Certified Arborist Prior to
treatment
activities and
during
treatment
activities
City of Santee
Planning and
Building
Department
Prior to
treatment
activities and
during
treatment
activities
MM BIO-10 Jurisdictional Aquatic Resources Permitting. The City of Santee shall obtain the applicable permits, for treatment activities (i.e., trimming or thinning of native or nonnative vegetation within Zones 1 and 2) occurring within jurisdictional aquatic resources, such as a Section 404 permit from USACE, a Streambed Alteration Agreement from CDFW, and a 401 Water Quality Certification/Waste Discharge
Requirement from the RWQCB. No native or non-native
vegetation trimming or thinning in Zones 1 and 2 shall occur within any jurisdictional riparian/wetland vegetation
communities on the Project Site prior to issuance of aquatic resources permits.
City of Santee Fire
Department,
Planning and
Building
Department
Prior to
treatment
activities and
during
treatment
activities
CDFW; USACE;
RWQCB
Prior to
treatment
activities and
during
treatment
activities
MM BIO-11 Jurisdictional Aquatic Resources Avoidance.
Vegetation management activities occurring within Zone 3 shall only involve treatment or removal of dead, dying, or invasive species. The Project shall commit to avoid impacting streams within Zones 1, 2, and 3 by crossing them using temporary rubber mats or pads to distribute weight and
minimize vegetation trampling and soil disturbance, and helicopter and/or crane removal where equipment access is constrained and hand carry is infeasible.
City of Santee Fire
Department;
Project Contractor
Prior to
treatment
activities and
during
treatment
activities
City of Santee
Planning and
Building
Department
Prior to
treatment
activities and
during
treatment
activities
MITIGATION MONITORING AND REPORTING PROGRAM
EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN 18611.01 JULY 2026 MMRP-16
Table MMRP-1 Mitigation Monitoring and Reporting Program Table Mitigation Measure
Implementation
Responsibility Timing
Monitoring
Responsibility Timing
Verification
Date and
Initials
MM CR-1 Resource Avoidance. Measures shall be taken to
prevent inadvertent disturbance of archaeological resource sites CA-SDI-005050, CA-SDI-010148, SDRFM-DF-S-002, and SDFRMDF-S-003. Prior to the commencement of any ground disturbing activities within 100 feet of the resource boundaries of CA-SDI005050, CA-SDI-010148, SDRFM-DF-S-002, and SDRFM-DF-S003, temporary work buffers shall be placed to protect the sites from inadvertent disturbances associated with project
implementation. Following Project implementation within the vicinity of CA-SDI-005050, CA-SDI-010148, SDRFM-DF-S-002, and SDRFM-DF-S-003, the temporary work buffers shall be removed. Temporary work buffers may include exclusionary fencing, flagging, and/or Environmentally Sensitive Area (ESA) signage. An archaeological monitor shall guide the placement and erection of the temporary work buffers to assure archaeological sites CA-SDI-005050, CA-SDI-010148, SDRFM-DF-S-002, and SDRFM-DF-S-003 are properly protected.
Temporary work buffers shall remain in place for the duration of Project activities occurring in the vicinity of the resource.
Following completion of work within each protected area, buffers shall be removed. The archaeological monitor shall confirm that removal occurs only after all potential disturbance risks have ended.
Under no circumstances shall Project personnel, equipment, or materials enter the established buffer zones. If construction staff, monitors, or City representatives observe potential encroachment or damage, ground‑disturbing activities shall be immediately redirected or halted until appropriate corrective action is taken.
Qualified
Archaeologist,
Project Contractor
Prior to
treatment
activities and
during
treatment
activities
City of Santee
Planning and
Building
Department
Prior to
treatment
activities and
during
treatment
activities
MM CUL-2 Cultural Resources Monitoring. To mitigate for potential impacts to previously unknown, buried cultural resources within the Project APE and to prevent impacts to Qualified
Archaeologist
meeting the SOI
Prior to
treatment
activities and
City of Santee
Planning and
Prior to
treatment
activities and
MITIGATION MONITORING AND REPORTING PROGRAM
EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN 18611.01 JULY 2026 MMRP-17
Table MMRP-1 Mitigation Monitoring and Reporting Program Table Mitigation Measure
Implementation
Responsibility Timing
Monitoring
Responsibility Timing
Verification
Date and
Initials
known archaeological resources, an archaeological monitoring program shall be implemented pursuant to the City of Santee (City) regulations, the California Environmental Quality Act (CEQA), and Section 106 of the National Historic Preservation Act and shall include the following requirements:
Pre-Construction
1. The applicant shall contract a Secretary of Interior qualified Lead Archaeologist to oversee the cultural
monitoring program. The Lead Archaeologist shall
contract with a Kumeyaay monitor to conduct Native
American monitoring for the Project. The Lead
Archaeologist and Kumeyaay Native American
monitor(s) shall attend the pre-construction meeting to explain the monitoring requirements.
Construction
2. Monitoring. Both the archaeological and Kumeyaay
Native American monitor(s) are to be on site during
initial ground-disturbing activities.
3. The frequency and location of monitoring of native
soils will be determined by the Lead Archaeologist in
consultation with the Kumeyaay Native American
monitor(s).
4. If cultural resources are identified:
a. Both the archaeological and Kumeyaay Native
American monitor(s) have the authority to
divert or temporarily halt ground disturbance
operations in the area of the discovery.
b. The archaeological monitor shall contact the
Lead Archaeologist.
c. The Lead Archaeologist shall contact the City.
Professional
Qualification
Standards; Native
American
Kumeyaay
Monitor
during
treatment
activities
Building
Department
during
treatment
activities
MITIGATION MONITORING AND REPORTING PROGRAM
EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN 18611.01 JULY 2026 MMRP-18
Table MMRP-1 Mitigation Monitoring and Reporting Program Table Mitigation Measure
Implementation
Responsibility Timing
Monitoring
Responsibility Timing
Verification
Date and
Initials
5. The Lead Archaeologist in consultation with the City and Kumeyaay Native American monitor(s) shall
determine the significance of discovered resources.
Construction activities will be allowed to resume after the City has concurred with the significance
evaluation.
a. Isolates and non-significant deposits shall be
minimally documented in the field. Should the
isolates and non-significant deposits not be
collected by the archaeological monitor, the
Kumeyaay Native American monitor(s) may
collect the cultural material for transfer to a
Tribal curation facility or repatriation program.
b. If cultural resources are determined to be
potentially significant, avoidance measures shall
be developed by the Lead Archaeologist in
consultation with the Kumeyaay Native
American monitor(s) and approved by the City. If
avoidance is not feasible, a research design and
data recovery plan shall be prepared by the Lead
Archaeologist in consultation with the Kumeyaay
Native American monitor(s) and approved by the
City. The preferred option is avoidance.
c. If human remains are identified
i. Upon the identification of possible
human remains, no further
disturbance shall occur in the area of
the find until procedures stipulated in
Public Resources Code Section
5097.98, CEQA Section 15064.5 and
Health and Safety Code Section
7050.5 are completed.
MITIGATION MONITORING AND REPORTING PROGRAM
EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN 18611.01 JULY 2026 MMRP-19
Table MMRP-1 Mitigation Monitoring and Reporting Program Table Mitigation Measure
Implementation
Responsibility Timing
Monitoring
Responsibility Timing
Verification
Date and
Initials
Upon completion of Project ground disturbance, a final report shall be prepared substantiating that earth-disturbing activities are completed and whether cultural resources were
encountered. A copy of the final report shall be submitted to the South Coastal Information Center and any culturally affiliated tribe who requests a copy.
MM CUL-3 Inadvertent Discovery. In order to mitigate impacts to human remains to a level that is less than significant, procedures for proper treatment of unanticipated discoveries must comply with the California Environmental Quality Act (CEQA) Guidelines. In the event of discovery of unanticipated human remains,
personnel shall comply with Public Resources Code Section 5097.98, CEQA Section 15064.5, and Health and Safety Code Section 7050.5 during earth-disturbing activities:
If any human remains are discovered, the construction
personnel or the appropriate representative shall contact the County Coroner and the City. Upon identification of human remains, no further disturbance shall occur in the area of the find until the County Coroner has made the necessary findings as to origin. If the remains are determined to be of Native American origin, the Most Likely Descendant, as identified by the Native American Heritage Commission, shall be contacted by the property owner or their representative in order to determine proper treatment and disposition of the remains.
The immediate vicinity where the Native American human
remains are located is not to be damaged or disturbed by further development activity until consultation with the Most Likely Descendant regarding their recommendations as
required by California Public Resources Code Section 5097.98 has been conducted. California Public Resources Code Section 5097.98, CEQA Section 15064.5 and Health and Safety Code Section 7050.5 shall be followed.
Project
Contractor;
County Coroner
Prior to
treatment
activities and
during
treatment
activities
City of Santee
Planning and
Building
Department;
Native American
Heritage
Commission
Prior to
treatment
activities and
during
treatment
activities
MITIGATION MONITORING AND REPORTING PROGRAM
EIR FOR SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN 18611.01 JULY 2026 MMRP-20
Table MMRP-1 Mitigation Monitoring and Reporting Program Table Mitigation Measure
Implementation
Responsibility Timing
Monitoring
Responsibility Timing
Verification
Date and
Initials
MM NOI-1 Noise Reduction Techniques: Should mobile or
stationary heavy construction equipment (i.e., self-propelled or electrically, mechanically, or hydraulically powered) associated with Project implementation operate at horizontal distances closer than 45 feet horizontal to an off-site noise-sensitive receiver position (e.g., exterior of an existing residence), the Project contractor(s) shall apply either of the following options as noise reduction techniques to keep noise exposures at or below the FTA guidance-based threshold (80 dBA 8-hour Leq during daytime hours):
6. Administrative noise control – reduce heavy equipment operation time to just 1 hour per 8-hour period; or
7. Temporary noise abatement – install 8-foot-tall
(minimum height) plywood sheet barriers (or
acoustical blankets suspended on chain-link fencing or
other support means) along or parallel with an extent
of the Project boundary that adjoins the receiving
noise-sensitive property. The barrier extent shall have, end to end, a length of no less than the sum of the
width of the property to be protected plus four times
the perpendicular distance between it and the receiver
position, where this perpendicular is extended from (or through) the midpoint of the receiving property line.
Prior to the installation and use of temporary noise
abatement, a qualified biologist shall confirm and
verify with the City that the placement of the barriers are not located within any environmentally sensitive
areas (e.g., special-status plant locations, sensitive
vegetation communities, or jurisdictional aquatic
resources) and would not impact any wildlife species
or their movement.
Project
Contractor;
Qualified Biologist
Prior to
treatment
activities and
during
treatment
activities
City of Santee
Planning and
Building
Department
Prior to
treatment
activities and
during
treatment
activities
RESOLUTION NO.
1 RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTEE, CALIFORNIA, APPROVING THE CITY OF SANTEE’S SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM: FUELS TREATMENT PLAN AND SUPPORTING
DOCUMENTS
WHEREAS, the San Diego River Corridor continues to present a significant wildfire risk due to the proximity of residential development, critical infrastructure, and natural vegetation within the wildland-urban interface; and
WHEREAS, the Santee Fire Department continues to respond to wildfire-related incidents throughout the corridor, underscoring the importance of proactive mitigation measures to reduce wildfire risk and protect life and property; and WHEREAS, the Federal Emergency Management Agency (FEMA) provides grant funding through the Hazard Mitigation Grant Program (HMGP) to state, local, tribal, and territorial governments to carry out long-term hazard mitigation projects intended to reduce the loss of life and property resulting from natural disasters; and WHEREAS, the City of Santee was awarded HMGP funding in June 2024 for a two-phase project to reduce wildfire risk within the San Diego River Corridor in Santee through hazardous fuels reduction and defensible space creation; and WHEREAS, the HMGP funds are administered through the California Governor’s Office of Emergency Services (Cal OES); and
WHEREAS, the total approved Grant allocation is $7,284,240, consisting of $6,555,816 in FEMA Hazard Mitigation Grant Program funding and $728,424 in required non-federal cost share contributions; and
WHEREAS, the City’s non-federal cost share obligation is satisfied through a separate $907,568 grant provided by the San Diego River Conservancy (SDRC); and WHEREAS, Phase 1 of the HMGP includes the development of the San Diego River Fire Hazard Mitigation Program: Fuels Treatment Plan (Fuels Treatment Plan or “Project”) and it’s supporting environmental documents, including the Final Environmental Impact Report (Final EIR) (ENV 2026-0001; State Clearinghouse Number #2026020351); permitting; community outreach; parcel identification; and proposed fuel assessment by parcel; and
WHEREAS, the Fuels Treatment Plan proposes implementation of specific fuel treatment and vegetation management in the San Diego River Corridor for three distinct zones; and
RESOLUTION NO.
2 WHEREAS, throughout the development of the Phase 1 materials, Cal OES has provided guidance, to the extent possible, related to the City’s environmental and historical document compliance with the grant requirements; and
WHEREAS, if approved by the City Council, the Phase 1 materials will be submitted to Cal OES for review; and
WHEREAS, upon determining the Phase 1 package complete, Cal OES will provide the package to FEMA for their consideration; and
WHEREAS, federal environmental review and permitting will need to be coordinated on the federal level in order for the Phase 2 implementation activities to be considered; and WHEREAS, Cal OES intends to work closely with FEMA to obtain authorization to proceed with Phase 2; and
WHEREAS, Phase 2 of the Grant Program will include the hazardous fuels reduction and vegetation management throughout the San Diego River Corridor within Santee in accordance with the Fuels Treatment Plan in order to reduce hazardous fuel loads, improve defensible space around vulnerable properties, enhance emergency access, and increase community resilience to wildfire events.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF SANTEE:
SECTION 1. The City Council hereby adopts a Resolution approving the San Diego River Fire Hazard Mitigation Program: Fuels Treatment Plan Project and Phase 1 deliverables submission;
SECTION 2. The City Council hereby authorizes the City Manager to submit the Phase 1 deliverables to Cal OES.
SECTION 3. The City Council hereby authorizes the City Manager to execute all documents necessary to obtain FEMA authorization to proceed with Phase 2 implementation activities.
SECTION 4. The City Council hereby authorizes the City Manager to administer and expend remaining grant funds in accordance with the approved Hazard Mitigation Grant Program upon receipt of all required approvals.
RESOLUTION NO.
3 ADOPTED by the City Council of the City of Santee, California, at a Regular Meeting thereof held this 12th day of August 2026, by the following roll call vote to wit:
AYES:
NOES:
ABSENT:
APPROVED:
JOHN W. MINTO, MAYOR
ATTEST:
JAMES JEFFRIES, CITY CLERK
San Diego River Fire Hazard
Mitigation Program
Fuels Treatment Plan
APRIL 2026
Prepared for
CITY OF SANTEE
FIRE DEPARTMENT
10601 Magnolia Avenue
Santee, California 92071
Contact: Harley Wallace
Prepared by:
687 South Coast Highway 101, Suite 110
Encinitas, California 92024
Contact: Noah Stamm
18611.01 i
JULY 2026
Table of Contents
SECTION PAGE NO.
Acronyms and Abbreviations............................................................................................................................................ iii 1 Introduction ..........................................................................................................................................................1
1.1 Purpose...................................................................................................................................................1
1.2 Project Area Location .............................................................................................................................1
1.3 Fuels Treatment Plan Scope and Phasing ............................................................................................2
1.4 Vegetation Management Goals and Objectives ...................................................................................2 2 Project Area Description ......................................................................................................................................5
2.1 Landownership .......................................................................................................................................5
2.2 Wildfire Environment..............................................................................................................................5
2.3 Climate and Fire Weather......................................................................................................................6
2.4 Topography and Hydrology.....................................................................................................................6
2.5 Vegetation and Fuels .............................................................................................................................7
2.6 Fire History and Ignitions .................................................................................................................... 19 3 Treatment Prescription ..................................................................................................................................... 21
3.1 Treatment Goals.................................................................................................................................. 21
3.2 Treatment Zones and Management Framework ................................................................................... 25
3.2.1 Zone 1: 0–50 Feet from Structures...................................................................................... 25
3.2.2 Zone 2: 50–100 Feet from Structures................................................................................. 25
3.2.3 Zone 3: Extended Fuels Management Zone ........................................................................ 26
3.3 Vegetation Management Techniques.................................................................................................... 26
3.3.1 Hand Labor............................................................................................................................. 27
3.3.2 Mechanical............................................................................................................................. 29
3.3.3 Chemical................................................................................................................................. 31
3.4 Treatment Recommendations............................................................................................................... 33
3.4.1 Treatment Recommendations by Zone ................................................................................ 34
3.4.2 Special Considerations ............................................................................................................ 39
3.4.3 Access..................................................................................................................................... 41
3.5 Biomass Disposal Recommendations ............................................................................................... 45
3.5.1 Recommended Vegetation Disposal Methods..................................................................... 45
3.5.2 Off-Site Transport to a Green Waste Facility ........................................................................ 45
3.5.3 On-Site Broadcast of Chips ................................................................................................... 45
3.5.4 Lop-and-Scatter...................................................................................................................... 45
3.5.5 Cranes and Helicopters ......................................................................................................... 46
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 ii
JULY 2026
3.5.6 Species-Specific Disposal Considerations ........................................................................... 46
3.5.7 Selecting the Appropriate Disposal Method......................................................................... 46
3.6 Maintenance........................................................................................................................................ 47 4 Resource Protection.......................................................................................................................................... 49
4.1 Biological Resources ........................................................................................................................... 49
4.2 Cultural Resources .............................................................................................................................. 49
4.3 Slope Stability/Erosion........................................................................................................................ 49
4.4 Water Quality ....................................................................................................................................... 50
4.5 Pests and Pathogens .......................................................................................................................... 51
4.6 Fire Protection ..................................................................................................................................... 51
4.7 Air Quality ............................................................................................................................................. 52
4.8 Recreation Resources......................................................................................................................... 52
4.9 Noise .................................................................................................................................................... 53
4.10 Biological Resources ........................................................................................................................... 53 5 References ........................................................................................................................................................ 55 TABLES
1 Vegetation Communities and Land Cover Types in the Project Site.................................................................7 2 Vegetation Treatment Summary by Zone ........................................................................................................ 34 3 Plant Species Identified for Treatment or Removal in Zone 3 ....................................................................... 38
FIGURES
1 Project Location ...................................................................................................................................................3 2A Biological Resources............................................................................................................................................9 2B Biological Resources......................................................................................................................................... 11 2C Biological Resources......................................................................................................................................... 13 2D Biological Resources......................................................................................................................................... 15 2E Biological Resources......................................................................................................................................... 17 3 Project Components.......................................................................................................................................... 23 4 Access Routes ................................................................................................................................................... 43
APPENDIX
A Treatment Areas by Parcel
18611.01 iii
JULY 2026
Acronyms and Abbreviations
Acronym/Abbreviation Definition
ANSI American National Standards Institute
BMP Best Management Practices
CAL FIRE California Department of Forestry and Fire Protection Cal OES California Office of Emergency Services
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
City City of Santee
EPA U.S. Environmental Protection Agency
FEMA Federal Emergency Management Agency
FTP Fuels Treatment Plan
ISA International Society of Arboriculture
MTDB Metropolitan Transit Development Board
NRCS Natural Resource Conservation Service
PCA pest control adviser
PRC California Public Resources Code
ROE Right of Entry
NEPA National Environmental Protection Act
SFD Santee Fire Department
USACE U.S. Army Corps of Engineers
WUI wildland–urban interface
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 iv
JULY 2026
INTENTIONALLY LEFT BLANK
18611.01 1
JULY 2026
1 Introduction
As a critical component of the City of Santee’s the San Diego River Fire Hazard Mitigation Program (project), the City of Santee Fire Department (SFD) has developed a Fuels Treatment Plan (FTP) to reduce wildfire risk in and around high-priority sites along the San Diego River corridor. This area lies within the wildland–urban interface (WUI) and includes critical public infrastructure, adjacent residential neighborhoods, and biologically sensitive habitats.
