202 6
SANTA MONICA
FIRE DEPARTMENT
EMS & FIRE HAZARD
FEE STUDY
JUNE 2026
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T i
TABLE OF CONTENTS
Executive Summary ............................................................................................................iv SECTION I: EMS SERVICE FEE STUDY .............................................................................1 EMS System Overview..........................................................................................................2 Introduction .............................................................................................................................. 2 Regional and State Oversight...................................................................................................... 3 Fire Department Leadership and Command Structure ................................................................ 4 EMS Staffing & Personnel .....................................................................................................9 Staffing Introduction .................................................................................................................. 9 Budget & Finance............................................................................................................... 15 SMFD Budget........................................................................................................................... 15 Ambulance Fee Study......................................................................................................... 18 Current EMS Fees .................................................................................................................... 18 Ambulance Fee Study Methodology.......................................................................................... 18 Fee Recommendations and Options......................................................................................... 28 EMS Cost Recovery Opportunities....................................................................................... 29 Treat and No Transport Fee (Engine Response) ......................................................................... 29 Treat and No Transport Fee (Advanced Provider Unit)................................................................ 30 Motor Vehicle Accident Response Fee...................................................................................... 30 Ambulance Subscription Program....................................................................................... 31 Administrative and Operational Considerations........................................................................ 31 Regulatory and Reimbursement Considerations ....................................................................... 32 Specialized Applications.......................................................................................................... 32 Proposition 26 Considerations ................................................................................................. 32 Program Pricing and Billing Considerations............................................................................... 33 SECTION II: FHSZ INSPECTION STUDY..........................................................................34 FHSZ Inspection Requirements........................................................................................... 35 Historical Wildfire Risk Context—Regional Narrative................................................................. 35 Requirements for Fire Hazard Severity Zone Inspections ........................................................... 38 Recommended Staffing Requirements ..................................................................................... 43 Full Cost of the Inspection Program.......................................................................................... 46 Potential Program Fees............................................................................................................ 48 Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T ii
SECTION III: FINDINGS & RECOMMENDATIONS............................................................50 Key Findings ...................................................................................................................... 51 EMS Service Fee Study ............................................................................................................. 51 FHSZ Inspection Fee Study....................................................................................................... 51 Recommended Strategies .................................................................................................. 52 SECTION IV: APPENDICES ...........................................................................................59 Appendix A: Table of Figures ............................................................................................... 60 Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T iii
ACKNOWLEDGMENTS
AP Triton wishes to extend its sincere appreciation to each of those individuals and organizations whose contributions and assistance made this project possible.
Our sincere appreciation is extended to each of you!
Santa Monica Fire Department
Matthew Hallock
Fire Chief
Tom Clemo
Deputy Fire Chief, Administration
Dan Caldwell
Deputy Fire Chief, Operations
Joe Cavin
Fire Marshal
Patrick Nulty
Battalion Chief – EMS
Jonathan Tang
Principal Administrative Analyst
Robert Erdmann
Battalion Chief, Administration
Dan Galvan
Assistant Fire Marshal
And to each of the firefighters, officers, support staff, and elected and appointed officials who daily serve the citizens and visitors of the City of Santa Monica.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T iv
EXECUTIVE SUMMARY
This report evaluates the current Emergency Medical Services (EMS) fee structure and Fire Hazard Severity Zone (FHSZ) inspection program of the Santa Monica Fire Department to identify opportunities for improved cost recovery, operational efficiency, and long-term program sustainability. Conducted by AP Triton, the study provides a comprehensive assessment of EMS system operations, ambulance transport cost recovery, and wildfire inspection program requirements to support informed policy and financial decision-making by the City.
The study found that the fire department operates a modern, integrated fire-based EMS delivery system that provides advanced life support (ALS) first response, in-house ambulance transport services, and innovative mobile integrated healthcare initiatives. EMS-related incidents account for approximately 77% of all department responses, demonstrating the significant operational demand placed on the EMS system. The Department’s transition from a contracted ambulance transport model to an inhouse Ambulance Operator Program represents a substantial operational enhancement intended to improve response efficiency, patient care coordination, and system integration.
This analysis determined that a comprehensive review and adjustment of EMS-related fees is warranted to ensure compliance with California Proposition 26 requirements and improve alignment between service costs and revenue recovery. The study identified opportunities to strengthen EMS cost recovery through evaluation of ambulance transport rates, advanced life support assessment fees, treat-and-release billing opportunities, first responder fees, lift-assist fees, and other supplemental cost recovery mechanisms. Additionally, the study recommends continued evaluation of subscriptionbased or membership program models and potential reimbursement opportunities associated with the department’s Advanced Provider Unit (APU) program.
Unlike most other types of businesses, where pricing is based on a single rate for service, healthcare operates differently. Each patient may have a different payer type, and reimbursement levels vary depending on insurance coverage. Cost recovery for ambulance transport, as analyzed in this report, represents a snapshot in time using historical averages and past performance to inform revenue projections, while recognizing that actual fee collections will likely be substantially lower than billed charges.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T v
The report also evaluated the City’s newly established Fire Hazard Severity Zone inspection responsibilities resulting from updated CAL FIRE Local Responsibility Area mapping requirements. The City now contains Moderate, High, and Very High Fire Hazard Severity Zones requiring implementation of defensible space inspection, compliance, and public education programs. Based on parcel inventories and projected inspection workloads, the analysis estimates that approximately 1.0 fulltime equivalent Fire Inspector position will be required to support annual inspections, re-inspections, AB 38 real estate transaction inspections, public education, and program administration activities.
The estimated annual cost to operate the FHSZ inspection program is approximately $363,024 with personnel costs representing the primary expense. To support long-term program sustainability, the study recommends implementation of a cost-based fee structure that includes defensible space inspection fees, re-inspection fees, AB 38 inspection fees, and landscape inspection and review fees.
A phased implementation strategy emphasizing education, voluntary compliance, and progressive enforcement is recommended to support community acceptance and operational effectiveness.
Overall, this study concludes that the Santa Monica Fire Department is well-positioned to continue providing high-quality EMS and community risk reduction services but would benefit from enhanced cost recovery methodologies, formalized wildfire compliance procedures, and ongoing evaluation of staffing and operational demands. The recommendations contained within this report are intended to improve fiscal sustainability, maintain regulatory compliance, strengthen wildfire resilience, and support the department’s ability to meet the evolving service expectations of the community.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 1 Section I:
EMS SERVICE
FEE STUDY
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 2 EMS SYSTEM OVERVIEW
INTRODUCTION
The Santa Monica Fire Department (SMFD) is an all-hazard organization that responds to all types of man-made and naturally occurring emergencies. SMFD’s Emergency Medical Services (EMS) system is vital to the city's public safety and health care delivery. The EMS system provides pre-hospital care and transportation to the residents and visitors of Santa Monica. SMFD is part of the Los Angeles County Department of Health Services (LEMSA), which provides emergency medical care to residents and visitors of the region.
Operating from five fire stations, the department deploys seven advanced life support (ALS) engine companies and one ALS assessment/Advanced Provider Unit (APU), staffed by highly trained professionals who respond to over 17,000 calls for service each year. SMFD runs six ambulances staffed with EMTs and responds to 9-1-1 calls for medical emergencies. SMFD also has fire trucks equipped with ALS capabilities that can provide initial response and patient stabilization.
SMFD collaborates with nearby fire agencies, communication centers, and hospitals to ensure the prompt and coordinated delivery of EMS services. SMFD adheres to the medical oversight and protocols set by the county's designated Local EMS Agency (LEMSA).
SMFD operates a tiered ALS first responder and ambulance model typical of an urban fire-based EMS system. Key features include ALS fire engine first response, BLS ambulance transport units, integrated clinical oversight, and transport to regional hospitals. About 77% of all fire department responses are EMS-related incidents, reflecting the medical nature of modern urban fire service demands.
The following figure illustrates the breakdown of “EMS” calls, including those in the “Fire” and “Other” categories (e.g., good intent calls, investigations, etc.). For the given data from 2023–2025, EMS Calls account for approximately 77% of the call volume, Fire accounts for 4.3%, and “Other” calls account for approximately 19%.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 3 Figure 1: EMS Responses (2023–2025)
REGIONAL AND STATE OVERSIGHT
SMFD operates within a multi-layered EMS regulatory structure typical of California fire-based EMS systems. Medical services are delivered locally but governed by regional and state EMS authorities.
Primary oversight entities include:
• Local EMS Authority: Los Angeles County Department of Health Services ▪ Functions as the Local Emergency Medical Services Agency (LEMSA) responsible for EMS system planning, provider certification, clinical protocols, and system performance monitoring within Los Angeles County.
▪ Establishes medical treatment protocols, scope of practice standards, and system performance requirements for all EMS providers.
• State Oversight: California Emergency Medical Services Authority ▪ Provides statewide regulatory oversight for EMS systems and sets minimum standards for certification, licensure, and EMS operations.
Within this framework, SMFD acts as a fire-based ALS first responder and ambulance transport provider operating under county-approved medical protocols and quality assurance standards.
75.4% 76.5%
79.7%
4.1% 4.5% 4.5%
20.5% 19.1%
15.8%
0.0%
10.0%
20.0%
30.0%
40.0%
50.0%
60.0%
70.0%
80.0%
90.0%
2023 2024 2025
EMS FIRE OTHER
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 4 FIRE DEPARTMENT LEADERSHIP AND COMMAND STRUCTURE
SMFD is organized into five divisions: Administration, Suppression & Rescue, Training, Prevention, and EMS. EMS functions are integrated into both the Suppression & Rescue Division and the EMS Division, ensuring clinical oversight while maintaining operational efficiency.
EMS program management within the department is organized through a dedicated EMS leadership structure:
Fire Department Chain of Command (EMS -related)
• Fire Chief
• Deputy/Assistant Chief (Operations Oversight)
• EMS Battalion Chief (Division Head)
• EMS Captains (3)
• EMS Coordinator (Registered Nurse)
• Firefighter/Paramedics assigned to the Advanced Provider Unit (APU) The EMS Battalion Chief serves as the principal administrator for EMS operations and is responsible for:
• EMS system planning and implementation
• Clinical performance monitoring
• Training and continuing medical education (CME) oversight • EMS equipment, supply management, and regulatory compliance • Coordination with hospitals, the county EMS agency, and regional partners This structure provides both operational oversight and clinical coordination, ensuring alignment between field operations and medical direction.
The EMS Battalion Chief oversees three EMS Captains, an EMS Coordinator, and personnel assigned to the APU, which makes up the EMS Division and is responsible for clinical protocol implementation, EMS training and continuing education, quality assurance and performance monitoring, equipment standardization and inventory control, EMS data collection and reporting, and community health programs.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 5 Except for the Ambulance Operators (AO), SMFD personnel are cross-trained for fire suppression and EMS response. Current staffing levels include approximately 170 EMT-Basic providers and 65 licensed paramedics. All operational firefighters maintain at least an EMT certification, with a substantial portion credentialed as paramedics. This staffing model supports a department-wide ALS-firstresponder capability.
A key component of the current EMS system is the Advanced Provider Unit (APU), an integrated mobile health resource pairing a nurse practitioner with a firefighter/paramedic. This unit provides:
• Advanced field assessment
• Treat-in-place capability
• Behavioral health and chronic care intervention
• Follow-up coordination for vulnerable patients
The program was developed to reduce unnecessary emergency department utilization and improve continuity of patient care.
