffing
has remained consistent between FY 2021 - 2023 where data is made available.54
Figure 53 below summarizes the Districts total budgeted staff over the report period.
Figure 53: CSA F’s Historical Budgeted Staff
Fiscal Year 2019 2020 2021 2022 2023 Average Trend
Type:
Paid Positions N/A N/A 22 22 22 22 0.0%
Volunteer Positions N/A N/A 27 27 27 27 0.0%
Total N/A N/A 49 49 49 49.0 0.0%
Per 100 residents N/A N/A 6.5 6.7 6.9 6.7 6.3%
Source: Sutter County Budgets FY 2019 - 2023
Volunteer firefighters receive $50 per 24-hour shift and $25 per 12-hour shift.
Department staff noted that while the Department currently has adequate staffing levels
to maintain its current level of services now and into the foreseeable future, Department
staff indicated that the Department did not receive a recent award for the Staffing for
Adequate Fire and Emergency Response (SAFER) Grant. As a result, the Department will
have to review staff capacity, and determine if current staffing levels can be maintained,
or if a reduction in staffing is necessary.
Training
CSA F fire personnel conduct regular trainings. CSA staff indicated that CSA F utilizes the
City of Yuba City’s training facilities on a periodic basis. Additionally, CSA staff noted that
54 Sutter County’s annual budgets for FY 2019 and FY 2020 do not provide budgeted staffing information for fire services.
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while the CSA does not conduct trainings regularly with CSA C and CSA D, CSA F believes
there is an opportunity for greater training collaboration between the three (3) CSAs.
MUNICIPAL SERVICES
CSA F was established to provide formal fire protection service in 1996. As granted under
Government Code Section 25213, CSA F is authorized to provide fire protection and
emergency medical services in Sutter County. CSA F’s emergency medical services are
classified as basic life support. The Sierra-Sacramento Valley EMS Agency designates Bi-
County Ambulance as the exclusive ambulance transport provider in Sutter County.
CSA F has two (2) fire stations, excluding the Live Oak Station No. 5, that the CSA operates
from. The current fire station details follow.
- Sutter Station No. 6 is located in the northern portion of CSA F at 2340 California
Street in the community of Sutter. The station was built in 2003 and is in good
condition according to CSA staff.
- Oswald Tudor Station No. 8 is located near the southeast perimeter of CSA F at 1280
Barry Road near Yuba City. The station was built in 1963 and is undersized for the
CSA’s modern equipment according to Department staff. CSA staff also noted that
while the station is functional, its location is not efficient for the CSA’s service
demands. CSA staff indicated that the CSA would benefit from moving this station
approximately six (6) miles south towards the southern perimeter of the CSA’s
jurisdictional boundary. The station also does not have a self-contained breathing
apparatus (“SCBA”) fill station which can result in operational disruptions, safety
concerns, and limited readiness for extended service responses. Lacking an SCBA
fill station, CSA staff are required to travel to another station or neighboring
jurisdiction to fill low or empty SCBA bottles. This action takes staff and apparatus
out of service and unavailable or delayed for emergency response until the SCBA
bottles are refilled and placed back in service on the apparatus. SCBA’s are vital
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to the effective operation of the fire department in their mission to protect life and
property. Without filled and ready SCBA’s, staff are unable to operate in an
atmosphere that is considered immediately dangerous to life or health (IDLH) as
developed by the National Institute for Safety and Health (NIOSH). This includes
smoke filled, gas filled, or oxygen deficient atmospheres that are regularly
encountered in fire and rescue operations.
CSA staff noted that both of its stations are equipped with exhaust removal systems. This
is beneficial to staff, as diesel exhaust emissions were designated as a carcinogen in 1998.
Ongoing exposure to diesel exhaust has been linked to lung cancer and bladder cancer,
and a suspected cause of other types of cancer. The National Fire Protection Association
(NFPA) 1500: Standard on Fire Department Occupational Safety, Health and Wellness
Program section 10.1.5 specifies “The fire department shall prevent exposure to firefighters
and contamination of living and sleeping areas to exhaust emissions through the use of
direct or source capture systems.” Though a station may have a door between the
apparatus bay and the living and sleeping quarters, the door alone will not prevent diesel
exhaust emissions from entering and remaining in other locations of the facility. Exhaust
removal systems capture the emissions at the tailpipe of the apparatus and remove the
emissions to the exterior of the building. Additionally, both stations have shower facilities
for firefighting personnel. This is important to allow firefighters the ability to
decontaminate their bodies following structure fires and other calls where carcinogens
may be absorbed.
The CSA currently has seven (7) apparatus that are stored at the CSA’s two (2) fire
stations. The CSA adopts a 2-0 staffing model for its apparatus in which each fire
apparatus is staff with two firefighters. CSA staff noted that the CSA would benefit from
upgrading the Department’s water tenders due to their age and operational condition.
Figure 16 summarizes the Department’s station staffing and apparatus conditions as of FY
2023.
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Figure 54: CSA F’s Fire Station(s) Assignments as FY 2023
Station No. 6 Station No. 8
Fire Engines Type 1 (2007) Type 1 (2024)
Type 1 (2005) Type 3 (2007)
Water Tenders Water Tender (1996) Water Tender (2006)
Other Vehicles Rescue ATV (2019) N/A
Total 4 3
Source: CSA F
CSA F also supplements its fire protection and emergency medical services by
maintaining reciprocal automatic and mutual aid agreements with neighboring
jurisdictions. This includes agreements with CSA C, CSA D, the Meridian Fire Protection
District, the Yuba City Fire Department, City of Marysville Fire Department, Colusa Fire
Department, and the City of Gridley Fire Department.
SERVICE DEMANDS AND CAPACITY
Overall demands for fire protection and emergency medical services from CSA F during
2020 to 2023 have averaged 2,873 dispatched calls annually or 7.9 calls daily. CSA F’s
largest single source of onsite responses involved emergency medical incidents which
accounted for 62.1% of all service calls for at the end of the report period (FY 2023).
Further, onsite arrivals necessitating fire protection services averaged 218 calls between
FY 2020 and FY 2023, and account for an overall decrease of 3.5 responses annually – or
(7.2%) from FY 2020 to FY 2023. CSA F’s peak demand was recorded in FY 2022 which
reflected a daily onsite response of 8.0 calls for service. Overall, CSA F’s total onsite
responses increased between FY 2020 and FY 2023 from 2,505 to 3,003 reflecting an
overall change of 19.88%.
Figure 55 below summarized CSA F’s fire protection and emergency medical demands
during FY 2020 – FY 2023.
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Figure 55: CSA F’s Service Demands between FY 2020 and FY 2023
Mentioned previously, CSA F receives a significantly higher volume of service calls when
compared to CSA C and CSA D. For instance, CSA C and CSA D responded to a total of
164 calls in 2023, while CSA F responded to 3,003 calls for service, reflecting significantly
higher service demands and a larger response area. Given the comparatively lower
service demand in CSA C and D, Sutter County should consider consolidating these
County Service Areas with CSA F. This merger could streamline operations, improve
service efficiency, and optimize resource allocation.
SERVICE PERFORMANCE
With respect to CSA F’s capacities to meet existing demands, the Department – as
measured by staffing and equipment – appear sufficiently sized to readily accommodate
the existing demands within its jurisdictional boundary through the timeframe of this
report. Other key performance measures follow.
- CSA F’s most recent evaluation of structural fire protection capabilities from the
Insurance Services Office (ISO) was completed in 2015 and resulted in a Class 4/5
rating for the Department’s Sutter Station No. 6 and a Class 5/10 rating for the
Department’s Oswald Tudor Station No. 8. This rating is considered appropriate for
a relatively rural service area where response travel distances can be long, and
credible water sources readily accessed by the fire department are limited. The
ISO score is a measure of the capability of the fire department to protect the
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community and is rated on a scale of 1 to 10, with 1 being the highest rating. ISO
evaluates the fire department for apparatus and equipment, weight of response
(number of firefighters arriving on scene), training, water supply and distribution,
emergency communications systems, and fire prevention/community risk
reduction efforts.
- CSA F does not have adopted response time standards for fire protection and
emergency medical calls. However, average response call data for 2023 are
detailed below in detailed below in Figure 56.55
Figure 56: CSA F’s Average Response Times as of FY 2023
Average Response
Station No.
Time
Station No. 6 7 minutes, 1 second
Station No. 8 7 minutes, 40 seconds
Source: Sutter County Fire
FISCAL HEALTH
The sections that follow evaluate County Service Area F’s (“CSA F” or “District”) fiscal
health, inclusive of revenue sources and major expenditure categories during the report
period (FY 2019 through FY 2023).
REVENUES & EXPENDITURES
CSA F’s total average revenues over the last five years totaled $3.9 million. The largest
single source of the District’s revenue is property taxes which account for $2.2 million – or
42.5% - of all revenues for the District. CSA F is the only CSA in the County Fire system with
a special fire tax. The tax has not had a cost-of-living adjustment since its adoption. Cost
55 The response time data presented in this table was provided directly by the respective fire protection service provider. RSG and
Planwest rely on the accuracy of the information submitted and is unable to independently verify this data.
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of living adjustments, or annual inflation rates, are common best practices when
adopting special taxes. The remainder of revenues for the District are derived from
income from intergovernmental revenues (grants and other state fundings), charges for
services, refunds and financing sources (sale of property, assets, debt proceeds, etc.). At
the end of FY 2023, CSA F total revenues amounted to $5.2 million and reflect an overall
increase of $2.1 million – or 70.8%.
With respect to expenditures, CSA F’s total average annual expenses over the report
period have been $3.7 million. The District’s expenses are further broken down into three
categories: (a) Salaries and Benefits; (b) Services and Supplies; and (c) Other. The
District’s costs associated with employee Salaries and Benefits account for more than
one-half – or 54.9% - of District expenditures, at $2.8 million as of FY 2023. It should be
noted that in January 2022, Sutter County came to agreement with the Professional Fire
Fighters Association, providing equity adjustments and one-time lump sum payments.
While the employees covered under this agreement are within CSA-F, dedicated funding
for the CSA is insufficient to sustain positions without financial support provided through
federal relief programs such as the CARES Act and ARPA, which are administered by
Sutter County.56 As a result, federal funding for CSA F has increased by approximately
295.8% from FY 2019 ($202,000) to FY 2023 ($799,300).
CSA F’s total expenditures at the end of the report period (FY 2023) totaled $5.2 million,
accounting for an overall increase of $2.3 million - or 79.3%. This amount translates to a
per capita cost of $547.5 based on a resident service population of 9,424 as of FY 2023.
The spike in expenditures can be largely attributed to an increase in salaries and benefits.
While there was a deficit in FY 2020, the District’s average net income over the last five
years totaled $190,000 and remained in a surplus for four out the five years reviewed.
Additional details regarding CSA F’s total revenues and expenditures are provided in
Figure 57 below.
56 Sutter County Comprehensive Annual Financial Report FY 2022-23
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Figure 57: Cash Flow – CSA F
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SOI/BOUNDARY & OTHER RECOMMENDATIONS – COUNTY SERVICE
AREA F
The following recommendations call for specific action from Sutter LAFCO and Sutter
County and pertain to the CSA F sphere of influence (“SOI”) amendments, boundary
changes, and any other recommendations:
1. Sutter LAFCO may proceed to re-affirm the CSA F sphere of influence with respect
to the delivery of fire protection and emergency medical services. CSA F’s sphere
of influence demarks the CSA’s current boundary and service area for fire
protection and emergency medical services.
2. CSA F may consider increasing its special assessment via a voter-approved ballot
initiative to maintain its current staffing levels and avoid potential disruptions to
service delivery. The Department’s existing special assessment has not had a cost-
of-living adjustment since its adoption. Cost of living adjustments, or annual
inflation rates, are standard best practices when adopting special taxes.
Additionally, the Department did not receive a recent award for the Staffing for
Adequate Fire and Emergency Response (SAFER) Grant. As a result, the
Department will have to review staff capacity, and determine if current staffing
levels can be maintained, or if a reduction in staffing is necessary.
An increase to the Department’s special assessment would offer greater financial
stability, enabling the Department to plan for future staffing needs, training, and
the acquisition of new equipment. Furthermore, implementing a cost-of-living
adjustment ensures that the Department’s special assessment keeps pace with
inflation and rising operational costs.
3. Sutter LAFCO should also consider proceeding with the approval of the
consolidation of County Service Area (“CSA”) C, D, and F upon receipt of a
completed change of organization application. CSA C and CSA D receive the
lowest call volumes in the County Fire system due to their small service populations,
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while CSA F experiences significantly higher service demands and services a larger
response area. Additionally, at present, CSA F personnel perform several
administrative oversight duties for both CSA C and D, which could be streamlined
through consolidation. This merger could thus streamline operations, improve
service efficiency, and optimize resource allocation. However, the County should
ensure collaboration and careful financial planning in order to preserve the fiscal
health of each County Service Area. A potential cost sharing agreement could
help preserve the financial resources of each service area by establishing a fair
funding allocation process, ensuring that existing funds are preserved for each
respective County Service Area, and creating a County Service Area Zone of
Increased Benefit to preserve CSA F’s existing special fire tax.