The need for a targeted, ecologically conscious approach to vegetation management is underscored by increasing fire risk, invasive plant encroachment, and complex access and ownership constraints unique to the corridor.
This FTP provides a framework for vegetation management across the approximately 300-acre project area and includes treatment strategies tailored to the site’s wildfire exposure, access conditions, existing vegetation, and proximity to sensitive resources. The plan is designed to protect future and existing built communities, critical infrastructure, and sensitive resources by reducing wildfire risk through coordinated vegetation management across the project area. The recommended treatment strategies described in this FTP are based on the following:
▪ Fire history
▪ Current vegetation cover
▪ Expected fire behavior
▪ Access
▪ Land use and vegetation cover on adjacent properties
▪ The composition and construction of adjacent structures This FTP is designed to balance fire risk reduction with environmental stewardship. It emphasizes selective vegetation modification techniques that support defensible space and risk reduction while preserving ecological function, minimizing soil disturbance, and protecting sensitive resources. The plan framework supports applicable California Environmental Quality Act (CEQA) and National Environmental Policy Acts (NEPA) requirements and will inform the implementation activities (Phase 2 of the project) under existing regulatory and permitting pathways.
1.1 Purpose
The purpose of this FTP is to provide a detailed, parcel-specific strategy for reducing hazardous fuel loads within the San Diego River corridor in Santee. This plan outlines defensible space creation/maintenance standards, prescribes vegetation treatments, and identifies zone boundaries to minimize wildfire risk in the WUI. It documents the species and quantities of vegetation to be removed, defines potential removal processes, and incorporates best management practices (BMPs) to minimize or avoid impacts to resources in the project area. Additionally, this plan ensures compliance with environmental regulations (e.g., CEQA and NEPA), integrates biological and cultural resource considerations and supports the overall goal of enhancing community safety by reducing combustible materials across the 300-acre project area.
1.2 Project Area Location
The project area encompasses 299.9 acres within the WUI along the San Diego River corridor in the City of Santee (Figure 1, Project Location). This corridor includes sensitive areas such as wetlands, the river itself, and adjacent
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 2
JULY 2026
parcels. The project area is characterized by a mix of natural vegetation and non-native species, as well as proximity to residential and commercial structures, making it a critical zone for wildfire hazard mitigation.
1.3 Fuels Treatment Plan Scope and Phasing
This FTP defines the strategies and actions necessary to reduce hazardous fuel loads within the San Diego River corridor as part of Phase 1 of the project. Phase 1 of the project is the planning and environmental review phase.
Phase 2 of the project is implementation of this plan (fuels treatment in the field). Development of this plan included conducting a site assessment, identifying defensible space and vegetation treatment zones, documenting vegetation and species for removal, identifying potential treatment methods, identifying vegetation and debris removal options, and identifying potential site access locations. This plan has been developed as part of the planning and environmental review phase, which precedes the implementation phase, and will be completed in alignment with Federal Emergency Management Agency (FEMA) and California Office of Emergency Services (Cal OES) requirements during the Phase 1 timeframe established by the Hazard Mitigation Grant that is funding the project.
1.4 Vegetation Management Goals and Objectives
This FTP aims to reduce wildfire risk in the San Diego River corridor by creating/maintaining defensible space and managing hazardous fuel loads across 299.9 acres in the WUI. Its primary objectives include identifying and prescribing treatments for vegetation management, prioritizing the removal and treatment of non-native, invasive, and dead plant material, and implementing strategies to minimize fuel continuity in defensible space areas. The plan also seeks to avoid or minimize impacts to sensitive environmental resources through identification and implementation of BMPs and ensure compliance with regulatory and CEQA/NEPA requirements.
Project Boundary
Date: 4/2/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Fire\Santee Fuels Treatment Plan.aprx Map: Figure 1 Project Location Layout: Figure 1 Project Location 0 1,000 2,000
n
Feet
Temecula
Murrieta
Chula
Vista
Solana
Beach Encinitas
San
Diego
Carlsbad
Oceanside
La Mesa El Cajon
Santee
Poway
San
Marcos
Escondido
Vista
Imperial
Beach
Del Mar
Coronado
ÄÆ905
ÄÆ54
ÄÆ52
ÄÆ94
ÄÆ163
ÄÆ195
ÄÆ125
ÄÆ274
ÄÆ56
ÄÆ74
ÄÆ86
ÄÆ78
ÄÆ67
ÄÆ76 ÄÆ79
§¨¦805
§¨¦15
§¨¦8
S a n D i e g o
C o u n t y
Project Site
SOURCE: USGS 7.5-Minute Series La Mesa and El Cajon Quadrangles San Diego River Fire Hazard Mitigation Program: Fuels Treatment Plan Project Location
FIGURE 1
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 4
JULY 2026
INTENTIONALLY LEFT BLANK
18611.01 5
JULY 2026
2 Project Area Description
Wildfire hazard within the 299.9-acre project area in the San Diego River corridor in Santee is shaped by the interaction of terrain, weather, and fuel (vegetation). Although riparian systems typically retain higher fuel moisture than surrounding uplands, the river corridor includes continuous stretches of flammable vegetation, invasive species, and disturbed open areas adjacent to residential and commercial development that contribute to a complex wildfire environment. These conditions, combined with regional fire weather patterns, create a fire environment that warrants focused fuels management.
2.1 Landownership
The 299.9-acre project area is composed of 29 distinct parcels and four (4) portions of right-of-way along the San Diego River corridor, where riparian and upland vegetation border residential neighborhoods, commercial development, public recreation areas, and transportation-related rights-of-way. This linear riparian system produces a continuous WUI, where structures and vegetated areas occur in close proximity. These spatial relationships shape how wildfire may affect developed parcels and inform the parcel-level treatment strategies later in this plan.
Land within the project area is primarily publicly owned. The City of Santee owns 69% (approximately 207 acres), the County of San Diego owns 16% (approximately 49 acres), and the Metropolitan Transit Development Board owns 2% (approximately 5 acres). City-owned parcels include both open space and actively managed recreational areas such as Mast Park and the Walker Preserve. The County of San Diego owns the central 49‑acre portion of the project area, which includes the Chubb Lane Bike Park. The remaining land in the project area consists of privately owned parcels (14 acres; 5%) and rights‑of‑way (25 acres; 8%).
Adjacent private parcels typically contain shallow structural setbacks, fences, accessory structures, and ornamental landscaping susceptible to ember intrusion and vegetation-to-structure ignitions. In some areas, manufactured homes are present. Such structures are not subject to ignition-resistant construction standards (California Building Code Chapter 7A) and are generally more vulnerable to fire due to limited structural resistance to radiant heat, and in some cases, deferred maintenance. Adjacent roadways, trail access points, and other publicly accessible spaces throughout the corridor further influence wildfire hazard by increasing the potential for human-caused ignitions.
Wildfire hazard varies substantially from parcel to parcel. The adjacency of off-site structures to vegetated areas, the presence of non-native and invasive species, and differing ownership and maintenance responsibilities all influence the degree of hazard and the types of fuel reduction strategies required. Subsequent sections of this plan provide parcel-level recommendations tailored to these conditions to support coordinated risk reduction across the entire corridor.
2.2 Wildfire Environment
The project area is situated along the San Diego River corridor in the City of Santee, a landscape defined by a mosaic of riparian woodlands, wetlands, shrublands, non-native grasslands, and disturbed areas contained within a broad floodplain. The river bisects the community of Santee in an east–west orientation and forms one of the major hydrological and ecological features of western San Diego County. Surrounding the corridor are urban
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 6
JULY 2026
neighborhoods, commercial districts, transportation infrastructure, parks, and open space preserves, creating a landscape typical of a WUI environment.
Although the project area is dominated by riparian vegetation, the broader fire environment in the region is shaped by the presence of flammable shrublands in surrounding foothills and by the region’s characteristic fire weather patterns. In San Diego County, inland valleys typically experience prolonged summer drying and periodic episodes of extreme offshore winds that can rapidly reduce fuel moisture and promote fast-moving wildfires (RCD of Greater San Diego County and San Diego County Fire Safe Council 2019; CAL FIRE 2025a). Human-caused ignitions are the most common type of ignition in the region (CAL FIRE 2025a); within the project area, public access and adjacency to development both contribute to elevated ignition potential.
The San Diego River corridor therefore represents a complex fire environment defined by urban adjacency, variable fuel conditions, and exposure to regional fire weather events. Because vegetation, land use, and ownership vary substantially throughout the project area, site-specific fuel reduction and defensible space actions are necessary to address localized risks and support the City’s broader hazard mitigation goals.
2.3 Climate and Fire Weather
The Santee area experiences a semi-arid Mediterranean climate characterized by hot, dry summers and mild winters with highly variable precipitation. Average annual rainfall at lower elevations in the county ranges from roughly 10 to 15 inches, with the majority occurring between December and March (RCD of Greater San Diego County and San Diego County Fire Safe Council 2019; CAL FIRE 2025a). Summer months are typically rainless, and prolonged dry periods contribute to the curing of fine fuels and the reduction of live fuel moisture across shrublands and grasslands. Peak temperatures in late summer and early fall frequently exceed 90°F in inland communities such as Santee, and fuel moisture typically reaches seasonal lows during this period.
A defining feature of the region’s fire weather is the occurrence of Santa Ana winds, which develop when warm, dry air flows from inland deserts toward the coast. These winds, which occur in late summer through the winter months, can reach sustained speeds of 25–35 mph on ridgetops and produce gusts exceeding 60 mph, traveling efficiently through east/west-oriented drainages, such as the San Diego River valley. Relative humidity during Santa Ana events often drops into the single digits, rapidly drying fine fuels and enabling fast, wind-driven fire spread (RCD of Greater San Diego County and San Diego County Fire Safe Council 2019; CAL FIRE 2025a). Seasonal winds in the inland foothills generally blow west to southwest during the summer but shift to northerly and easterly directions during fall and winter storm cycles, reinforcing the potential for wind alignment within the corridor (Eucalyptus Hills Fire Safe Council 2009). During such events, ignitions have the potential to develop into fast-moving, high-intensity fires capable of significant spotting and embers carried long distances through the WUI.
2.4 Topography and Hydrology
The San Diego River corridor in Santee occupies a broad alluvial valley bounded by foothill terrain to the north and east. Elevations in the immediate vicinity of the corridor range from roughly 300 feet along the river bottom to over 1,000 feet on adjacent ridgelines in neighboring communities (Lakeside Fire Safe Council 2024; Eucalyptus Hills Fire Safe Council 2009). Slopes in these upland areas can exceed 50 degrees, creating steep gradients that can accelerate upslope fire runs under certain weather conditions.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 7
JULY 2026
The east–west orientation of the river reflects a broader regional drainage pattern that can channel Santa Ana winds toward the coast, increasing wind speeds within valley bottoms and contributing to rapid fire spread (CAL FIRE 2025a). Within the project area, the corridor includes active and secondary channels, wetlands, and riparian stands. Hydrologic conditions influence vegetation structure and fuel continuity in the corridor. Riparian species generally exhibit higher moisture content, though accumulated dead biomass, storm-deposited debris, and invasive vegetation can create locally high fuel loading. Periods of drought and high temperatures can exacerbate drying and flammability of vegetation.
2.5 Vegetation and Fuels
Vegetation in the project area reflects the composition typical of inland valleys and river corridors in western San Diego County. Riparian vegetation, including willows, cottonwoods, mulefat, and associated understory species, dominates the immediate river margins. The acreage of each vegetation community and land cover type is presented in Table 1, and their spatial distributions are presented in Figure 2A–2E, Biological Resources. Although riparian vegetation often retains higher moisture levels, it can contain dense stands of shrubs, branches, and debris, along with invasive species such as Arundo donax, which can contribute to elevated fire intensity. Nonnative trees (palms, eucalyptus, tamarisk, pines) also present a hazard, especially when dry branches form a fuel ladder and/or when they completely or partially detach from the canopy.
Upland terraces and disturbed areas support coastal sage scrub dominated by California sagebrush, black sage, and California buckwheat, along with patches of non-native grasses that cure early in the fire season and readily carry surface fire. Mixed chaparral is present in the surrounding foothills but is less extensive within the river corridor itself. However, chaparral in adjacent uplands can influence ember production, wind-driven spread, and fire intensity during extreme weather events.
Table 1. Vegetation Communities and Land Cover Types in the Project Site Vegetation Community/Land Cover Type1 Project Site (Acres) Sensitive (Y/N)2 Native Vegetation Communities
Riparian and Bottomland Habitat
Southern Arroyo Willow (Salix lasiolepis) Riparian Forest 9.00 Y Southern Cottonwood–Willow (Populus spp.- Salix spp.) Riparian Forest
122.08 Y
Southern Riparian Scrub 1.22 Y
Southern Willow (Salix spp.) Scrub 17.26 Y
Mulefat (Baccharis salicifolia) Scrub 0.44 Y
Open Water 42.89 Y
Non-Vegetated Channel or Floodway 0.08 Y
Subtotal 192.97 N/A
Bog and Marsh
Coastal and Valley Freshwater Marsh 29.71 Y
Emergent Wetland 3.85 Y
Subtotal 33.56 N/A
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 8
JULY 2026
Table 1. Vegetation Communities and Land Cover Types in the Project Site Vegetation Community/Land Cover Type1 Project Site (Acres) Sensitive (Y/N)2 Woodlands
Coast Live Oak (Quercus agrifolia) Woodland (including Open subform)
1.84 Y
Scrub and Chaparral
Diegan Coastal Sage Scrub (including Baccharis-dominated subform)
27.76 Y
Subtotal of Native Vegetation Communities 256.13 N/A
Non-native Vegetation Communities and Land Covers
Riparian and Bottomland Habitat
Non-native Riparian 0.76 Y
Disturbed Wetland 2.75 Y
Tamarisk Scrub 1.49 Y
Subtotal 5.00 N/A
Woodlands
Non-native Woodland 0.48 N
Eucalyptus Woodland 2.29 N
Subtotal 2.77 N/A
Grasslands
Non-native Grassland 1.85 Y
Disturbed or Developed Areas
Disturbed Habitat 27.71 N
Urban/Developed 6.52 N
Subtotal 34.23 N/A
Subtotal of Non-native Vegetation Communities/Land Covers 43.85 N/A Grand Total 299.93 N/A
Notes: N/A = Not Applicable.
Totals may not sum due to rounding.