First Responder Advanced Life Support System
SMFD operates a fire-based ALS first responder system. Key features include:
• ALS capability on all engine companies
• Rapid paramedic response from neighborhood stations
• BLS ambulance transport units integrated into the response model • Advanced mobile health resources (APU)
This system ensures that advanced medical care begins within minutes of dispatch, significantly improving survival rates for critical conditions such as cardiac arrest, stroke, and severe trauma.
Firefighter-paramedics provide advanced interventions, including:
• Cardiac monitoring and defibrillation
• Advanced airway management
• Intravenous medication administration
• Trauma stabilization
• Prehospital ECG transmission to hospitals
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 6 EMS Quality Assurance and Performance Management
SMFD maintains a formal EMS clinical quality management program. Core QA components include clinical key performance indicators, incident and chart review, Medical Director participation, provider performance feedback, quarterly quality improvement reports, and patient complaint processes.
The EMS Division tracks system performance through response-time monitoring, clinical outcome tracking, protocol-compliance review, and audits of patient-care reports.
Patient outcomes are tracked through manual review by the EMS Coordinator and coordination with receiving hospitals. System improvement initiatives are guided by findings from the quality improvement committee, data-driven performance evaluation, research participation, and clinical protocol development.
Ambulance Transport System
SMFD recently transitioned to an in-house ambulance transport system utilizing a dedicated Ambulance Operator (AO) Program. Program characteristics include:
• Six staffed ambulances
• Two-person EMT crews
• Integrated response with firefighter-paramedics
• 120 scheduled daily ambulance unit hours
The program replaced a longstanding contract transport model and aims to improve response efficiency and clinical integration.
Community Health and Mobile Integrated Healthcare Programs SMFD uses a Mobile Integrated Healthcare (MIH) approach for high-utilization patients and vulnerable populations. Program components include:
• Frequent EMS user management
• Care coordination services
• Fall prevention initiatives
• Community CPR education
• Bystander emergency preparedness training
These programs support the broader EMS goal of reducing system strain while improving patient outcomes.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 7 Regional Healthcare Transport Destinations
Primary receiving hospitals include:
• Providence Saint John's Health Center
• UCLA Santa Monica Medical Center
• Ronald Reagan UCLA Medical Center (online medical control—base station) These facilities offer a variety of specialized care, including trauma, cardiac care, and advanced critical care services.
Records Management and Data Systems
SMFD uses an electronic patient care reporting (ePCR) platform:
• Digital EMS (transitioning to First Due in 2026)
• NEMSIS compliant
• HIPAA compliant
• Integrated with CAD systems
The transition to a unified First Due records management system (RMS) will integrate fire and EMS records to improve system analytics and operational decision-making.
EMS Communications and Dispatch
Emergency calls are processed through a criteria-based Emergency Medical Dispatch (EMD) system.
Capabilities include:
• Pre-arrival instructions for callers
• EMD quality assurance monitoring
• Time-stamped incident tracking (call received, dispatch, arrival, patient contact, transport, hospital arrival)
This structured dispatch system supports rapid response and improved patient outcomes by providing early-intervention instructions, including CPR and airway management guidance.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 8 SMFD EMS System Overview Summary
The Santa Monica Fire Department operates a modern, integrated fire-based EMS system combining ALS first response, in-house ambulance transport, and innovative community health initiatives. The system is governed by Los Angeles County EMS protocols, supported by dedicated medical direction, and strengthened by robust quality improvement processes.
Recent enhancements, including the Advanced Provider Unit and in-house ambulance program, demonstrate a strategic shift toward system efficiency, community paramedicine, and patientcentered care.
Together, these components position the Santa Monica Fire Department as a progressive municipal EMS provider capable of delivering rapid, high-quality prehospital medical care within a coordinated regional healthcare system.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 9 EMS STAFFING & PERSONNEL
The following section outlines SMFD’s current staffing levels and their relevance to EMS delivery. Any staffing recommendations based on this review will be in the Recommendations section of this report.
STAFFING INTRODUCTION
The size and structure of a fire department’s staff depend on its specific needs. These must directly align with the community’s needs and funding capacity, and a structure that works for one department may not necessarily work for another. As an all-hazard emergency response department, SMFD’s staffing is crucial to providing safe and efficient services.
Several national organizations recommend standards to address staffing issues. The Occupational Safety & Health Administration (OSHA) Respiratory Protection Standard and National Fire Protection Association (NFPA) Standard 1710 are frequently cited as authoritative documents. The Center for Public Safety Excellence (CPSE) publishes benchmarks on the number of personnel recommended on the emergency scene for various risk levels. The staffing and personnel needs depend heavily on the type of system, call volume, and the department's and community's overall needs.
Organizations must commit to consistency, fairness, safety, and growth opportunities. These values will be the foundation of the overall organizational culture. There are always challenges as organizations grow. Leadership and staff will face ambiguity, a changing environment, and the need for collaboration. Creating a positive culture is an opportunity to build a long-term, sustainable organization.
A key element of a healthy organization is balancing administration, support staff, and operational resources. This study and analysis will examine the current ratios for each part of the organization and offer recommendations for a combined staffing model. Staffing considerations could enhance service delivery. This process will review various organizational charts and establish a framework for future staffing.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 10 Administrative Support Staffing
The following figure illustrates the administrative support staffing. All these positions are funded as of FY 2023–24.
Figure 2: EMS Non-Uniformed Administrative Staffing
Position Title FTE Hours
Worked/Week Work Schedule
EMS Coordinator (Registered Nurse) 1 40 hours Full-time Contracted Nurse Practitioners 5 part-time 10–20 Part-time Total: 1 FTE + PT
The following figure illustrates the uniformed administrative and support staff for SMFD.
Figure 3: EMS Uniformed Administrative & Support Staff
Position Title FTE Hours
Worked/Week Work Schedule
Battalion Chief – EMS 1 40 hours Full-time
Fire Captain – EMS 3 56 hours Full-time
Firefighter/Paramedic (APU) 3 56 hours Full-time
Total: 7
Operational Staffing Levels
Organizational success is based on a safe working environment, equitable treatment, the opportunity for input, and recognition of the workforce's commitment and sacrifice. Organizational priorities should correlate with the community. This section overviews SMFD’s current staffing configuration, particularly in delivering EMS.
The operational staff is usually the face of any fire service organization because of their frequent interaction with the citizens they serve. This group is involved in nearly every aspect of the organization’s operations.
For SMFD, this includes fire suppression, emergency medical response, technical rescue, vehicle extrication, fire investigations, fire safety inspections, public education, building plan reviews, and hazardous materials response.
The next figure summarizes SMFD’s budgeted operations staff positions. This includes full-time and part-time employees who are primarily assigned to provide emergency services at the operational level.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 11 Figure 4: Uniformed Operational Staff
Position Title FTE
Deputy Chief 2
Battalion Chief 7
Captains 32
Engineer 27
Firefighter/Paramedics 26
Firefighter 25
Ambulance Operators (not included in total below) 19.4 (March 24, 2026) Total: 119
Staff Scheduling Methodology
Staff scheduling involves creating a timetable for employees, including selecting the days and hours they will work and the tasks they will handle. There are various staff scheduling methods that organizations can adopt, including:
• Fixed schedule
• Rotating schedule
• Flexible schedule
• On-call scheduling
• Part-time scheduling
The current staff scheduling uses fixed shifts for fire and EMS resources. SMFD staffs five fire stations, housing seven ALS engine companies, one ALS assessment truck company, and six BLS ambulances.
Each fire station has one fire engine, and the truck company is located at Station 1.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 12 A typical daily staffing plan for the Santa Monica Fire Department is as follows: During each 24-hour shift, the department assigns one on-duty Battalion Chief, working on a 56-hour FLSA schedule (structured as a 48/96 or a 24-hour Kelly schedule variant). Field operations include multiple engine and truck companies staffed with one Captain, one Engineer, and two Firefighters or Firefighter/Paramedics per company, with at least one Paramedic on each ALS apparatus to ensure advanced life support services. Additionally, the department operates dedicated ambulance units staffed by two Ambulance Operators, who often work a 40-hour or modified 42-hour workweek (not on the 56-hour FLSA), sometimes on 12-hour or 10-hour shifts to cover peak activity times. Meanwhile, suppression personnel (Captains, Engineers, Firefighters, and Firefighter/Paramedics) stay on the 56- hour FLSA schedule aligned with platoon cycles. This staffing approach helps the department balance suppression readiness with high EMS call volumes by utilizing both cross-trained Paramedic Firefighters and dedicated transport units.
No matter which staffing or scheduling method an organization chooses, it is essential to consider factors such as the organization's needs, employee preferences, rising call volumes, and legal or regulatory requirements when creating schedules. Regularly reevaluating these programs helps organizations adapt to industry changes and serve community needs. Peak-hour staffing demonstrates how to adjust to community conditions.
Beyond the listed categories, departments need to use data to choose a deployment and staffing model that best fits their community's needs. A framework based on unit hour utilization (UHU), effective response force (ERF), call concurrency, fractile analysis, and coverage liability (the likelihood of unit availability) provides essential information to guide staffing decisions. To support this, the National Fire Protection Association (NFPA 1710) sets staffing and response standards linked to ERF and turnout/travel times. The International City/County Management Association (ICMA) and Center for Public Safety Excellence (CPSE) highlight data-driven deployment models rather than static schedules.
Firefighter/EMS Staff Distribution
SMFD utilizes firefighters in suppression and EMS rescue functions. The size and complexity of a city can pose specific challenges, and Santa Monica has addressed them through a diverse allocation of resources. The current model emphasizes getting the most qualified person to the scene as quickly as possible. This model gets the most qualified personnel to the scene quickly on each call, and patient care is seamless as SMFD responds in its own ambulances. SMFD’s daily operations are managed by one Battalion Chief, with five stations and seven ALS engine companies, one ALS assessment truck company, and six ambulances. SMFD falls on the upper end of their span of control.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 13 Figure 5: Battalion 1 (Suppression) Staffing Model
Unit BC Captain Engineer Firefighter/
Paramedic Non-Safety EMT
Battalion Chief 3 3
Station 1
Engine 3 3 6
Engine 3 3 6
Truck 3 3 3
BLS Ambulance 1 and 6 *8
Utility (REM)
Reserve RA
Rescue Utility
Reserve BC
RU-1
3 RU-1
3 Station 2
Engine 3 3 6
BLS Ambulance 6
Utility and USAR (CS)
Reserve Engine
Station 3
Engine 3 3 3 6
Engine 4 3 3 6
BLS Ambulance 3 & 4 *8
Station 5
Engine 3 3 6
BLS Ambulance 6
Haz Mat Unit (CS)
Haz Mat Utility (CS)
ARFF Unit (CS)
ARFF Utility (CS)
Station 7
Engine 3 3 6
Medical Cart (CS)
Utility (CS)
*One BLS ambulance is staffed for 24 hours, while the other one is staffed for 12 hours daily.