4. Sutter LAFCO may also consider exploring a broader, countywide consolidation of
all fire protection service providers in the County in the long term. Countywide
consolidation may offer several long-term benefits to fire protection and
emergency services in Sutter County, including enhanced operational efficiency,
improved coordination of resources, elimination of service redundancies, and
more equitable delivery of fire protection and emergency medical services across
service areas. Given the fiscal and staffing constraints faced by several of its
existing providers, consolidation may serve as a strategic pathway to strengthen
service reliability, ensure consistent standards of training and equipment, and
improve long-term fiscal sustainability.
To inform future decision making regarding countywide consolidation, it is
recommended that all fire protection service providers within the County
participate in a comprehensive Standards of Response Coverage (“SORC”) study.
This analysis should evaluate response times, station locations and coverage,
staffing, wages, benefits including pensions, and a forecast of past, current, and
future service delivery needs. Importantly, the study should also assess the financial
feasibility of a consolidated fire protection system.
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5. CSA F’s Oswald Tudor Station No. 8 is located near the southeast perimeter of CSA
F at 1280 Barry Road near Yuba City. While the station is operational, CSA F staff
noted that its current location is not well-suited to meet the CSA’s service needs.
CSA F staff indicated that relocating the station approximately six (6) miles south,
closer to the southern boundary of the CSA, would better align with existing and
future service demands.
RSG and Planwest recommend that any station relocation of Station No. 8 be
considered within the framework of a comprehensive Standards of Response
Coverage (“SORC”) and/or consolidation study. This analysis would provide the
data necessary to evaluate optimal station placement, assess coverage impacts,
and inform future resource deployment. Additionally, if Station No. 8 is relocated,
the Yuba City Fire Department 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.
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MSR DETERMINATIONS – COUNTY SERVICE AREA F
Sutter County LAFCO is directed to prepare written determinations to address the various
governance factors enumerated under Government Code Section 56430 whenever it
prepares a municipal service review. These determinations serve as independent
statements derived from the information collected, analyzed, and presented in the report
by RSG and Planwest. The purpose of the determinations is to provide an independent
assessment to the ability of CSA F to provide fire protection and emergency medical
services to residents within its jurisdictional boundary now and in the near future.
SERVICE PROVISION DETERMINATIONS
1. Growth and Population Projections
- There are approximately 9,424 residents in County Service Area (“CSA”) F as of
2024. CSA F has gained approximately 50 residents since 2010.
- The CSA F housing inventory has increased by approximately 58 housing units since
2010, representing an annual increase of 4 units each year.
- The CSA F resident population is projected to grow to 9,485 residents by 2029, an
annual growth rate of approximately 0.1%.
- The number of housing units in CSA F is expected reach 3,567 housing units by 2029.
This represents an annual growth rate of approximately 0.1%.
2. Location and Characteristics of Disadvantaged Unincorporated Communities within or
Contiguous to SOI
According to Sutter LAFCO’s policies, there is one (1) Disadvantaged
Unincorporated Communities (“DUCs”) contiguous to the southwestern boundary
of CSA F in the Sutter Basin Fire Protection District. The Sutter Basin Fire Protection
District is the primary fire protection and emergency medical services provider to
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this DUC. Additionally, there is one (1) DUC and one (1) SDUC located contiguous
the City of Live Oak city limits. CSA F is the primary fire protection and emergency
medical service provider to these areas.
3. Present and Planned Capacity of Facilities, Adequacy of Public Services, and
Infrastructure Needs and Deficiencies in any Disadvantaged Unincorporated
Communities within or Contiguous to SOI
The following statements apply to the County Service Area F (“CSA F” or
“Department”) with respect to the availability, adequacy, and performance of its
fire protection and emergency medical services available under Government
Code Section 25213. These statements serve to confirm the determination that CSA
F has the adequate capacity, infrastructure and availability to continue to provide
fire protection and emergency medical services to its residents now and into the
foreseeable future.
- Fire protection and emergency medical services are provided from two (2)
fire stations, excluding Live Oak Station No. 5 that is used to provide fire
protection and emergency medical services to the City of Live Oak via a
formal contract with Sutter County Fire.
- The Sutter Station No. 6 is located in the northern portion of CSA F at 2340
California Street in the community of Sutter. The station was built in 2003 and
is in good condition according to CSA staff.
- The Oswald Tudor Station No. 8 is located near the southeast perimeter of
CSA F at 1280 Barry Road near Yuba City. The station was built in 1963 and is
undersized for the CSA’s modern equipment. CSA staff also noted that while
the station is functional, the CSA would benefit from moving this station
approximately six (6) miles south towards the southern perimeter of the CSA’s
jurisdictional boundary.
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- The CSA currently has seven (7) apparatus that are stored at the CSA’s two
(2) fire stations, including four (4) fire engines, two (2) water tenders, and one
(1) rescue ATV vehicle. CSA staff noted that the CSA would benefit from
upgrading the Department’s water tenders due to their age and operational
condition.
- Overall demands for fire protection and emergency medical services from
CSA F during 2020 to 2023 have averaged 2,873 dispatched calls annually or
7.9 calls daily.
- CSA F has the sufficient capacity and related infrastructure to meet the
community’s needs now and in the near future.
4. Financial Ability to Provide Services
CSA F has the financial ability to provide fire and emergency medical services to
its existing residents located within its jurisdictional boundary.
- At the end of FY 2023, the CSA F’s total revenues amounted to $5.2 million
and reflect an overall increase of 70.8% since FY 2019.
- CSA F’s total expenditures at the end of FY 2023 totaled $5.2 million,
representing an overall increase of 79.3% since the beginning of the report
period.
- The Department has increasingly relied on federal funds administered by
Sutter County to supplement its annual budget as a result of Sutter County
reaching an agreement with the Professional Fire Fighters Association to
provide equity adjustments and one-time lump sum payments to CSA staff
in January 2022. In FY 2023, CSA F received approximately $799,300 from
these funds.
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- The Department’s average net income over the last five years was about
$190,000 and remained in a surplus for four out the five years reviewed.
- CSA F is the only CSA in the County Fire system with a special fire tax. The tax
has not had a cost-of-living adjustment since its adoption. Cost of living
adjustments, or annual inflation rates, are common best practices when
adopting special taxes.
- Department staff indicated that the Department did not receive a recent
award for the Staffing for Adequate Fire and Emergency Response (SAFER)
Grant. As a result, the Department will have to review staff capacity, and
determine if current staffing levels can be maintained, or if a reduction in
staffing is necessary.
5. Opportunities for Shared Facilities
There may be an opportunity for consolidation between County Service Area C, D,
and F, given CSA C and D’s comparatively lower call volume and the existing
administrative inefficiencies mentioned above. No other opportunities for shared
facilities were identified as part of this MSR.
6. Accountability for Community Service Needs, including Governmental Structure and
Operational Efficiencies
The Board of Supervisors regularly meets on every Tuesday of the month. The
meetings are recorded and live streamed on via the internet for the public. CSA F
provides access to public information through Facebook and town hall meetings.
To enhance accountability and transparency for its public constituents, Sutter
County should make accessible information regarding the Fire Department’s range
of fire protection and emergency medical services, governance structure
(including an organizational chart), compensation details, annual budgets, reserve
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fund policy, and the current and historical annual financial reports provided to the
State Controller’s Office.
7. Any Other Matter Related to Effective or Efficient Service Delivery as Required by
Commission Policy
Other matters related to effective or efficient service delivery as requires by LAFCO
policy were not identified.
Sutter County LAFCO is also directed to prepare a written statement of determinations in
determining the sphere of influence of each local agency enumerated under
Government Code Section 56425 whenever it prepares a sphere of influence update. The
purpose of the determinations is to provide an independent assessment to the ability of
CSA F to provide fire protection and emergency medical services to residents within its
sphere of influence now and in the near future.
SPHERE OF INFLUENCE DETERMINATIONS
1. Present and Planned Land Uses
Most land within CSA F’s sphere of influence primarily consists of agricultural and
residential uses. While there are no significant developments planned within the
CSA F jurisdictional boundary, the Sutter Pointe Specific Plan area is a master-
planned, mixed-use community located in CSA D’s jurisdictional boundary that will
include a combination of residential, employment, service, open space, and
public uses. The Plan area will break ground in the fall of 2025 and may result in
significant increases in call volume for CSA F.
2. Present and Probable Need for Public Facilities and Services
The CSA F’s sphere of influence defines the CSA’s current boundary and service
area for fire protection and emergency medical services. However, RSG and
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Planwest Partners recommend Sutter LAFCO should consider proceeding with the
approval of the consolidation of County Service Area (“CSA”) C, D, and F upon
receipt of a completed change of organization application to streamline
operations, improve service efficiency, and optimize resource allocation.
3. Present Capacity and Adequacy of Public Facilities
CSA F has sufficient capacity and adequate infrastructure and related facilities to
continue to provide fire protection and emergency medical services to its residents
now and in the future. The comprehensive review of the Sutter County Fire capacity
and demands in this report supports these claims.
4. Presence of Social or Economic Communities of Interest
The CSA F sphere of influence does not include any social or economic
communities of interests.
5. Present and Probable Need for Public Services of any Disadvantaged Unincorporated
Communities (“DUCs”)
According to Sutter LAFCO’s policies, there is one (1) Disadvantaged
Unincorporated Communities (“DUCs”) contiguous to the southwestern boundary
of CSA F in the Sutter Basin Fire Protection District. The Sutter Basin Fire Protection
District is the primary fire protection and emergency medical services provider to
this DUC. Additionally, there is one (1) DUC and one (1) SDUC located contiguous
the City of Live Oak city limits. CSA F is the primary fire protection and emergency
medical service provider to these areas.
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COUNTY SERVICE AREA G
County Service Area G (“CSA G”) is a dependent special district formed in May 2001 to
provide fire protection services to the former Walton Fire Protection District. CSA G is
legally authorized to provide fire protection and emergency medical services in the
northeast portion of Sutter County. The Yuba City Fire Department provides fire protection
services to the entirety of CSA G through a contract with Sutter County.
CSA G’s jurisdictional boundary currently spans approximately 18.5 square miles and is
surrounded by County Service Area F to the north, west, and south, and Yuba City to the
east. CSA G’s SOI is coterminous with its service boundary.
JURISDICTIONAL BOUNDARY & SPHERE OF INFLUENCE
CSA G’s current jurisdictional boundary spans an area of approximately 18.5 square miles
with a coterminous sphere of influence designation. The District’s sphere was last updated
in 2017.
As of FY 2023, the total assessed value (land and structures) within CSA G is approximately
$1.9 billion, a per capita value of approximately $271,028 based on the current resident
population of 7,070. Figure 58 presents CSA G’s sphere in relation to its jurisdictional
boundary.
BOGUE STEWART MASTER PLAN
In 2021, the City of Yuba City annexed approximately 741 acres, known as the Bogue
Stewart Master Plan area, located at the southern boundary of Yuba City’s city limits,
which borders the CSA G’s southern boundary. The Bogue Stewart Master Plan area
(“Plan area”) will include over 2,500 residential units, almost 1.2 million square feet of non-
residential space, and 84 acres of parks, open space, and public facilities. At build-out,
the Plan area will result in an additional 6,720 residents and 1,894 employees. The project
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will be constructed in three distinct phases in which development will initially occur along
Highway 99 and then generally spread further to the east and west.57
57 Source: Bogue Stewart Master Plan (May 2019)
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Figure 58: CSA G Jurisdictional Boundary and SOI Map
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DEMOGRAPHICS
POPULATION & HOUSING
CSA G’s total current resident population within its jurisdictional boundary is estimated at
7,070 as of 2024. This amount represents 7.1% of the countywide population total. The
estimated resident population in CSA G has risen overall by 5.9% - or approximately 395
residents - since 2010, demonstrating an upward trend.58 Similarly, CSA G experienced a
reduction of 11 residents each year since 2020, from 7,114 residents to 7,070 residents in
2024. The latter produces a population density of 0.6 residents for every acre and
underlies the overall rural characteristic of CSA G’s jurisdictional boundary. The Sutter
County 2030 General Plan does not specify the exact percentages of land use types
within CSA G; however, the area consists of a mix of residential and agricultural land uses.
CSA G’s population is expected to decline by approximately (0.13%) annually over the
next five-years falling to 7,024 residents by 2029 and reflects an overall decrease of 46
residents.59 On the other hand, the countywide population is expected to grow 0.3% and
reach 99,795 residents by 2029. Figure 59 summarizes CSA G’s and the County’s past,
present and future population growth.