1 According to Oberbauer et al. (2008).
2 Considered sensitive under the Draft Santee MSCP Subarea Plan (City of Santee 2025).
Mission Gorge Rd
Fanita Dr
Carlton Hills Blvd
Fanita Pkwy
Gorge Pl
Gorge Ct
Sunwood Dr
Double M
R
d
Singing
Wood Way
Carlton Oaks Dr
Calle del Verde
Gorge Ave
Willowgrove Ave
Ä125
DW
CLOW
CLOW
CLOW
CSS
CSS
CSS CSS
CSS
CSS
CSSB
CSSB
CSSB
CSSB
CSSB
DEV
DEV
DEV
DEV
DH
DH
DH DH
DH
DH
DH
DH
DH
DH
DH
DH
DH
EUC
EUC
EUC
EUC
EW
EW
EW
EW
EW
FWM
FWM
FWM
FWM
FWM
FWM
FWM
FWM
MFS
MFS
MFS
NNR
NNW
NNW
NVC
NVC
OW
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SWS
SWS
SWS
SWS
SWS
SWS
SWS
Date: 4/2/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Fire\Santee Fuels Treatment Plan.aprx Map: Figure 2 Biological Resources Layout: Figure 2 Biological Resources 0 150 300
n
Feet
Project Boundary
Invasive Plant Species Proposed for Removal
Areas of Concentrated Non-Native Dead and Dying
Vegetation Removal
Cortaderia selloana (Uruguayan pampas grass)
Special-Status Plant Species
Iva hayesiana (San Diego marsh-elder)
Vegetation Communities and Land Covers
Sensitive Riparian Vegetation Communities
Sensitive Upland Vegetation Communities
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharisdominated
DEV, Urban/Developed
DH, Disturbed Habitat
DW, Disturbed Wetland
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
MFS, Mule Fat Scrub
NNR, Non-Native Riparian
NNW, Non-Native Woodland
NVC, Non-Vegetated Channel or Floodway
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWS, Southern Willow Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program: Fuels Treatment Plan Biological Resources
FIGURE 2A
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 10
JULY 2026
INTENTIONALLY LEFT BLANK
N CuyamacaSt
Carlton Oaks Dr
Town Center Pkwy
Mandeville Rd
Willowgrove Pl
Cobblestone Pl
Willowbrook Way
Brookstone Pl
Wintercreek Pl
Parkside Pl
Whis
pering Willow Dr
River Park Dr
River Rock Ct
Brookview Ct
River Trail Pl
Willowgrove Ave
Silvercreek Dr
CLOW
CLOW
CSS
CSS
CSS
CSS
CSSB
CSSB
CSSB CSSB
CSSB
CSSB
CSSB
DEV
DEV
DEV
DH
DH
DH
DH
DH
DH
DH
DH
DH
DH
EUC
EW
FWM
FWM
FWM
FWM
NNG
NNR
OW
OW
SCWRF
SCWRF
SCWRF
SWS
SWS
SWS SWS
SWS
OW
OW
Date: 4/2/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Fire\Santee Fuels Treatment Plan.aprx Map: Figure 2 Biological Resources Layout: Figure 2 Biological Resources 0 150 300
n
Feet
Project Boundary
Invasive Plant Species Proposed for Removal
Areas of Concentrated Non-Native Dead and Dying
Vegetation Removal
Arundo donax (giant reed)
Special-Status Plant Species
Iva hayesiana (San Diego marsh-elder)
Vegetation Communities and Land Covers
Sensitive Riparian Vegetation Communities
Sensitive Upland Vegetation Communities
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharisdominated
DEV, Urban/Developed
DH, Disturbed Habitat
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
NNG, Non-Native Grassland
NNR, Non-Native Riparian
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWS, Southern Willow Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program: Fuels Treatment Plan Biological Resources
FIGURE 2B
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 12
JULY 2026
INTENTIONALLY LEFT BLANK
N Magnolia Ave
Town Center Pkwy
Civic Center Rd
Eve Way Eve Ln
Leila Ln
Jim Ln
Park Center Dr
Cottonwood Ave
River Park
Dr
Riverview Pkwy
Claudia Ave
C
hubb Lane / Cotton
wood Ave
CLOW
CLOW
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSSB
CSSB
CSSB
CSSB CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
CSSB
DEV
DEV
DEV
DH
DH
DH
DH
DH
DH
DH
DH
DH
EUC
EUC
EUC
EW
EW
FWM
FWM
FWM FWM
FWM
FWM
FWM
FWM
FWM
FWM
FWM
FWM
NNG
NNG
NNG
NNG
NNG
SCWRF SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SWRF
TS
TS
TS
TS
TS
TS
OW
Date: 4/2/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Fire\Santee Fuels Treatment Plan.aprx Map: Figure 2 Biological Resources Layout: Figure 2 Biological Resources 0 150 300
n
Feet
Project Boundary
Invasive Plant Species Proposed for Removal
Areas of Concentrated Non-Native Dead and Dying
Vegetation Removal
Arundo donax (giant reed)
Vegetation Communities and Land Covers
Sensitive Riparian Vegetation Communities
Sensitive Upland Vegetation Communities
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharisdominated
DEV, Urban/Developed
DH, Disturbed Habitat
EUC, Eucalyptus Woodland
EW, Emergent Wetland
FWM, Coastal and Valley Freshwater Marsh
NNG, Non-Native Grassland
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWRF, Southern Arroyo Willow Riparian Forest
TS, Tamarisk Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program: Fuels Treatment Plan Biological Resources
FIGURE 2C
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 14
JULY 2026
INTENTIONALLY LEFT BLANK
N Magnolia Ave
Woodside Ave
N Woodside Ave
Share Ct
Hillcre
e
k
Way
Ra
msgate
Way
Chubb
Ln
H
illcreek Ln
Mavin Dr
Wheatlands Ct
Jeremy St
Stevens
Rd
Wheatlands Rd
Hartley Rd
Bundy Dr
Hinton Dr
Amster Dr
Abraham Way
Hillcreek Rd
Wheatlands Ave
Ä67
CLOW
CLOW
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
CSS
DEV
DEV
DEV
DEV
DEV DEV
DH
DH
DH
DH
DH
DH
FWM
FWM FWM
FWM
FWM
FWM
FWM FWM FWM
FWM
FWM
FWM
NNW
OW
OW
OW
OW
OW
SCWRF
SCWRF
SCWRF
SCWRF
SCWRF SCWRF
SCWRF
SRS SCWRF
SRS
SRS
SRS
SRS
SWRF
SWRF
SWRF
SWS
SWS
SWS
SWS
SWS
SWS SWS
SWS
Date: 4/2/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Fire\Santee Fuels Treatment Plan.aprx Map: Figure 2 Biological Resources Layout: Figure 2 Biological Resources 0 150 300
n
Feet
Project Boundary
Invasive Plant Species Proposed for Removal
Areas of Concentrated Non-Native Dead and Dying
Vegetation Removal
Arundo donax (giant reed)
Special-Status Plant Species
Iva hayesiana (San Diego marsh-elder)
Vegetation Communities and Land Covers
Sensitive Riparian Vegetation Communities
Sensitive Upland Vegetation Communities
CLOW, Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
DEV, Urban/Developed
DH, Disturbed Habitat
FWM, Coastal and Valley Freshwater Marsh
NNW, Non-Native Woodland
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SRS, Southern Riparian Scrub
SWRF, Southern Arroyo Willow Riparian Forest
SWS, Southern Willow Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program: Fuels Treatment Plan Biological Resources
FIGURE 2D
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 16
JULY 2026
INTENTIONALLY LEFT BLANK
Woodside Ave
Riverford Rd
N Woodside Ave
Calle R Tuttle
Mission Park Pl
Security Way
Los Sanderos Dr
Woodside Ter
Karerllyn Dr
Ä67
CLOW
CLOWO
CLOWO
CSS
CSS
CSS
CSS
CSS CSS
CSS
CSS
CSS
CSS
CSSB
DEV
DEV
DH
DH
DH
FWM
FWM
FWM
FWM
FWM
FWM
FWM
NNR
NNW
NNW
NNW
OW
OW
SCWRF
SCWRF SCWRF
SCWRF
SCWRF
SCWRF
SCWRF
SWRF
SWRF
SWRF
SWS
SWS
SWS
SWS
Date: 4/2/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Fire\Santee Fuels Treatment Plan.aprx Map: Figure 2 Biological Resources Layout: Figure 2 Biological Resources 0 150 300
n
Feet
Project Boundary
Invasive Plant Species Proposed for Removal
Areas of Concentrated Non-Native Dead and Dying
Vegetation Removal
Arundo donax (giant reed)
Vegetation Communities and Land Covers
Sensitive Riparian Vegetation Communities
Sensitive Upland Vegetation Communities
CLOW, Coast Live Oak Woodland
CLOWO, Open Coast Live Oak Woodland
CSS, Diegan Coastal Sage Scrub
CSSB, Diegan Coastal Sage Scrub: Baccharisdominated
DEV, Urban/Developed
DH, Disturbed Habitat
FWM, Coastal and Valley Freshwater Marsh
NNR, Non-Native Riparian
NNW, Non-Native Woodland
OW, Open Water
SCWRF, Southern Cottonwood-Willow Riparian Forest
SWRF, Southern Arroyo Willow Riparian Forest
SWS, Southern Willow Scrub
A
B
C
D
E
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program: Fuels Treatment Plan Biological Resources
FIGURE 2E
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 18
JULY 2026
INTENTIONALLY LEFT BLANK
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 19
JULY 2026
2.6 Fire History and Ignitions
According to the fire perimeter data available from CAL FIRE (2025b), no fires have been recorded within the project area since 1950. However, the threshold for inclusion in CAL FIRE’s fire perimeter database are fires measuring 10 acres in timber, 50 acres in brush, or 300 acres in grass. The lack of mapped fires in this database since 1950 is not for lack of historical ignitions just below the database listing threshold: the Santee Fire Department responded to 174 fires near the Project Site in 2024 and 2025 alone, 81 of which were in the project boundary. On March 29, 2026, an approximately 10-acre fire occurred within the project area. The surrounding foothills also have a wellestablished fire history. The most notable regional event was the 2003 Cedar Fire, which burned more than 273,000 acres and demonstrated the potential for large, wind-driven fires to spread rapidly from the east (RCD of Greater San Diego County and San Diego County Fire Safe Council 2019).
Across the CAL FIRE San Diego Unit, CAL FIRE responds to approximately 510 wildland fires per year, with an average of 15,000 acres burned annually when the extreme fire-siege years of 2003 and 2007 are excluded (CAL FIRE 2025a). Large fire years (i.e., those in which more than 20,000 acres burn) occur every 7 years on average, with recurrence intervals ranging from 1 to 22 years. The 2003 and 2007 fire sieges together burned over 500,000 acres countywide, underscoring the region’s potential for extreme fire growth under severe wind and weather conditions (CAL FIRE 2025a).
Human-caused ignitions, including vehicle fires, debris burning, equipment use, and campfires, are the predominant ignition sources in the region (CAL FIRE 2025a). Ignitions affecting the project area stem from the corridor’s urban adjacency, recreational access, and use by unhoused populations in certain segments and are expected to increase.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 20
JULY 2026
INTENTIONALLY LEFT BLANK
18611.01 21
JULY 2026
3 Treatment Prescription
3.1 Treatment Goals
The fuel treatments for the project will reduce wildfire hazard within the WUI, where the San Diego River corridor meets adjacent development. The primary intent of such treatments is to reduce ignition potential and potential fire intensity should a wildfire occur within the project area. The treatment goals will be achieved by reducing the overall volume of flammable vegetation as well as disrupting the horizontal and vertical continuity of fuels across the treated area. Treatments will be focused on defensible space areas proximate to adjacent structures and on the removal of non-native and invasive species occurring within the river corridor that in their abundance pose a significant wildfire hazard. Three treatment zones have been identified to clarify the spatial application of prescriptions appropriate for each zone.
The sections below describe the general treatment prescriptions for each zone (Section 3.2, Treatment Zones and Management Framework), and more specific prescriptions for each project area (Section 3.4, Treatment Recommendations). They are based on the type and condition of the flammable vegetation present, terrain, land use, and the presence of protected resources or habitat within the treatment area. A map depicting the location of treatment zones is presented in Figure 3, Project Components.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 22
JULY 2026
INTENTIONALLY LEFT BLANK
Fanita
D
r
Mission Gorge Rd
N
Magnolia Ave
Prospect Ave
Carlton
Hills
Blvd
N Cuy
a
m
aca St
Mast Blvd
Woodside Ave
Cuyamaca St Ä125
Ä67
Ä52
Project Boundary
Project Components
Zone 1
Zone 2
Zone 3
Areas of Concentrated Non-Native Dead and Dying Vegetation Removal Date: 4/28/2026 User: jgreenstein Path: Z:\Projects\j1861101\MAPDOC\Fire\Santee Fuels Treatment Plan.aprx Map: Figure 3 Project Components Layout: Figure 3 Project Components 0 500 1,000
n
Feet
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program: Fuels Treatment Plan Project Components
FIGURE 3
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 24
JULY 2026
INTENTIONALLY LEFT BLANK
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 25
JULY 2026
3.2 Treatment Zones and Management Framework
Vegetation management recommendations for the project area are organized into three zones that provide a framework for reducing fuel continuity while protecting the hydrologic, ecological, and recreational functions of the river corridor. Treatments vary in intensity across zones but are designed to be ecologically conscientious and appropriate for a highly used, hydrologically sensitive environment. Vegetation management shall be carried out by qualified vegetation management contractors.
Important Permitting Consideration
Any trimming of native vegetation shall occur only following acquisition of required permits. Depending on the timing of permitting, it may be necessary to phase implementation of this plan, with initial treatment focused on non-native species and dead or dying vegetation in Zones 1–3, followed by permitted native vegetation treatments in Zone 1 and Zone 2, as necessary, to achieve the intended fire protection objectives. If necessary to phase implementation, non-native regrowth or newly dead vegetation treated during the initial phase may also require follow-up treatment.
In an effort to balance fire risk reduction with habitat value, treatment of native vegetation is not recommended or included within Zone 3. Accordingly, permits associated with native vegetation treatment are not anticipated to be required for this zone.
3.2.1 Zone 1: 0–50 Feet from Structures
Zone 1 is approximately 9.2 acres of the project area and encompasses the area immediately adjacent to structures and represents the highest priority for reducing direct flame contact, radiant heat exposure, and ember ignition.
Vegetation management in this zone focuses on eliminating combustible materials, disrupting fuel continuity, and minimizing ignition pathways to buildings.
Throughout Zone 1, all fine fuels, dead vegetation, leaf litter, and woody debris will be treated or removed. Grasses will be trimmed/mowed to a height not to exceed 4 inches. Shrubs will be thinned to reduce horizontal continuity to a residual surface coverage of approximately 30%. Shrubs or other surface vegetation (e.g., ground cover) will be treated to reduce vertical continuity beneath tree canopies to achieve a separation of three times the height of the surface vegetation. Non-native, invasive, or flammable plant species will be removed wherever present. Ladder fuels will also be addressed by trimming low tree branches (in addition to treating shrubs or surface vegetation beneath tree canopies). All trimming activities would be done to industry standards (ISA, ANSI) to minimize likelihood of plant death. In addition, clearance will be maintained around fences, propane tanks, accessory structures, and other features susceptible to ignition, as applicable. Live and healthy native species may be treated as allowed (e.g., trimmed) through additional permitting only.
3.2.2 Zone 2: 50–100 Feet from Structures
Zone 2, encompassing approximately 22.5 acres, lies beyond the immediate structure buffer zone (0–50 feet) and provides an intermediate level of fuel reduction intended to moderate fire behavior as it approaches developed parcels. This zone generally includes landscaped edges and transitional areas between riparian vegetation and upland shrublands or grasslands.
Vegetation management in Zone 2 consists of treating or removing all non-native and dead vegetation, including invasive species and shrubs or trees with extensive dead or desiccated material. Treatments also include trimming
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 26
JULY 2026
dead and dying branches from native vegetation to reduce ladder fuels and minimize the potential for tree canopy torching. Shrubs will be thinned to reduce horizontal continuity to a residual surface coverage of approximately 50%. Shrubs or other surface vegetation (e.g., ground cover) will be treated to reduce vertical continuity beneath tree canopies to achieve a separation of three times the height of the surface vegetation. Grasses will be trimmed/mowed to a height not to exceed 4 inches. All trimming activities would be done to industry standards (ISA, ANSI) to minimize likelihood of plant death. Vegetation removal and treatment in this zone is intended to reduce fire intensity and rate of spread while maintaining ecological structure where feasible. Live and healthy native species may be treated (e.g., trimmed) as allowed through additional permitting only.
3.2.3 Zone 3: Extended Fuels Management Zone
Zone 3, encompassing approximately 268.2 acres, includes the broader vegetated areas of the river corridor (outside Zones 1 and 2), including most riparian zones, floodplain terraces, and open space areas, such as portions of Mast Park and Walker Preserve. Treatments in this zone focus on reducing hazardous, non-native vegetation while preserving riparian canopy, hydrologic function, and recreational access. Vegetation management in Zone 3 is focused on treatment or removal of non-native species, dead or dying vegetation, and debris, including accumulations deposited during storm events. Removal and other treatment of live and healthy native species would not occur within Zone 3.
3.3 Vegetation Management Techniques
Vegetation management within the project area will rely on a combination of techniques aimed at altering existing vegetation to reduce the potential for ignitions and modify fire behavior. Method selection will depend on site conditions, access availability/condition, target vegetation types, zone designation, proximity to sensitive resources, and the potential for soil or habitat disturbance in sensitive areas. Given the dynamic nature of vegetation, a single treatment technique or management prescription may not be appropriate for one site over time. Therefore, an adaptive approach for selecting management techniques is needed to achieve the vegetation management standards outlined in this FTP.
In general, recommended vegetation management techniques can be classified into three categories:
▪ Hand Labor (e.g., hand cutting, trimming)
▪ Mechanical (e.g., mowing, masticating)
▪ Chemical (e.g., EPA approved herbicide)
The following sections discuss each vegetation management technique that may be implemented in the project area, including information regarding equipment, application, limiting factors, special considerations, and BMPs.
Selection of a qualified and trained contractor, appropriate training, scheduling, and supervision to carry out vegetation management treatments and any associated BMPs are also key components of an effective vegetation management program. It is anticipated that the selected contractor will decide the appropriate technique based on access and constraints.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 27
JULY 2026
3.3.1 Hand Labor
Hand labor treatments involve trimming, cutting, or removing trees, shrubs, and grasses by hand or using handheld equipment. Other hand labor treatments include removing dead wood, litter, and mulching. Hand labor is most effective for smaller areas or areas with difficult access, such as where topographic or environmental constraints preclude the use of heavy equipment or where heavy equipment move-in costs may be high. Due to their precision, hand labor techniques typically have lower potential for adverse environmental effects and so are most appropriate in areas near the streambank or in otherwise sensitive habitats. Although, large volumes of foot traffic, specifically in areas with steep slopes, can result in surface soil compaction and increase erosion potential. Hand labor, particularly tree trimming, tree removal, or brush removal, also generates debris that must be chipped or removed so it does not add readily available fuel for a wildfire. Depending on the vegetation type, debris can be carried offsite by hand in bundles or burlap, or chipped; some areas may warrant the use of lop-and-scatter techniques. More detailed recommendations are provided in Section 3.5, Biomass Disposal Recommendations.
Hand labor treatments are appropriate for all zones but especially critical in Zone 1 and riparian-adjacent portions of Zones 2 and 3 where mechanical methods may not be feasible or desirable due to environmentally sensitive areas, or access constraints.
3.3.1.1 Line Trimming
Line trimming is one of the most common and successful methods for reducing light, flashy fuel loads. This technique uses a handheld tool (normally gas-powered) that cuts grass, herbaceous vegetation, ground covers, and small shrubs with a plastic line or cutting blade. Line trimming is typically used after grasses have dried or cured to prevent regrowth in the same year. This technique reduces fuel height and retains the cut material in a compacted layer on the ground surface, minimizing the potential for bare soil. On steep slopes or in areas with retained shrubs/trees, line trimming is more feasible than using mechanical equipment. Implementation of this technique avoids direct contact of the cutting line or blade with the soil surface to minimize disturbance. Crews shall be notified of retained trees or shrubs to minimize potential damage from cutting line/blade contact.
3.3.1.2 Shrub Removal
Shrub removal can involve using chainsaws, pruners, and other equipment to remove live and dead shrubs. Cut material shall either be chipped and spread back onto the site or removed from the site. Distributing cut shrubs on site is not recommended as it increases the risk of high-intensity wildfire. Woody shrubs, particularly in dense clusters, contribute to higher-intensity wildfires and create a fuel ladder for fire to transition to the tree canopies.
Removing woody shrubs reduces these wildfire risks.
Shrub removal entails two practices. First, shrubs beneath larger trees or dripline thinning in areas with tree canopy cover are removed. This practice removes ladder fuels that could allow fire to spread into the tree canopy and reduces wildfire intensity. Second, selective removal of individual or clusters of shrubs or mosaic thinning occurs.
This practice breaks up large continuous areas of woody shrubs, reducing the risk of very intense fires and periods of rapid-fire growth (aka fire runs). Chainsaws are recommended for both practices; hand tools can remove limited amounts of brush but are inefficient in larger areas.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 28
JULY 2026
3.3.1.3 Tree Trimming
Tree trimming can involve using handsaws, chainsaws, pruners, and other equipment to prune branches, remove dead limbs, stems, and branches, and lop larger material into smaller sizes. Fallen branches and cut material can be distributed across the site or removed for disposal. Implementation of this technique shall avoid cutting and breakage to trees or shrubs retained within the treatment area to minimize damage to stem tissue.
Tree trimming entails two practices. First, lower tree branches are removed to create vertical separation between surface fuels and the bottom of the tree canopy. This practice removes fuel ladders, decreasing the potential for crown fire transition. Trimming lower branches of trees can be done with a handheld pole saw or pole chainsaw.
Lower branches on shorter trees may be pruned with loppers. Second, trimming trees and large shrub branches along trails and roadways removes obstructions to foot, bicycle, and vehicle traffic. Trimming for trail and road clearance can be done with handheld pole saws or pole chainsaws for lower branches. Higher branches may require mechanical equipment. An International Society of Arboriculture (ISA) Certified Arborist shall conduct all trimming according to American National Standards Institute (ANSI) A300 standards (ANSI 2017).
3.3.1.4 Tree Removal
Tree removal can involve chainsaws, handsaws, and axes to remove live and dead trees and shrubs. Felled trees are cut into smaller logs for removal, further treatment (chipping), or distribution across the site. An ISA Certified Arborist shall conduct tree removals, particularly large tree removal, according to ANSI A300 standards (ANSI 2017).
Tree removal may require mechanical equipment or specialized felling techniques both for safety and to minimize local impacts to nearby vegetation, structures, or other resources.