SMFD provides constant staffing at 1 BC, 10 Captains, 9 Engineers, and a combination of 17 Firefighters or Firefighter/Paramedics.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 14 Staff scheduling within the Santa Monica Fire Department is driven not solely by traditional shift models, but by a data-informed deployment strategy that aligns personnel resources with temporal and geographic demand. With peak-load staffing (BLS ambulances), unit-hour utilization benchmarks, and dynamic status management, the department, like leading Southern California fire agencies, ensures reliable EMS and fire response. Ongoing evaluation using performance metrics, including response-time compliance and workload distribution, ensures that staffing models evolve in alignment with community risk, call-volume growth, and firefighter health and safety considerations.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 15 BUDGET & FINANCE
SMFD B UDGET
The City of Santa Monica operates under a biennial (two-year) budget, with the current budget covering the period July 1, 2025, through June 30, 2027. The budget process begins in March of the first year of the biennial budget with a City Council meeting to set priorities for the next two years. The budget process also includes opportunities for community engagement and input through public meetings.
The biennial budget is approved by the City Council in late June. The City processes and publishes an addendum during the second year of each biennial budget, also called the exception-based budget year.
The following figure outlines SMFD’s actual General Fund revenue and expenses for the last five completed individual fiscal years (FY 2021 through FY 2025), grouped by major category.
Figure 6: SMFD Actual General Fund Revenue and Expenses (FY 2021–2025) Revenue/Expenses 2021 Actual 2022 Actual 2023 Actual 2024 Actual 2025 Actual Permits and Fees 1,195,683 2,121,520 2,064,637 1,956,329 2,385,824 Charges for Services 3,067,789 3,365,283 1,074,752 1,331,865 4,364,084 Miscellaneous Revenue 1,190 800 3,046 64,697 2,720
TOTAL REVENUE: $4,264,662 $5,487,603 $3,142,435 $3,352,891 $6,752,628 Salaries & Wages 20,145,241 20,503,137 24,100,664 24,113,193 25,578,565 Overtime 8,076,837 9,676,802 9,279,628 10,772,167 11,702,103 Benefits 14,135,190 14,360,538 17,841,160 16,922,880 18,500,011 Total Personnel Costs: 42,357,268 44,540,477 51,221,452 51,808,240 55,780,679 Materials, Services, & Supplies 856,839 1,154,396 1,066,257 1,322,739 989,995 Equipment and Maintenance 1,898,035 1,996,461 2,126,727 2,284,718 2,276,754 Other Expenses 460,478 787,928 901,716 940,962 1,226,227 Total Recurring Expenses: 45,572,620 48,479,262 55,316,152 56,356,659 60,273,655 Total Non-Recurring
Expenses: (Capital Projects) 2,551,354 1,677,608 5,152,368 1,804,380 250,019 TOTAL EXPENSES: $48,123,974 $50,156,870 $60,468,520 $58,161,039 $60,523,674 (Net Funding from GF:) ($43,859,312) ($44,669,267) ($57,326,085) ($54,808,148) ($53,771,046) Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 16 Charges for services account for the majority of SMFD’s revenue. This revenue category includes reimbursement from the State of California for strike team deployments, resulting in significant fluctuations in overall revenue from year to year. Permits and fees from fire prevention activities are also a significant source of revenue. Total revenues for SMFD were $6,752,628 in FY 2025, an increase of 58% from FY 2021.
Personnel costs accounted for 92% of all SMFD expenses in FY 2025. Total SMFD actual expenses have increased from $48,123,974 in FY 2021 to $60,523,674 in FY 2025, an increase of $12,399,700, or 26% over the five-year period.
Emergency Medical Services Budget
SMFD’s EMS Division was officially established in the middle of FY 2025. Therefore, there is no historical financial data available. Additionally, the EMS Division budget does not include costs for operational staff (Firefighter/Paramedics and Ambulance Operators) and other operating costs (vehicles, training, materials, and supplies) associated with emergency medical response and transportation. These costs are identified and allocated in the following section (Ambulance Fee Study).
Billing and Collections
Wittman Enterprises (Wittman) has a contract agreement with SMFD to provide medical billing and collection services for ambulance transport and related services. Under the agreement, Wittman provides the following billing services: prepares all invoices; gathers insurance information from the patient; prepares invoices and electronically conveys to Medicare and Medi-Cal fiscal intermediaries; bills all secondary and coinsurance billing; bills private insurance, supplemental insurance, secondary insurance, and Workers’ Compensation according to specific requirements. Wittman contacts patients with claims aging over 45 days for payment arrangements over telephone. Follow-up continues until payment in full is received or the account is dismissed by the City to an outside collection agency. Wittman coordinates receipt of payments and deposits monies daily into the City of Santa Monica’s bank account and provides detailed electronic notification. Additionally, Wittman performs month-end closing procedures that result in monthly financial reports.
Under the contract agreement, SMFD pays Wittman 3.99% of net collections for transports, defined under the contract as the amount collected by Wittman from the patient (e.g., the insurance reimbursement or cash payment), the property owner, or the responsible party.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 17 Payer Mix
Payer mix includes four primary entities that account for most of the transport reimbursement. These payers are: Medicare, Medi-Cal, private commercial insurance, and private pay, which is the term generally applied to those without insurance. Medicare is the primary health care coverage for persons over the age of 65. Medi-Cal is a component of the federal Medicaid program and is provided for specific qualified individuals and families (primarily low-income at 138% of the national poverty level).
Commercial insurance is most associated with benefits provided by employers to their employees, but it may also be purchased independently. Finally, private pay is the term generally applied to those without insurance.
The following figure shows the payer mix for SMFD from 2021 through 2025 and is derived from information provided to SMFD by McCormick Ambulance, SMFD’s previous provider of ambulance services and ambulance billing.
Figure 7: Payer Mix for SMFD (FY 2021—2025)
Payer 2021
Percentage
2022
Percentage
2023
Percentage
2024
Percentage
2025
Percentage
Medicare 46% 45% 41% 47% 48%
Medi-Cal 25% 23% 22% 22% 21%
Commercial Insurance 16% 11% 8% 7% 8%
Private Pay 12% 20% 18% 21% 19%
Other 1% 1% 11% 3% 4%
TOTALS 100% 100% 100% 100% 100%
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 18 AMBULANCE FEE STUDY
CURRENT EMS FEES
SMFD’s current EMS fees, including ambulance transportation fees, follow the rates published by the Los Angeles County Emergency Medical Services Agency (LEMSA), as outlined in the following figure.
Figure 8: SMFD Current EMS Fees
Fee Type Fee Amount
Advanced Life Support (ALS) Emergency Transportation $3,408 Basic Life Support (BLS) Emergency Transportation 2,276 Oxygen 120
Medical Supply Costs 35
Mileage 30
The LEMSA fees are adjusted annually. LEMSA sends notifications of the new rates to all cities and paramedic provider agencies in March, and the new fees are effective on July 1 of each year. It is a common practice for fire departments in Los Angeles County to follow these rates. However, if a department can demonstrate that its actual costs to provide the service are higher, it may charge a higher rate.
A MBULANCE FEE STUDY METHODOLOGY
AP Triton compiled all direct and indirect costs associated with providing ALS and BLS transports and used this information to calculate separate total costs for ALS and BLS transports. Total costs were divided by the number of annual transports to obtain a cost per transport. The following sections and accompanying figures provide the details for these costs. Costs are based on FY 2027 budget, as provided by SMFD staff.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 19 Direct Costs
Direct costs include staffing (Firefighter/Paramedics and Ambulance Operators), EMS Administration costs, and vehicle costs.
Staffing Costs —Firefighter/Paramedics
As noted in the previous section, SMFD’s EMS budget does not include labor costs for Firefighter/Paramedics. Instead, these costs are included in the overall Suppression and Rescue budget and cannot be easily extracted. Therefore, the following figures were constructed to show the costs of Firefighter/Paramedics associated with the ALS transportation system.
Figure 9: Salary and Benefit Costs—Firefighter/Paramedic Cost Type Amount
Salary $171,736
Benefits $138,983
Total salary and benefits (per FTE) $310,719
Total cost per daily staffing position (FTE x 3) $932,157 The preceding figure shows the average cost for each full-time equivalent (FTE) Firefighter/Paramedic.
Salary costs include base salary and all skill pays, while benefits include health benefits, retirement, workers’ compensation, and other employee benefits. The total salary and benefits costs per FTE are multiplied by three, representing the three shifts that constitute the constant staffing model.
Figure 10: Constant Staffing/Overtime Costs—Firefighter/Paramedic Cost Type Amount
Hourly rate (salary/2912) $58.98
Hourly Medicare costs $0.86
Hourly overtime rate $89.76
Cost per overtime shift $2,154.24
Annual overtime shifts needed per FTE 7.59
Annual overtime shifts needed per daily staffing position 22.77 Annual overtime costs per daily staffing position $49,052.04 Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 20 Constant staffing/overtime costs are required to account for paid time off for each Firefighter/Paramedic. First, an average hourly rate was calculated by dividing the average annual salary by 2,912 (the number of annual hours per FTE on a 56-hour workweek). Medicare costs were added and the sum was multiplied by 1.5 to obtain an average hourly overtime rate of $89.76. AP Triton then reviewed paid time off for all Firefighter/Paramedics for calendar year 2025 and calculated an average of 182.07 hours per FTE, equating to 7.59 24-hour shifts per FTE. This number was multiplied by three to obtain an estimated number of overtime shifts needed to cover each constant staffing position. The cost per overtime shift was multiplied by the number of overtime shifts needed for the annual overtime costs per daily staffing position.
Figure 11: Total Costs—Firefighter/Paramedic
Cost Type Amount
Total annual cost per daily staffing position $932,157
Annual overtime costs per daily staffing position $49,052 Total annual cost per daily staffing position $981,209
Cost for 10 daily staffing positions $9,812,090
SMFD’s staffing model includes two Firefighter/Paramedics on each engine. However, because SMFD operates four 24-hour ambulances and two 12-hour ambulances each day, for the purposes of the fee study it is assumed that there are 10 Firefighter/Paramedics associated with ambulance transportation each day. The preceding figure shows the full cost of each daily staffing position in the Firefighter/Paramedic rank and multiplies that by the number of Firefighter/Paramedics associated with the ambulance transportation system to get a total annual cost of $9,812,090.
Since Firefighter/Paramedics spend a portion of their time responding to BLS calls, it is appropriate to allocate a commensurate amount of their costs to the BLS Program. BLS transports account for 62% of transports. Additionally, it is estimated that Firefighter/Paramedics are on scene of a BLS transport for one-third of the duration of the incident. The following figure allocates Firefighter/Paramedic staffing costs accordingly.
Figure 12: Allocation of Firefighter/Paramedic Staffing Costs Costs BLS ALS
Initial allocation of Firefighter/Paramedic staffing costs — $9,812,090 % of total transports 62% 38%
% of time of BLS incident on scene 33.3% —
Allocation to BLS $2,025,804 —
Remainder to ALS — $7,786,286
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 21 Staffing Costs —Ambulance Operators
Like the Firefighter/Paramedics, Ambulance Operators are deployed using a constant staffing model.
Ambulance Operators differ from Firefighter/Paramedics, though, in that they are hired on a part-time, “as-needed” basis. “As-needed” employees in Santa Monica are paid an hourly rate but do not receive benefits; however, there are Medicare, unemployment, and other payroll costs associated, which total
5.7%. Additionally, “as-needed” employees are limited to 960 hours per year. If an employee exceeds this number of hours, he or she is entitled to health and retirement benefits in the subsequent year.
Because Ambulance Operators are hourly employees, Triton calculated the number of Ambulance Operator hours needed on an annual basis and multiplied that number by the hourly rate for the position. The following figures show these calculations.