Figure 59: CSA G’s Resident Population
There are an estimated 2,494 housing units within CSA G’s boundary as of FY 2024. This
amount accounts for an overall increase of 35 units – or 1.4% - since 2010 for an annual
58 Source: ESRI Business Analyst
59 Source: ESRI Business Analyst
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change of 3 housing units. This creates a ratio of 0.1 housing units for every 1 new resident.
Furthermore, it is expected that the District’s total number of housing units will remain
largely unchanged over the next five years.
Of the total number of current housing units in CSA G, approximately 70.0% are owner-
occupied. The remainder of housing units are divided between 25.3% being renter-
occupied and 4.6% being vacant. Further, the average household size in CSA G for 2024
is 2.93. This amount reflects an increase of 3.9% since 2010 wherein the average household
size was 2.82. Figure 60 includes additional details regarding CSA G’s housing
characteristics.
Figure 60: CSA G’s Housing Characteristics
AGE DISTRIBUTION & INCOME
Relative to the County as a whole, the population of the CSA G service area has been
somewhat older. The median age of residents in CSA G is 40.2 and reflects an increase of
1.0% since 2010 wherein the median age was 39.8. The current median age in CSA G
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remains slightly higher than the countywide median age of 37.5 demonstrating an older
resident population.
Similarly, 93.0% - of residents within the prime working age group (between the ages of
25-64) are employed while the remaining 7.0% are unemployed, reflecting a stable
workforce within the District’s jurisdictional boundary.60 Additional details regarding CSA
G’s age distribution and employment rates are provided in Figure 61.
Figure 61: CSA G’s Age Distribution
Age Distribution CSA G Sutter County
2010 Median Age 39.8 34.6
2024 Median Age 40.2 37.5
% Change (2010-2024) 1.0% 7.7%
2024 Employment Levels (Ages 25-64) 93.0% 92.5%
2024 Unemployment Levels (Ages 25-64) 7.0% 7.5%
Source: ESRI Business Analyst
The median household income of CSA G is $94,562 which is approximately 25.2% higher
than the County’s median household income of $70,700. This amount confirms households
in CSA G are receiving moderately more pay over the report period compared to the
county as whole. Furthermore, CSA G has a poverty level rate of 10.9%, which is
approximately (21.1%) lower than the County’s poverty level rate of 13.2%.
According to Sutter LAFCO’s policies, there are three Disadvantaged Unincorporated
Communities (DUCs) located in CSA G. The Yuba City Fire Department is the primary fire
protection and emergency medical services provider to these DUCs. A DUC is defined as
60 The prime working age group does not include individuals between the ages of 16-25 nor 65 and above given residents within
these age groups are typically in school or nearing/in retirement.
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any unincorporated area wherein the median household income is less than $76,416.80.61
Figure 62 provides an overview of income characteristics in CSA G and the County.
Figure 62: CSA G’s Income Characteristics
Income Characteristics CSA G Sutter County
2024 Median Household Income $94,562 $70,700
2024 Median Household Income Per $40,850 $32,860
Poverty Level (2018-2022) 10.9% 13.2%
Source: ESRI Business Analyst
GOVERNANCE AND STAFFING
The County Service Area G (“CSA G”) operates as a county-dependent special district
under the County Service Area Law and codified under Government Code Section 25210
et seq. The act empowers CSA districts to provide a range of municipal services in the
county upon approval by LAFCOs - including but not limited to – water, wastewater,
police protection, and fire protection. CSA G is currently authorized by Sutter LAFCO to
provide fire protection and emergency medical services within unincorporated Sutter
County. The remaining service functions (i.e., powers) enumerated under the principal
act are deemed latent, meaning they are authorized by statute but would need to be
formally activated by Sutter LAFCO at a noticed public hearing and would be subject to
conducting authority proceedings. Similarly, CSA G may not divest itself from any of its
authorized service functions without LAFCO approval.
While CSA G is legally governed by the County Board of Supervisors, which consists of
five-members that represent an area of the County, known as a Supervisorial District, the
City of Yuba City governs the day-to-day operations of CSA G. Each member of the Board
61 Source: Government Code Section 56033.5 and 56046, Water Code Section 79505.5(a), Public Resources Code Section
75005(g), American Community Survey Census 2019-2023 data
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of Supervisors is elected by registered voters to four-year terms. The Board of Supervisors
regularly meets every Tuesday at the Yuba City Council Chambers at City Hall located at
1201 Civic Center Boulevard in Yuba City. The meetings are recorded and live streamed
on via the internet for the public.
The Board of Supervisors appoints an at-will Fire Chief to oversee the administrative
operations of the CSA. The current County Fire Chief – Richard Epperson – was selected
to serve as the Interim Fire Chief in May 2024. The current Yuba City Fire Chief – Josh
Hubbard – oversees the day-to-day operations of providing fire protection and
emergency medical services to the CSA through its contract with County Fire. Page 78
summarizes the Yuba City Fire Department’s total budgeted staff over the report period.
MUNICIPAL SERVICES
CSA G was established to provide formal fire protection service in 2001. As granted under
Government Code Section 25213, CSA D is authorized to provide fire protection and
emergency medical services in Sutter County. CSA G’s emergency medical services are
classified as basic life support. The Sierra-Sacramento Valley EMS Agency designates Bi-
County Ambulance as the exclusive ambulance transport provider in Sutter County.
Fire protection and municipal services for CSA G are provided from the Yuba City Fire
Department’s five (5) fire stations. One of the stations, Yuba City Station No. 4, is located
within CSA G’s jurisdictional boundary. The Yuba City Fire Department owns all of the
apparatus equipment utilized to provide services to CSA G, which includes all seventeen
(17) pieces of the Department’s apparatus equipment. A total of six (6) apparatus are
stored within Yuba City Station No. 4 located within CSA G. Additional details regarding
the Yuba City Fire Department’s fire stations and apparatus equipment can be found
beginning on Page 80.
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SERVICE DEMANDS AND CAPACITY
The Yuba City Fire Department does not track service calls in CSA G separate from service
calls received within Yuba City city limits. Yuba City Fire Department staff noted that it
can be challenging to separate CSA G calls from the Department’s total call volume
since each service call’s location would have to be evaluated on a call-by-call basis.
However, in 2022, the Department attempted to track its calls for service in the CSA G
service area and estimates that it responded to approximately 1,078 calls in CSA G that
calendar year. This equates to approximately 9.4% of the Department’s total call volume
in 2022. Additional details regarding the Yuba City Fire Department’s total service
demands during the reporting period can be found beginning on Page 84.
SERVICE PERFORMANCE
With respect to the Yuba City Fire Department’s capacities to meet existing demands in
CSA G, the Department – as measured by staffing and equipment – appear sufficiently
sized to readily accommodate the existing demands within its jurisdictional boundary
through the timeframe of this report. Additional details regarding the Yuba City Fire
Department’s service performance can be found beginning on Page 85.
FISCAL HEALTH
The sections that follow evaluate County Service Area G’s (“CSA G” or “Department”)
fiscal health, inclusive of revenue sources and major expenditure categories during the
report period (FY 2019 through FY 2023).
REVENUES & EXPENDITURES
CSA G’s total average revenues over the last two years of available data totaled
$912,000. The largest single source of the District’s revenue is property taxes which
account for $920,000 – or 98.0% - of all revenues for the District. The remainder of revenues
for the District are derived from investment income. At the end of FY 2023, CSA G’s total
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revenues amounted to $937,000 and reflect an overall increase of $5,000 – or 5.6% from
the previous fiscal year.
With respect to expenditures, CSA G’s total average annual expenses over the last two
years of available data totaled $913,000. The District’s costs associated with supplies and
services account for over nine-tenths – or 99.0% - of District expenditures, at $928,000 as
of FY 2023.
CSA G’s total expenditures at the end of the report period (FY 2023) totaled $936,000, This
translates to a per capita cost of $132.20 based on a resident service population of 7,081
as of FY 2023.
In FY 2023, the District maintained a minimal surplus to cover operational costs, leaving
little to no financial cushion for unexpected expenses. Similarly, in FY 2022, the District
experience a deficit suggesting the District did not maintain sufficient revenues to cover
operational costs for that year. Further, based on the two fiscal years of data available,
the District’s financial position appears fragile, with limited flexibility to absorb
unanticipated cost or economic fluctuations. While revenues were sufficient to cover
expenses in FY 2023, the minimal surplus suggests a lack of financial resilience. Without
additional revenue sources or cost-saving measures, CSA G may encounter challenges
to responding to unforeseen financial pressures which may impact service delivery in the
future and/or affect long-term fiscal sustainability. However, given the limited financial
information made available, a more accurate assessment of the District’s financial
capacity would require obtaining additional financial information. Additional details
regarding CSA G’s total revenues and expenditures are provided in Figure 63 below.
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Figure 63: Cash Flow – CSA G
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SOI/BOUNDARY & OTHER RECOMMENDATIONS – COUNTY SERVICE
AREA G
The following recommendations call for specific action from Sutter LAFCO and Sutter
County and pertain to the CSA G’s sphere of influence (“SOI”) amendments, boundary
changes, and any other recommendations:
1. Sutter LAFCO should proceed to affirm CSA G’s sphere of influence with respect to
the delivery of fire protection and emergency medical services. CSA G’s sphere of
influence demarks the CSA’s current boundary and service area for fire protection
and emergency medical services.
2. Sutter County could consider establishing a County Service Area Zone of Increased
Benefit (“ZIB”) for the CSA G service area. A ZIB can provide a structured and
sustainable funding mechanism for the ongoing delivery of fire protection and
emergency medical services and ensure the service area receives an enhanced
level of service delivery due to its comparatively higher population density. There
may be administrative and operational inefficiencies with four (4) separate County
Service Areas within a single County, especially when all of the CSAs are providing
the same services. ZIBs can allow for targeted service delivery based on the
specific needs of different areas within a consolidated CSA, ensuring efficiency
and equitable service provision.
3. Sutter LAFCO may also consider exploring a broader, countywide consolidation of
all fire protection service providers in the County in the long term. Countywide
consolidation may offer several long-term benefits to fire protection and
emergency services in Sutter County, including enhanced operational efficiency,
improved coordination of resources, elimination of service redundancies, and
more equitable delivery of fire protection and emergency medical services across
service areas. Given the fiscal and staffing constraints faced by several of its
existing providers, consolidation may serve as a strategic pathway to strengthen
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service reliability, ensure consistent standards of training and equipment, and
improve long-term fiscal sustainability.
To inform future decision making regarding countywide consolidation, it is
recommended that all fire protection service providers within the County
participate in a comprehensive Standards of Response Coverage (“SORC”) study.
This analysis should evaluate response times, station locations and coverage,
staffing, wages, benefits including pensions, and a forecast of past, current, and
future service delivery needs. Importantly, the study should also assess the financial
feasibility of a consolidated fire protection system.
4. CSA G currently receives its share of the 1% property tax allocation; however, CSA
G may consider the establishment of a permanent funding source, such as a
special assessment or parcel tax to cover the entire cost of contracted fire and
emergency medical services with the Yuba City Fire Department. The CSA
maintained a minimal surplus to cover operational costs in FY 2023 and
experienced a deficit in FY 2022. A permanent funding source, such as a special
assessment or parcel tax, would offer greater financial stability, enabling the CSA
G to continue contracting with the Yuba City Fire Department for fire protection
and emergency medical services.
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MSR DETERMINATIONS – COUNTY SERVICE AREA G
Sutter County LAFCO is directed to prepare written determinations to address the various
governance factors enumerated under Government Code Section 56430 whenever it
prepares a municipal service review. These determinations serve as independent
statements derived from the information collected, analyzed, and presented in the report
by RSG and Planwest. The purpose of the determinations is to provide an independent
assessment to the ability of CSA G to provide fire protection and emergency medical
services to residents within its jurisdictional boundary now and in the near future.
SERVICE PROVISION DETERMINATIONS
1. Growth and Population Projections
- RSG estimates there are approximately 7,078 residents in County Service Area
(“CSA”) G as of 2024. RSG estimates CSA G has gained approximately 395 residents
since 2010.
- CSA G has gained approximately 35 housing units since 2010. This new
development accounts for an annual increase of 3 units each year.
- The CSA G resident population is expected to amount to 7,024 residents by 2029.
This accounts for an annual growth rate of approximately (0.1%).
- The number of housing units in CSA F is expected to reach 2,528 housing units by
2029. This accounts for an annual growth rate of less than 1.0%.
2. Location and Characteristics of Disadvantaged Unincorporated Communities within or
Contiguous to SOI
According to Sutter LAFCO’s policies, there are three Disadvantaged
Unincorporated Communities (DUCs) located in CSA G. The Yuba City Fire
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Department is the primary fire protection and emergency medical services
provider to these DUCs.
3. Present and Planned Capacity of Facilities, Adequacy of Public Services, and
Infrastructure Needs and Deficiencies in any Disadvantaged Unincorporated
Communities within or Contiguous to SOI
The following statements apply to the County Service Area G (“CSA F” or
“Department”) with respect to the availability, adequacy, and performance of its
fire protection and emergency medical services through its contract with the Yuba
City Fire Department. These statements serve to confirm RSG and Planwest’s
determination that the Yuba City Fire Department has the adequate capacity,
infrastructure and availability to continue to provide contracted fire protection
and emergency medical services to CSA G’s residents now and into the
foreseeable future.