Tree removal entails three practices. First, dead trees of any size are removed. This practice removes a readily ignited fuel supply for a fire and source of embers, therefore reducing the risk of high-intensity fire behavior or generating spot fires. Small dead trees (4 inches in diameter or less) can be removed with hand saws or axes; larger trees would be removed with chainsaws. Second, understory or dripline vegetation is thinned. This practice removes the smaller live trees in forest or woodland areas that occupy the position between the largest trees in the forest canopy and the surface vegetation. This removes ladder fuels and decreases the potential for surface fire transitioning into the tree canopy. Understory thinning is preferably accomplished with a chainsaw. The third practice is the removal of hazard trees, which are likely to fall onto a structure, road/trail, or other occupied target area. These trees can be live or dead but share these characteristics: (1) the tree has a significant defect that increases the likelihood of uprooting or trunk failure (e.g., decay, cracking, or fire damage); and (2) the tree is leaning toward the structure, road/trail or other target or is likely to fall in the direction of the structure, road/trail or other target due to site conditions. Hazardous trees shall be removed with a chainsaw, and an ISA Certified Arborist experienced with tree removal conducts the removal of hazardous trees.
3.3.1.5 Best Management Practices for Hand Labor
The following BMPs shall be implemented, where feasible, when utilizing hand labor vegetation management techniques. In all circumstances, tools and equipment shall be utilized only for their intended use.
1. Ensure equipment operators and project personnel are properly trained in equipment use.
2. Ensure that vehicles and equipment arrive at the treatment area clean and weed-free.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 29
JULY 2026
3. An ISA Certified Arborist shall conduct all trimming according to International Society of Arboriculture and American National Standards Institute A300 standards.
4. To minimize soil disturbance, leave stumps from removed trees and shrubs intact, with stump heights not exceeding 6 inches, as measured from the uphill side; treat stump-sprouting species using the cut and daub technique described in Section 3.3.3.2 of the FTP.
5. Protect retained trees and vegetation from tool and equipment damage.
6. Service and fuel tools only in areas that will not allow grease, oil, fuel, or other hazardous materials to pass into streams or retained vegetation.
7. Remove from the site and properly dispose of all refuse, litter, trash, and non-vegetative debris resulting from vegetation treatment operations, and other activity in connection with vegetation treatment operations.
3.3.2 Mechanical
Mechanical techniques include all fuel reduction methods that employ motorized heavy equipment to remove or alter vegetation, typically across larger areas. Mechanical techniques can be used to treat grass/herbaceous material (e.g., mowers) or woody material (e.g., masticators). Mechanical treatment techniques rearrange vegetation structures, compact or chip/shred material, and move material to landings, staging areas, or disposal areas. Mechanical equipment is usually equipped with either rubber tires or tracks, although skids and cables are also used. Sometimes, two or more pieces of heavy equipment will work in concert to achieve the fuel treatment standard.
Mechanical equipment is generally used in more uniform fuels where its use more efficiently reaches treatment standards. Constraints to mechanical equipment use include steep slopes, dense tree cover prohibiting travel, saturated soils, sensitive resource areas, and dry, high-fire-hazard weather conditions where equipment use could result in ignition. In addition, selective plant removal is typically not achievable with mechanical equipment (e.g., mosaic thinning) due to equipment size, although equipment can be guided around avoidance areas. The use of mechanical equipment may also result in damage to retained vegetation.
Appropriate use of mechanical equipment depends on terrain, access, vegetation type, and treatment standard of the treatment area to treat vegetation and minimize environmental impact potential effectively. Supervision and specialized training are also necessary. Mechanical equipment is often used with other treatment techniques to achieve vegetation standards that cannot be achieved by mechanical equipment alone (e.g., tree trimming).
3.3.2.1 Mowing
Mowing tools, such as rotary mowers on wheeled tractors, straight-edged cutter bar mowers, or flails, can cut herbaceous and woody vegetation above the ground. Mowing results in shorter, more compacted fuels, which reduces potential flame length and fire spread rates. The timing of mowing has an impact on the type of grasses promoted.
Mowing after annual grasses have cured enhances growing conditions for perennial grasses, provided mowing does not occur during seed production. Mowing at the appropriate time to a height of approximately 4 inches minimizes weed and brush encroachment and reduces the amount of manual work needed to maintain the site.
Mowing is most effective on grasslands or grass-shrub lands, on gentle slopes, areas without tree canopy cover, and free of obstacles the mower would have to avoid.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 30
JULY 2026
3.3.2.2 Masticating
Masticating equipment installed on Bobcats, wheeled or crawler-type tractors, excavators, or other specialized vehicles is used to cut or shred shrubs and trees into small pieces that are then scattered across the ground, where they act as mulch. Shrubs and sapling-size trees are typically masticated with Bobcats and crawler-type tractors, while excavators are often used when larger trees are removed. Bobcats typically operate on slopes with gradients less than 20%, while excavators and tractors can operate on slopes with gradients up to 45%. Cutting tools attached to a boom arm can cut vegetation on steeper slopes where the equipment has a road to operate from.
Mechanical cutting or crushing works well on woody vegetation, including shrubs, trees, and logs. This includes forest or shrub-covered areas, provided the slopes are not rocky or excessively steep.
3.3.2.3 Chipping
Chipping is used following other treatment techniques to process larger cut material. Chippers used in vegetation management are typically towed behind another vehicle or parked at a convenient location at a treatment site, and cut material is brought to the chipper. Chipped material can be deposited into a truck and hauled off-site for disposal to eliminate the chips as a potential fuel source. Where access or other constraints limit removal, chipped material can be broadcast evenly across the treatment area to prevent deep accumulations that could support smoldering.
Chipping is a particularly effective means for processing cut woody vegetation on site. It works best where there is adequate road access to the treatment areas to minimize the distance cut material needs to be transported.
3.3.2.4 Best Management Practices for Mechanical Techniques The following BMPs shall be implemented, where feasible, when utilizing mechanical vegetation management techniques. In all circumstances, equipment shall be utilized only for its intended use.
1. Utilize low ground-pressure equipment, to the extent feasible.
2. Ensure equipment operators and project personnel are properly trained in equipment use.
3. Ensure that vehicles and equipment arrive at the treatment area clean and weed-free.
4. Control fugitive dust resulting from equipment use by watering disturbed areas.
5. Protect retained trees and vegetation from potential damage resulting from heavy equipment use.
6. To minimize soil disturbance, leave stumps from removed trees and shrubs intact, with stump heights not exceeding 6 inches, as measured from the uphill side.
7. Limit the size and quantity of equipment to that which is necessary to meet the identified vegetation management standard.
8. Wherever possible, limit heavy equipment staging and placement to existing roads and access routes.
9. Regrade or recontour any areas subject to soil disturbance from heavy equipment, including dragging or skidding of trees or other material.
10. Where work is unavoidable in saturated soils or along creek banks, hand place temporary high-density flexible rubber mats to distribute equipment load and protect soils.
11. Use temporary rubber mats or plates to cross over jurisdictional creek areas.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 31
JULY 2026
12. Use temporary rubber mats or pads when driving across vegetated areas to distribute vehicle weight and minimize vegetation removal and soil disturbance.
13. Equipment used for mechanical treatment shall not operate on hillsides with slopes greater than 50% (27°).
14. Service and fuel heavy equipment only in areas that will not allow grease, oil, fuel, or other hazardous materials to pass into streams or retained vegetation.
15. Remove from the site and properly dispose of all refuse, litter, trash, and non-vegetative debris resulting from vegetation treatment operations, and other activity in connection with vegetation treatment operations.
16. Ensure that hazardous materials spill kits are available on all heavy equipment.
17. To the fullest extent possible and with due consideration given to topography, lean of trees, utility lines, local obstructions, and safety factors, trees shall be felled away from structures, landscape improvements (fences, signage), streams, sensitive biological resources areas, and retained trees. Cabling, sectional removal, or other felling techniques shall also be employed, where feasible, to minimize impacts to streams, sensitive biological resource areas, and retained trees.
18. Remove and fell trees according to ISA and American National Standards Institute A300 standards.
3.3.3 Chemical
Chemical techniques involve the use of herbicides to kill vegetation or prevent growth and are typically used in combination with other types of fuel reduction treatments. Herbicides do not remove any vegetation from a treatment area; therefore, dead plant material remains unless otherwise treated. Application of herbicides and other chemicals is typically performed by hand, and can include sponging, spraying, or dusting chemicals onto undesirable vegetation. Hand application provides flexibility in application and is ideally suited for small treatment areas.
Herbicide application requires specific storage, training, and licensing to ensure proper and safe use, handling, and storage. Only personnel with the appropriate license are allowed to use chemicals to treat vegetation. Herbicide application is also only applied per a prescription prepared by a licensed pest control adviser (PCA). Personal protection equipment is essential to limit personnel exposure to chemicals, and includes long pants and longsleeved shirts, gloves, safety goggles, hard hats, sturdy boots, face masks, and, in some instances, respirators.
3.3.3.1 Herbicides
The application of herbicides may be used on its own or as a secondary vegetation treatment technique following manual (hand labor) or mechanical removal for controlling sprout growth and regeneration. Use of herbicides would not occur within 25 feet of a water body. Only Environmental Protection Agency (EPA) approved herbicides would be used, consistent with labeling instructions and applicable Federal and State regulations. The advantage of herbicide treatments is that they typically result in high kill rates and can prevent treated plants from setting seed.
Thus, in the long run, targeted plants are eliminated as their “seed bank” is eventually eliminated. Some disadvantages include the necessity of applicators to be trained and then licensed by the State of California, the cost of application and safety equipment, the cost of the herbicide itself, the potential to affect non-target vegetation and/or wildlife, and public concern regarding potential health impacts from herbicide use. Despite these disadvantages, herbicides, or herbicides in combination with hand/mechanical removal, are the most widely used and effective techniques for controlling certain types of vegetation.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 32
JULY 2026
Herbicides are broadly classified into two basic types: pre-emergent and post-emergent. Pre-emergent herbicides are sprayed directly onto the ground and prevent plants from germinating and/or growing. As such, they have a larger potential to impact seeds of desired species remaining in the soil and often have longer persistence times in the environment. Post-emergent herbicides are applied directly onto the plants, often during the early phases of their growth, killing them before they have the chance to mature and set seed. With proper equipment and training, herbicides can be applied selectively, minimizing impacts to seeds of desired species residing in the soil. However, should the target vegetation be intermixed with growing desired vegetation, the chance of affecting desired vegetation would be increased.
Different plants vary in their response to any particular herbicide and can also vary in their response depending upon in which stage of their life cycle the herbicide is applied. Herbicides applied during the “bolting” phase (when flowing stalks are being produced) may have greater kill rates than the same chemical applied during the rosette stage or the flowering stage. Some herbicides are specific to particular groups of plants (e.g., Fusillade affects only grasses), while others can kill nearly all kinds of plants. Still others are both EPA-approved and permitted for use in California, while others are not. Systemic herbicides (as opposed to contact herbicides) are likely the most effective for control of highly flammable/rapidly spreading species due to their ability to spread via translocation into root tissue.
Herbicide application shall be used following removal of all tree and other perennial species that have the ability to regenerate from root fragments when removal of all plant material is not feasible. Herbicide use shall be limited to localized applications rather than foliar applications to eliminate the possibility of drift and impacts to neighboring desirable vegetation. A wide range of herbicides are available for such types of treatment; however, only EPAapproved herbicides would be used. Herbicide labels and material safety data sheets list susceptible target plant species and provide proper direction in the use and handling of the products. Herbicides shall be applied in accordance with state and federal law. To prevent runoff and off-site transport, herbicide applications would be avoided during precipitation events or when rainfall is forecast, and application would not occur during high wind conditions that could result in drift beyond the target area. Erosion and Sediment control measures would be maintained where applicable to prevent treated soils or plant material from entering adjacent drainages
3.3.3.2 Cut and Daub
Cut and daub treatment is recommended for larger highly flammable/rapidly spreading plants, such as large trees and shrubs, to control regrowth and kill the portion of the plant remaining belowground. This method is applicable to stump-sprouting species only. Non-stump-sprouting species would not require herbicide treatment. Non-stumpsprouting species in the project area include palms, pines, castor bean, thistle, smilo grass, bottlebrush, carob, golden raintree, and yellowwood. Cut and daub involves the cutting of plant stalks or trunks and then the direct application of an appropriate systemic herbicide directly to the cambium layer of the freshly cut stump or stem.
Other related methods include drill and fill, where holes are drilled into the trunk of a tree and herbicide is injected, or the glove method, where an herbicide-soaked glove is used to apply directly to plant foliage or freshly cut stumps.
It is critical that the herbicide treatment occurs immediately after the plants are severed so that the herbicide is carried into the plant tissue. If enough time elapses to allow the cut surface of the severed plant to dry out, a fresh cut shall be made prior to herbicide application.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 33
JULY 2026
3.3.3.3 Best Management Practices for Chemical Techniques The following BMPs shall be implemented, where feasible, when utilizing chemical vegetation management techniques. In all circumstances, equipment shall be utilized only for its intended use.
1. Herbicide use shall be considered only when other treatment techniques are determined to be infeasible or ineffective in achieving desired management and maintenance standards.
2. SFD shall consult with a state-licensed pest control adviser (PCA) and/or the San Diego County agricultural commissioner to identify the appropriate site-specific herbicide application approach to meet vegetation management standards.
3. The timing of herbicide applications shall be considered to minimize impacts to adjacent retained vegetation and nearby resources (typically between June 15 and November 15, with a potential extension through December 31 or until local rainfall greater than 0.5 inches is forecasted within a 24-hour period from planned application). Herbicide application shall not occur during winds that exceed 7 miles per hour.
4. Only herbicides that have been approved for aquatic use by EPA and are registered for use by the California Department of Pesticide Regulation would be used for aquatic vegetation control work.
5. Herbicide application shall be consistent with Federal Insecticide, Fungicide, and Rodenticide Act label instructions and use conditions issued by EPA, California Department of Pesticide Regulation, and the San Diego County agricultural commissioner.
6. The lowest recommended rate to achieve vegetation management objectives of both herbicides shall be utilized to achieve desired control.
7. An appropriate indicator dye shall be added to the tank mix to help the applicator identify areas that have been treated and better monitor the overall application.
8. No application to plants whose base is submerged in stream channels shall occur.
9. Safe procedures for transporting, mixing, and loading herbicides shall be followed.
10. The use of foliar (spray) applications shall be minimized, prioritizing localized or direct applications.
11. Herbicides shall not be applied within 25 feet of a perennial stream or water body.
3.4 Treatment Recommendations
As outlined in Section 3.2, any removal or trimming of native vegetation in Zones 1 or 2 will only occur following acquisition of the required permits. Until such permits are secured, vegetation management in these zones will focus solely on non-native species and dead or dying vegetation. Once permitting is complete, native vegetation treatments in Zones 1 and 2 may proceed as needed to meet fire protection objectives.
Vegetation management activities occurring in Zone 3 would only involve removal of dead, dying, or non-native species. A biological monitor shall be present in accordance with MM BIO-3: Biological Monitor, to ensure vegetation management activities occur only for dead, dying, and invasive species. The project would implement MM BIO-9:
Tree Survey, to provide comprehensive mapping, by a Certified Arborist, of the dead, dying, and invasive species that would be removed under the proposed project.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 34
JULY 2026
3.4.1 Treatment Recommendations by Zone
3.4.1.1 Treatment Zone Summary
Field assessments conducted in support of this plan involved mapping the locations of treatment areas. Data collected concurrently with the mapping effort included treatment zone identification, plant type (grass, shrub, tree), species, treatment recommendations, and estimated biomass requiring removal. The collected data was processed in a GIS and further broken out on a parcel basis. A summary of vegetation to be treated under this plan is presented in Error! Reference source not found.. Maps presenting the location of recommended treatment zones and vegetation to be managed under this FTP are included in Appendix A along with detailed data tables by parcel.
Table 2. Vegetation Treatment Summary by Zone
Zone Total Acres
Estimated
Treatment
Acres*
Estimated Number of Trees
to be Removed (quantity)
Estimated Biomass to be
Removed (cubic yards)
1 9.2 9.7 46 22,454.7
2 22.5 26.4 275 42,786.8
3 268.2 130.8 1,509 2,812,856.5
Total 299.9 166.9 1,830 2,878,098.0
Note:
* Estimated Treatment Acres may exceed Total Acres due to overlapping polygons generated during field mapping efforts.
3.4.1.2 Zone 1 Treatment Recommendations
Zone 1 consists of the area within 50 feet of structures adjacent to but outside the project area. These areas consist of mixed vegetation, typically including grass, ornamental trees, native shrubs, and other landscape vegetation.
Treatments in this zone are of the highest intensity and are designed specifically for structure protection.
Pre-Treatment Work Activities
▪ Flag or mark the outer edge of the treatment area (50 feet from structures, distance from property lines or fences will be variable).
▪ Flag or mark work avoidance areas.
▪ Flag or mark hazard trees.
▪ For mechanical treatment, walk treatment areas with contractors and identify access, parking, and staging areas. Identify water sources.
Grassland/Herbaceous Vegetation
▪ Cut/mow grass and herbaceous plants to 4 inches in height or less. ▪ Cut grass may be left on the ground surface to protect soil as long as it does not exceed 6 inches in height. ▪ All dead or dying ground cover, vines, or other surface vegetation shall be removed or chipped and spread on site.
▪ All dead twigs, branches, or limbs from overstory shrubs and/or trees shall be removed or treated (e.g., chipped) and spread as a ground cover (mulch) on site.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 35
JULY 2026
▪ All mulch or chipped material shall be spread to a depth not to exceed 6 inches. ▪ Stockpiling of vegetative material and equipment will be limited to designated upland areas outside of aquatic resources to the maximum extent practicable. Any temporarily staged materials will be placed to avoid contact with waters and minimize the potential for sediment discharge, and all stockpiled materials and equipment will be removed from the site at the end of each workday.
Shrub Vegetation
▪ All dead shrubs shall be removed.
▪ All dead and dying growth shall be removed from shrubs. ▪ Prioritize removal of non-native and invasive plant species to achieve identified spacing standards. Any removal or trimming of native vegetation shall occur only following acquisition of required permits. ▪ Individual shrub crowns shall be horizontally separated from adjacent shrubs, shrub groupings, or trees by at least four times the height of the shrub crown. Groupings of shrubs may be retained such that the grouping does not exceed 8 feet in diameter. Shrub groupings shall be horizontally separated from adjacent shrubs, shrub groupings, or trees by at least four times the height of the shrub crown. ▪ Where shrubs are located within the dripline of an individual, isolated tree or small tree grouping, the vertical separation between the top of the shrub and the lowest tree branch shall be at least three times the height of the shrub crown or 8 feet, whichever is greater. ▪ To minimize soil erosion potential, removed shrubs shall be cut at or near the ground surface and root systems left intact.
▪ All vegetative material from shrub removal or trimming shall be removed or treated (e.g., chipped) and spread on site.
▪ All chipped material shall be spread to a depth no greater than 6 inches. ▪ Stockpiling of vegetative material and equipment will be limited to designated upland areas outside of aquatic resources to the maximum extent practicable. Any temporarily staged materials will be placed to avoid contact with waters and minimize the potential for sediment discharge, and all stockpiled materials and equipment will be removed from the site at the end of each workday.
Tree Vegetation
▪ All dead trees shall be removed.