Figure 13: Salary and Benefit Costs—Ambulance Operator
Cost Type Amount
Hourly rate $22.67
Payroll costs per hour (5.7%) $1.29
Loaded hourly base rate $23.96
Hourly overtime rate (including Medicare) $34.50
Benefits per employee exceeding 960 annual work hours $30,002 The preceding figure includes the hourly rate, additional payroll costs, and the hourly overtime rate at time and a half. The cost of employee benefits for each employee who exceeds 960 hours in a one-year period is also included.
Figure 14: Annual Hours Needed—Ambulance Operator
Unit Type
# of Straight
Time Hours
Needed
# of Overtime
Hours
Needed
Total Hours
Needed
24-hour units (4 daily) 50,112 19,968 70,080
12-hour units (2 daily) 7,928 832 8,760
12-hour peak season unit (1 daily, for 4 months) 2,928 — 2,928 Total Hours Needed 60,968 20,800 81,768
Each 24-hour ambulance is staffed by two Ambulance Operators each day, requiring a total of 24 Ambulance Operators. Ambulance Operators on these units work 24-hour shifts; however, Ambulance Operators are not permitted to be on a 56-hour workweek schedule. Therefore, each Ambulance Operator working on a 24-hour unit will need to work an average of 16 hours of overtime per week.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 22 Each 12-hour ambulance is staffed by two Ambulance Operators each day, requiring a total of eight Ambulance Operators. Ambulance Operators working on the 12-hour ambulances will typically work 84 hours each biweekly period, requiring an average of two hours of overtime each week.
The 12-hour peak season unit will be staffed by two Ambulance Operators each day, requiring four Ambulance Operators for the four-month period. Overtime hours are not calculated for the peak season unit since it is assumed that additional seasonal staff will be hired to cover these shifts.
Figure 15: Total Costs—Ambulance Operator
Unit/Cost Type Straight
Time Cost Overtime Cost Total Costs
24-hour units (4 daily) 1,200,793 688,858 1,889,651
12-hour units (2 daily) 189,972 28,702 218,674
12-hour peak season unit (1 daily, for 4 months) 70,161 — 70,161 Total Salaries and Wages 1,460,926 717,560 2,178,486
Benefits for employees exceeding 960 hours (10) 300,020 Total Cost for Ambulance Operators $2,478,506
The preceding figure includes calculations for the total cost of Ambulance Operators. Straight time hours needed are multiplied by the loaded hourly base rate of $23.96, while overtime hours needed are multiplied by the overtime rate of $34.50, resulting in a total of $2,178,486. Additionally, due to the hours required to operate the system, AP Triton estimated that nearly all of the 32 Ambulance Operators working on year-round units would need to work over 960 hours each year, resulting in their eligibility to receive health and retirement benefits in each subsequent year. However, since the Ambulance Operator classification is a pathway to a career in the fire service, it is recognized that there will be heavy turnover, and many Ambulance Operators will not remain employed by SMFD for multiple years. Therefore, AP Triton estimates that approximately one-third, or 10, Ambulance Operators will receive these benefits each year. Total Ambulance Operator staffing costs for the system are estimated to be $2,478,506.
EMS Program Costs
EMS Program costs include the staffing costs of the following positions: 1.0 FTE Battalion Chief, 1.0 FTE EMS Coordinator, 2.0 FTE Fire Captains, and 2.0 FTE Firefighter/Paramedics. Additional costs include medical supplies and contractual and professional services. Total EMS program costs for FY 2027 are budgeted at $2,341,715. These costs are allocated to BLS and ALS programs based on the ratios of BLS and ALS transports to total transports, 62% for BLS and 38% for ALS.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 23 Vehicle and Equipment Costs
The financial information provided by SMFD did not identify costs specific to the ambulances and associated equipment. Therefore, the costs in the following figure were sourced from other ambulance programs currently operating in California and represent the major cost items for purchasing and outfitting an ambulance for emergency response.
While some items, such as radios and gurneys, may have a longer lifespan, the five-year window provides a useful framework for cost projections.
The following figure is broken down into five columns:
• Years of Amortization: Most items are depreciated over five years. This is an estimate and shows the cost distributed over that span.
• Equipment Estimated Cost: Each item is assigned an estimated cost to project its total system cost.
• Estimated Total Cost: The total cost is a basic calculation of the number of ambulances estimated in the system multiplied by the depreciated cost. AP Triton projects a need for nine ambulances to support the system (four 24-hour ambulances and three 12-hour ambulances— which includes the peak season unit ). However, two reserve or spare ambulances that are fully stocked and ready to deploy will also be required. Therefore, cost estimates are based on nine units.
• Annual Amortized Costs: This is the simple depreciated annual cost for the nine ambulances.
Figure 16: Vehicle and Equipment Costs
Cost Center Per
Ambulance
Years of
Amortization
Estimated
Cost per
Ambulance
Estimated
Total Cost
(Nine
Ambulances)
Annual
Amortized
Costs
Ambulance Replacement 5 Years $230,000 $2,070,000 $414,000 Cardiac Monitor 5 Years 52,000 468,000 93,600
Make-Ready Equipment 5 Years 25,000 225,000 45,000
Data Tablets 3 Years 3,000 27,000 9,000
Power Gurney 5 Years 72,000 648,000 129,600
Ambulance Setup 5 Years 15,000 135,000 27,000
Lucas CPR Devices 5 Years 21,000 189,000 37,800
AEDs 5 Years 4,000 36,000 7,200
Stair Chair 5 Years 5,000 45,000 9,000
Totals $427,000 $3,843,000 $772,200
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 24 Operational costs for the ambulances include vehicle insurance, fuel, maintenance, and vehicle license fees. The following figure provides this cost per ambulance as well as the total cost for all nine ambulances.
Figure 17: Annual Operating Costs for Ambulances
Cost Center Per
Ambulance
Cost per
24-hour
Ambulance
Cost for 4
24-hour
Ambulances
Cost per 12-
hour
Ambulance/
Spare
Cost for 5
12-hour
Ambulances/
Spares
Cost for all
Ambulances
Ambulance Insurance 2,600 10,400 2,600 13,000 23,400
Fuel/Maintenance/License 41,000 164,000 20,500 102,500 266,500 Totals $43,600 $174,400 $23,100 $115,500 $289,900
Vehicle and equipment costs are allocated to BLS and ALS programs based on the ratios of BLS and ALS transports to total transports.
The following figure summarizes all direct costs for BLS and for ALS.
Figure 18: Summary of Direct Costs for BLS and ALS
Cost Type BLS ALS Totals
Firefighter/Paramedic Staffing Costs 2,025,804 7,786,286 9,812,090 Ambulance Operator Staffing Costs 2,478,507 — 2,478,507 EMS Program Costs 1,447,887 893,828 2,341,715
Vehicle Costs 656,698 405,402 1,062,100
Totals $6,608,896 $9,085,516 $15,694,412
Indirect/Allocated Costs
Indirect costs are allocated, administrative, or shared costs associated with the delivery of ambulance transportation services, and include: administration, training, fire station costs, technology costs, Ground Emergency Medical Transportation Program costs, and citywide indirect costs.
Administration, Training, and Technology Costs
Fire Department administration, training, and technology programs provide vital support to the ambulance transportation program. These costs are allocated to BLS and ALS transports based on the respective percentage of department-wide FTEs each program comprises, as shown in the following figure.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 25 Figure 19: FTE Ratios—BLS and ALS Programs
Program # of FTEs % of FTEs
Basic Life Support 33.3 18.26%
Advanced Life Support 30.00 16.45%
Department Total 182.3
The following figure shows the allocation of Administration, Training, and Technology Costs to the BLS and ALS Programs.
Figure 20: Allocation of Administration, Training, and Technology Costs Administration, Training, and Tech Costs Administration Costs Training Costs Technology Costs
Total Costs $6,953,119 $1,181,422 $506,658
Costs Allocated to Basic Life Support 1,269,640 194,344 92,516 Costs Allocated to Advanced Life Support 1,143,788 87,015 83,345 Fire Station Operating Costs
Fire station operating costs include utilities, building maintenance, custodial supplies, and other costs essential to maintaining and operating SMFD’s five fire stations. Total facilities operating costs are allocated based on calculating BLS and ALS staff as a percentage of all staff operating out of fire stations. The following figure shows the allocation of fire station operating costs to BLS and ALS Programs.
Figure 21: Allocation of Fire Station Operating Costs
Fire Station Operating Costs Fire Station Operating Costs Total Costs $365,465
Costs Allocated to Basic Life Support (28.57%) 104,419
Costs Allocated to Advanced Life Support (23.81%) 87,015 Public Provider -Ground Emergency Transportation (GEMT) In accordance with Assembly Bill 1705 (2019), the California Department of Health Care Services developed the Public Provider Ground Emergency Medical Transport (PP-GEMT) Program to provide increased reimbursements provided by eligible GEMT providers for each Medi-Cal transport. The enhancement is currently $1,168.18, with a pending proposed increase to $1,518.61 for 2026. The program requires a quarterly payment equating to $321.95 per Medi-Cal transport. The annual costs for this payment are outlined in the following figure.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 26 Figure 22: Annual PP-GEMT Costs
Medi-Cal Transports BLS ALS Totals
Cost per Medi-Cal Transport $321.95 $321.95 $321.95
# of Annual Medi-Cal Transports 1,150 710 1,860
Annual Cost $370,243 $228,585 $598,828
Citywide Indirect Costs
Citywide indirect costs include financial management, human resources, and other centralized general government costs which can be allocated to services. SMFD reports an indirect cost rate of
12.9% of direct labor costs (salaries and benefits). Applying this rate to the BLS and ALS programs results in the costs outlined in the following figure.
Figure 23: Citywide Indirect Costs Applied to BLS and ALS Indirect Cost BLS ALS Totals
Total Direct Labor Costs $4,504,310 $7,786,286 $12,290,596 Citywide Indirect Cost Rate 12.9% 12.9% 12.9%
Indirect Cost $581,056 $1,004,431 $1,585,487
The following figure summarizes all indirect/allocated costs for BLS and for ALS.
Figure 24: Summary of Indirect/Allocated Costs for BLS and ALS Cost Type BLS ALS Totals
Fire Administration 1,269,640 1,143,788 2,413,428
Fire Training 215,728 194,344 410,072
Technology 92,516 83,345 191,434
Fire Station Operating Costs 104,419 87,015 175,861
PP-GEMT 370,243 228,585 598,828
Citywide Indirect 581,056 1,004,431 1,585,487
Totals $2,633,602 $2,741,508 $5,375,110
Total Costs
Total direct and indirect/allocated costs from the preceding figures are summarized in the following figure.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 27 Figure 25: Total Direct and Indirect/Allocated Costs for BLS and ALS Cost Category BLS ALS Totals
Direct Costs 6,608,895 9,085,516 15,694,411
Indirect/Allocated Costs 2,633,602 2,741,508 5,375,110
Totals $9,242,497 $11,827,024 $21,069,521
Cost per Transport
The cost per transport is then calculated by dividing the total costs of BLS and ALS transports by the number of annual transports. This number was derived by taking the average number of transports for the four-year period of 2022 through 2025. The annual average number of BLS transports was 5,103, while the annual average of ALS transports was 3,150.
The following figure outlines the cost per transport for BLS and ALS.