- Yuba City provides fire protection and emergency medical services by way
of a formal contract with CSA G out of its five (5) fire stations with a total
public safety staffing of 56.0 personnel at the end of the report period (FY
2023).
- One of the stations, Yuba City Station No. 4, is located within CSA G’s
jurisdictional boundary.
- The Yuba City Fire Department owns all of the apparatus equipment utilized
to provide services to CSA G, which includes all seventeen (17) pieces of the
Department’s apparatus equipment.
- The Yuba City Fire Department does not track service calls in CSA G separate
from service calls received within Yuba City city limits. However, in 2022, the
Department attempted to track its calls for service in the CSA G service area
and estimates that it responded to approximately 1,078 calls in CSA G that
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calendar year. This equates to approximately 9.4% of the Department’s total
call volume in 2022.
- The Yuba City Fire Department has sufficient capacity and related
infrastructure to meet the community’s needs now and in the near future by
way of formal contract.
4. Financial Ability to Provide Services
CSA G has the financial ability to provide fire and emergency medical services to
its existing residents located within its jurisdictional boundary.
- At the end of FY 2023, CSA F’s total revenues amounted to $937,000 and
reflect an overall increase of 5.6% from the prior fiscal year.
- CSA G’s total expenditures at the end of the report period (FY 2023) totaled
$913,000.
- The District’s average net income over the last two fiscal years reviewed
totaled $190,000.
- In FY 2023, the District maintained a minimal surplus to cover operational
costs, leave little to no financial cushion for unexpected expenses. Similarly,
in FY 2022, the District experienced a deficit suggesting the District did not
maintain sufficient revenues to cover operational costs for that year.
- Based on the two fiscal years of data available, the District’s financial
position appears fragile, with limited flexibility to absorb unanticipated cost
or economic fluctuations. CSA G may encounter challenges to responding
to unforeseen financial pressures which may impact service delivery in the
future and/or affect long-term fiscal sustainability.
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5. Opportunities for Shared Facilities
The Yuba City Fire Department provides contracted fire protection and emergency
medical services to the CSA G service area. No other opportunities for shared
facilities were identified as part of this MSR.
6. Accountability for Community Service Needs, including Governmental Structure and
Operational Efficiencies
The Board of Supervisors regularly meets on every Tuesday of the month. The
meetings are recorded and live streamed on the internet for the public.
Furthermore, the Yuba City City Council regularly meets on the first and third
Tuesday of every month in the Council Chambers in the City Hall located at 1201
Civic Center Boulevard in Yuba City.
7. Any Other Matter Related to Effective or Efficient Service Delivery as Required by
Commission Policy
Other matters related to effective or efficient service delivery as requires by LAFCO
policy were not identified.
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Sutter County LAFCO is also directed to prepare a written statement of determinations in
determining the sphere of influence of each local agency enumerated under
Government Code Section 56425 whenever it prepares a sphere of influence update. The
purpose of the determinations is to provide an independent assessment to the ability of
CSA G to provide fire protection and emergency medical services to residents within its
sphere of influence now and in the near future.
SPHERE OF INFLUENCE DETERMINATIONS
1. Present and Planned Land Uses
Most land within CSA G’s sphere of influence primarily consists of agricultural and
residential uses. CSA G is in proximity to the Bogue Stewart Master Plan area,
consisting of approximately 741 acres that was annexed by the City of Yuba City
in 2021. The Bogue Stewart Master Plan area will include over 2,500 residential units,
almost 1.2 million square feet of non-residential space, and parks, open space, and
public facilities. No other major planned developments were identified as part of
this MSR.
2. Present and Probable Need for Public Facilities and Services
The CSA G’s sphere of influence roughly demarks the CSA’s current boundary and
service area for fire protection and emergency medical services. At present, CSA
G’s jurisdictional boundary follows a roughly square shape bound by Eager Road
to north, North Township Road to the west, the Feather River to the east, and Reed
Road to the south, which may not accurately reflect actual population densities
and service demands. By aligning the CSA’s sphere of influence more closely with
actual service needs, Sutter LAFCO could ensure that existing and future delivery
of fire protection and emergency medical services to the CSA G area are
accurately reflected.
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3. Present Capacity and Adequacy of Public Facilities
The Yuba City Fire Department has sufficient capacity and adequate infrastructure
and related facilities to continue to provide fire protection and emergency
medical services to CSA G’s residents now and in the future. The comprehensive
review of the Yuba City Fire Department capacity and demands in this report
supports these claims.
4. Presence of Social or Economic Communities of Interest
The CSA G sphere of influence does not include any social or economic
communities of interests.
5. Present and Probable Need for Public Wastewater of any Disadvantaged
Unincorporated Communities (“DUCs”)
According to Sutter LAFCO’s policies, there are three Disadvantaged
Unincorporated Communities (DUCs) located in CSA G. The Yuba City Fire
Department is the primary fire protection and emergency medical services
provider to these DUCs.
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MERIDIAN FIRE PROTECTION DISTRICT
The Meridian Fire Protection District (“Meridian FPD”) - originally established in 1928 and
previously known as “Meridian Fire Department” - is an independent special district
formed in 1977 and is legally authorized to provide fire protection and emergency
medical services in the northwest portion of Sutter County. Meridian FPD’s jurisdictional
boundary currently spans approximately 81 square miles and is anchored by Robbins
Sutter Basin Fire Protection District to the south, County Service Area F to the north and
east, and Colusa County to the west. The District’s SOI is coterminous with its service
boundary.
JURISDICTIONAL BOUNDARY & SPHERE OF INFLUENCE
Meridian FPD’s current jurisdictional boundary spans an area of approximately 81 square
miles with coterminous sphere of influence designation. Meridian FPD’s sphere of
influence was last updated in 2011.
As of FY 2023, the total assessed value (land and structures) within the Meridian FPD is
approximately $574.1 million, a per capita value of approximately $776,848 based on the
current resident population of 739.
Figure 64 presents Meridian FPD’s sphere in relation to its jurisdictional boundary.
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Figure 64: Meridian FPD Jurisdictional Boundary and SOI Map
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DEMOGRAPHICS
POPULATION & HOUSING
Meridian FPD’s total current resident population within its jurisdictional boundary is
estimated at 739 as of 2024. This amount represents 0.7% of the countywide population
total. The estimated resident population in Meridian FPD has decreased overall by 2.1% -
or approximately 16 residents - since 2010, demonstrating a downward trend.62 More
recently, Meridian FPD has added 15 residents each year over the last 4 years, from 680
in 2020 to 739 in 2024. The current resident population produces a population density of
0.37 residents for every acre and underlies the overall rural characteristic of Meridian
FPD’s jurisdictional boundary. The Sutter County 2030 General Plan does not specify the
exact percentages of land use types within the Meridian FPD; however, the area consists
of a mix of residential and agricultural land uses. Lastly, a majority of the District, or
approximately 53.5%, is designated as a Local Flood Hazard Area.63
Meridian FPD’s population is expected to decrease by approximately 0.16% annually over
the next five-years reaching 733 residents by 2029 and reflects an overall decrease of 6
residents.64 This growth is slightly lower than the anticipated annual population growth
countywide which is expected to grow 0.03%, reaching 99,795 residents by 2029. Figure
65 summarizes Meridian FPD and the County’s past, present and future population
growth.
62 Source: ESRI Business Analyst
63 Source: Sutter County GIS
64 Source: ESRI Business Analyst
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Figure 65: Resident Population
There are an estimated 303 housing units within Meridian FPD’s boundary as of FY 2024.
This amount accounts for an overall decrease of 26 units – or 7.9% - since 2010 for an
annual change of 2 housing units. It is expected that the District’s total number of housing
units will remain the same through the year 2029.
Of the total number of current housing units in Meridian FPD approximately 54.1% are
owner-occupied. The remainder of housing units are divided between 37.0% being renter-
occupied and 8.9% being vacant. Further, the average household size in Meridian for
2024 is 2.68. This amount reflects a decrease of 5.0% since 2010 wherein the average
household size was 2.82. Figure 66 includes additional details regarding Meridian FPD’s
housing characteristics.
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Figure 66: Housing Characteristics
AGE DISTRIBUTION & INCOME
Relative to the County as a whole, the population of the Meridian FPD service area has
been somewhat older. The median age of residents in the Meridian FPD is 40.2 and reflects
an increase of 1.0% from 39.8 since 2010. The current median age in Meridian FPD remains
slightly higher than the countywide median age of 37.5 demonstrating an older resident
population.
Similarly, 96.9% of residents within the prime working age group (between the ages of 25-
64) are employed while the remaining 3.1% are unemployed, reflecting a stable
workforce within the District’s jurisdictional boundary.65 Additional details regarding the
Meridian FPD’s age distribution and employment rates are provided in Figure 67.
65 The prime working age group does not include individuals between the ages of 16-25 nor 65 and above given residents within
these age groups are typically in school or nearing/in retirement.
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Figure 67: Meridian FPD’s Age Distribution
Age Distribution Meridian FPD Sutter County
2010 Median Age 39.8 34.6
2024 Median Age 40.2 37.5
% Change (2010-2024) 1.0% 7.7%
2024 Employment Levels (Ages 25-64) 96.9% 92.5%
2024 Unemployment Levels (Ages 25-64) 3.1% 7.5%
Source: ESRI Business Analyst
The median household income of Meridian FPD is $64,698 which is approximately 9.3%
lower than the County’s median household income of $70,700. This amount confirms
households in the Meridian FPD are receiving moderately less pay over the report period
compared to the county as whole. Furthermore, the Meridian FPD has a poverty level rate
of 11.2%, which is approximately (17.9%) lower than the County’s poverty level rate of
13.2%.
According to Sutter LAFCO’s policies, there is one (1) Disadvantaged Unincorporated
Communities (“DUCs”) contiguous to the southern boundary of the District in the Sutter
Basin Fire Protection District. The Sutter Basin Fire Protection District is the primary fire
protection and emergency medical services provider to this DUC. A DUC is defined as
any unincorporated area wherein the median household income is less than $76,416.80.66
Figure 68 provides an overview of income characteristics in the Meridian FPD and County.
66 Source: Government Code Section 56033.5 and 56046, Water Code Section 79505.5(a), American Community Survey Census
2019-2023 data
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Figure 68: Income Characteristics
Income Characteristics Meridian FPD Sutter County
2024 Median Household Income $64,698 $70,700
2024 Median Household Income Per $26,955 $32,860
Poverty Level (2018-2022) 11.2% 13.2%
Source: ESRI Business Analyst
GOVERNANCE AND STAFFING
The Meridian Fire Protection District operates as an independent special district under the
Fire Protection District Law of 1987 and codified under Health and Safety Code 13800 et.
seq. This principal act empowers fire protection districts to provide a range of municipal
services upon approval by LAFCOs including fire protection, rescue, emergency medical,
hazardous material, ambulance services, and any other services relating to the
protection of lives and property. Meridian FPD is currently authorized by Sutter LAFCO to
provide fire protection, emergency medical care, basic life support services, vehicle
extraction, water rescue, and hazardous material clean up. The remaining service
functions (i.e., powers) enumerated under the principal act are deemed latent, meaning
they are authorized by statute but would need to be formally activated by Sutter LAFCO
at a noticed public hearing and subject to conducting authority proceedings.
Meridian FPD is governed by a five-member Board of Directors that serve four-year terms.
The Meridian FPD Board of Directors regularly meets in-person every month. Meeting
agendas are posted 72 hours in advance of each Board meeting.
The District appoints an at-will Fire Chief and Assistant Fire Chief to oversee the day-to-
day operations of the District. The current Fire Chief – Jason Cooper – oversees ten (10)
staff members, including the Assistant Fire Chief, seven (7) part-time employees, and two
(2) volunteer firefighters.
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Figure 69 below summarizes the Departments total budgeted staff over the report period.
Figure 69: Meridian’s FPD’s Budgeted Staff
Fiscal Year 2019 2020 2021 2022 2023 Average Trend
Type:
Paid Positions 2 2 3 3 2 2.4 0.0%
Volunteer Positions 5 6 7 11 11 8 120.0%
Total 7 8 10 14 13 10.4 85.7%
Per 100 residents 0.9 1.0 1.3 1.9 1.8 1.4 105.9%
Source: SCO - Public Pay Data FY 2019 - 2022, Meridian FPD FY 2023
District staff noted that it has been difficult to recruit and retain volunteers at the District
due to the rural nature and low call volume in the District’s service area. District staff also
noted that potential volunteers often work out of the District, which presents a challenge
to daytime responses to calls for service. The District also expressed difficulty in
maintaining duty officer coverage due to long-term workers’ compensation injury leave,
and limited staff available to fill the duty officer roll. Periodic duty officer assistance is
provided by Sutter County Fire.