▪ All dead/dying growth and litter shall be removed from trees. ▪ Prioritize removal of non-native and invasive plant species to achieve identified spacing standards. Any removal or trimming of native vegetation shall occur only following acquisition of required permits. ▪ Thin tree groupings or remove trees to ensure that retained tree canopies reach an average 30-foot horizontal spacing between retained tree canopies. Prioritize retention of healthy trees. ▪ Where small trees, shrubs or other vegetation is located within the dripline of a tree, the vertical separation between the top of the retained shrubs and the lowest tree branch shall be at least three times the height of the retained shrub crown or 8 feet, whichever is greater. ▪ To minimize soil erosion potential, stumps from removed trees shall be left intact, with stump heights not exceeding 6 inches (as measured from the uphill side).
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 36
JULY 2026
▪ All vegetative material from shrub removal or trimming shall be removed or treated (e.g., chipped) and spread on site.
▪ All chipped material shall be spread to a depth no greater than 6 inches. ▪ Stockpiling of vegetative material and equipment will be limited to designated upland areas outside of aquatic resources to the maximum extent practicable. Any temporarily staged materials will be placed to avoid contact with waters and minimize the potential for sediment discharge, and all stockpiled materials and equipment will be removed from the site at the end of each workday.
Other Combustible Material
▪ Other combustible material, including, but not limited to, debris, trash, or yard waste that is placed, left, or deposited in this zone shall be removed or chipped and spread according to the standards outlined above.
3.4.1.3 Zone 2 Treatment Recommendations
Zone 2 consists of the area between 50 and 100 feet from structures located adjacent to but outside the project area. These areas consist of mixed vegetation, typically including grass, ornamental trees, native shrubs, native trees, and other landscape vegetation. Treatments in this zone are designed to moderate fire behavior approaching developed areas through thinning, trimming, and removal of dead or invasive vegetation.
Pre-Treatment Work Activities
▪ Flag or mark the outer edge of the treatment area (100 feet from structures, distance from property lines or fences will be variable).
▪ Flag or mark work avoidance areas.
▪ Flag or mark hazard trees.
▪ For mechanical treatment, walk treatment areas with contractors and identify access, parking, and staging areas. Identify water sources.
Grassland/Herbaceous Vegetation
▪ Cut/mow grass and herbaceous plants to 4 inches in height or less. ▪ Cut grass may be left on the ground surface to protect soil as long as it does not exceed 10 inches in height. ▪ All dead or dying ground cover, vines, or other surface vegetation shall be removed or chipped and spread on site.
▪ All dead twigs, branches, or limbs from overstory shrubs and/or trees shall be removed or treated (e.g., chipped) and spread as a ground cover (mulch) on site.
▪ All mulch or chipped material shall be spread to a depth not to exceed 6 inches. ▪ Stockpiling of vegetative material and equipment will be limited to designated upland areas outside of aquatic resources to the maximum extent practicable. Any temporarily staged materials will be placed to avoid contact with waters and minimize the potential for sediment discharge, and all stockpiled materials and equipment will be removed from the site at the end of each workday.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 37
JULY 2026
Shrub Vegetation
▪ All dead shrubs shall be removed.
▪ All dead and dying growth shall be removed from shrubs. ▪ Prioritize removal of non-native and invasive plant species to achieve identified spacing standards. Any trimming of native vegetation shall occur only following acquisition of required permits. ▪ Individual shrub crowns shall be horizontally separated from adjacent shrubs, shrub groupings, or trees by at least two times the height of the shrub crown. Groupings of shrubs may be retained such that the grouping does not exceed 8 feet in diameter. Shrub groupings shall be horizontally separated from adjacent shrubs, shrub groupings, or trees by at least two times the height of the shrub crown. ▪ Where shrubs are located within the dripline of an individual, isolated tree or small tree grouping, the vertical separation between the top of the shrub and the lowest tree branch shall be at least three times the height of the shrub crown or 8 feet, whichever is greater. ▪ To minimize soil erosion potential, removed shrubs shall be cut at or near the ground surface and root systems left intact.
▪ All vegetative material from shrub removal or trimming shall be removed or treated (e.g., chipped) and spread on site.
▪ All chipped material shall be spread to a depth no greater than 6 inches. ▪ Stockpiling of vegetative material and equipment will be limited to designated upland areas outside of aquatic resources to the maximum extent practicable. Any temporarily staged materials will be placed to avoid contact with waters and minimize the potential for sediment discharge, and all stockpiled materials and equipment will be removed from the site at the end of each workday.
Tree Vegetation
▪ All dead trees shall be removed.
▪ All dead/dying growth and litter shall be removed from trees. ▪ Prioritize removal of non-native and invasive plant species to achieve identified spacing standards. Any removal or trimming of native vegetation shall occur only following acquisition of required permits. ▪ Thin tree groupings or remove trees to ensure that retained tree canopies reach an average 10-foot horizontal spacing between retained tree canopies. Prioritize retention of healthy trees. ▪ Where small trees, shrubs or other vegetation is located within the dripline of a tree, the vertical separation between the top of the retained shrubs and the lowest tree branch shall be at least three times the height of the retained shrub crown or 8 feet, whichever is greater. ▪ To minimize soil erosion potential, stumps from removed trees shall be left intact, with stump heights not exceeding 6 inches (as measured from the uphill side).
▪ All vegetative material from shrub removal or trimming shall be removed or treated (e.g., chipped) and spread on site.
▪ All chipped material shall be spread to a depth no greater than 6 inches. ▪ Stockpiling of vegetative material and equipment will be limited to designated upland areas outside of aquatic resources to the maximum extent practicable. Any temporarily staged materials will be placed to avoid contact with waters and minimize the potential for sediment discharge, and all stockpiled materials and equipment will be removed from the site at the end of each workday.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 38
JULY 2026
Other Combustible Material
▪ Other combustible material, including, but not limited to, debris, trash, or yard waste that is placed, left, or deposited in this zone shall be removed or chipped and spread according to the standards outlined above.
3.4.1.4 Zone 3 Treatment Recommendations
Zone 3 consists of a broad, habitat-sensitive fuels-management zone where lighter-intensity treatments reduce hazardous vegetation while preserving and enhancing riparian function, canopy cover, and ecological integrity. In this zone, vegetation management activities are focused on treatment and removal of dead vegetation, non-native plant species, and combustible debris (including dead and dying non-native and native vegetation). Areas not including such material are not proposed for treatment under this plan. Access across native vegetation in this zone may be necessary to facilitate treatment activities. The resource protection standards included in Section 4 are intended to avoid or minimize impacts to native vegetation in Zone 3.
As identified during field assessments, the plant species presented in Error! Reference source not found. are located in Zone 3 and are proposed for treatment under this plan. All native tree or non-tree species listed in the table would only be removed if the individual was dead or dying.
Table 3. Plant Species Identified for Treatment or Removal in Zone 3 Non-Tree Species Tree Species Tree Species Continued
Arrowweed
Arundo donax
Bamboo
Blackberry
Bougainvillea
California sagebrush
Cape honeysuckle
Castor bean
Desert broom
Pampas grass
Prickly Russian thistle
Smilo grass
Tobacco tree
Toyon
Yucca
Aleppo pine
American sweetgum
Arizona cypress
Arroyo willow
Shamel ash
Bottlebrush (spp.)
Brazilian pepper
California fan palm
Canary island date palm
Canary island pine
Carob
Carrotwood
Chinese elm
Chinese flame tree
Coast live oak
Date palm (spp.)
Eucalyptus (spp.)
Fan palm (spp.)
Fig (spp.)
Glossy privet
Golden raintree
Italian stone pine
Laurel sumac
Mexican fan palm
Monterey pine
Olive (spp.)
Paloverde (spp.)
Pepper tree (spp.)
Pine (spp.)
Red willow
Siberian elm
Silk oak
Tree of Heaven
Weeping Bottlebrush
Yellowwood (spp.)
Willow (spp.)
Note: All native tree or non-tree species listed in the table would only be removed if the individual was dead or dying.
Pre-Treatment Work Activities
▪ Flag or mark the edge of the treatment area.
▪ Flag or mark work avoidance areas.
▪ Flag or mark hazard trees adjacent to work areas.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 39
JULY 2026
▪ For mechanical treatment, walk treatment areas with contractors and identify access, parking, and staging areas. Identify water sources.
Vegetation Treatment Activities
▪ To minimize soil erosion potential, removed non-tree vegetation shall be cut at or near the ground surface and root systems left intact. For removed trees, stumps shall be left intact, with stump heights not exceeding 6 inches (as measured from the uphill side).
▪ All vegetative material from vegetation treatments shall be removed or treated (e.g., chipped) and spread on site.
▪ All chipped material shall be spread to a depth no greater than 6 inches. ▪ Stockpiling of vegetative material and equipment will be limited to designated upland areas outside of aquatic resources to the maximum extent practicable. Any temporarily staged materials will be placed to avoid contact with waters and minimize the potential for sediment discharge, and all stockpiled materials and equipment will be removed from the site at the end of each workday.
Other Combustible Material
▪ Other combustible material, including, but not limited to, debris, trash, or yard waste that is placed, left, or deposited in this zone shall be removed or chipped and spread according to the standards outlined above.
3.4.2 Special Considerations
3.4.2.1 Parks and Preserves
Mast Park
Mast Park includes both the developed park space and the adjacent river corridor extending west toward the Carlton Oaks Golf Course. The developed park space would not be treated as part of the fuel treatment plan and is not included in the project area. The segment of the San Diego River Trail accessible from Mast Park is one of the most active, with high year-round use from walkers, cyclists, equestrians, and dog walkers. As such, visibility, trail clearance, and user safety are important considerations when planning vegetation treatments. The need for risk reduction must be balanced with the need to maintain the high-quality recreational experience park users expect along the trail, including access to shade and viewsheds that highlight the park’s natural character.
The river corridor area of the park falling within the project area contains a broad riparian system dominated by willows, cottonwoods, mulefat, sycamores, and patches of emergent wetland vegetation. Although restoration work has improved portions of the corridor, non-native shrubs, vines, and annuals persist and can create localized fuel continuity. Periodic flood deposition also results in dense vegetation mats and accumulated woody material that may require targeted management. Portions of the corridor contain persistent wet or saturated soils, especially following rain events or seasonal high flows, and these conditions can limit access for vegetation management crews. Wet soils may preclude the use of heavy equipment and restrict treatment methods to hand labor. This issue can be mitigated by timing operations during the dry season or using temporary access mats designed to distribute equipment load.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 40
JULY 2026
Active restoration areas, newly planted vegetation, and all wetland features within Mast Park shall be avoided during treatment activities. These sites contain sensitive biological resources, are naturally low risk from a fire behavior standpoint, and have been the focus of ongoing investment by the City and its partners. Mast Park also supports sensitive riparian-dependent bird species, including the endangered least Bell’s vireo and the California gnatcatcher. Some portions in and near the project area overlap with federal critical habitat for these species. All vegetation work in these areas will follow the specific mitigation measures outlined in the Biological Resources Report (Dudek 2025a), which are designed to avoid disturbance during critical breeding periods and substantial alterations to suitable habitat.
Walker Preserve
The Walker Preserve is located upstream of Mast Park along the San Diego River corridor between Magnolia Avenue and the eastern city limits of Santee. It occupies a 107-acre stretch historically used for agriculture and sand mining and now functions as a restored multi-use open space. The Walker Preserve Trail is a 1.3-mile, 14-foot-wide gravel pathway that runs east to west along the Preserve’s northern perimeter. Like Mast Park, it includes extensive riparian and wetland vegetation along the river, transitioning to coastal sage scrub on the north-facing slopes.
Species composition, habitat value, and invasive species pressures are similar to those described for Mast Park, and treatment considerations follow the same general framework. Saturated soils in some areas are also a concern in this portion of the project area and may limit access or the use of certain treatment techniques during portions of the year.
Because this segment supports the same suite of federally protected bird species present in Mast Park, treatments shall be coordinated across the two areas to maintain consistency in timing, methods, and habitat protection measures.
3.4.2.2 Unhoused Populations
Unhoused populations may be present within areas targeted for hazardous fuels treatment, creating unique safety and communication challenges. These individuals often seek shelter in vegetated zones, which can overlap with identified treatment areas.
To protect both workers and vulnerable populations, jurisdictions shall provide advance notice of planned activities through multiple channels, such as in-person outreach, posted signage, and collaboration with service providers.
Clear messaging shall explain the timing, purpose, and safety risks of vegetation treatment. On the day of operations, the City shall confirm that sites are clear before work begins. If individuals are present, outreach personnel shall assist with clearing active work areas by contacting law enforcement and public safety officers for removals to safe areas. The City’s Public Services Division handles the posting and clearing of encampments but would also utilize assistance from the San Diego County Sheriff’s Office to help abate encampments under certain circumstances.
3.4.2.3 Private Land Access and Public Notification
Access to public and private lands will be a critical consideration when planning vegetation management activities in the project area. The City shall secure proper rights of entry (ROEs) before any work begins for access to properties where work is being performed. This process shall include clear communication about the scope of work,
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 41
JULY 2026
anticipated timelines, and any potential impacts to property or recreational use. Establishing these agreements early helps prevent delays and ensures legal compliance.
For publicly accessible recreation areas such as parks and trails, the City shall proactively alert the public to upcoming management activities to maintain safety and transparency. This can be achieved through posted signage at trailheads, park entrances, and online platforms, as well as notifications through local media and social channels. Messaging shall include the purpose of the project, expected dates, and any temporary closures or restrictions.
3.4.3 Access
Based on field assessments, potential access routes for vegetation management activities were identified. These routes are those that may accommodate vehicles and were broken into two categories:
▪ Class 1: Capable of supporting full-size vehicles and associated equipment (e.g., chippers) and equipment trailers
▪ Class 2: Capable of supporting smaller vehicles (e.g., Bobcats, side-by-sides) These routes shall be confirmed by the vegetation management contractor prior to use. Obtaining ROEs will be necessary in some locations (i.e., non-City owned land). A map of these routes is presented in Figure 4, Access Routes. In addition to these routes, it is anticipated that overland travel by foot will be conducted by field crews along disturbed areas to access vegetation management work locations.
Project implementation would prioritize existing roads and trails, minimizing the need for new disturbance. To the extent feasible, staging areas would be located away from residential areas and popular trailheads to reduce noise, dust, and congestion. When mechanical equipment is required, operators shall use designated entry points and avoid sensitive resources areas or high-use recreation corridors.
Access via public roadways may also be necessary. In such cases, the selected contractor will be responsible for traffic control to maintain safe working conditions.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 42
JULY 2026
INTENTIONALLY LEFT BLANK
Fanita
D
r
Mission Gorge Rd
N
Magnolia Ave
Prospect Ave
Carlton
Hills
Blvd
N Cuy
a
m
aca St
Mast Blvd
Woodside Ave
Cuyamaca St
Ä125
Ä67
Project Boundary
Ä52
Project Components
Zone 1
Zone 2
Zone 3
Areas of Concentrated Non-Native
Dead and Dying Vegetation Removal
Class 1 Access Route
Class 2 Access Route
Date: 4/2/2026 User: cgardner Path: Z:\Projects\j1861101\MAPDOC\Fire\Santee Fuels Treatment Plan.aprx Map: Figure 4 Access Routes Layout: Figure 4 Access Routes 0 500 1,000
n
Feet
SOURCE: Vantor 2025; Open Street Map 2025
San Diego River Fire Hazard Mitigation Program: Fuels Treatment Plan Access Routes
FIGURE 4
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 44
JULY 2026
INTENTIONALLY LEFT BLANK
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 45
JULY 2026
3.5 Biomass Disposal Recommendations
3.5.1 Recommended Vegetation Disposal Methods
Because most of the project area is relatively accessible, several disposal options are feasible; however, some methods provide substantially greater long-term hazard reduction than others. The following recommended practices are listed in order of preference. Mechanical treatments, such as mastication or mowing, may generate biomass that is inherently disposed of as part of the treatment itself (i.e., biomass is chipped or thatched). Chemical treatments generally produce little to no biomass at the time of application, but any subsequent cutting of dead material resulting from herbicide treatments shall follow the disposal methods described below.
3.5.2 Off-Site Transport to a Green Waste Facility
Off-site disposal is the preferred approach for most areas because it provides the greatest reduction in long-term fuel loading. By ensuring that logs, slash, or other cut material do not remain on site, off-site removal also maintains the treated area’s effectiveness over time by limiting the accumulation of surface fuels and avoids creating concentrated piles of drying material that could temporarily increase hazard. In most parts of the project area, the logistics of loading, hauling, and disposal are relatively straightforward, making transport to a green waste facility the most reliable option available in terms of hazard reduction.
This method is particularly well suited to the relatively small-diameter woody shrubs, cut limbs, and general brush material typical of the project area. It is also appropriate for any biomass generated after chemical treatments have caused vegetation death, particularly where remaining material presents a hazard and must be removed during follow-up work. With reliable access for trucks and trailers, crews can stage cut material in designated clearings and transport it to an approved green waste facility. Material can also be chipped directly into a trailer or truck bed, which typically allows for greater tonnage per haul compared to raw cut material.
3.5.3 On-Site Broadcast of Chips
Broadcasting chips on site is an effective alternative where off-site hauling is inefficient or unnecessary. This method is appropriate only for woody material, as chippers cannot accommodate fibrous vegetation such as Arundo. When used appropriately, chipping rearranges fuels into a compact layer of small fragments that lie close to the ground, hastening decomposition. Chips shall be broadcast evenly across the treatment area to prevent deep accumulations that could support smoldering. Although the biomass remains on site, its hazard level is dramatically reduced because branches and ladder fuels are converted into a form that does not readily carry fire either horizontally or vertically. Spreading will not occur within jurisdictional streambeds to avoid impacts and the need for permitting.
3.5.4 Lop-and-Scatter
Lop-and-scatter may be employed in small portions of the project area where neither hauling nor chipping is feasible due to restricted access, limited maneuvering room, or steep, uneven ground. Under this method, crews cut material into shorter lengths and scatter it evenly, so it lies as close to the ground as possible (i.e., within 12 to 18 inches). While lop-and-scatter does reduce fuel continuity, it leaves the material on site and therefore provides only modest benefits in terms of long-term surface fuel reduction. Because scattered material dries and persists, this
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 46
JULY 2026
technique is considered the least effective disposal option and shall be used sparingly and only where other methods cannot be safely or practically implemented. In these limited cases, careful distribution of the material is important to avoid creating localized concentrations of slash or unintentional fuel pathways.
Some trees, such as large, isolated palms, may need to be left on the ground after cutting due to site access constraints or prohibitive costs associated with their removal from the site. Larger diameter debris, such as tree trunks, retain fuel moisture for much longer periods than finer fuels and thus do not readily ignite. Limited quantities of tree trunk sections are not expected to contribute significantly to fire hazard within the river corridor. Material will not occur within jurisdictional streambeds to avoid impacts and the need for permitting.
3.5.5 Cranes and Helicopters
In isolated or inaccessible areas where large trees cannot be safely removed using standard ground-based methods, helicopter or crane-assisted removal may be used. These techniques allow large trees to be lifted out without disturbing sensitive terrain or adjacent properties but require advance planning for safe lift paths, staging zones, and coordination with permitting agencies. Due to their cost and operational complexity, helicopter and crane removal would be considered only when no practical ground-based alternative exists and the tree cannot be safely left in place.