Figure 26: Cost per Transport for BLS and ALS
Cost/# of Transports BLS ALS Totals
Total Cost $9,242,497 $11,827,024 $21,069,521
# of Transports 5,103 3,150 8,253
Cost per Transport $1,811.19 $3,754.61
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 28 Other Transport -Related Fees
It is typical for transporting agencies to itemize additional charges for services, including oxygen, medical supplies, and mileage. However, SMFD does not have enough financial and transport information to calculate the costs for these services. Therefore, it is recommended that SMFD charge the LEMSA-approved rates for these services.
FEE R ECOMMENDATIONS AND O PTIONS
The following figure outlines the cost of providing each service and the options for new fees. Options include: implementing fees that generate cost recovery, based on this fee study; or continuing to implement LEMSA-approved fees.
Figure 27: Cost of EMS Services and Fee Options
Fee Current
Fee
Option #1:
Cost Recovery
Option #2:
LEMSA-Approved
Fees (2026–2027)
ALS Transportation $3,408 $3,754 $3,572
BLS Transportation $2,276 $1,811 $2,385
Oxygen $120 Not available $127
Medical Supplies $35 Not available $37
Mileage $30 Not available $31
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 29 EMS COST RECOVERY OPPORTUNITIES
AP Triton also reviewed and identified other cost recovery opportunities available to SMFD. Other fees to consider include Treat and No Transport fees (for both engines and SMFD’s Advanced Provider Unit) and a Motor Vehicle Accident Fee.
TREAT AND NO TRANSPORT FEE (ENGINE RESPONSE)
Many EMS responses do not result in patient transport. A Treat and No Transport Fee allows agencies to recover the staff costs of responding to these incidents. The following figure shows the $394.48 cost of an engine response to an EMS incident, assuming that the resources are dedicated to the incident for 45 minutes.
Figure 28: Treat and No Transport Costs (Engine Response) Personnel/Supplies Annual
Salary
Annual
Benefits
Loaded
Annual
Cost
Hourly Rate
(Annual
Cost/2912)
Cost for
Response
Fire Captain $237,336 $171,820 $409,156 $140.51 105.39
Fire Engineer 199,856 157,545 357,401 122.73 92.05
Firefighter/Paramedic 171,736 138,983 310,719 106.70 80.03 Firefighter/Paramedic 171,736 138,983 310,719 106.70 80.03 Medical Supplies 37.00
Total Cost $394.50
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 30 TREAT AND NO TRANSPORT FEE (ADVANCED P R OVIDER UNIT) SMFD operates an Advanced Provider Unit, which is staffed with one Firefighter/Paramedic and one Contract Nurse Practitioner. The following figure outlines the costs for a Treat and No Transport for this unit.
Figure 29: Treat and No Transport Costs (Advanced Provider Unit) Personnel/Supplies Annual
Salary
Annual
Benefits
Loaded
Annual
Cost
Hourly Rate
(Annual
Cost/2912)
Cost for
Response
Firefighter/Paramedic 171,736 138,983 310,719 106.70 80.03 Contract Nurse
Practitioner (Hourly) 108.15 81.11
Medical Supplies 37.00
Total Cost $198.14
MOTOR VEHICLE ACCIDENT RESPONSE FEE
Fire departments often respond to vehicle accidents. Costs involve supplies to clean up the incident in an environmentally responsible manner, such as absorbent pads and granules for fluid clean-up, as well as a significant amount of staff time. Typically, this fee is charged to the vehicle insurance company of the at-fault driver(s). The following figure outlines the cost of responding to a motor vehicle accident, assuming staff time of one hour.
Figure 30: Motor Vehicle Accident Response Costs
Personnel/Supplies Annual
Salary
Annual
Benefits
Loaded
Annual
Cost
Hourly Rate
(Annual
Cost/2912)
Cost for
Response
Fire Captain 237,336 171,820 409,156 140.51 140.51
Fire Engineer 199,856 157,545 357,401 122.73 122.73
Firefighter/Paramedic 171,736 138,983 310,719 106.70 106.70 Firefighter/Paramedic 171,736 138,983 310,719 106.70 106.70 Supplies 50.00
Total Cost $526.64
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 31 AMBULANCE SUBSCRIPTION PROGRAM
Although ambulance subscription programs are not typically included as part of a standard fee study, AP Triton has evaluated and discussed these programs in prior engagements. Subscription-based ambulance programs can provide an alternative revenue source for agencies; however, they also present administrative, financial, and regulatory considerations that should be carefully evaluated prior to implementation.
Under a typical subscription model, residents or property owners pay a recurring monthly or annual fee in exchange for reduced or waived out-of-pocket ambulance transport costs. In many systems, participating subscribers authorize the agency to accept insurance reimbursement as payment in full for covered ambulance services. If a subscriber lacks insurance coverage, the agency may waive additional patient billing obligations for eligible services. Subscription fees are commonly incorporated into municipal utility billing systems to simplify collection and administration.
Several fire departments in Orange County, California have implemented variations of subscription programs, including models tied to individual residents, households, or property addresses. These programs can generate supplemental revenue independent of actual service utilization, thereby creating a predictable funding stream. In practice, subscription programs may provide the greatest financial benefit to residents with limited financial means or those concerned about ambulance copayments and deductibles, while participation rates among higher-income residents may be lower.
ADMINISTRATIVE AND OPERATIONAL CONSIDERATIONS
Subscription programs require significant administrative oversight to ensure compliance and program accuracy. Agencies must maintain current subscriber records, including address verification and annual updates, particularly in situations where the subscription is associated with a property address rather than a specific individual. Without careful management, situations may arise in which property owners or tenants continue paying subscription fees without full awareness of the associated benefits or enrollment status.
Additionally, agencies must establish clear policies allowing subscribers to opt out of the program in accordance with applicable legal and consumer protection requirements.
Operationally, agencies should recognize that subscription programs may reduce opportunities to collect otherwise allowable co-payments or deductibles from insured patients. As a result, the financial success of a subscription program depends largely on accurately forecasting participation levels and service utilization rates.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 32 REGULATORY AND REIMBURSEMENT CONSIDERATIONS
Potential interactions with California’s Ground Emergency Medical Transportation (GEMT) and Public Provider Ground Emergency Medical Transportation (PP-GEMT) supplemental reimbursement programs should be carefully reviewed with legal counsel and reimbursement specialists prior to implementation.
Industry stakeholders have raised concerns regarding whether subscription programs could be interpreted as providing “gap insurance” coverage for ambulance-related patient liabilities. For example, prior discussions involving ambulance subscription billing practices in California suggested that if Medicaid or Medi-Cal beneficiaries participate in a subscription program that effectively covers patient balances, questions could arise regarding balance billing prohibitions and the agency’s eligibility to claim certain supplemental reimbursement funds. Although no known enforcement action or adverse ruling has occurred related to these concerns, the issue remains a potential future compliance consideration.
At present, subscription programs are generally considered lawful when properly structured and administered.
SPECIALIZED APPLICATIONS
Subscription models may be particularly beneficial for residential care facilities, assisted living facilities, or group care homes where ambulance utilization rates are higher and residents commonly incur Medicare or Medi-Cal co-payments. In these situations, agencies may establish agreements with facility operators to reduce or eliminate patient balance billing exposure associated with ambulance transport services.
PROPOSITION 26 CONSIDERATIONS
In California, agencies considering the implementation of a subscription program should evaluate Proposition 26 implications. To remain compliant, the agency must demonstrate that the program constitutes a voluntary fee-for-service arrangement rather than a general tax. Some agencies have addressed this issue by incorporating additional subscriber benefits, such as community newsletters, wellness information, vaccination reminders, or related public safety educational services, to further support the value proposition associated with the subscription fee.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 33 PROGRAM PRICING AND BILLING CONSIDERATIONS
One of the primary implementation challenges is establishing an appropriate subscription price and clearly defining the value provided to participants. Agencies should conduct detailed financial modeling to determine sustainable pricing based on anticipated participation rates, transport volumes, payer mix, and waived patient liabilities.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 34 Section II:
FHSZ INSPECTION
STUDY
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 35 FHSZ INSPECTION REQUIREMENT S
SMFD is in the process of launching and formalizing a Fire Hazard Severity Zone (FHSZ) inspection and compliance program within the areas designated as Local Responsibility Area (LRA) Moderate, High, and Very High Fire Hazard Severity Zones. Fire Hazard Severity Zones (FHSZ), as designated by California Department of Forestry and Fire Protection (CAL FIRE) and the Office of the State Fire Marshal (OSFM), identify geographic areas where wildfire conditions, topography, vegetation, and environmental factors contribute to increased potential for structure ignition and rapid fire spread.1 The purpose of implementing the FHSZ inspection program is to reduce wildfire ignition exposure through systematic verification of defensible space requirements, consistent property owner notification, and progressive compliance enforcement. Industry best practice programs emphasize a balanced approach that integrates proactive education with formalized inspection and community risk reduction programs.
This section evaluates the requirements and program components necessary to support Santa Monica’s initial program launch and long-term implementation across the City’s Moderate, High, and Very High Fire Hazard Severity Zones.
HISTORICAL WILDFIRE RISK CONTEXT —REGIONAL NARRATIVE
Santa Monica’s wildfire risk is due to its proximity to the Santa Monica Mountains and associated wildland–urban interface conditions along the City’s northern boundary. Recent regional wildfire events have demonstrated the potential for wind-driven fire behavior, ember exposure, structure-tostructure ignition, and rapid structure loss in interface communities throughout coastal Los Angeles County.
1 CAL FIRE / Office of the State Fire Marshal. Fire Hazard Severity Zones – Overview, Methodology, and LRA Mapping. https://osfm.fire.ca.gov/what-we-do/community-wildfire-preparedness-and-mitigation/fire-hazard-severity-zones.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 36 In January 2025, the Palisades Fire ignited in the Pacific Palisades area immediately northwest of Santa Monica and burned nearly 24,000 acres within one week, resulting in the loss of 6,837 structures and 12 confirmed fatalities, impacting both wildland and developed areas. Santa Monica’s newly mapped hazard severity zones lie within only a few miles of the Palisades incident footprint, reinforcing the relevance of similar fuel, terrain, and Santa Ana wind-driven fire conditions that may affect the City’s fire hazard areas.2 Santa Monica’s exposure is further underscored by other historical wildfire events in the surrounding Santa Monica Mountains region. Fires such as the Woolsey Fire (2018), which burned nearly 100,000 acres across the Santa Monica Mountains, and the Old Topanga Fire (1993), which destroyed hundreds of structures in adjacent mountain communities, demonstrate the recurring potential for large, wind-driven wildfires within the same fuel and weather climate present along Santa Monica’s interface boundary.3
While Santa Monica has not experienced widespread wildfire structure loss within City limits in recent incidents, wildfire impacts are highly dependent on ignition location, fuel alignment, and the weather conditions present at the time of an event. As demonstrated during the Palisades Fire, wind-driven fire conditions—including Particularly Dangerous Situation (PDS) red flag events—can rapidly increase ember exposure potential and create extreme structure ignition risk in communities located along the wildland–urban interface.4
2 Palisades Fire key impacts (structures destroyed and fatalities):
County of Los Angeles Fact Sheet (official):
https://file.lacounty.gov/SDSInter/lac/1199046_Eaton_Palisades_Fires_Anniversary_Fact_Sheet.pdf.
Los Angeles Fire Department After Action Report:
https://lafd.org/sites/default/files/pdf_files/Palisades_AARR_10_08_2025_final.pdf.