Training
Meridian FPD personnel conduct and attend regular trainings. District staff noted that the
District has a decent training budget, which allows District staff to travel elsewhere to
attend relevant trainings, including trainings with Sutter County Fire personnel. District staff
also indicated that the District has sponsored fire personnel to complete Emergency
Medical Technician (“EMT”) training in recent years. Lastly, District staff anticipates that
the City of Live Oak’s new training facility will be an opportunity for further shared training
opportunities with County Fire.
MUNICIPAL SERVICES
Meridian FPD established formal fire protection service in 1977. As granted under the Fire
Protection District Law of 1987, the Meridian FPD is authorized to provide fire protection
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and emergency medical services in Sutter County. The District’s emergency medical
function is classified as basic life support and enabled by the County of Sutter which
designates Bi County Ambulance as the exclusive transport provider in Sutter County.
Meridian FPD has one (1) fire station that the District operates from. The current fire station
details follow.
- Meridian Station No. 65 is located at the northwest perimeter of the District at 1100
3rd Street in the community of Meridian. According to District staff, the station was
built in 1950s or 1960s. District staff noted that the District’s station is in good
condition but is slightly undersized for the District’s needs and is not equipped with
an exhaust removal system. An exhaust removal system is vital for firefighter health
and wellness, as diesel exhaust emissions were designated as a carcinogen in 1998.
Ongoing exposure to diesel exhaust has been linked to lung cancer and bladder
cancer, and a suspected cause of other types of cancer that commonly affect
firefighters. The National Fire Protection Association (NFPA) 1500: Standard on Fire
Department Occupational Safety, Health and Wellness Program section 10.1.5
specifies “The fire department shall prevent exposure to firefighters and
contamination of living and sleeping areas to exhaust emissions through the use of
direct or source capture systems.” Though a station may have a door between the
apparatus bay and the living and sleeping quarters, the door alone will not prevent
diesel exhaust emissions from entering and remaining in other locations of the
facility. Exhaust removal systems capture the emissions at the tailpipe of the
apparatus and remove the emissions to the exterior of the building. The District
noted that it would be difficult to facilitate future facility improvements since the
station is located in a floodplain.
The District currently has a total of five (5) apparatus that are maintained and replaced
on an as-needed basis. The District noted that while the District’s Type 1 engine will
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eventually need to be replaced over the next several years, there are no plans for
apparatus replacement at this time.
Figure 70 summarizes the Department’s station staffing and apparatus conditions as of FY
2023.
Figure 70: Meridian FPD’s Fire Station(s) Assignments as FY 2023
Station No. 65
Fire Engines Type 1 (2004)
Type 3 (2008)
Type 6 (2015)
Water Tenders Water Tender (2012)
Other Fleet Vehicles Utility Truck (2016)
Total 5
Source: Meridian FPD
Meridian FPD also supplements its fire protection and emergency medical services by
maintaining reciprocal automatic and mutual aid agreements with neighboring
jurisdictions. This includes an automatic aid agreement with Sutter County Fire.
SERVICE DEMANDS AND CAPACITY
Overall demands for fire protection and emergency medical services from the Meridian
FPD during FY 2023 included 165 dispatched calls annually or 0.45 calls daily. Meridian
FPD’s largest single source of onsite responses involved emergency medical incidents
necessitating which accounted for 44.2% of all service calls for at the end of the report
period (FY 2023). Further, onsite arrivals necessitating fire protection services included 47
calls in FY 2023.
The District’s call volume is comparatively low to other fire protection and emergency
medical service providers given the District’s limited growth with respect to housing and
resident population. However, the District must remain prepared for any sporadic or high-
impact events (such as a wildfire or large accidents) that can occur despite its low
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response volume. Figure 71 below summarizes Meridian FPD’s fire protection and
emergency medical demands during FY 2023.
Figure 71: Meridian FPD’s Service Demands for FY 2023
Existing Service Demands 2019 2020 2021 2022 2023 Average Trend
Category
Fire N/A N/A N/A N/A 4 7 4 7 N/A
EMS N/A N/A N/A N/A 7 3 7 3 N/A
Good Intent/Service Call N/A N/A N/A N/A 3 5 3 5 N/A
False Alarm N/A N/A N/A N/A 8 8 N/A
Special Incident Type N/A N/A N/A N/A 2 2 N/A
Total Onsite Responses N/A N/A N/A N/A 165 165 N/A
Source: Meridian FPD
Given the low call volume in the District, there may be opportunity for future consolidation
between County Fire and the District. This merger could streamline operations, improve
service efficiency, and enhance service delivery in the District.
SERVICE PERFORMANCE
With respect to Meridian FPD’s capacities to meet existing demands, the Department –
as measured by staffing and equipment – appear sufficiently sized to readily
accommodate the existing demands within its jurisdictional boundary through the
timeframe of this report. For large or staffing-intensive incidents, Meridian FPD
supplements its staffing and apparatus needs through automatic and mutual aid
agreements with neighboring jurisdictions, including an automatic aid agreement with
Sutter County Fire. Staff did note challenges for mutual aid response into the District, as
the District’s west boundary is the Sacramento River, the east boundary is the Sutter By-
Pass Aqueduct, with both offering few bridge crossing locations. Other key performance
measures follow.
- Meridian FPD’s most recent evaluation of structural fire protection capabilities from
the Insurance Services Office (ISO) was completed in 2021 and resulted in a Class
8 rating for the Department. This rating is considered appropriate for a largely rural
service area where response travel distances can be long, and credible water
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sources readily accessed by the fire department are limited. The ISO score is a
measure of the capability of the fire department to protect the community and is
rated on a scale of 1 to 10, with 1 being the highest rating. ISO evaluates the fire
department for apparatus and equipment, weight of response (number of
firefighters arriving on scene), training, water supply and distribution, emergency
communications systems, and fire prevention/community risk reduction efforts.
FISCAL HEALTH
The sections that follow evaluate Meridian Fire Protection District’s (“Meridian” or
“District”) fiscal health, inclusive of revenue sources and major expenditure categories
during the report period (FY 2019 through FY 2023). It should be noted that Meridian FPD’s
financial audits were difficult to obtain for this report since the District only keeps hard
copies of its audits on file.
REVENUES & EXPENDITURES
Meridian’s total average revenues over the last five years totaled $552,000. The largest
single source of the District’s revenue is property taxes which account for $335,000 – or
59.5% - of all revenues for the District. This figure also includes revenues generated from
the District’s special assessment fee which was passed in 2000. The special assessment
fee does not contain a fee escalator. The remainder of revenues for the District are
derived from income from other (striker team and workers compensation
reimbursements), intergovernmental sources (property tax relief, highway rental and
national and state wildlife) and use of money and property (interest). At the end of FY
2023, Meridian’s total revenues amounted to $563,000 and reflect an overall decrease of
($102,000) – or (15.3%).
With respect to expenditures, Meridian’s total average annual expenses over the report
period have been $580,000. The District’s expenses are further broken down into two
categories: (a) Public Protection; and (b) Depreciation. The District’s costs associated
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with providing public protection account for nearly all – or 93.7% - of District expenditures,
at $577,000 as of FY 2023.
Meridian’s total expenditures at the end of the report period (FY 2023) totaled $616,000
accounting for an overall decrease of $9,000 - or (1.5%). This translates to a per capita
cost of $850.79 based on a resident service population of 724 as of FY 2023.
Despite experiencing surpluses in FY 2019 and FY 2021, Meridian FPD’s overall financial
performance over the last five years reflect an average net deficit of ($27,000). While the
District maintained a surplus in two of the five years reviewed, the recurring deficits
indicate potential financial instability, emphasizing the need for strategic fiscal
management to ensure long-term sustainability. Additional details regarding Meridian’s
total revenues and expenditures are provided in Figure 72 below.
Figure 72: Cash Flow – Meridian FPD
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SOI/BOUNDARY & OTHER RECOMMENDATIONS – MERIDIAN FIRE
PROTECTION FIRE DEPARTMENT
The following recommendations call for specific actions from Sutter LAFCO and pertain
to the Meridian Fire Protection District’s sphere of influence (“SOI”) amendments,
boundary changes, and any other recommendations:
1. Sutter LAFCO may proceed to re-affirm the Meridian Fire Protection District’s sphere
of influence with respect to the delivery of fire protection and emergency medical
services. The Meridian Fire Protection District’s sphere of influence demarks the
City’s current and/or probable near-future boundary and service area for fire
protection and emergency medical services.
2. Sutter LAFCO may consider future consolidation of the Meridian Fire Protection
District with Sutter County Fire. The District expressed significant difficulty recruiting
and retaining volunteers, in addition to a low call volume when compared to the
County Fire system. The District also expressed difficulty in maintaining duty officer
coverage due to long-term workers’ compensation injury leave, and limited staff
available to fill the duty officer roll. Periodic duty officer assistance was provided
by Sutter County Fire. Furthermore, Meridian FPD’s overall financial performance
over the last five years reflect a deficit, indicating potential financial instability, and
emphasizing the need for strategic fiscal management.
A consolidation between the Meridian Fire Protection District and Sutter County
Fire could provide a more sustainable and efficient fire service model by pooling
resources, streamlining operations, and addressing the recruitment and retention
challenges faced by the Meridian FPD. This consolidation could also improve
operational effectiveness by consolidating resources and allowing for more
centralized management, which may help mitigate the District’s financial instability
and ensure a more reliable fire protection service provider for the community.
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3. Sutter LAFCO may also consider exploring a broader, countywide consolidation of
all fire protection service providers in the County in the long term. Countywide
consolidation may offer several long-term benefits to fire protection and
emergency services in Sutter County, including enhanced operational efficiency,
improved coordination of resources, elimination of service redundancies, and
more equitable delivery of fire protection and emergency medical services across
service area. Given the fiscal and staffing constraints faced by several of its existing
providers, consolidation may serve as a strategic pathway to strengthen service
reliability, ensure consistent standards of training and equipment, and improve
long-term fiscal sustainability.
To inform future decision making regarding countywide consolidation, it is
recommended that all fire protection service providers within the County
participate in a comprehensive Standards of Response Coverage (“SORC”) study.
This analysis should evaluate response times, station locations and coverage,
staffing, wages, benefits including pensions, and a forecast of past, current, and
future service delivery needs. Importantly, the study should also assess the financial
feasibility of a consolidated fire protection system.
4. The Meridian FPD may consider the establishment of a permanent funding source,
such as a special assessment or parcel tax to ensure the long-term operational
sustainability of fire and emergency medical services. While the District maintained
a surplus in two of the five years reviewed, the District’s recurring deficits indicate
potential financial instability, emphasizing the need for strategic fiscal
management to ensure long-term sustainability. A permanent funding source, such
as a special assessment or parcel tax, would offer greater financial stability,
enabling the City to continue providing fire protection and emergency medical
services.
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5. The District should ensure it maintains digital copies of its financial audits, in
addition to hard copies. Maintaining digital copies will improve accessibility and
record management, in addition to facilitate future financial reporting. Digital
copies of audits and budgets should be available on the District website.
6. To enhance accountability and transparency, the Meridian FPD should make
accessible information regarding the District’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.
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MSR & SOI DETERMINATIONS – MERIDIAN FIRE PROTECTION
DISTRICT
Sutter County LAFCO is directed to prepare written determinations to address the various
governance factors enumerated under Government Code Section 56430 whenever it
prepares a municipal service review. These determinations serve as independent
statements derived from the information collected, analyzed, and presented in the report
by RSG and Planwest. The purpose of the determinations is to provide an independent
assessment to the Meridian FPD’s ability to provide fire protection and emergency
medical services to residents within its jurisdictional boundary now and in the near future.
SERVICE PROVISION DETERMINATIONS
1. Growth and Population Projections
- There are approximately 739 residents in the Meridian Fire Protection District
(“Meridian FPD” or “District”) as of 2024. The District has lost approximately 16 new
residents since 2010.
- The Meridian FPD has lost approximately 26 housing units since 2010. This results in
an annual decrease of 2 new units each year.
- The Meridian FPD resident population will reach 733 residents by 2029. This accounts
for an annual growth rate of approximately (0.1%).
- The number of housing units in the Meridian FPD is expected remain the same by
2029.
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2. Location and Characteristics of Disadvantaged Unincorporated Communities within or
Contiguous to SOI
According to Sutter LAFCO’s policies, there is one (1) Disadvantaged
Unincorporated Communities (“DUCs”) contiguous to the southern boundary of the
District in the Sutter Basin Fire Protection District. The Sutter Basin Fire Protection
District is the primary fire protection and emergency medical services provider to
this DUC.