3.5.6 Species-Specific Disposal Considerations
Some vegetation types within the project area require specialized handling. Arundo is of particular concern because it cannot be safely chipped and readily spreads through stem or rhizome (root) fragments. Arundo forms dense, bamboo-like stands with thick rhizomes capable of producing new plants from even small fragments, and these fragments are easily transported by water or human activity. The species is highly flammable throughout much of the year and increases fire susceptibility, displaces native vegetation, and contributes to flooding and sedimentation in riparian corridors (DiTomaso et al. 2013). For these reasons, all cut Arundo material must be contained immediately by bundling or bagging and transported off-site to an appropriate waste facility. Herbicidebased treatments do not eliminate the need for careful disposal, as dead stems and rhizome fragments remain capable of vegetative spread (DiTomaso et al. 2013).
Other invasive or weed species may also require off-site disposal when seed heads or vegetative propagules are present. Any species that produces viable seed during the treatment window or that spreads through stem fragmentation shall be removed from the project area rather than chipped or scattered.
3.5.7 Selecting the Appropriate Disposal Method
Selecting an appropriate disposal approach depends on access, vegetation type, and the volume of material generated. Off-site removal shall be prioritized where feasible due to its long-term hazard reduction benefits.
Chipping may be used where equipment access is available, and vegetation consists of suitable woody material.
Lop-and-scatter shall be limited to small, constrained areas.
All disposal activities must comply with the requirements of any applicable CDFW, U.S. Army Corps of Engineers, and other necessary permits. These authorizations include specific conditions related to vegetation removal and protection of riparian and aquatic resources. Disposal near channels must avoid unauthorized deposition of
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 47
JULY 2026
material, prevent the introduction of invasive propagules to waterways, and maintain consistency with all permit conditions.
3.6 Maintenance
The purpose of ongoing maintenance is to ensure that initial vegetation treatments continue to reduce wildfire hazard over time. Maintenance activities are intended to (1) prevent the re-accumulation of hazardous fuels, (2) sustain desired vegetation structure and species composition, (3) protect initial treatment investments, and (4) improve firefighter access and suppression effectiveness during wildfire events.
Maintenance Frequency and Inspections
Maintenance intervals will vary depending on vegetation type, treatment zone, and treatment technique. The plan area will be inspected biannually to determine maintenance needs. It is expected that maintenance within Zones 1 and 2 will occur at least once annually. Maintenance within Zone 3 will be determined during biannual inspections and will be based on:
▪ Establishment (or re-establishment) or non-native plant species ▪ Vegetation mortality (dead plant material presence)
▪ Accumulation or deposition of combustible debris (including dead and dying non-native and native vegetation)
The frequency of maintenance activities in Zone 3 will be dependent on observations made during biannual inspections. It is expected that one-quarter of the total project area will be maintained annually to preserve reduced hazardous fuel conditions.
Maintenance Techniques and Material Disposal
Maintenance of the plan area will utilize the techniques outlined in Section 4.3 (hand labor, mechanical, and chemical). Biomass disposal associated with maintenance activities will follow the recommendations outlined in Section 4.5. Access for maintenance will be achieved as outlined in Section 4.4.3.
Treatment Recommendations
Maintenance activities are intended to retain conditions established by the initial treatment. The treatment recommendations for each Zone defined in Section 4.4.1 will be followed during maintenance activities.
Resource Protection
The BMPs identified for each vegetation management technique (Sections 4.3.1.4, 4.3.2.4, and 4.3.3.3) will be implemented during maintenance activities. Additionally, the resource protection practices outlined in Section 5 will be implemented during maintenance activities.
Responsibilities
The City will be responsible for conducting biannual inspections, determining maintenance needs for each zone, coordinating or engaging maintenance crews, and ensuring compliance with this plan and associated resource protection measures.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 48
JULY 2026
INTENTIONALLY LEFT BLANK
18611.01 49
JULY 2026
4 Resource Protection
In addition to the BMPs identified for the vegetation management techniques identified in this FTP, this section outlines additional practices intended to avoid or minimize potential impacts associated with vegetation treatment or removal.
4.1 Biological Resources
The vegetation management activities identified in this FTP have the potential to impact biological resources via ground disturbance, vegetation removal or treatment, and the use of vegetation management tools and equipment.
To avoid or minimize the potential for impacts to biological resources, the specific measures identified in the Biological Resources Letter Report (Dudek 2025a) shall be implemented, depending on species present in the identified treatment area. In general, these measures include conducting pre-construction biological surveys, identifying and marking avoidance or buffer areas, conducting biological monitoring during vegetation management operations, and establishing work windows to avoid and minimize adverse effects on nesting birds and specialstatus plants and animals. Any trimming of native vegetation shall occur only following acquisition of required permit. To facilitate implementation of the biological resource measures, potentially jurisdictional aquatic resources shall be avoided through implementation of BMPs, and measures outlined in the Biological Resources Letter Report (Dudek 2025a). The City shall contract with qualified biological consultants to implement the specific measures identified in the Biological Resources Letter Report (Dudek 2025a).
4.2 Cultural Resources
The vegetation management activities identified in this FTP have the potential to impact cultural resources, primarily via ground disturbance. To avoid or minimize the potential for impacts to cultural resources, the specific measures identified in the Cultural Resources Assessment Report (Dudek 2025b) shall be implemented.
4.3 Slope Stability/Erosion
Minimizing erosion risk means any features or actions taken to reduce surface erosion, gullying, channel erosion, and mass erosion within the treatment area during or after the fuel reduction work is complete. Post-treatment, there is the potential for erosion caused by the loss of vegetation cover that previously had intercepted rain and runoff or slowed down the velocity of rainfall and runoff. This is an especially crucial consideration as erosion within the project area has the potential to contribute to sedimentation of the San Diego River, resulting in turbidity and potential infill.
To minimize the risk of excessive erosion post-treatment, this treatment prescription recommends using a combination of erosion and sedimentation BMPs from the construction and forestry industries, including the California Forest Practice Rules, San Diego County Erosion and Sediment BMPs, and EPA erosion and sediment control BMPs. Management recommendations during and after fuel reduction treatment to reduce the potential for soil erosion within the treatment area or on adjacent downstream lands include the following:
1. Avoid work during and immediately following wet periods when soils are saturated.
2. Where work is unavoidable in saturated soils or along creek banks, hand place high-density flexible rubber mats to distribute equipment load and protect soils.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 50
JULY 2026
3. No vehicle or equipment is used on roads when roads are wet or muddy.
4. Equipment used for mechanical treatment shall not operate on hillsides with slopes greater than 50% (27°).
5. No removal of stumps or root balls of cut material. The root systems of cut vegetation shall be left intact as much as possible.
6. Mature, native tree canopy will be left intact.
7. Treated vegetation shall be masticated or chipped and spread back onto the treatment area where slopes do not exceed 45° (100% slope or 1:1 slope).
8. On slopes exceeding 45° (greater than 100% slope or greater than 1:1 slope), cut tree branches can be spread onto the surface to help prevent chips from sliding down the slope during precipitation.
9. Only hand labor shall be performed within 25 feet of a wetland or water body. Only hand labor or chemical spot treatment shall be performed between 25 and 100 feet of a perennial stream or water body.
10. Areas of bare soil created by fuel reduction treatments shall be covered entirely with chipped or masticated vegetation.
Not all of the above recommendations need to be applied to the entire treatment area, and some areas, such as flat expanses of Mast Park and the Walker Preserve, may not need any erosion control measures. The most effective measures will be actions taken to minimize soil disruption and prevent erosion caused by rain impacting soil previously sheltered by untreated vegetation. Therefore, at a minimum, it is recommended that treatment be avoided when and where soils are wet, that mechanical treatment is not used on steep slopes, and that the treatment work provides a ground cover (e.g., chips or masticated material) onto the treated areas. None of the treatment standards or methods recommend creating denuded areas or bare soil to achieve treatment prescription goals. The creation of small bare areas is possible during the vegetation treatment work but will not be intentionally created and will be covered with cut, chipped, or masticated material.
4.4 Water Quality
In addition to other measures identified in this plan, the following BMPs shall be implemented, to minimize potential negative effects on water quality:
1. Mechanical tools, equipment, and vehicles shall be routinely inspected to ensure that fuel, oil, and other fluids and lubricants are not leaking.
2. Tool and equipment refueling shall be conducted in identified re-fueling areas in staging or parking areas that provide secondary containment located away from watercourses.
3. Provide spill kits at refueling areas.
4. Store tools, lubricants, and fuels away from watercourses, ensuring secondary containment and clear labeling.
5. Stockpiling of vegetative material and equipment will be limited to designated upland areas outside of aquatic resources to the maximum extent practicable. Any temporarily staged materials will be placed to avoid contact with waters and minimize the potential for sediment discharge, and all stockpiled materials and equipment will be removed from the site at the end of each workday.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 51
JULY 2026
4.5 Pests and Pathogens
Several invasive pests and plant pathogens are known to threaten native riparian trees in the San Diego River corridor, including the goldspotted oak borer, shot hole borer, and Phytophthora root disease. Pest and pathogen BMPs shall be incorporated where applicable within the project area. The following BMPs shall be implemented accordingly:
1. Schedule all oak trimming or removal, where permitted, between October and March to avoid the goldspotted oak borer adult flight period and minimize wound-attraction.
2. Avoid trimming or ground disturbance during or immediately after wet periods (rainfall greater than 0.5 inches within a 24-hour period), when pest and pathogen transmission risk is highest.
3. Clean and sanitize vehicles, equipment, tools, footwear, and clothes before arriving at a project site or when leaving an area with infestations of invasive species. Sanitize all hand tools and chainsaws that come into contact with infected material, or material suspected to be infected, before leaving a work site using a 10% bleach solution or 70% isopropyl alcohol.
4. Remove all soil/mud and plant debris from boots, tracked equipment, tires, and undercarriages before entering and leaving a site, especially when working near the San Diego River or wetlands.
5. Treated woody vegetation shall be chipped or masticated and spread on site to a depth not exceeding 6 inches, unless material shows signs of active pest infestation.
6. Do not stage or transport cut wood from host species (e.g., oak, sycamore, willow) unless it is chipped, debarked, solarized, or disposed of at an approved facility.
7. Cover all infested wood in clear plastic tarps sealed at the edges for at least 6–12 months if immediate removal is not feasible.
8. Never move unprocessed wood or logs off site from the project area unless securely covered and delivered to an approved biomass, composting, or landfill facility.
9. Report any suspected pest infestations (e.g., exit holes, staining, sap flow, crown dieback) to the project manager immediately.
For additional reference, see:
▪ Goldspotted Oak Borer Resources – UCANR: https://ucanr.edu/site/goldspotted-oak-borer ▪ Shot Hole Borer Resources – UCANR: https://ucanr.edu/site/invasive-shothole-borers ▪ Phytophthora Resources – CA Oak Mortality Task Force: https://www.suddenoakdeath.org
4.6 Fire Protection
The following fire protection BMPs are provided to minimize the potential for ignition during implementation operations:
1. During operations that involve the use of any vehicle, machine, tool or equipment powered by an internal combustion engine operated on hydrocarbon fuels, provide and maintain suitable and serviceable tools for firefighting purposes. Equipment shall be located at a point accessible in the event of a fire and shall include one backpack pump-type fire extinguisher filled with water, two axes, two McLeod fire tools, and a sufficient number of shovels so that each employee at the operation can be equipped to fight fire.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 52
JULY 2026
2. Ensure that all equipment with an internal combustion engine using hydrocarbon fuels is equipped with a spark arrestor, as defined in California Public Resources Code Section 4442.
3. Establish communication procedures with staff and contractors for reporting fires or call 911 in emergencies.
4. Restrict the use or timing of use of tools or equipment with the potential to generate heat or sparks during Red Flag Warnings and High to Extreme Fire Danger days.
5. Identify staging areas prior to initiating operations. Staging areas shall be contained within already disturbed areas or non-vegetated areas (e.g., roads, parking lots) and shall account for vehicle parking and tool/equipment storage.
4.7 Air Quality
The following BMPs shall be implemented, where feasible, to minimize potential negative effects on air quality:
1. Control fugitive dust resulting from equipment use as needed by watering disturbed areas and ingress/egress locations.
2. Maintain all trucks and equipment in good working order and compliant to current emission standards, including Tier 4 Final Air Pollution Control District – San Diego County required equipment and Best Available Control Technology, where possible.
3. Avoid work during unfavorable weather conditions, including excessive wind/Santa Ana events, to reduce unnecessary contributions to dust and particle suspension.
4. Securely cover all material (e.g., mulch, trees, tree debris) transported off site.
5. Limit the size and quantity of equipment to that which is necessary to meet the identified vegetation management standard.
6. Limit traffic speeds on dirt roads to 15 miles per hour.
7. Clean construction vehicles and equipment to prevent dust, silt, mud, and dirt from being tracked onto paved roadways.
8. Limit vehicle idling time to a maximum of 2 minutes for diesel-powered equipment and 5 minutes for all other vehicles and equipment, except where idling is required for the equipment to perform its task.
9. Post a publicly visible sign with the telephone number and person to contact at the lead agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s phone number shall also be visible to ensure compliance with applicable regulations.
4.8 Recreation Resources
This plan does not recommend actions that would permanently close or prevent recreation activities, but temporary closures or use restrictions may be necessary for the safe operation of equipment and to ensure public safety. To minimize potential negative effects of plan implementation on recreation resources, the following BMPs have been identified:
1. Restore disturbed recreation areas to pre-operation conditions (e.g., clear blocked trails, recontour damaged trails to minimize the potential for erosion or the creation of unauthorized trails).
2. Repair, replace, or reinstall damaged, removed, or relocated park infrastructure (e.g., signs, gates).
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 53
JULY 2026
3. Minimize the extent or duration of closures by phasing work and/or conducting work outside of peak visitation periods, where feasible.
4. Where feasible, conduct operations on weekdays during daytime hours (7 a.m. to 7 p.m.).
5. Control public access by posting detours, installing and maintaining appropriate and adequate signage, using flaggers/monitors where necessary, closing work areas via exclusionary fencing, and providing necessary monitoring/patrolling staff to ensure access control measures are maintained and effective.
6. Disseminate information regarding planned project activities on the City’s website, social media, in-park signage, local newspaper, and via outreach to regular known user groups.
4.9 Noise
1. All noise-producing project equipment and vehicles using internal combustion engines shall be equipped with mufflers, air-inlet silencers where appropriate, and any other factory-installed shrouds, shields, or other noise-reducing features in good operating condition that meet or exceed original factory specification.
Mobile or fixed “package” equipment shall be equipped with shrouds and noise control features that are readily available for that type of equipment.
2. Mobile equipment staging, parking, maintenance areas, and construction equipment shall be located as far as practicable from noise-sensitive receivers.
3. The on-site construction supervisor shall have the responsibility and authority to receive and resolve noise complaints. A clear appeal process to the Owner shall be established prior to construction commencement that shall allow for resolution of noise problems that cannot be immediately solved by the site supervisor.
4.10 Biological Resources
1. Retain at least 75% of the overstory and 50% of the understory canopy of native riparian vegetation within 100 feet of perennial streams and 50 feet of intermittent streams during thinning activities.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 54
JULY 2026
INTENTIONALLY LEFT BLANK
18611.01 55
JULY 2026
5 References
ANSI (American National Standards Institute). 2017. ANSI A300 Standards. https://www.tcia.org/TCIA/ BUSINESS/ANSI_A300_Standards_/TCIA/BUSINESS/A300_Standards/A300_Standards.aspx?hkey= 202ff566-4364-4686-b7c1-2a365af59669.
CAL FIRE (California Department of Forestry and Fire Protection). 2025a. 2025 Strategic Fire Plan:
https://34c031f8-c9fd-4018-8c5a-4159cdff6b0d-cdn-endpoint.azureedge.net/-/media/osfm-website/ what-we-do/community-wildfire-preparedness-and-mitigation/2025-san-diego-imperial-unit-fireplanwithvp_paulbisson.pdf?rev=b196aeafb31848178fb4032e6541fd86&hash=A97DAC275C65C1B6B 0BE4B01DCA0377F.
CAL FIRE. 2025b. Historical Fire Perimeters. https://www.fire.ca.gov/what-we-do/fire-resource-assessmentprogram/fire-perimeters.
City of Santee. 2025. Santee MSCP Subarea Plan Public Review Draft. August 2025. Accessed January 2026. https://www.cityofsanteeca.gov/active-projects-map/santee-mscp-subarea-draft-plan-and-draft-programenvironmental-impact-report.
DiTomaso, J.M., G.B. Kyser et al. 2013. Weed Control in Natural Areas in the Western United States. Weed Research and Information Center, University of California. 544 pp.
Dudek. 2025a. Biological Resources Assessment Letter Report for the San Diego River Fire Hazard Mitigation Plan Project. Prepared for the City of Santee.
Dudek. 2025b. Cultural Resource Assessment Report San Diego River Fire Hazard Mitigation Plan – Phase 1 Prepared for the City of Santee.
Eucalyptus Hills Fire Safe Council. 2009. Eucalyptus Hills Community Wildfire Protection Plan. https://firesafesdcounty.org/wp-content/uploads/2016/06/Eucalyptus-Hills-11-2009.pdf.
Lakeside Fire Safe Council. 2024. Lakeside Community Wildfire Protection Plan. Accessed November 26, 2025. https://firesafesdcounty.org/wp-content/uploads/2024/08/Lakeside_2024_CWPP_FINAL.pdf.
Oberbauer, T., M. Kelly, and J. Buegge. 2008. Draft Vegetation Communities of San Diego County. Based on “Preliminary Descriptions of the Terrestrial Natural Communities of California,” Robert F. Holland, Ph.D., October 1986.
RCD of Greater San Diego County (Resource Conservation District of Greater San Diego County) and San Diego County Fire Safe Council. 2019. San Diego County Community Wildfire Protection Plan. https://firesafesdcounty.org/wp-content/uploads/2023/09/CA_SanDiego_CNTY_2019.pdf.
SAN DIEGO RIVER FIRE HAZARD MITIGATION PROGRAM / FUELS TREATMENT PLAN 18611.01 56
JULY 2026
INTENTIONALLY LEFT BLANK
Appendix A
Treatment Areas by Parcel
APPENDIX A / TREATMENT AREAS BY PARCEL
18611.01 A-1
JULY 2026
This appendix presents parcel- and zone-level summaries of vegetation type, biomass, acreage, and tree counts within the project area. Parcel boundaries were intersected with treatment zones and vegetation layers to support parcelscale reporting. For clarity, parcels overlapping less than 0.25 acres of the project area are not included in the tables below, as these parcels contain no or negligible vegetation eligible for removal. For this reason, the total biomass reported in Table 2 of the FTP differs slightly from the sum of grand totals presented in Tables A-1 through A-5 below.
Furthermore, the biomass, acreage, and count estimates presented here are for planning purposes and may differ from actual vegetation removal, which will be guided by the treatment recommendations in Section 3.4 of the FTP.
The data collected during field assessments is only a preliminary mapping of the potential areas slated for treatment within Zone 3. The project would implement MM BIO-9 Tree Survey, to provide comprehensive mapping, by a Certified Arborist, of the dead, dying, and invasive species that would be removed under the proposed project. A biological monitor shall be present in accordance with MM BIO-3: Biological Monitor, to ensure vegetation management activities occur only for dead, dying, and invasive species.
Totals may not sum due to rounding. Acres include all mapped vegetation, including tree stands. Isolated trees are not included in the acreage estimate.