CAL FIRE Incident Page (general reference): https://www.fire.ca.gov/incidents/2025/1/7/palisades-fire. 3 National Park Service. 2018 Woolsey Fire (Santa Monica Mountains). https://www.nps.gov/samo/learn/management/2018- woolsey-fire.htm.
USGS Old Topanga Fire (1993): https://www.usgs.gov/media/images/monitoring-trends-burn-severity-mtbs-map-oldtopanga-fire. 4 City of Santa Monica. Palisades Fire Community Update (No Direct Damage Statement). https://www.santamonica.gov/topic-explainers/palisades-fire.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 37 Figure 31: Palisades Fire (January 2025) Incident Footprint in Relation to Santa Monica5 Wildfire risk in California has increased substantially over the past two decades, with larger and more damaging fires occurring at an unprecedented scale. CAL FIRE’s “Top 20 Largest California Wildfires” dataset indicates that more than half of the 20 largest fires in California history have burned since 2007, underscoring the growing importance of proactive defensible space inspection programs and community ignition risk reduction strategies statewide.6 5 Los Angeles County GIS Data Portal. Palisades and Eaton Dissolved Fire Perimeters (as of January 21, 2025), Feature Layer 1:
Palisades Fire Perimeter. ArcGIS Online Map Viewer.
https://services.arcgis.com/RmCCgQtiZLDCtblq/ArcGIS/rest/services/Palisades_and_Eaton_Dissolved_Fire_Perimeters_as_ of_20250121/FeatureServer/1.
6 CAL FIRE. Top 20 Largest California Wildfires Dataset. https://www.fire.ca.gov/-/media/calfire-website/our-impact/firestatistics/top-20-largest-ca-wildfires.pdf.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 38 REQUIREMENTS FOR FIRE HAZARD SEVERITY ZONE INSPECTIONS New Local Responsibility Areas (LRAs)
Santa Monica’s adoption of the updated CAL FIRE Local Responsibility Area Fire Hazard Severity Zone maps represents the first time the City has been formally designated as containing mapped Moderate, High, and Very High hazard severity zones under the statewide Fire Hazard Severity Zone framework. As a result, Santa Monica is now establishing a defined fire hazard severity inspection program, requiring the development of standardized procedures, recurring compliance capacity, and supporting resources to implement an effective defensible space and wildfire risk reduction program. This newly mapped hazard boundary and parcel inventory provides the foundational basis for the City’s inspection workload, cost evaluation, and the staffing requirements assessed in subsequent sections of this report.
The Office of the State Fire Marshal (OSFM) and CAL FIRE designate Fire Hazard Severity Zones as Moderate, High, or Very High based on statewide hazard modeling that considers fuels, slope, fire weather, and expected fire behavior.7 Santa Monica has adopted the updated CAL FIRE Local Responsibility Area Fire Hazard Severity Zone maps, consistent with recent statewide mapping expansion requirements. These maps establish the geographic foundation for defensible space inspection obligations and wildfire compliance enforcement within the City.
CAL FIRE’s Fire Hazard Severity Zone maps are developed using a science-based hazard assessment methodology that considers key factors influencing wildfire likelihood and fire behavior, including fire history, fuel conditions, predicted flame length, ember exposure, terrain, and typical fire weather patterns.8 Within Santa Monica, the newly mapped Moderate, High, and Very High hazard severity areas now provide the geographic basis for defensible space inspection authority, real estate transaction disclosure requirements, and local enforcement procedures.
Santa Monica’s Moderate, High, and Very High hazard severity areas include developed neighborhoods with meaningful concentrations of people (of 5,491 to over 6,000 persons per square mile), further emphasizing the need for a quality wildfire risk reduction program. 7 California Civil Code §1102.19 (AB 38). Defensible Space Real Estate Disclosure Requirements. https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=1102.19&lawCode=CIV. 8 California Department of Forestry and Fire Protection (CAL FIRE), Fire Hazard Severity Zone (FHSZ) Maps – Methodology and Data Sources, describing the science-based hazard assessment process incorporating fuel conditions, fire history, predicted fire behavior (including flame length and ember production), terrain, and weather patterns. https://osfm.fire.ca.gov/what-wedo/community-wildfire-preparedness-and-mitigation/fire-hazard-severity-zones.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 39 The number of parcels and unique addresses located within each hazard severity zone are as follows:
• Moderate Zone Parcels: 467 parcels, and 565 unique addresses • High Zone Parcels: 557 parcels, and 605 unique addresses • Very High Zone Parcels: 1,239 parcels, and 1,888 unique addresses Requirements by Zone
The City of Santa Monica is located entirely within a Local Responsibility Area (LRA). Fire Hazard Severity Zones (FHSZ) within LRAs are designated by the Office of the State Fire Marshal (OSFM) as Moderate, High, or Very High based on modeled wildfire hazard conditions, including fuel loading, slope, predicted flame length, ember exposure, and weather patterns. These designations reflect relative wildfire hazard potential and inform regulatory implementation and local enforcement authority.
Because Santa Monica contains no State Responsibility Area (SRA) lands, the applicable statutory framework for defensible space and vegetation management enforcement is governed primarily by Government Code §51175–§51189.
Moderate Fire Hazard Severity Zone
Properties located within a Moderate Fire Hazard Severity Zone in the Local Responsibility Area are not independently subject to the statutory defensible space mandate of Government Code §51182. While the California Fire Code provides general authority to address hazardous vegetation and combustible conditions, the 100-foot defensible space requirements do not apply unless specifically adopted by local ordinance.
Inspection and enforcement activity within Moderate Zones must therefore be grounded in local ordinance authority and adopted Fire Code provisions. Since overgrown vegetation is not governed by 100-foot defensible space requirements, complaints related to overgrown vegetation in these areas typically would be considered nuisance complaints subject to the City of Santa Monica’s department responsible for general code enforcement for the city.
High Fire Hazard Severity Zone
Properties located within a High Fire Hazard Severity Zone in Santa Monica’s Local Responsibility Area are subject to the California Fire Code (2025 Edition), as adopted locally.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 40 Section 4907 of the 2025 California Fire Code (Defensible Space) requires the establishment and maintenance of defensible space around structures in Fire Hazard Severity Zones in accordance with Public Resources Code §4291.9
While Government Code §51182 specifically references Very High Fire Hazard Severity Zones for statutory defensible space enforcement in LRAs, the 2025 California Fire Code (adopted by Santa Monica by ordinance) provides the Santa Monica Fire Department with inspection and enforcement authority and responsibility for defensible space compliance within High Fire Hazard Severity Zones.
Accordingly, properties located within High Fire Hazard Severity Zones are subject to:
• Defensible space requirements consistent with PRC §4291 (generally 100 feet, where property lines permit);
• Inspection and enforcement authority under the adopted California Fire Code; and • Real estate transaction documentation requirements pursuant to Civil Code §1102.19 (AB 38).
Very High Fire Hazard Severity Zone
Within Local Responsibility Areas, Government Code §51182 provides that a person owning, leasing, controlling, operating, or maintaining an occupied dwelling or structure located in a Very High Fire Hazard Severity Zone designated by the local agency shall maintain defensible space of 100 feet from each side of the structure, subject to statutory limitations.10 Like High FHSZ, Very High FHSZ parcels are also subject to the AB 38 real estate transaction documentation requirements.
Assembly Bill 3074 directed the development of additional ember-resistant “Zone 0” requirements applicable to the very high fire hazard areas. The final regulations are pending, however, when released, these regulations will impose an additional responsibility and workload upon Santa Monica Fire Department. The regulations will apply to local responsibility very high fire hazard areas. 9 2025 California Fire Code, Section 4907 – Defensible Space, and California Public Resources Code §4291 – Defensible space requirements (100-foot clearance).
10 California Government Code §51182 - defensible space in Very High Fire Hazard Severity Zones (LRA).
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 41 Requirements During Real Estate Transactions
California Assembly Bill 38 (AB 38) established defensible space compliance documentation requirements during the sale of residential property located in a High or Very High Fire Hazard Severity Zone. Under AB 38, sellers of applicable properties must provide documentation that defensible space requirements have been met, pursuant to California Civil Code Section 1102.19.11 AB 38 inspections represent a transaction-based compliance trigger and should be incorporated into Santa Monica’s inspection workload planning alongside recurring zone-based inspections and complaint-driven enforcement activity.
Defensible Space Requirements
California’s foundational defensible space requirements are established under Public Resources Code Section 4291, which requires property owners in designated fire hazard areas to maintain vegetation clearance and fuel modification around structures. CAL FIRE defines defensible space as the area around a building where vegetation and combustible materials are managed to reduce flame spread, ember ignition potential, and structure vulnerability.12 Santa Monica’s inspection program should therefore be grounded in statewide defensible space standards while incorporating local procedures for notice, enforcement, and compliance verification. 11 California Legislature, Assembly Bill 38 (2019), codified in California Civil Code §1102.19, requiring defensible space compliance documentation during the transfer of residential property located in High and Very High Fire Hazard Severity Zones.
12 CAL FIRE. Defensible Space Requirements (Public Resources Code §4291). https://www.fire.ca.gov/dspace.
California Public Resources Code §4291:
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PRC§ionNum=4291.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 42 Notification Procedures for Non -Compliant Properties Established defensible space inspection programs typically provide advance seasonal notification to property owners in areas subject to inspection, outlining defensible space requirements, expected inspection timelines, and the potential consequences of non-compliance. These notifications are commonly distributed in early spring (March through April), allowing property owners sufficient time to complete vegetation management prior to the established compliance deadline and the commencement of initial inspections. For coastal communities, a later inspection start date around June 1 may be appropriate, consistent with regional defensible space programs that account for extended seasonal vegetation growth in coastal areas.13 In some jurisdictions, parcels with potentially hazardous vegetation conditions are declared as a public nuisance through a formal local process to support notice, inspection, due process, and enforcement authority. Other jurisdictions rely on existing fire code and state law authority without a formal declaration process. The appropriate approach for Santa Monica should be determined based on desired program scale, enforcement strategy, and coordination with the City Attorney’s Office.
Regional programs may utilize a formal “declaration of public nuisance” or inspection list process, where parcels identified through FHSZ mapping and risk-based criteria are included in an annual notice and inspection program, with property owners provided notice and an opportunity to contest inclusion or demonstrate compliance prior to enforcement actions.
For properties identified as non-compliant, programs typically involve issuance of a written notice that clearly identifies observed deficiencies, references applicable code or program requirements, and outlines required corrective actions along with a defined compliance deadline. Effective programs document all notifications within an inspection tracking system and may utilize multiple delivery methods (e.g., mail, electronic communication, or on-site posting) to ensure receipt and support enforcement consistency.
13 Los Angeles County Fire Department, Annual Brush Clearance Program, establishing differentiated compliance timelines for coastal and interior areas, including later inspection start dates for coastal properties to account for extended seasonal vegetation growth patterns; available at: https://fire.lacounty.gov/brush-clearance-program/.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 43 Timelines for Corrective Action
Well-established programs generally incorporate clearly defined compliance timelines that are consistent across the areas inspected, with flexibility to account for hazard severity. A common approach is to structure inspection programs with progressively shorter compliance periods following initial notification. Regional program models commonly provide property owners approximately 30 days to correct identified violations following initial inspection, followed by a re-inspection to verify compliance. If the property remains non-compliant, subsequent notices may reduce the compliance timeframe, with continued non-compliance resulting in more immediate correction requirements and potential escalation to enforcement actions such as administrative citations, inspection fees, or abatement enforcement fees.