3. Present and Planned Capacity of Facilities, Adequacy of Public Services, and
Infrastructure Needs and Deficiencies in any Disadvantaged Unincorporated
Communities within or Contiguous to SOI
The following statements apply to the Meridian Fire Protection District (“Meridian
FPD” or “District”) with respect to the availability, adequacy, and performance of
its fire protection and emergency medical services available under Health and
Safety Code 13800 et. seq. These statements serve to confirm the determination
that Meridian FPD has the adequate capacity, infrastructure and availability to
continue to provide fire protection and emergency medical services to its residents
now and into the foreseeable future.
- The Meridian FPD provides fire protection and emergency medical services
out of one fire station – Meridian Station No. 65 located at 1100 3rd Street in
Meridian - with a total public safety staffing at 11.0 at the end of the report
period (FY 2023).
- Meridian Station No. 65 is in good condition but is slightly undersized for the
District’s needs. The District noted that it would be difficult to facilitate future
facility improvements since the station is located in a designated floodplain.
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- Overall demands for fire protection and emergency medical services from
Meridian FPD during FY 2023 (“report period”) have averaged 165
dispatched calls annually or 0.45 calls per day.
- The Meridian FPD’s comparatively low total onsite responses during FY 2023
align with the overall rural characteristics and limited growth trends within its
jurisdictional boundary.
4. Financial Ability to Provide Services
The Meridian FPD has the financial ability to provide fire and emergency medical
services to its existing residents. However, it is unclear whether the District can
continue to provide these services at current levels over time without establishing
a permanent funding source, such as a parcel tax or special assessment. Additional
information is provided below.
- At the end of FY 2023, the Meridian FPD’s total revenues for providing fire
protection and emergency medical services amounted to $563,000 and
reflect an overall decrease of (15.3%) since the beginning of the report
period.
- Meridian FPD’s total expenditures at the end of FY 2023 totaled $616,000,
representing an overall decrease of (1.5%) since the beginning of the report
period.
- While the District maintained a surplus in two of the five years reviewed, the
District’s recurring deficits indicate potential financial instability, emphasizing
the need for strategic fiscal management to ensure long-term sustainability.
5. Opportunities for Shared Facilities
The District attends trainings with Sutter County Fire on a periodic basis. Given the
District’s difficulty recruiting and retaining volunteers, in addition to the District’s
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comparatively low call volume, there may be opportunity for future consolidation
between County Fire and the District. No other opportunities for shared facilities
were identified as part of this MSR.
6. Accountability for Community Service Needs, including Governmental Structure and
Operational Efficiencies
- Meridian FPD is governed by a five-member Board of Directors that serve
four-year terms. The Meridian FPD Board of Directors regularly meets in-
person every month. Meeting agendas are posted 72 hours in advance of
each Board meeting.
- Meridian FPD’s financial audits were difficult to obtain because the District
only keeps hard copies of audits on file. The District should ensure it maintains
digital copies of its financial audits, in addition to hard copies. Maintaining
digital copies will improve accessibility, improve record management, and
facilitate financial reporting.
- To enhance accountability and transparency, the Meridian FPD should make
accessible information regarding the District’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.
7. Any Other Matter Related to Effective or Efficient Service Delivery as Required by
Commission Policy
Other matters related to effective or efficient service delivery as required by
LAFCO policy were not identified.
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Sutter County LAFCO is also directed to prepare a written statement of determinations in
determining the sphere of influence of each local agency enumerated under
Government Code Section 56425 whenever it prepares a sphere of influence update. The
purpose of the determinations is to provide an independent assessment to the Meridian
FPD’s ability to provide fire protection and emergency medical services to residents within
its sphere of influence now and in the near future.
SPHERE OF INFLUENCE DETERMINATIONS
1. Present and Planned Land Uses
Most land within the Meridian FPD’s sphere of influence consists of a mix of
residential and agricultural land uses. No other major planned developments were
identified as part of this MSR.
2. Present and Probable Need for Public Facilities and Services
The Meridian FPD’s sphere of influence defines the District’s current and/or
probable future boundary and service area for fire protection and emergency
medical services. The District’s public facilities are adequate to meet the current
level of fire and emergency medical services now and into the foreseeable future.
3. Present Capacity and Adequacy of Public Facilities
The Meridian FPD has sufficient capacity and adequate infrastructure and related
facilities to continue to provide fire protection and emergency medical services to
its residents now and in the future. Given the District’s difficulty recruiting and
retaining volunteers, in addition to the District’s comparatively low call volume,
there may be opportunity for future consolidation between County Fire and the
District. The comprehensive review of the District’s capacity and demands
supports these claims.
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4. Presence of Social or Economic Communities of Interest
The Meridian FPD sphere of influence does not include any social or economic
communities of interests.
5. Present and Probable Need for Public Services of any Disadvantaged Unincorporated
Communities (“DUCs”)
According to Sutter LAFCO’s policies, there is one (1) Disadvantaged
Unincorporated Communities (“DUCs”) contiguous to the southern boundary of the
District in the Sutter Basin Fire Protection District. The Sutter Basin Fire Protection
District is the primary fire protection and emergency medical services provider to
this DUC.
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ROBBINS SUTTER BASIN FIRE PROTECTION DISTRICT
The Robbins Sutter Basin Fire Protection District (“Robbins Sutter Basin FPD”) is an
independent special district formed in 1950 and is legally authorized to provide fire
protection and emergency medical services in the southwest portion of Sutter County.
Robbins Sutter Basin FPD’s jurisdictional boundary currently spans approximately 126.8
square miles and is anchored by Yolo County to the south, Meridian Fire Protection District
and County Service Area F to the north, Yolo and Colusa County to the west, and County
Service Area C, D, and F to the east. The District’s SOI is coterminous with its service
boundary.
JURISDICTIONAL BOUNDARY & SPHERE OF INFLUENCE
Robbins Sutter Basin FPD’s current jurisdictional boundary spans an area of approximately
126.8 square miles with a coterminous sphere of influence designation. Sutter Basin FPD’s
sphere of influence was last updated in 2012.
As of FY 2023, the total assessed value (land and structures) within the District is
approximately $568.7 million, a per capita value of approximately $824,275 based on the
current resident population of 690.
Figure 73 presents Robbins Sutter Basin FPD’s sphere in relation to its jurisdictional
boundary.
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Figure 73: Sutter Basin FPD Jurisdictional Boundary and SOI Map
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DEMOGRAPHICS
POPULATION & HOUSING
Robbins Sutter Basin FPD’s total current resident population within its jurisdictional
boundary is estimated at 690 as of 2024. This amount represents 0.7% of the countywide
population total. The estimated resident population in Robbins Sutter Basin FPD has
decreased overall by 21.6% - or approximately 190 residents - since 2010, demonstrating
a downward trend.67 More recently, Robbins Sutter Basin FPD has lost 23 residents each
year over the last 4 years, from 780 in 2020 to 690 in 2024. The current resident population
produces a population density of 0.06 residents for every acre and underlies the overall
rural characteristic of Robbins Sutter Basin FPD’s jurisdictional boundary. The Sutter County
2030 General Plan does not specify the exact percentages of land use types within the
Meridian FPD; however, the area primarily consists of agricultural land uses, in addition to
limited residential, public, and commercial uses. Lastly, a vast majority of the District, or
approximately 80.2%, is designated as a Local Flood Hazard Area.68
Robbins Sutter Basin FPD’s population is expected to decrease by approximately 0.12%
annually over the next five-years reaching 686 residents by 2029 and reflects an overall
decrease of 4 residents.69 This growth is slightly lower than the anticipated annual
population growth countywide which is expected to grow 0.03%, reaching 99,795
residents by 2029. Figure 74 summarizes Robbins Sutter Basin FPD and the County’s past,
present and future population growth.
67 Source: ESRI Business Analyst
68 Source: Sutter County GIS
69 Source: ESRI Business Analyst
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Figure 74: Resident Population
There are an estimated 327 housing units within Robbins Sutter Basin FPD’s boundary as of
FY 2024. This amount accounts for an overall decrease of 47 units – or 14.4% - since 2010
for an annual change of 3 housing units. It is expected that the District’s total number of
housing units will remain the same through the year 2029.
Of the total number of current housing units in Robbins Sutter Basin FPD approximately
49.3% are owner-occupied. The remainder of housing units are divided between 42.9%
being renter-occupied and 3.7% being vacant. Further, the average household size in
Robbins Sutter Basin FPD for 2024 is 2.67. This amount reflects a decrease of 11.6% since
2010 wherein the average household size was 3.02. Figure 75 includes additional details
regarding Robbins Sutter Basin FPD’s housing characteristics.
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Figure 75: Housing Characteristics
AGE DISTRIBUTION & INCOME
Relative to the County as a whole, the population of the Robbins Sutter Basin FPD service
area has been somewhat older. The median age of residents in the Robbins Sutter Basin
FPD is 41.0 and reflects an increase of 13.3% from 36.2 since 2010. The current median
age in Robbins Sutter Basin FPD remains slightly higher than the countywide median age
of 37.5 demonstrating an older resident population.
Similarly, 96.9% - of residents within the prime working age group (between the ages of
25-64) are employed while the remaining 3.8% are unemployed, reflecting a stable
workforce within the District’s jurisdictional boundary.70 Additional details regarding the
Robbins Sutter Basin FPD’s age distribution and employment rates are provided in Figure
76.
70 The prime working age group does not include individuals between the ages of 16-25 nor 65 and above given residents within
these age groups are typically in school or nearing/in retirement.
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Figure 76: Age Distribution
Age Distribution Robbins Sutter Basin FPD Sutter County
2010 Median Age 36.2 34.6
2024 Median Age 41.0 37.5
% Change (2010-2024) 11.7% 7.7%
2024 Employment Levels (Ages 25-64) 96.9% 92.5%
2024 Unemployment Levels (Ages 25-64) 3.8% 7.5%
Source: ESRI Business Analyst
The median household income of Robbins Sutter Basin FPD is $64,715 which is
approximately 9.2% lower than the County’s median household income of $70,700. This
amount confirms households in the Robbins Sutter Basin FPD are receiving moderately less
pay over the report period compared to the county as whole. Furthermore, the Robbins
Sutter Basin FPD has a poverty level rate of 10.0%, which is approximately (32.0%) lower
than the County’s poverty level rate of 13.2%.
According to Sutter LAFCO’s policies, there is one (1) Disadvantaged Unincorporated
Communities (DUCs) that consists of the entire Robbins Sutter Basin Fire Protection District.
The District is the primary fire protection and emergency medical services provider to this
DUC. A DUC is defined as any unincorporated area wherein the median household
income is less than $76,416.80.71 Figure 77 provides an overview of income characteristics
in the Meridian FPD and County.
71 Source: Government Code Section 56033.5 and 56046, Water Code Section 79505.5(a), Public Resources Code Section
75005(g), American Community Survey Census 2019-2023 data
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Figure 77: Income Characteristics
Income Characteristics Robbins Sutter Basin FPD Sutter County
2024 Median Household Income $64,715 $70,700
2024 Median Household Income Per $30,455 $32,860
Poverty Level (2018-2022) 10.0% 13.2%
Source: ESRI Business Analyst
GOVERNANCE AND STAFFING
The Robbins Sutter Basin Fire Protection District operates as an independent special
district under the Fire Protection District Law of 1987 and codified under Health and Safety
Code 13800 et. seq. This principal act empowers fire protection districts to provide a
range of municipal services upon approval by LAFCOs including fire protection, rescue,
emergency medical, hazardous material, ambulance services, and any other services
relating to the protection of lives and property. Robbins Sutter Basin FPD is currently
authorized by Sutter LAFCO to provide fire protection and first response medical and
emergency services to its residents. The remaining service functions (i.e., powers)
enumerated under the principal act are deemed latent, meaning they are authorized by
statute but would need to be formally activated by Sutter LAFCO at a noticed public
hearing and subject to conducting authority proceedings.
The Robbins Sutter Basin FPD is governed by a three-member Board of Directors. Board
terms are generally undefined according to District staff; however, District staff indicated
that board terms are ideally two (2) years. The Board meets regularly on the second
Tuesday of each month.
The District appoints an at-will Fire Chief and Assistant Fire Chief to oversee the day-to-
day operations of the District. The District has a total of five (5) paid positions, including
one part-time paid Fire Chief position, one part-time paid Assistant Chief position, and
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three (3) part-time paid firefighters who staff the station during the station’s operating
hours. The District’s remaining positions are volunteer firefighters.
Figure 78 below summarizes the Department’s total staff over the report period.
Figure 78: Robbins Sutter Basin FPD’s Budgeted Staff
Fiscal Year 2019 2020 2021 2022 2023 Average Trend
Type:
Paid Positions N/A N/A N/A N/A 5 5 N/A
Volunteer Positions N/A N/A N/A N/A 6 6 N/A
Total N/A N/A N/A N/A 11 11 N/A
Per 1,000 residents N/A N/A N/A N/A 1.6 1.6 N/A
Source: Robbins Sutter Basin FPD
Volunteer firefighters receive a call stipend of $10/call at the District. The District noted
difficulties recruiting volunteers since most volunteers work out of the District during the
daytime. District staff indicated that it would be ideal to have two (2) firefighters staff the
District’s main station during operating hours as opposed to the District’s current staffing
level of one (1) firefighter per shift.