Table A-1. City of Santee: Estimated Area (Ac), Biomass (CY), and Tree Quantities for Removal by Zone and Parcel
Parcel ID
Biomass (CY)
Biomass
(CY)
Tree
Quantity
Total
Biomass Total Acres
Non-Tree
Vegetation Trees
Zone 1 3,980 7,904 28 11,884 7.50
742404 1 0 0 1 0.01
743712 263 0 0 263 1.05
743713 0 0 0 0 0
743714 0 0 0 0 0
743715 74 898 1 971 0.16
743868 12 3 1 14 0.57
744411 229 0 0 229 0.63
744414 18 0.26 1 18 1.46
745255 1,509 842 2 2,351 1.42
5049964 29 6 1 35 0.71
5097906 6 0 0 6 0.16
5097912 1,839 6,156 22 7,995 1.31
Zone 2 8,998 1,774 212 10,772 20.87
742404 6 0 1 6 0.06
743712 294 1 0 295 1.26
743713 12 3 1 16 0.08
743714 0 0 0 0 0
743715 1,155 0 0 1,155 1.25
743868 18 9 6 27 1.09
744411 1,251 0.1 1 1,251 1.82
744414 50 23 5 73 4.19
APPENDIX A / TREATMENT AREAS BY PARCEL
18611.01 A-2
JULY 2026
Table A-1. City of Santee: Estimated Area (Ac), Biomass (CY), and Tree Quantities for Removal by Zone and Parcel
Parcel ID
Biomass (CY)
Biomass
(CY)
Tree
Quantity
Total
Biomass Total Acres
Non-Tree
Vegetation Trees
745255 2,400 341 9 2,741 4.42
5049964 73 15 5 88 1.79
5097906 12 2 1 14 0.37
5097912 3,727 1,379 183 5,105 4.52
Zone 3 1,327,983 17,571 843 1,345,554 53.05
742404 12 976 7 988 0.16
743712 40,619 4 3 40,623 1.66
743713 27,126 52 13 27,178 0.72
743714 13,500 1 2 13,501 0.31
743715 42,704 11 12 42,715 1.02
743868 40,501 2 2 40,503 1.06
744411 81,044 186 22 81,230 2.46
744414 189,480 82 24 189,562 5.06
745255 162,956 4,257 148 167,212 8.90
5049964 216,053 224 34 216,277 5.45
5097906 54,057 2 4 54,059 4.81
5097912 459,929 11,776 572 471,705 21.45
Grand Total 1,340,960 27,250 1,083 1,368,210 81.42
Table A-2. County of San Diego: Estimated Area (Ac), Biomass (CY), and Tree Quantities for Removal by Zone and Parcel
Parcel ID
Biomass (CY)
Biomass
(CY)
Tree
Quantity
Total
Biomass Total Acres
Non-Tree
Vegetation Trees
Zone 1 0 0 0 0 0
Zone 2 0 0 0 0 0
Zone 3 280,118 6,424 420 286,541 36.45
5224913 13,505 0 2 13,505 0.61
5261822 27,000 0 0 27,000 0.62
5261823 224,812 6,372 406 231,184 31.70
5261825 11,586 0 0 11,586 1.33
5267294 3,161 0 0 3,161 1.45
5267295 53 27.8 6 81 0.63
5285206 0 24 6 24 0.10
APPENDIX A / TREATMENT AREAS BY PARCEL
18611.01 A-3
JULY 2026
Table A-2. County of San Diego: Estimated Area (Ac), Biomass (CY), and Tree Quantities for Removal by Zone and Parcel
Parcel ID
Biomass (CY)
Biomass
(CY)
Tree
Quantity
Total
Biomass Total Acres
Non-Tree
Vegetation Trees
Grand Total 280,118 6,424 420 286,541 36.45
Table A-3. San Diego Metropolitan Transportation Development Board: Estimated Area (Ac), Biomass (CY), and Tree Quantities for Removal by Zone and Parcel Parcel ID
Biomass (CY)
Biomass
(CY)
Tree
Quantity
Total
Biomass Total Acres
Non-Tree
Vegetation Trees
Zone 1 0 0 0 0 0
Zone 2 0 0 0 0 0
Zone 3 81,082 0 0 81,082 3.22
5224911 54,080 0 0 54,080 2.47
5261821 27,002 0 0 27,002 0.75
Grand Total 81,082 0 0 81,082 3.22
Table A-4. Private Parcel: Estimated Area (Ac), Biomass (CY), and Tree Quantities for Removal by Zone and Parcel
Parcel ID
Biomass (CY)
Biomass
(CY)
Tree
Quantity
Total
Biomass Total Acres
Non-Tree
Vegetation Trees
Zone 1 110 3 9 113 1.06
207756 77 3 9 80 0.41
743709 0 0 0 0 0
743710 0 0 0 0 0
743711 0 0 0 0 0
745210 0 0 0 0 0
5058644 32 0 0 32 0.11
5097911 1 0 0 1 0.53
Zone 2 209 25 6 235 2.13
207756 162 25 4 187 1.10
743709 0 0 0 0 0
743710 0 0 0 0 0
APPENDIX A / TREATMENT AREAS BY PARCEL
18611.01 A-4
JULY 2026
Table A-4. Private Parcel: Estimated Area (Ac), Biomass (CY), and Tree Quantities for Removal by Zone and Parcel
Parcel ID
Biomass (CY)
Biomass
(CY)
Tree
Quantity
Total
Biomass Total Acres
Non-Tree
Vegetation Trees
743711 0 0 0 0 0
745210 0 0 0 0 0
5058644 32 1 0 32 0.11
5097911 15 0 2 15 0.92
Zone 3 284,392 137 40 284,529 13.14
207756 54,158 7 3 54,165 3.31
743709 38 0 0 38 0.50
743710 40,574 4 4 40,578 1.86
743711 27,032 1 5 27,034 1.03
745210 162,538 124 28 162,662 5.87
5058644 0 0 0 0 0
5097911 52 0 0 52 0.57
Grand Total 284,711 166 55 284,876 16.32
Table A-5. Rights-of-Way: Estimated Area (Ac), Biomass (CY), and Tree Quantities for Removal by Zone and Parcel.
Parcel ID
Biomass (CY)
Biomass
(CY)
Tree
Quantity
Total
Biomass Total Acres
Non-Tree
Vegetation Trees
Zone 1 10,433 18 9 10,451 1.08
Carlton Hills
Boulevard
0 0 0 0 0
Chubb Lane 0 0 0 0 0
Cuyamaca Street 0 0 0 0 0
Magnolia Avenue 0 0 0 0 0
Right-of-Way 10,433 18 9 10,451 1.08
Zone 2 30,982 764 55 31,746 3.28
Carlton Hills
Boulevard
1 0 0 1 0.03
Chubb Lane 0 0 0 0 0
Cuyamaca Street 2 0 0 2 0.01
Magnolia Avenue 0 0 0 0 0
Right-of-Way 30,979 764 55 31,743 3.24
APPENDIX A / TREATMENT AREAS BY PARCEL
18611.01 A-5
JULY 2026
Table A-5. Rights-of-Way: Estimated Area (Ac), Biomass (CY), and Tree Quantities for Removal by Zone and Parcel.
Parcel ID
Biomass (CY)
Biomass
(CY)
Tree
Quantity
Total
Biomass Total Acres
Non-Tree
Vegetation Trees
Zone 3 810,463 1,428 205 811,891 24.92
Carlton Hills
Boulevard
0 0 0 0 0
Chubb Lane 88 1 3 89 0.66
Cuyamaca Street 0.13 74 33 74 0.46
Magnolia Avenue 60 0 0 60 0.66
Right-of-Way 810,314 1,353 169 811,667 23.13
Grand Total 851,878 2,209 269 854,087 29.27
APPENDIX A / TREATMENT AREAS BY PARCEL
18611.01 A-6
JULY 2026
INTENTIONALLY LEFT BLANK
Due to file size, the Final Environmental Impact Report Attachment is available via the link provided below:
https://www.cityofsanteeca.gov/documents/planningbuilding/active-projects/hazard-mitigation-grant/hmgpfinal-environmental-impact-report.pdf
60139.00162\45166771.2
- 1 -
RESOLUTION NO. __________
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
SANTEE, CALIFORNIA AMENDING THE CONSOLIDATED
FEE SCHEDULE TO INCLUDE THE AMBULANCE
TRANSPORT FEES ADOPTED BY THE SANTEELAKESIDE EMERGENCY MEDICAL SERVICES
AUTHORITY
WHEREAS, the City of Santee (the “City”) is authorized by California Government Code Section 66018 to set and collect fees to cover the costs of providing certain public services to the community; and
WHEREAS, on June 27, 2012, the City Council adopted Resolution 047-2012 establishing a Consolidated Fee Schedule and set user fee amounts for various services at no more than the estimated reasonable cost of providing each service to be adjusted as necessary to reflect the rate of inflation; and
WHEREAS, Santee Municipal Code Section 3.02.010(A) authorizes amendments to the Consolidate Fee Schedule by a resolution of the City Council; and WHEREAS, on September 8, 2022, the City Council adopted Resolution 106-2022 approving the Santee-Lakeside Emergency Medical Services Authority (the “Authority” or “SLEMSA”) Joint Exercise of Powers Agreement (the “JPA”) with the Lakeside Fire Protection District (“LFPD”); and
WHEREAS, the JPA provides for the administration of the Authority and authorizes the City and the LFPD to administer, fund, manage, and oversee coordination of ambulance transport services within their defined boundaries; and WHEREAS, the JPA designates the City as the Member Agency to serve as the Administrative Services Provider responsible for the provision of services reasonably necessary for the administrative functions of the authority; and WHEREAS, on December 20, 2022, the Authority adopted Ordinance No. 22-001 establishing a Schedule of Fees, effective January 1, 2023, to be charged to each person receiving services from the Authority for the costs necessary to provide emergency medical and ambulance services, which increase by 3.0% each January 1 thereafter; and WHEREAS, on December 31, 2022, the Authority entered into an agreement for billing services with Digitech Computer LLC to be overseen by the City as the Administrative Services Provider; and
WHEREAS, on May 17, 2024, the Authority adopted Ordinance No. 24-001 amending the Schedule of Fees to increase the fees charged for Resident Ambulance Transport to more accurately reflect the actual and reasonable costs to provide such services; and
WHEREAS, on July 22, 2025, the Authority adopted Resolution 25-001 awarding a special services contract to NBS Government Finance Group (“NBS”) to conduct a comprehensive analysis of the Authority’s ambulance service costs and associated Schedule of Fees; and
60139.00162\45166771.2
- 2 -
WHEREAS, NBS presented its Ambulance Services Rate and Fee Study, attached as Exhibit A and incorporated here for all purposes (the “Cost of Service Study”), to the Authority on May 14, 2026; and
WHEREAS, in consideration of the Cost of Service Study, the Authority published notice pursuant to Government Code Section 6066 of its intention to amend the Resident Ambulance Transport fee and Non-Resident Transport fee to more accurately reflect the actual and reasonable costs to provide such services and to change the methodology by annual increases in all fees would be calculated from an automatic 3.0% increase each January 1 to a calculation based upon the Consumer Price Index (“CPI”) Medical Care component based on the twelve month period ending in March and updated based on this inflator beginning on July 1 of each fiscal year; and WHEREAS, on June 8, 2026, the Authority opened and closed a public hearing and adopted Ordinance No. 26-001, attached as Exhibit B for reference, to amend the Schedule of Fees to reflect the costs of providing transport services included in the Cost of Service Study and to revise the fee adjustment methodology to utilize applicable CPI percentage changes instead of a fixed percentage as recommended in the Cost of Service Study; and
WHEREAS, the City desires its Consolidated Fee Schedule to include fees for the provision of emergency medical and ambulance transport services that are commensurate with the fees established by the Authority in which the City participates; and
WHEREAS, the City has published notice of its intention to consider a resolution amending the City’s Schedule of Fees to add Ambulance Transport Fees and has met the procedural requirements of Government Code Sections 66018 and 6062(a); and WHEREAS, all legal prerequisites to the adoption of this Resolution have occurred and the City Council now desires to adopt the proposed resolution; NOW THEREFORE, BE IT RESOLVED, by the City Council of the City of Santee, California, as follows:
SECTION 1. The foregoing Recitals are true and correct and are incorporated herein by this reference.
SECTION 2. The fees adopted by the Santee – Lakeside Emergency Medical Services Authority as reflected in Exhibit B to this Resolution are hereby adopted and incorporated into the Consolidated Fee Schedule as follows:
The following fees are intended to be consistent with the Schedule of Fees adopted by the Santee – Lakeside Emergency Medical Services Authority. In the event of conflict, the fees established by the Authority shall govern absent further resolution by the City.
Rates shall increase every July 1 by CPI-U, Medical Care Component.
Description Fees
Resident Ambulance Transport $2,948
Non-Resident Ambulance Transport $3,624
Non-Transport (Treat & Release) $170
Mileage $46/mile (minimum 1 mile)
Oxygen $72
60139.00162\45166771.2
- 3 -
Night Charge (1900-0700) $45
*Standby Charge $269/hour
The Consolidated Fee Schedule shall note that the fees are intended to align with the fees set by the Authority and that in the event of conflict the fees established by the Authority shall govern absent further resolution by the City; and SECTION 3. The City Council finds that this Resolution is exempt from the California Environmental Quality Act ("CEQA") because this Resolution does not qualify as a “project” under CEQA and will not result in a direct or reasonably foreseeable indirect physical change in the environment. (State CEQA Guidelines section 15060, subd. (c)(2), (3)).
ADOPTED by the City Council of the City of Santee, California, at a Regular meeting thereof held this 12th day of August, 2026, by the following roll call vote to wit:
AYES:
NOES:
ABSENT:
APPROVED:
JOHN W. MINTO, MAYOR
ATTEST:
JAMES JEFFRIES, CITY CLERK
EXHIBIT A: April 30, 2026 NBS Cost Of Service Study
EXHIBIT B: SLEMSA Ordinance No. 26-001 and Schedule of Fees 60139.00162\45166771.2
A-1
EXHIBIT “A”
April 30, 2026 NBS Cost of Service Study
[Insert Study]
nbsgov.com
Corporate Headquarters
32605 Temecula Parkway, Suite 100
Temecula, CA 92592
Toll free: 800.676.7516
Prepared by:
EMERGENCY MEDICAL
DRAFT Report for:
Ambulance Services Rate and Fee Study
April 30, 2026
Corporate Headquarters
32605 Temecula Parkway, Suite 316
Temecula, CA 92592
Toll free: 800.676.7516
Prepared by:
nbsgov.com
TABLE OF CONTENTS
Executive Summary ........................................................................................................1 Project Approach............................................................................................................2
2.1 Legal Foundation.....................................................................................................2
2.2 Project Approach.....................................................................................................3 Analysis..........................................................................................................................8
3.1 Cost-of-Service Analysis ..........................................................................................8
3.2 Fee Establishment .................................................................................................14
3.3 Cost Recovery Evaluation......................................................................................14 Conclusion.................................................................................................................... 18
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 1
EXECUTIVE SUMMARY
NBS performed a study of Santee-Lakeside Emergency Medical Services Authority’s ambulance service fees. The primary purpose of the Study was to evaluate the Authority’s existing ambulance fee structure, determine the full cost of providing ambulance transport services, and present maximum allowable fee levels consistent with local, state, and federal guidelines.
Santee-Lakeside Emergency Medical Services Authority (SLEMSA) is a Joint Powers Authority formed by the City of Santee and the Lakeside Fire Protection District (the Agencies) to provide advanced life support ambulance transport services within its service area in eastern San Diego County.
The body of this report illustrates the calculation of maximum fee amounts that reflect the Authority’s full cost of providing ambulance transport services. These amounts represent the upper limit of what may be charged and are not intended to prescribe specific fee adoption levels.
This Study identified approximately $50.5 million in total annual Authority costs associated with providing fire department services, with the total cost of providing Emergency Medical Services (EMS) at approximately $42.4 million. While not all EMS activity results in an ambulance transport, resources are deployed and maintained to support system-wide response, including instances of treatment without transport and other non-transport outcomes. As such, all costs necessary to support ambulance readiness and response capacity are reflected in the cost-of-service analysis.
The Authority currently collects approximately $8.9 million per year for ambulance services. Actual collections are influenced by payer mix, contractual agreements, and statutory reimbursement limitations. In addition, not all EMS responses result in a billable service, and not all billed amounts are collected in full due to write downs, write offs, and other reimbursement constraints. Based on an analysis of billing and revenue receipts data, the Authority receives, on average, approximately 41% of the annually billed amount for services.
As discussed in Section 2.2.3 of this report, there may be local policy considerations for adopting fees at less than the calculated maximum allowable amount. Additionally, the Centers for Medicare and Medicaid Services (CMS) establishes reimbursement limits for certain payers, which may affect the amount ultimately collected for ambulance services. These factors do not impact the calculation of the maximum allowable rates but may influence actual cost recovery outcomes.
Table 1 provides a cost and billing overview for ambulance services.
TABLE 1. COST AND BILLING OVERVIEW
Description Amount
Total Authority Costs $ 50,526,479
Total Costs of Providing EMS $ 42,357,934
Billed $ 21,931,582
Collected $ 8,895,449
Current Collection Rate 40.6%
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 2
PROJECT APPROACH
In approaching any fee study, NBS assesses the unique conditions of the agency with which we work, applies a core philosophy, and selects methodologies that best fit the requirements of the individual agency. Given the diversity and nuances present in many aspects of Authority finance and policy, this is a necessary strategy since one-size-fits-all methods are not sustainable once they become owned by the agency served.
There is a legal foundation in place that provides the Authority with the authority to impose fees for the services it provides. The cost of providing these services and activities can be reasonably calculated and fees can be structured in a manner that allows the Authority to recover up to 100% of service costs. The calculation of the cost of providing services is an analytical effort that involves adopted and expected cost information and estimates of time (or time tracking information) required to perform a service or activity.
Determining the targeted level of cost recovery from a new or increased fee is not an analytical exercise.
It involves agency-specific judgments linked to a variety of factors, such as existing Authority policies, agency-wide or departmental revenue objectives, economic goals, community values, market conditions, level of demand, and others. Further, the Centers for Medicare and Medicaid Services (CMS) sets limits, or “caps,” for how much a provider can be reimbursed for administering ambulance services. CMS, however, does not regulate how much can be charged to patients or private insurance companies. If the adopted fee is set at an amount that does not exceed the estimated and reasonable full cost of providing the service or activity requested, the Authority is in compliance with the legal framework currently in place.
2.1 Legal Foundation
In California, there is great variability amongst fees charged to individuals for receiving ambulance transport and/or treatment. There is no set standard in California locally or statewide for how ambulance fees and rates should be calculated or administered. Therefore, in our opinion, the foundation for justification of ambulance fees for services needs to rely on a combination of federal guidelines and requirements as well as California state authorities for charging fees.