This tiered approach—progressing from initial inspection to notice of violation, re-inspection, and ultimately enforcement—supports consistency in program implementation while providing property owners with a reasonable opportunity to achieve compliance. Parcels that remain non-compliant after re-inspection may be referred for enforcement, including administrative fines, cost recovery, or abatement where authorized.
The Potential Program Fees section provides recommended program strategies and implementation approaches based on the preceding analysis.
RECOMMENDED STAFFING REQUIREMENTS
The staffing required to support Santa Monica’s Fire Hazard Severity Zone (FHSZ) inspection program is driven by inspection volume, re-inspection rates, AB 38 real estate transaction inspections, and public education efforts.
For planning purposes, the number of unique addresses provides a practical indicator of inspection workload, particularly within higher-density areas of the Very High Fire Hazard Severity Zone. Higher population density also increases workload due to additional time required for public interaction, coordination, and follow-up communication.
Training Requirements
Personnel assigned to the FHSZ inspection program should meet applicable California and industry training standards, including:
• California State Fire Training Fire Inspector 1A, 1B, 1C, and 1D courses • California State Fire Training Fire Inspector 1 certification Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 44 • Knowledge of defensible space requirements (PRC §4291, GC §51182) • Understanding of AB 38 inspection requirements and documentation procedures • Wildland fire behavior training, such as S-190 (Introduction to Wildland Fire Behavior), to support defensible space evaluation and understanding of fire spread potential Staff should be proficient in wildfire risk reduction strategies, inspection documentation, customer service, and enforcement procedures to support consistent program implementation.
To support a higher level of service and community engagement, particularly related to home hardening and wildfire risk reduction, the following advanced training is recommended:
• NFPA Wildfire Mitigation Specialist certification
Public Education and Staffing Integration
Public education plays a key role in improving compliance and reducing inspection workload. Staff time should be allocated for outreach, presentations, and property owner communication as part of the overall program. Public education efforts also support voluntary compliance and help build community trust and acceptance of the program, which are critical to long-term success. Proactive engagement with property owners can improve program effectiveness while fostering positive relationships between the fire department and the community.
The estimated inspection times reflected in the following discussion include a reasonable allowance for public interaction and property owner engagement during field inspections. AB 38 inspections typically require additional coordination and on-site interaction with property owners, real estate agents, or authorized representatives, which is reflected in the longer time allocations for those inspections.
Inspection Workload Analysis
The following analysis summarizes the estimated annual workload associated with Santa Monica’s Fire Hazard Severity Zone (FHSZ) inspection program, including defensible space inspections, AB 38 real estate transaction inspections, plan review activities, and public education efforts. Although full-time positions account for 2,080 hours annually, the actual time for inspection activities is reduced due to vacation, sick leave, holidays, and training. The National Fire Protection Association Standard 1730 provides guidance for estimating available staff hours.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 45 Figure 32: Available Work Hours/FTE
Available Staff Hours Hours
Annual Hours at 100% Availability 2,080
Annual Leave and Holiday -240
Estimated Sick Leave Usage -24
Annual Training -80
Total Hours 1,528
The following figure, based on NFPA 1730 staffing analysis methods and utilizing input provided by Santa Monica Fire personnel, shows the FTEs required to complete each activity.
Figure 33: Total Estimated Annual Workload
Activity # Annually Hours per
activity
Total Time
(Hours) FPB FTE
VHFHSZ initial inspection 1,888 0.33 629 0.41
HFHSZ initial inspection 605 0.33 202 0.13
VH and High re-inspection rate 30% or 747 0.33 249 0.16 Second re-inspection 224 0.33 74 0.045
Defensible Space SUBTOTAL 1,154 0.75
AB 38 Initial Inspection 60 1 60 0.04
AB 38 re-inspections 30 0.75 22 0.01
AB 38 Inspections SUBTOTAL 82 0.05
Landscape Plan Review and Inspection 60 2 120 0.08
Public Education Events/Outreach 24 3 72 0.05
Program Administration Hours 112 112 0.073
TOTAL 1,540 1.01
Staffing Calculation
• Total workload: approximately 1,540 hours
• Effective capacity per inspector: approximately 1,528 hours • Calculated staffing need: approximately 1.01 full-time equivalent (FTE) Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 46 Recommended Staffing Level
To account for operational variability and program demands, the recommended staffing level is: 1.0 full-time equivalent personnel for ongoing operations, with temporary or supplemental staffing utilized during initial program startup.
The staffing level is intended to provide capacity for the minimum level of service required to support:
• Re-inspections and enforcement
• AB 38 workload variability
• Complaint-based inspections
• Public education and program administration
Additional staffing would be required to expand beyond this baseline level of service, including full program buildout and enhanced inspection coverage, as further described in the Potential Program Fees section of this report.
FULL COST OF THE INSPECTION PROGRAM
The full cost of Santa Monica’s Fire Hazard Severity Zone (FHSZ) inspection program is primarily driven by personnel time required to conduct inspections, perform re-inspections, process AB 38 real estate transaction requests, and support public education and program administration.
For this analysis, a simplified cost model is used based on the fully burdened hourly rate for the Fire Inspector position at mid-range. Fully burdened rates are typically established to include salary, benefits, and typical overhead costs such as vehicles, equipment, information technology, and inspection software. As a result, these costs are not separately itemized.
Personnel Cost Analysis
Based on the workload analysis in the preceding workload analysis:
• Estimated annual workload: approximately 1,540 hours
• Fully burdened hourly rate: $235.73 per hour
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 47 Figure 34: Estimated Annual Program Cost
Component Value
Total Annual Hours Approximately 1,540
Hourly Rate $235.73
Total Estimated Annual Cost Approximately $363,024
Additional Cost Considerations
While the fully burdened rate captures most ongoing program costs, initial implementation may require limited one-time or short-term expenditures, including:
• Development of inspection procedures and documentation systems • Public outreach and notification materials
• Staff training and onboarding
• Configuration or expansion of inspection tracking systems These costs are expected to be modest relative to ongoing personnel costs and may be absorbed within existing departmental resources or addressed through short-term staffing or project support.
Administrative Support Considerations
The cost model assumes inspection personnel will perform both field and administrative functions. As the program matures, additional administrative support may be considered to assist with:
• Scheduling inspections
• Processing AB 38 requests
• Data entry and records management
• Customer service and public inquiries
At the baseline staffing level identified in Section 4B, these functions are expected to be manageable within the Fire Inspector role.
Summary
• Estimated annual program cost: approximately $363,024 • Primary cost driver: personnel
• Additional costs: minimal due to inclusion within fully burdened rate This simplified cost model provides an estimate of program costs for planning and fee development purposes.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 48 POTENTIAL PROGRAM FEES
A fee program should be established to recover the reasonable cost of providing Fire Hazard Severity Zone (FHSZ) inspection services, consistent with California law. Fees should be based on the cost of service and structured to support program sustainability while encouraging compliance.
Recommended Fee Framework
To support a sustainable Fire Hazard Reduction Program, the following fee framework is recommended:
• AB 38 Inspections: Full cost recovery through direct service fees • Annual Defensible Space Inspections: Full cost recovery through direct service fees • Re-Inspections: Applied when properties remain non-compliant • Administrative citations: Used for continued non-compliance Administrative citations may be utilized to escalate for repeat violations to encourage timely compliance.
Estimated Cost of Service by Activity
The following figure summarizes estimated costs per activity based on Step 5 of the fully burdened Fire Inspector rate, as Santa Monica Fire anticipates that the position will be staffed by Fire Inspectors at Step 5 in the range for the next several years.
Figure 35: Estimated Cost of Service by Activity
Fee
Fire Inspector
Fully Burdened
Rate
Hours per
activity Proposed Fee
Annual Defensible Space Inspection $235.73 0.33 $78.57
Defensible Space Re-inspection Fee $235.73 0.33 $78.57
State Mandated AB 38 Initial Inspection $235.73 1 $235.73 AB 38 Re-inspections $235.73 0.75 $176.79
Landscape Plan Review $235.73 1 $235.73
Landscape Inspection $235.73 1 $235.73
Landscape Re-inspection Fee $235.73 0.33 $78.57
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 49 Compliance and Cost Recovery Considerations
Re-inspection fees not only recover program costs but also serve as an incentive for property owners to achieve compliance at the time of the initial inspection. Clearly communicated enforcement and fee structures are associated with higher rates of voluntary compliance and reduced program workload.
Fee Adjustment and Review
To maintain alignment with actual program costs:
• Fees should be reviewed periodically and adjusted as needed, particularly following the first year of program implementation
• Adjustments should reflect changes in staffing costs, workload, and service demand Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 50 Section I II:
FINDINGS &
RECOMMENDATIONS
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 51 KEY FINDINGS
EMS SERVICE FEE STUDY
• SMFD’s EMS systems are on the upper end of an appropriate level of span of control. • SMFD staffs four ambulances 24 hours per day, and two ambulances 12 hours per day.
FHSZ INSPECTION FEE STUDY
• SMFD has the foundation to implement a Fire Hazard Reduction Program supported by a defensible, cost-based fee structure.
• SMFD should consider implementing a risk-based inspection program. • SMFD's inspection programs should include seasonal notification and education of the community.
• SMFD should establish a standardized compliance workflow that transitions from education to enforcement in a consistent and defensible manner.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 52 RECOMMENDED STRATEGIES
Recommendation 1: C onduct c ontinuous evaluation of workload relative to span of control .
Description: The span of control for any organization is of critical importance. SMFD's EMS System is managed by a Battalion Chief assigned to EMS with support from three EMS Captains. With approximately 77% of the overall call volume routed to the EMS system, finding an appropriate workload balance can be challenging. In addition to administrative and operational staff, adequate ambulance staffing requires periodic review to ensure performance metrics are met or exceeded.
Outcome: Organizations that optimize span of control are successful organizations. A one-size-fits-all approach doesn’t work well for all communities; each community has its own microclimate that needs to be addressed. Having well-defined key performance indicators (administratively, operationally, ambulance capability) and routine evaluation of workload and span of control helps organizations optimize service levels. Prioritizing healthy employees is critical to long-term success.
Estimated Cost: Staff time to review and report. Additional costs will vary depending on the findings of each evaluation.
Recommendation 2: Consider Updating Ambulance Transportation Fees Description: SMFD should update ambulance transportation fees based on the cost-of-service analysis and the City’s selected cost recovery policy. The fee study identifies the calculated cost per transport for ALS and BLS services and compares those costs with the LEMSA-approved rates. The City should determine whether to adopt the cost recovery rate where legally supported, continue using the LEMSA-approved rate, or use another defensible policy approach approved through the City’s fee adoption process.
The following figure outlines the cost of providing each service and the options for new fees. Options include: implementing fees that generate cost recovery, based on this fee study; or continuing to implement LEMSA-approved fees.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 53 Figure 36: Cost of EMS Services and Fee Options
Fee Current
Fee
Option #1:
Cost Recovery
Option #2:
LEMSA-Approved
Fees (2026–2027)
ALS Transportation $3,408 $3,754 $3,572
BLS Transportation $2,276 $1,811 $2,385
Oxygen $120 Not available $127
Medical Supplies $35 Not available $37
Mileage $30 Not available $31
Outcome: Updated ambulance transportation fees will improve alignment between service costs and revenue recovery, support Proposition 26 compliance, and provide a more transparent basis for future fee adjustments.