Training
District staff train approximately eight (8) hours per month at a minimum. The District trains
with Sutter County Fire and the Knights Landing Fire Protection District on a regular basis.
The District also attends periodic training with Williams Fire Protection Authority and the
Woodland Fire Department on a periodic basis.
MUNICIPAL SERVICES
Robbins Sutter Basin FPD established formal fire protection service in 1950. As granted
under the Fire Protection District Law of 1987, the Robbins Sutter Basin FPD is authorized
to provide fire protection and emergency medical services in Sutter County. The District’s
emergency medical function is classified as basic life support. The Sierra-Sacramento
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Valley EMS Agency designates (“S-SV EMS”) Bi-County Ambulance (“BCA”) as the
exclusive ambulance transport provider in Sutter County.
Robbins Sutter Basin FPD has one (1) fire station that the District operates from. The
District’s main station, Robbins Station No. 48, is staffed three days a week—Monday,
Wednesday, Friday—from 8am to 5pm. The current fire station details follow.
- Robbins Station No. 48 is located near the western perimeter of the District’s
boundary at 17510 Pepper Street in the community of Robbins. The station’s built
date is unknown; however, District staff noted the station is in fair condition.
However, the station is not large enough to accommodate the District’s apparatus
equipment. The District noted that it would be difficult to facilitate future facility
improvements since the station is located in a floodplain.
- The District also owns an auxiliary building—Robbins Station No. 49—that was
constructed in the 1960s. The building is located at the far south end of the District,
but its exact address was not made available. The building has power but does not
have any other utilities or facilities.
The District has a total of five (5) apparatus that are maintained to provide fire protection
services, including four (4) fire engines and one (1) 4,500-gallon water tender. District staff
noted that its main fire station can only fit up to three (3) of the District’s apparatus. One
(1) of the District’s reserve Type 3 fire engines is stored in the District’s Station No. 49, while
the District’s water tender is parked at the John Deere dealership approximately a quarter
mile from the District’s main station.
Figure 79 summarizes the Department’s station staffing and apparatus conditions as of FY
2023.
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Figure 79: Robbins Sutter Basin FPD’s Fire Station(s) Assignments as FY 2023
The Robbins Sutter Basin FPD also supplements its fire protection and emergency medical
services by maintaining unofficial reciprocal mutual aid agreements with neighboring
jurisdictions. This includes partnerships with the Knights Landing Fire District in Yolo County,
Yolo Fire District in Yolo County, Sutter County Fire Department, East Nicolaus Fire
Department (CSA C), and the Meridian Fire Protection District.
SERVICE DEMANDS AND CAPACITY
Overall service demands for fire protection and emergency medical services in Sutter
Basin FPD in FY 2023 amounted to 92 dispatched calls annually - or 0.25 per day. Sutter
Basin FPD’s largest single source of onsite responses involved emergency medical
incidents necessitating Basic Life Support service which accounted for 35.9% of all service
calls for at the end of the report period (FY 2023). Further, onsite arrivals necessitating fire
protection services amounted to 27 calls in FY 2023.
Figure 80 below summarized Robbins Sutter Basin FPD’s fire protection and emergency
medical demands during FY 2023.
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Figure 80: Robbins Sutter Basin FPD Demands in FY 2023
Existing Service Demands 2019 2020 2021 2022 2023 Average Trend
Category
Fire N/A N/A N/A N/A 2 7 2 7 N/A
EMS N/A N/A N/A N/A 3 3 3 3 N/A
Vehicle Accident N/A N/A N/A N/A 1 7 1 7 N/A
Good Intent/Service Call N/A N/A N/A N/A 5 5 N/A
False Alarm N/A N/A N/A N/A 5 5 N/A
Rescue N/A N/A N/A N/A 1 1 N/A
Weather Incident N/A N/A N/A N/A 2 2 N/A
Unknown N/A N/A N/A N/A 2 2 N/A
Total Onsite Responses N/A N/A N/A N/A 9 2 9 2 N/A
Source: Robbins Sutter Basin FPD
SERVICE PERFORMANCE
With respect to Robbins Sutter Basin FPD’s capacities to meet existing demands, the
Department – as measured by staffing and equipment – appear sufficiently sized to
readily accommodate the existing demands within its jurisdictional boundary through the
timeframe of this report. Other key performance measures follow.
- The Robbins Sutter Basin FPD’s most recent evaluation of structural fire protection
capabilities from the Insurance Services Office (ISO) resulted in a Class 4/4Y rating
for residents within the Town of Robbins and an 8B/10 for the entire basin. This rating
is considered appropriate for a largely rural service area where response travel
distances can be long, and credible water sources readily accessed by the fire
department are limited. The ISO score is a measure of the capability of the fire
department to protect the community and is rated on a scale of 1 to 10, with 1
being the highest rating. ISO evaluates the fire department for apparatus and
equipment, weight of response (number of firefighters arriving on scene), training,
water supply and distribution, emergency communications systems, and fire
prevention/community risk reduction efforts.
- Robbins Sutter Basin FPD does not have adopted response time standards for fire
protection and emergency medical calls. However, formally adopting response
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time standards could establish service expectations, guide future resource
planning, and enhance accountability.
FISCAL HEALTH
The sections that follow evaluate Robbins Sutter Basin Fire Protection District (“Sutter
Basin” or “District”) fiscal health, inclusive of revenue sources and major expenditure
categories during the report period (FY 2019 through FY 2023). However, it should be
noted that the District’s financial audits were difficult to obtain. According to District and
County Auditor-Controller staff, the District is not required to complete an annual audit
pursuant to Government Code Section 26909. Government Code Section 26909
establishes that a special district may, by unanimous request of the governing board of
the special district and with unanimous approval of the County Board of Supervisors,
conduct audits at a lesser frequency as established by the County Auditor-Controller’s
office. However, County Auditor-Controller personnel did not have these established
requirements readily available upon request. As a result, data obtained from the
California State Controller’s Office (“SCO”) “By the Numbers” was utilized for the sections
below.
REVENUES & EXPENDITURES
Sutter Basin’s total average revenues over the last two years of available data totaled
$129,000. The largest single source of the District’s revenue is property taxes which
account for $137,000– or 94.7% - of all revenues for the District. The remainder of revenues
for the District are derived from investment income. At the end of FY 2023, Sutter Basin’s
total revenues amounted to $145,000 and reflect an overall increase of $3,100 – or 27.2%
from the previous fiscal year.
With respect to expenditures, the District’s total average annual expenses over the last
two years of available data totaled $74,000. The District’s costs associated with supplies
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and services account for nearly three-fifths – or 59.1% - of District expenditures, at $64,000
as of FY 2023.
Sutter Basin’s total expenditures at the end of the report period (FY 2023) totaled $109,000
and reflect an overall increase of $7,000 - or 180.9% from the previous fiscal year. This
translates to a per capita cost of $152.72 based on a resident service population of 713
as of FY 2023.
While the District’s has demonstrated strong revenue growth between the two fiscal years
reviewed, expenses have risen at an unsustainable pace which may lead to a significant
decline in surplus over time. Although the District remained in a surplus in the two years
of available data reviewed, the narrowing financial safety-net raises concerns for the
District’s long-term financial stability. Should the trend in expenses continue, the District
may encounter financial shortfalls that would require either cost-control measures,
revenue diversification, or external fundings sources to sustain service levels and
operation efficiency. To ensure the long-term operational sustainability of fire and
emergency medical services, the District may consider establishing a permanent funding
source, such as a special assessment or parcel tax.
However, given the limited financial information made available, a more accurate
assessment of the District’s financial capacity would require obtaining additional
financial information.
Additional details regarding Sutter Basin’s total revenues and expenditures are provided
in Figure 81 below.
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Figure 81: Cash Flow – Sutter Basin FPD
Robbins Sutter Basin FPD FY 2019 FY 2020 FY 2021 FY 2022 FY 2023 Average Trend
Total Revenues $ - $ - $ - $ 1 13,629 $ 1 44,565 $ 5 1,639 27.2%
Total Expenses - - - 3 8,740 1 08,815 2 9,511 180.9%
Surplus/(deficit) $ - $ - $ - $ 74,889 $ 35,750 $ 22,128 -52.3%
Revenues per Capita $ - $ - $ - $ 1 54.60 $ 2 02.90 $ 71.50 31.2%
Expenses per Capita $ - $ - $ - $ 52.71 $ 1 52.72 $ 41.09 189.8%
Sources: Robbins Sutter Basin FPD's Annual Financial Reports FYs 2022-2023
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SOI/BOUNDARY & OTHER RECOMMENDATIONS – MERIDIAN FIRE
PROTECTION FIRE DEPARTMENT
The following recommendations call for specific actions from Sutter LAFCO, Sutter County,
or the Robbins Sutter Basin Fire Protection District and pertain to the District’s sphere of
influence (“SOI”) amendments, boundary changes, and any other recommendations:
1. Sutter LAFCO may proceed to re-affirm the Robbins Sutter Basin Fire Protection
District’s sphere of influence with respect to the delivery of fire protection and
emergency medical services. The Robbins Sutter Basin Fire Protection District’s
sphere of influence demarks the City’s current and/or probable near-future
boundary and service area for fire protection and emergency medical services.
2. The District may consider the establishment of a permanent funding source, such
as a special assessment or parcel tax to ensure the long-term operational
sustainability of fire and emergency medical services. While the District has
demonstrated strong revenue growth and remained in a surplus between the two
fiscal years reviewed, expenses have risen at an unsustainable pace which may
lead to a significant decline in surplus over time. A permanent funding source, such
as a special assessment or parcel tax, would offer greater financial stability,
enabling the District to plan for future staffing needs, training, and the acquisition
of new equipment.
3. Sutter LAFCO may consider future consolidation of the Robbins Sutter Basin Fire
Protection District’s with Sutter County Fire. The District expressed difficulty
recruiting and retaining volunteers, in addition to a low call volume when
compared to the County Fire system. Furthermore, the District may experience
future challenges with its financial health if it is unable to successfully establish a
permanent funding source, such as a special assessment or parcel tax. A
consolidation between the Robbins Sutter Basin Fire Protection District and Sutter
County Fire could provide a more sustainable and efficient fire service model by
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pooling resources, streamlining operations, and addressing the recruitment and
retention challenges faced by the District.
4. Sutter LAFCO may also consider exploring a broader, countywide consolidation of
all fire protection service providers in the County in the long term. Countywide
consolidation may offer several long-term benefits to fire protection and
emergency services in Sutter County, including enhanced operational efficiency,
improved coordination of resources, elimination of service redundancies, and
more equitable delivery of fire protection and emergency medical services across
service area. Given the fiscal and staffing constraints faced by several of its existing
providers, consolidation may serve as a strategic pathway to strengthen service
reliability, ensure consistent standards of training and equipment, and improve
long-term fiscal sustainability.
To inform future decision making regarding countywide consolidation, it is
recommended that all fire protection service providers within the County
participate in a comprehensive Standards of Response Coverage (“SORC”) study.
This analysis should evaluate response times, station locations and coverage,
staffing, wages, benefits including pensions, and a forecast of past, current, and
future service delivery needs. Importantly, the study should also assess the financial
feasibility of a consolidated fire protection system.
5. The County Auditor-Controller’s office should publish a copy of its policy regarding
Government Code Section 26909(b) on its website. Government Code Section
26909(b) provides that a special district may, by unanimous request of the
governing board of the special district and with unanimous approval of the board
of supervisors, replace an annual required audit with alternative reporting
requirements, as determined by the county auditor. However, upon request, the
County-Auditor Controller’s office did not have the alternative reporting
requirements available upon request. By publishing a copy of the County Auditor-
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Controller’s policy on its website, it can ensure greater transparency, enable the
facilitation of information to special districts, and promote greater compliance with
financial reporting requirements.
6. To enhance accountability and transparency, the Robbins Sutter Basin FPD should
make accessible information regarding the District’s 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.
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MSR & SOI DETERMINATIONS – MERIDIAN FIRE PROTECTION
DISTRICT
Sutter County LAFCO is directed to prepare written determinations to address the various
governance factors enumerated under Government Code Section 56430 whenever it
prepares a municipal service review. These determinations serve as independent
statements derived from the information collected, analyzed, and presented in the report
by RSG and Planwest. The purpose of the determinations is to provide an independent
assessment to the Robbins Sutter Basin FPD’s ability to provide fire protection and
emergency medical services to residents within its jurisdictional boundary now and in the
near future.
SERVICE PROVISION DETERMINATIONS
1. Growth and Population Projections
- There are approximately 690 residents in the Robbins Sutter Basin Fire Protection
District (“Robbins Sutter Basin FPD” or “District”) as of 2024. The District has lost
approximately 190 residents since 2010.
- The Robbins Sutter Basin FPD has lost approximately 47 housing units since 2010. This
accounts for an annual decrease of 3 housing units each year.