Estimated Cost: Staff time for policy review, fee adoption, and billing system updates. Revenue impacts will vary based on the fee option selected and payer reimbursement limits.
Recommendation 3: Implement Treat and No Transport Fees Description: SMFD should consider adopting Treat and No Transport fees for qualifying EMS responses that involve patient evaluation, treatment, or advanced assessment without ambulance transport. Based on the cost analysis, the estimated cost is approximately $394.50 for an engine response and $198.14 for an Advanced Provider Unit response.
The following figure outlines the costs for a Treat and No Transport.
Figure 37: Treat and No Transport Costs (Advanced Provider Unit) Personnel/Supplies Annual
Salary
Annual
Benefits
Loaded
Annual
Cost
Hourly Rate
(Annual
Cost/2912)
Cost for
Response
Firefighter/Paramedic 171,736 138,983 310,719 106.70 80.03 Contract Nurse
Practitioner (Hourly) 108.15 81.11
Medical Supplies 37.00
Total Cost $198.14
Outcome: A Treat and No Transport fee would allow the City to recover a portion of the cost associated with EMS responses that require staff time, medical supplies, and clinical assessment but do not result in transport billing.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 54 Estimated Cost: Staff time for policy development, legal review, fee adoption, billing coordination, and public communication.
Recommendation 4 : Implement a Motor Vehicle Accident Response Fee Description: SMFD should consider adopting a Motor Vehicle Accident response fee to recover eligible costs associated with staff time, supplies, and incident mitigation activities at vehicle accidents. The fee should be structured for billing to the responsible party’s vehicle insurance carrier where legally permissible and administratively feasible.
The following figure outlines the cost of responding to a motor vehicle accident, assuming staff time of one hour.
Figure 38: Motor Vehicle Accident Response Costs
Personnel/Supplies Annual
Salary
Annual
Benefits
Loaded
Annual
Cost
Hourly Rate
(Annual
Cost/2912)
Cost for
Response
Fire Captain 237,336 171,820 409,156 140.51 140.51
Fire Engineer 199,856 157,545 357,401 122.73 122.73
Firefighter/Paramedic 171,736 138,983 310,719 106.70 106.70 Firefighter/Paramedic 171,736 138,983 310,719 106.70 106.70 Supplies 50.00
Total Cost $526.64
Outcome: A Motor Vehicle Accident response fee would provide a cost recovery mechanism for incident-related expenses that are not otherwise recovered through existing EMS or fire service fees.
Estimated Cost: Staff time for policy development, legal review, fee adoption, billing coordination, and public communication.
Recommendation 5: Implement a Cost -Per -Service FHSZ Inspection Fee Description: Santa Monica should implement its Fire Hazard Inspection fee program in a phased and structured manner to support both program startup and long-term sustainability. Initial fee adoption should be based on the cost-of-service analysis presented in the preceding workload analysis, with priority placed on implementing AB 38 inspection fees, annual defensible space inspections, landscape plan review and inspections, and re-inspection fees as the primary cost recovery mechanisms during early program rollout.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 55 The following figure summarizes estimated costs per activity based on Step 5 of the fully burdened Fire Inspector rate, as Santa Monica Fire anticipates that the position will be staffed by Fire Inspectors at Step 5 in the range for the next several years.
Figure 39: Estimated Cost of Service by Activity
Fee
Fire Inspector
Fully Burdened
Rate
Hours per
activity Proposed Fee
Annual Defensible Space Inspection $235.73 0.33 $78.57
Defensible Space Re-inspection Fee $235.73 0.33 $78.57
State Mandated AB 38 Initial Inspection $235.73 1 $235.73 AB 38 Re-inspections $235.73 0.75 $176.79
Landscape Plan Review $235.73 1 $235.73
Landscape Inspection $235.73 1 $235.73
Landscape Re-inspection Fee $235.73 0.33 $78.57
As the program matures and operational data becomes available, the City may expand its cost recovery framework to include additional tools such as administrative citations and abatement cost recovery, where appropriate and legally supported. Following the first year of implementation, the City should evaluate and adjust fees based on program data and cost recovery performance.
Outcome: SMFD realizes full cost recovery for all FHSZ inspections.
Estimated Cost: $363,024 fully burdened cost for an inspector.
Recommendation 6 : Implement a Risk -Based Inspection Program Description: Santa Monica should continue to implement a risk-based inspection approach that prioritizes properties and activities based on statutory requirements, hazard severity, and community risk.
Recommended prioritization includes:
• AB 38 real estate transaction inspections
• Complaint-based inspections
• Annual inspections within the Very High Fire Hazard Severity Zone • High Fire Hazard Severity Zone inspections as staffing and program capacity allow Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 56 Outcome: This approach ensures that available resources are directed toward the highest-risk and time-sensitive activities while allowing for future program expansion.
Estimated Cost: None if the Cost Per Service approach is adopted.
Recommendation 7: Provide Seasonal Notification and Education Description: An education-first approach should be implemented prior to the start of inspection activities. Seasonal notification should be distributed to property owners in advance of inspections and should clearly communicate:
• Defensible space requirements
• Program purpose and inspection timelines
• AB 38 inspection requirements
• Potential consequences of non-compliance
For a coastal community such as Santa Monica, a June 1 inspection start date is consistent with surrounding fire departments and accounts for extended vegetation growth conditions.
Outcome: Community is aware of the requirements.
Estimated Cost: Dependent on the method(s) utilized to communicate with the community.
Recommendation 8 : Develop a Standardized Compliance Workflow that Transitions into Progressive Enforcement
Description: Santa Monica should establish a standardized compliance workflow that transitions from education to enforcement in a consistent and defensible manner. A recommended framework includes:
1. Advance seasonal notification
2. Initial inspection
3. Written notice of violation, if applicable
4. Defined correction period (e.g., approximately 30 days)
5. Re-inspection
6. Escalation to re-inspection fees, administrative citations, or abatement where authorized Outcome: This structured approach supports fairness, transparency, and consistent program implementation
Estimated Cost: Staff time required to develop the workflows.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 57 Recommendation 9 : Formalize AB 38 Inspections
Description: AB 38 inspections should be formalized as a defined program component, separate from recurring inspection cycles but integrated into workload planning. Establishing clear procedures for inspection requests, scheduling, documentation, and reporting will support timely service delivery and compliance with statutory requirements.
Outcome: Compliance with statutory requirements.
Estimated Cost: Staff time to formalize the program.
Recommendation 10: Coordinate the Inspection Program with other City Departments
Description: Successful implementation of the FHSZ inspection program will require coordination across multiple City departments, including:
• Planning and Building
• Public Works
• City Attorney’s Office
Outcome: This coordination supports alignment with development review processes, ordinance authority, and broader City planning and hazard mitigation efforts.
Estimated Cost: Staff time required to coordinate with other city departments.
Recommendation 11: Consider the Implementation of Community -Focused Vegetation Management Support Programs
Description: To support voluntary compliance and build community trust, Santa Monica should consider implementing community-focused support programs, such as:
• Vegetation management assistance (e.g., green waste collection or chipping programs) • Public education campaigns and community meetings
• Participation in programs such as Firewise USA or local Fire Safe Councils Outcome: These efforts can reduce barriers to compliance and improve overall program effectiveness.
Estimated Cost: Staff time required to develop programs. If green waste collection and chipping programs are implemented, there will be costs associated with both.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 58 Recommendation 12: Consider Long -Term Inspection Program Enhancements
Description: As the program matures, Santa Monica may consider additional enhancements, including:
• Development of formal abatement authority and processes • Participation in statewide wildfire risk reduction recognition programs, such as the State Board of Forestry’s Community Risk Reduction Program designation • Integration with hazard mitigation planning and insurance-related initiatives Outcome: These enhancements can further strengthen community resilience and support long-term wildfire risk reduction.
Estimated Cost: Staff time required to develop formal processes.
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 59 Section IV :
APPENDICES
Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 60 APPENDIX A: TABLE OF F IGURES
Figure 1: EMS Responses (2023–2025)............................................................................................... 3 Figure 2: EMS Non-Uniformed Administrative Staffing ...................................................................... 10 Figure 3: EMS Uniformed Administrative & Support Staff................................................................... 10 Figure 4: Uniformed Operational Staff.............................................................................................. 11 Figure 5: Battalion 1 (Suppression) Staffing Model............................................................................ 13 Figure 6: SMFD Actual General Fund Revenue and Expenses (FY 2021–2025) .................................... 15 Figure 7: Payer Mix for SMFD (FY 2021—2025).................................................................................. 17 Figure 8: SMFD Current EMS Fees.................................................................................................... 18 Figure 9: Salary and Benefit Costs—Firefighter/Paramedic ............................................................... 19 Figure 10: Constant Staffing/Overtime Costs—Firefighter/Paramedic ............................................... 19 Figure 11: Total Costs—Firefighter/Paramedic ................................................................................. 20 Figure 12: Allocation of Firefighter/Paramedic Staffing Costs............................................................ 20 Figure 13: Salary and Benefit Costs—Ambulance Operator............................................................... 21 Figure 14: Annual Hours Needed—Ambulance Operator .................................................................. 21 Figure 15: Total Costs—Ambulance Operator .................................................................................. 22 Figure 16: Vehicle and Equipment Costs.......................................................................................... 23 Figure 17: Annual Operating Costs for Ambulances.......................................................................... 24 Figure 18: Summary of Direct Costs for BLS and ALS ........................................................................ 24 Figure 19: FTE Ratios—BLS and ALS Programs ................................................................................. 25 Figure 20: Allocation of Administration, Training, and Technology Costs ........................................... 25 Figure 21: Allocation of Fire Station Operating Costs ........................................................................ 25 Figure 22: Annual PP-GEMT Costs.................................................................................................... 26 Figure 23: Citywide Indirect Costs Applied to BLS and ALS................................................................ 26 Figure 24: Summary of Indirect/Allocated Costs for BLS and ALS ...................................................... 26 Figure 25: Total Direct and Indirect/Allocated Costs for BLS and ALS ................................................ 27 Figure 26: Cost per Transport for BLS and ALS.................................................................................. 27 Figure 27: Cost of EMS Services and Fee Options ............................................................................. 28 Figure 28: Treat and No Transport Costs (Engine Response).............................................................. 29 Figure 29: Treat and No Transport Costs (Advanced Provider Unit) .................................................... 30 Figure 30: Motor Vehicle Accident Response Costs .......................................................................... 30 Figure 31: Palisades Fire (January 2025) Incident Footprint in Relation to Santa Monica..................... 37 Attachment E
E M S & F I R E H A Z A R D F E E S T U D Y | S A N T A M O N I C A F I R E D E P A R T M E N T 61 Figure 32: Available Work Hours/FTE ............................................................................................... 45 Figure 33: Total Estimated Annual Workload .................................................................................... 45 Figure 34: Estimated Annual Program Cost ...................................................................................... 47 Figure 35: Estimated Cost of Service by Activity................................................................................ 48 Figure 36: Cost of EMS Services and Fee Options ............................................................................. 53 Figure 37: Treat and No Transport Costs (Advanced Provider Unit) .................................................... 53 Figure 38: Motor Vehicle Accident Response Costs .......................................................................... 54 Figure 39: Estimated Cost of Service by Activity................................................................................ 55 Attachment E