- The Robbins Sutter Basin FPD resident population will amount to 686 residents by
2029. This accounts for an annual growth rate of approximately (0.1%).
- The number of housing units in the Robbins Sutter Basin FPD is expected remain the
same by 2029.
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2. Location and Characteristics of Disadvantaged Unincorporated Communities within or
Contiguous to SOI
According to Sutter LAFCO’s policies, there is one (1) Disadvantaged
Unincorporated Communities (DUCs) that consists of the entire Robbins Sutter Basin
Fire Protection District. The District is the primary fire protection and emergency
medical services provider to this DUC.
3. Present and Planned Capacity of Facilities, Adequacy of Public Services, and
Infrastructure Needs and Deficiencies in any Disadvantaged Unincorporated
Communities within or Contiguous to SOI
The following statements apply to the Robbins Sutter Basin FPD with respect to the
availability, adequacy, and performance of its fire protection and emergency
medical services available under Health and Safety Code 13800 et. seq. These
statements serve to confirm the determination that Robbins Sutter Basin FPD has
the adequate capacity, infrastructure and availability to continue to provide fire
protection and emergency medical services to its residents now and into the
foreseeable future.
- The Robbins Sutter Basin FPD provides fire protection and emergency
medical services out of its one fire station – Robbins Station No. 48 located
at 17510 Pepper Street in Robbins - with a total public safety staffing at 11 as
of FY 2023.
- The Robbins Station No. 48 is in fair condition. However, the station is not
large enough to accommodate all of the District’s apparatus equipment.
One (1) of the District’s apparatus must be stored at the District’s auxiliary
building, while the District’s water tender is stored at the John Deere
dealership approximately a quarter mile from Robbins Station No. 48.
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- Overall demands for fire protection and emergency medical services from
Robbins Sutter Basin FPD during FY 2023 (“report period”) have averaged 92
dispatched calls annually or 0.25 calls per day.
4. Financial Ability to Provide Services
The Robbins Sutter Basin FPD has the financial ability to provide fire and emergency
medical services to its existing residents. However, it is unclear whether the District
can continue to provide these services at current levels over time without
establishing a permanent funding source, such as a parcel tax or special
assessment. Additional information is provided below.
- At the end of FY 2023, the Robbins Sutter Basin FPD total revenues for
providing fire protection and emergency medical services amounted to
$145,000 and reflect an overall increase of 27.2% from the prior fiscal year.
- Robbins Sutter Basin FPD’s total expenditures at the end of FY 2023 totaled
$109,000, representing an overall increase of 180.9% from the prior fiscal
year.
- While the District’s has demonstrated strong revenue growth between the
two fiscal years reviewed, expenses have risen at an unsustainable pace.
The District may encounter financial shortfalls that would require either cost-
control measures, revenue diversification, or external fundings sources to
sustain service levels and operation efficiency if expenses continue to rise.
5. Opportunities for Shared Facilities
The District trains with Sutter County Fire and the Knights Landing Fire Protection
District on a regular basis. The District also attends periodic training with Williams
Fire Protection Authority and the Woodland Fire Department on a periodic basis.
Given the District’s difficulty recruiting volunteers, in addition to the District’s
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comparatively low call volume, there may be opportunity for future consolidation
between County Fire and the District. No other opportunities for shared facilities
were identified as part of this MSR.
6. Accountability for Community Service Needs, including Governmental Structure and
Operational Efficiencies
- The Robbins Sutter Basin FPD is governed by a three-member Board of
Directors that serve approximately two-year terms. The Board of Directors
regularly meets in-person every month.
- Robbins Sutter Basin FPD’s financial audits were difficult to obtain. While the
District is not required to complete an annual audit pursuant to Government
Code Section 26909(b), the County Auditor-Controller’s office was unable to
provide the County’s policy on this requirement upon request. The County
Auditor-Controller should ensure it publishes the County’s policy on financial
audit requirements established by Government Code Section 26909 on its
website.
- To enhance accountability and transparency, the Robbins Sutter Basin FPD
should make accessible information regarding the District’s 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.
7. Any Other Matter Related to Effective or Efficient Service Delivery as Required by
Commission Policy
Other matters related to effective or efficient service delivery as required by
LAFCO policy were not identified.
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Sutter County LAFCO is also directed to prepare a written statement of determinations in
determining the sphere of influence of each local agency enumerated under
Government Code Section 56425 whenever it prepares a sphere of influence update. The
purpose of the determinations is to provide an independent assessment to the Meridian
FPD’s ability to provide fire protection and emergency medical services to residents within
its sphere of influence now and in the near future.
SPHERE OF INFLUENCE DETERMINATIONS
1. Present and Planned Land Uses
Most land within the Robbins Sutter Basin FPD’s sphere of influence consists of a mix
of residential and agricultural land uses. No other major planned developments
were identified as part of this MSR.
2. Present and Probable Need for Public Facilities and Services
The Robbins Sutter Basin FPD’s sphere of influence defines the District’s current
and/or probable future boundary and service area for fire protection and
emergency medical services. The District’s public facilities are adequate to meet
the current level of fire and emergency medical services now and into the
foreseeable future.
3. Present Capacity and Adequacy of Public Facilities
The Robbins Sutter Basin FPD has sufficient capacity and adequate infrastructure
and related facilities to continue to provide fire protection and emergency
medical services to its residents now and in the future. Given the District’s difficulty
recruiting and retaining volunteers, in addition to the District’s comparatively low
call volume, there may be opportunity for future consolidation between County
Fire and the District. The comprehensive review of the District’s capacity and
demands supports these claims.
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4. Presence of Social or Economic Communities of Interest
The Robbins Sutter Basin FPD sphere of influence does not include any social or
economic communities of interests.
5. Present and Probable Need for Public Services of any Disadvantaged Unincorporated
Communities (“DUCs”)
According to Sutter LAFCO’s policies, there is one (1) Disadvantaged
Unincorporated Communities (DUCs) that consists of the entire Robbins Sutter Basin
Fire Protection District. The District is the primary fire protection and emergency
medical services provider to this DUC.
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APPENDIX 1 – PUBLIC COMMENTS RECEIVED
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.
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• 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 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.
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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.
• 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
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• 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 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.
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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)
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• 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.
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• 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 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.
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• 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.
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.
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• 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%.
• 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.
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• 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
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.
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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.”
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.
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• 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
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.
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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.
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.
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• 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
• 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
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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.
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?
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• 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?
• 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?
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• 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?
• 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?
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• 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.
• 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
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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.
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]
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• 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 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.
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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]
• 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.
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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, 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.
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• 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.
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.
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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
• 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%]
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• 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…”]
• 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)
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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)
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Attachment 1 : LAFCO Commissioner Marc Boomgaarden email (June 24, 2025)
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Attachment 2: LAFCO Commissioner Marc Boomgaarden email (June 26, 2025)
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Attachment 3: Yuba City Fire Department email (July 1, 2025)
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Attachment 4: Kingsley Bogard Attorneys at Law letter (July 7, 2025)
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Attachment 5: Sutter County Administrator Steve Smith Attachment (July 7, 2025)
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Attachment 6: Jane Vandenhoff email (July 10, 2025)
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Attachment 7: Marty Vinson email (July 10, 2025)
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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.
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Attachment 9: City of Live Oak comments (August 26, 2025)
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Attachment 10: Robbins Sutter Basin Fire Protection District (September 1, 2025)
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APPENDIX 2 – SUTTER LAFCO RESOLUTION NO. 2025-07
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Resolution 2025-07
Su tter Loca l Agency For mation Commission
Resolution of the Sutter Local Agency Formation Commission
Determining the Project Exempt from the California Environmental Quality Act and Adopting the
Municipal Service Review (MSR) and Sphere of Influence (SOI) Update for Fire Protection
Agencies within Sutter County
Whereas , The Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000 governs
the organization and reorganization of cities and special districts by local agency formation
commissions established in each county, as defined and specified in Government Code Section
56000 et seq. (unless otherwise indicated all statutory references are to the Government Code);
and,
Whereas, Section 56425 et seq. provides that the local agency formation commission in each
county shall develop and determine the sphere of influence of each local governmental agency
within the county, and enact policies designed to promote the logical and orderly development
of areas within the sphere of influence, as more fully specified in Section 56425 et seq.; and,
Whereas, Section 56430 requires that local agency formation commission conduct a municipal
service review prior to, or in conjunction with, consideration of action to establish or update a
sphere of influence in accordance with Section 56076 and 56425; and,
Whereas , the last municipal service reviews (MSR) and sphere of influence update (SOI) for fire
service providers in Sutter County were completed as follows:
City of Live Oak, Resolution No. 2012-001, February 23, 2012 (all services)
City of Yuba City, Resolution No. 2020-003, November 12, 2020 (all services)
County Service Areas C, D, F, G, Resolution No. 2017-003 and -004, April 27, 2017
Meridian Fire District, Resolution No. 2011-018, October 27, 2011
Robbins Sutter Basin Fire District, Resolution No. 2012-005, July 26, 2012
Whereas , on March 9, 2024, the Sutter Local Agency Formation Commission (LAFCO)
meeting, authorized the release of a Request for Proposals (RFP) and established an Ad-Hoc
Committee comprised of Commissioners Conant, Boomgaarden and Elphick. The RFP was
released on March 20, 2024, with responses due by the end of the day on April 26, 2024.; and,
Whereas, the Ad-Hoc Committee met on Monday, July 1, 2024, to consider a proposal
submitted by RSG Inc. The meeting was attended by Commissioners Boomgaarden and
Elphick. Following a discussion, the Ad-Hoc Committee recommended the full Commission
consider entering into an Independent Contractor Agreement with RSG Inc.
Whereas, On July 11, 2024, LAFCO authorized the Executive Officer to enter into an
independent Contractor Agreement with RSG, Inc. with Planwest Partners, Inc. as a
subconsultant to complete a comprehensive MSR/SOI update of all fire agencies in Sutter
County including a review of emergency medical services which are a critical component related
to the delivery of emergency response; and
Whereas, a Technical Advisory Committee (TAC) was formed consisting of the Fire Chiefs from
Sutter County, Yuba City, Meridian and Robbins Sutter Basin Fire Districts. The TAC held
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meetings on September 30, 2024, January 28, 2025, and May 13, 2025, where the fire agencies
provided the consultant team and Executive Officer with insight and recommendations regarding
fire services in Sutter County, including the Interim Live Oak City Manager who participated in
the May 13, 2025, TAC meeting; and
Whereas, the consultants conducted interviews with all fire service providers within Sutter
County over the course of this Municipal Service Review; and,
Whereas, based on the results of the interviews and TAC meetings, the consultants made
municipal service review and sphere of influence update recommendations; and,
Whereas, the Executive Officer has reviewed the Municipal Service Review pursuant to the
California Environmental Quality Act (CEQA) and determined that the proposed Municipal
Service Review and Sphere of Influence Update is Categorically Exempt pursuant to CEQA
Guidelines Section 15306 which exempts basic data collection, research, experimental
management, and resource evaluation activities which do not result in a serious or major
disturbance to an environmental resource. This type of exemption may be used strictly for
information gathering purposes, or as part of a study leading to an action which a public agency
(LAFCO) has not yet approved, adopted or funded. The information gathered for this Municipal
Service Review will not have an effect on environmental resources. The Sphere of Influence
Update will validate the boundaries of existing spheres of influence for each study agency and
no changes to that spheres of Influence are proposed. Therefore, no environmental impacts will
result.
Additionally, staff believes the proposal is covered by the general rule of CEQA Guidelines,
Section 15061b (3) that states that CEQA only applies to projects that have the potential for
causing a significant effect on the environment. Where it can be seen with certainty that there is
no possibility that the activity in question may have a significant effect on the environment, the
activity is not subject to CEQA. This comprehensive fire services MSR/SOI update evaluates
the current operations of the various fire agencies and does not propose any changes of
organization or reorganization. It does provide recommendations that if implemented, would be
subject to CEQA and a future environmental analysis would need to be completed. In addition,
each fire agency sphere of Influence is proposed to remain unchanged. As a result, this
MSR/SOI Update will not have any impact upon the environment and is, therefore, not subject
to CEQA.
Whereas, the Executive Officer set a public hearing on July 10, 2025, for consideration of the
public draft Municipal Service Review and Sphere of Influence Update and caused notice
thereof to be posted and published at the times and in the manner required by law at least
twenty-one (21) days in advance of the date; and,
Whereas, on July 10, 2025, the public review draft Municipal Service Review and Sphere of
Influence Update for all fire agencies in Sutter County was heard before LAFCO, at the time and
place specified in the Notice of Public Hearing; and,
Whereas, at the July 10, 2025 public hearing, LAFCO reviewed and considered the public
review draft Municipal Service Review and Sphere of Influence Update and the Executive
Officer's report, which recommends determinations as required by Government Code Sections
56430 and 56425, and all other matters presented as prescribed by law; and,
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