CMS is a federal agency within the United States Department of Health and Human Services (HHS) that administers the Medicare program and works in partnership with state governments to administer Medicaid. CMS develops a national Ambulance Fee Schedule for services eligible for partial reimbursement to providers. CMS sets limits, or “caps,” for how much a provider can be reimbursed for administering ambulance services. CMS, however, does not regulate how much can be charged to patients or private insurance companies. For the ambulance transport benefit under Medicare Part B, payment limits are updated annually effective January 1 based on the Ambulance Inflation Factor (AIF), which is derived from the Consumer Price Index for All Urban Consumers (CPI-U) and adjusted in accordance with federal regulations. This study relies on several of the CMS guidelines to structure which types of fees are charged for Medicare and Medicaid billing purposes.
It is generally accepted in California that cities are granted the authority to impose user and regulatory fees for services and activities they provide through provisions of the State Constitution. More specifically, the type of fees the Santee-Lakeside Emergency Medical Services Authority seeks to establish for ambulance services fall under the California Constitution Article XIII C. Section 1(e), which provides seven stated exceptions to the State’s definition of a “tax.” The Authority’s ambulance fees represent cost recovery opportunities entirely within the Authority’s control. These are revenues which the Authority
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 3
Board may, at its sole discretion upon public hearing, implement and/or modify without further public process or approval. The only legal limitation on the establishment of these fees is that they may not exceed the estimated and reasonable costs incurred to provide the service or perform the function for which the fee is charged.
2.2 Project Approach
The fee study is a quantitative effort which compiles the full cost of providing governmental services and activities and translates those costs into proposed fee amounts best aligned with how services are provided. There were three phases of analysis completed during this study:
1. Cost-of-Service Analysis
2. Fee Establishment
3. Cost Recovery Evaluation
2.2.1 COST-OF-SERVICE ANALYSIS
A Cost-of-Service Analysis is a quantitative effort that compiles the full cost of providing governmental services and activities. There are two primary types of costs considered: direct and indirect costs. Direct costs are those that specifically relate to an activity or service, including the real-time provision of the service. Indirect costs are those that support the provision of services in general but cannot be directly or easily assigned to a singular activity or service. The following are different types of direct and indirect costs that are considered in the Cost-of-Service Analysis:
Direct Costs:
• Direct personnel costs – Salary, wages and benefits expenses for personnel specifically involved in the provision of services and activities to the public. • Direct non-personnel costs – Discrete expenses incurred by the Authority due to a specific service or activity performed, such as contractor costs, third-party charges, and specific materials used in the service or activity.
Indirect Costs:
• Indirect personnel costs – Personnel expenses supporting the provision of services and activities. This can include line supervision and departmental management, administrative support within a department, and staff involved in technical support activities related to the direct services provided to the public.
• Indirect non-personnel costs – Expenses other than labor involved in the provision of services.
In most cases, these costs are allocated across all services provided by a department, rather than directly assigned to individual fee categories.
• Overhead costs – These are expenses, both labor and non-labor, related to Authority-wide support services. Support services include general administrative services such as the Agencies’ Manager, Finance, Human Resources, etc.
•
All cost components in this Study use annual (or annualized) figures, representing a twelve-month cycle of expenses incurred by each Agency in the provision of services. Once the total estimated annual costs of providing services are known, further analysis is completed to identify service costs that may not be eligible for recovery in the fees subject to study.
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 4
To translate the annual costs of providing fee-related services into full cost-recovery individual fee amounts, we applied estimated or tracked time data and estimated or tracked activity data as an indicator of the level of service provided by type of service provided.
2.2.2 FEE ESTABLISHMENT
The Study’s process provided the opportunity to propose additions and deletions to the fee schedule, as well as to rename, reorganize, and clarify fees imposed. Many such revisions better conform fees to current practices, as well as improve the calculation of fees owed by an individual, the application of said fees, and the collection of revenues.
The current structure of fees did not change; the focus is to recalibrate the fee amount to match the costs of services.
2.2.3 COST RECOVERY EVALUATION
The fee model compares the existing fee for each service or activity to the average total cost of service quantified through this analysis. A cost recovery rate of 0% identifies no current recovery of costs from fee revenues (or insufficient information available for evaluation). A rate of 100% means that the fee currently recovers the full cost of service. A rate between 0% and 100% indicates partial recovery of the full cost of service through fees. A rate greater than 100% means that the fee exceeded the full cost of service.
Fees examined in this Study should not exceed the full cost of service. In other words, the cost recovery rate achieved by a fee should not be greater than 100%. We assist with modeling the “recommended” or “targeted” level of cost recovery for each fee, always established at 100%, or less, than the calculated full cost of service.
As covered in section 2.1 Legal Foundation, while CMS sets limits, or “caps,” for how much a provider can be reimbursed for administering ambulance services, the agency does not regulate how much can be charged to patients or private insurance companies. As such, targets and recommendations always reflect agency-specific judgments linked to a variety of factors, such as existing Authority policies, revenue objectives, economic goals, community values, market conditions, level of demand, and others. Because this element of the Study is subjective, the results of this study provide the cost-of-service calculation based on 100% full cost recovery as well as the framework for the Authority to adjust in accordance with the Authority’s goals as pertains to code compliance, cost recovery, economic development, and social values.
2.2.4 COMPARATIVE FEE SURVEY
Often policy makers request a comparison of their jurisdiction’s fees to surrounding or similar communities. As illustrated in the comparison survey, the Authority’s fees are lower than all of the comparison agencies.
While a comparison can provide a sense of the local market pricing for services and be useful in gauging the impact of recommendations for fee adjustments, the following should be noted about the general use of comparative survey data:
• Comparative surveys typically do not provide information about the cost recovery policies or procedures inherent in each comparison agency.
• A “market based” decision to price services below the full cost of service calculation, is the same as deciding to subsidize that service.
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 5
• Comparative agencies may or may not base their fee amounts on the estimated and reasonable cost of providing services.
• Comparative fee survey efforts are often non-conclusive for many fee categories. Comparison agencies typically use varied terminology for the provision of similar services.
The results of the Comparative Fee Survey for the Authority’s fees are shown on the following page. 1 Resident Ambulance Transport per patient $ 1,240 $ 1,447 $ 3,442 $ 3,716 $ 5,365 $ 6,144 $ 4,267 $ 3,743 $ 4,897 $ 3,705 2 Non-Resident Ambulance
Transport
per patient $ 2,949 $ 3,442 $ 3,442 $ 3,716 $ 5,365 $ 6,144 $ 4,267 $ 3,743 $ 4,897 $ 3,705 3 Non-Transport (Treat & Release) per patient $ 162 $ 2,414 $ 2,414 $ 1,005 $ 3,410 no fee $ 200 $ 460 $ 1,069 $ 572 4 Mileage per mile [4] $ 44 $ 28 $ 20 $ 29 $ 40 $ 48 $ 33 $ 52 5 Oxygen per patient $ 69 $ 67 $ 80 $ 110 $ 100 no comparison
$ 89 $ 153 6 Night Charge (1900-0700) per patient $ 43 no comparison
$ 64 no
comparison
no
comparison
no
comparison
$ 64 $ 58 7 Standby Charge per hour [2] $ 256 no
comparison
no
comparison
no
comparison
no
comparison
$ 235 Variable Variable
Notes
[1]
[2]
[3] 2025 San Diego County Ambulance Rate Survey not conducted by NBS [4] Mimimum 1 mile.
Santee-Lakeside Emergency Medical Services Authority Comparison Agencies Fee
No.
Fee Description [1] Fee Type / Unit Notes
Current Fee
[1] City of Vista City of Poway
2025 San Diego
County Ambulance
Rate Survey -
Regional Fee
Average [3]
Fees currently subjected to a 3.0% increase annually beginning on January 1st of each calendar year.
Standby may include, but are not limited to: Event standby; Pre-arranged upstaffing; and, Ambulance offload times at hospitals exceeding 30-minutes in duration.
Fee Study
Results -
Resident
Transport Fee
Reduced
Average of the
Five Comparison
Agencies
City of
Coronado
City of
Escondido
County of San
Diego Fire
District
Fee Study
Results - No
Reduced Fee
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 6
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 7
2.2.5 DATA SOURCES
The following data sources were provided by the Agencies and used to support the cost-of-service analysis and fee establishment phases of this Study:
• Adopted budget for Fiscal Year (FY) 2025-26
• A complete list of the Fire Department’s personnel, salary/wage rates, paid benefits, etc. • Prevailing fee schedules
• Annual ambulance activity and billing data for FY 2024-25 • Calls for service data for FY 2024-25
Each Agency’s adopted budget is the most significant source of information affecting cost of service results. We did not audit or validate the Authority’s financial management and budget practices, nor was cost information adjusted to reflect different levels of service or any specific, targeted performance benchmarks. This Study has accepted each Agency’s budget as a legislatively adopted directive describing the most appropriate and reasonable level of spending.
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 8
ANALYSIS
The focus of this Study is on fees charged for ambulance services provided by the Authority. The following is a summarized list of fees studied:
• Treatment – Medical assessment and treatment provided by Authority personnel in response to an emergency call for service, followed by ground ambulance transport of the patient to a hospital or other medical facility. This fee includes all medically necessary care rendered at the scene and during transport within the scope of practice of responding EMS personnel. • Non-Transport (Treat and Release) – Medical assessment and treatment provided by Authority personnel in response to an emergency call for service where the patient is treated at the scene and not transported to a hospital or other medical facility. • Related Add-Ons – Itemized charges for Mileage, Oxygen, Night Charge, and Standby Charge.
The fees examined in this Study excluded other fire related fees for services, development impact fees, utility rates, and any special tax assessments, all of which fall under distinct legal, analytical, and procedural requirements different from the body of user fees analyzed in this effort. Additionally, this Study excluded fines and penalties imposed by the Authority for violations to its requirements or codes.
3.1 Cost-of-Service Analysis
A full range of fire and paramedic services are provided by the Agencies. The full range of services can be summarized into seven main functional areas for purposes of this analysis:
• Fire Administration - Leadership for the personnel and programs of the department. Also responsible for budgeting, planning, directing, and team building. Sets and reviews department policy and provides administrative support to all Fire divisions. • Emergency Medical Services (EMS) – Ambulance response services that typically result in a transport to a hospital or treatment on-scene without a transport. • Suppression – Emergency response related to fire incidents and other types of emergencies.
A significant portion of suppression directly supports Emergency Medical Services response. • Fire Training – Coordinates all aspects of employee training, keeping current with the local, state, and federally mandated training requirements.
• Fleet Operations and Maintenance – Maintenance of all apparatuses and equipment. • Fire Prevention – Annual inspections of commercial buildings, development review, Fire Code permits, investigative and code enforcement activities, etc. • Emergency Preparedness – Involves the planning, preparation, and mitigation of any major emergency or regional disaster.
Personnel respond from seven (7) strategically located fire stations to provide quick and effective response.
3.1.1 ANNUAL COST OF EMS SERVICES
The focus of this cost-of-service analysis was to reasonably estimate the total annual costs of providing ambulance services that can be recovered through fees for services. Table 2 presents the total cost-of-
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 9
service analysis for each respective Agencies’ Fire Departments, segregated into the main service delivery programs:
TABLE 2. TOTAL FIRE DEPARTMENT SERVICE COSTS PER PROGRAM As shown, the total cost of providing all Department services is approximately $50.5 million. EMS services are approximately $42.4 million, comprised of $20.2 million under EMS and $22.2 million under Suppression – EMS Support, which is 84% of total Authority costs.
EMS DIRECT LABOR COSTS
The amount of “Labor” costs shown in Table 2 above was established as follows.
Firefighters and paramedics are divided into 3 shifts working on a rotational schedule.
According to the calls for service report, most calls for service responded to by the Authority are EMS rather than suppression related.
• The four (4) ALS ambulances and three (3) BLS ambulances in service are supported by seven (7) paramedic fire engines, one (1) truck company, and one (1) paramedic squad. • Each time an ambulance responds to a call for service, a paramedic engine, paramedic truck, or paramedic squad (Santee only) accompanies an ambulance to provide medically necessary support to the ambulance and personnel inside it.
• For Lakeside Fire Protection District, each ALS ambulance is staffed with two people; both are paramedic firefighters. For City of Santee, each ALS ambulance is staffed with one paramedic and one emergency medical technician. Each BLS ambulance is staffed with two EMTs. • Each paramedic engine and ladder truck is staffed with three people: a captain, an engineer, and a firefighter. Lakeside Fire Protection District has four emergency medical technicians/engineers. The rest of suppression personnel are paramedics. • Each squad is staffed with two firefighter paramedics.
The following calls for service analysis from FY 2024/25 shows the breakdown of incidents EMS calls versus other types of calls.
Cost Element
Emergency
Medical Services
(EMS)
Suppression -
EMS Support
Suppression -
Non-EMS
Support
Fire Prevention
Emergency
Preparedness TOTAL
Labor $ 11,676,988 $ 16,407,356 $ 4,854,949 $ 460,810 $ 33,400,104 - $ Recurring Non-Labor 4,367,638 1,203,207 696,593 40,271 46,870 6,354,579 Fleet Replacement Costs 544,612 367,604 633,619 12,943 1,558,778 - Citywide Overhead 1,137,832 1,548,508 431,138 - 7,031 3,124,508 Fire Department Admin 2,428,811 2,675,378 906,509 70,427 7,385 6,088,510 Department Total $ 20,155,882 $ 22,202,052 $ 7,522,808 $ 584,451 $ 61,285 $ 50,526,479
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 10
TABLE 3. CALLS FOR SERVICE
Table 3 shows the Authority’s percentage of incidents for Emergency Medical Services is approximately 79% of all calls for service, while 21% are non-medical. Because the Authority accounts for salaries and benefit expenses for all paramedic personnel in two budgetary units, Emergency Medical Services and Suppression, a method for allocating direct labor costs between the Department’s main service delivery programs is needed. To estimate the amount of salaries and benefit costs dedicated to providing EMS services, NBS used calls for service data as a general means of allocating staff that are on ambulances and supporting paramedic engines.
OPERATING COSTS
Review of the Agencies’ adopted expenditure budget for FY 2025/26 identified several on-going operating costs that are directly attributable to the provision of EMS services. These are shown in Table 2 as “recurring non-labor,” and further detailed in Table 4, below:
Type of
Incident
Assigned
Incidents
Percentage of
Incidents
Medical 13,758 79%
Other 3,637 21%
Grand Total 17,395 100%
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 11
TABLE 4. EMS OPERATING COSTS
Approximately $5.6 million are operating costs directly dedicated to providing Emergency Medical Services. Operating costs include services and supplies needed to support operations.
OVERHEAD COSTS
Several types of overhead costs are also considered in this analysis. Overhead costs include administrative services that support such as Finance, Human Resources, Information Technology, and similar functions.
Rather than applying a formal cost allocation plan, a 15% de minimis indirect cost rate was applied in accordance with 2 CFR 200.414(f) for the City of Santee expenditures. Lakeside Fire Protection District’s Operating Cost Item Sum of 2025-26
Adopted Budget
Accounting/Auditing $ 4,500
Agency Reimbursements 19,550
Bank Fees 15,120
EMS Contract Services 125,000
Expert/Consulting Services 550,212
Fire Department Sustenance 12,493
Fitness Equipment/Education 8,425
Furnishings and Fixtures 14,871
Heartland Communications Facility
Auth. 440,322
Household Cleaning Supplies 4,950
Internal Service Charges 143,153
Laundry/Cleaning Services 540
Legal Services - City Attorney 25,000
Liability and Property Insurance 241,175
Materials and Supplies 486,988
Medical Equipment, Uniforms,
Services, Supplies, Waste Control 723,704
Meetings 7,563
Memberships 5,500
Non-inventory equipment 39,500
Other Equipment - SCBA, Rescue 38,640
Other Governmental Purposes 990,000
Outreach and Education 6,500
Postage 1,905
Repair/Maint - Automotive
Equipment, Equipment, Other 343,043
Services - Auditing,
Communications, Computer
Maintenance 509,427
Software Maintenance & Licensing 31,700
Special department expenses 18,299
Station Maintenance 82,783
Subscriptions/Memberships 730
Training & Development 180,430
Utilities 498,825
Grand Total $ 5,570,845
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 12
overhead costs are already included in the FY 25/26 budget. This rate was applied to the appropriate direct cost base to estimate allowable indirect costs attributable to the City of Santee’ fire department.
TABLE 5. CITYWIDE OVERHEAD COSTS
Citywide Overhead Costs were allocated to all service areas, with EMS receiving approximately $2.7 million, as shown in Table 6.
TOTAL ANNUAL COST ALLOCATION SUMMARY
Based on the analysis completed for each attributable cost component described above, Table 6 summarizes the Authority’s total estimated annual cost of providing EMS services at $42.4 million. As described above, the total estimated cost of providing services includes all identifiable direct and indirect costs.
TABLE 6. TOTAL ANNUAL EMS COSTS
3.1.2 INDIVIDUAL FEE FOR SERVICE COSTS
To translate the total annual EMS costs established in Table 6 into individual costs per type of ambulance service, EMS costs were allocated to individual fees for service categories based on the average number of calls by type and the average amount of time required to service each type of call according to dispatch records.
Utilizing calls for service data provided by the Authority’s dispatch system, a weighted distribution factor was derived by call time between Transports, Non-Transports, and Other Calls. Each time an ambulance responds to a call for service, a paramedic engine also accompanies that ambulance to provide medically necessary support. Therefore, service time must reflect the total number of personnel responding to each call, on average:
• Ambulance or Medic Unit: ALS two-person crew consisting of Paramedic/Firefighters. BLS two-person crew consisting of 2 EMTs.
Allocated Indirect/Support Services
2025-26 De
Minimis
Calculation
Citywide Overhead $ 3,413,090
TOTAL CITYWIDE OVERHEAD COSTS 3,413,090 $
Cost Element
Emergency
Medical
Services (EMS)
Labor $ 28,084,344
Recurring Non-Labor 5,570,845
Fleet Replacement Costs 912,216
Citywide Overhead 2,686,340
Fire Department Admin 5,104,189
Total $ 42,357,934
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 13
• Paramedic Engine: Three-person crew consisting of Captain, Engineer, and Firefighter. • Transports are defined as calls that consisted of a patient being transported to the hospital or medical facility by ambulance.
• Non-Transports are defined as calls where treatment was administered on the scene, but the ambulance did not transport the patient to a hospital or medical facility. • Other Calls are defined as calls where no incident was found, which would be indicative of no treatment was administered on-scene and no transport was provided by ambulance.
The cost-of-service analysis for individual ambulance services is shown in Table 7 below.
TABLE 7. AVERAGE TOTAL COST PER TYPE OF SERVICE
Per the dispatch data, Table 7 shows the average annual distribution of effort required to service various types of Emergency Medical Services calls as 79.78% Transports, 19.58% Treatment Non-Transports, and
0.63% Other Calls. Applying the $42.4 million of costs shown in Table 6, the average cost of service per ambulance call is $3,443 for Transport, $2,415 for Treatment Non-Transports, and $528 for Other Calls.
During the Study, the Authority indicated its desire to explore the impact of maintaining separate fees for Resident and Non-Resident transports. The current Resident transport fee is approximately 42% lower than the Non-Resident transport fee. While the Authority can charge a Resident Transport fee of up to $3,443 per patient, table 8 below represents the cost per service considering the Transport fee for Residents is lower than the Transport fee for Non-Residents.
TABLE 8. AVERAGE TOTAL COST PER TYPE OF SERVICE – RESIDENT VS. NON-RESIDENT TRANSPORT FEE Table 8 shows the average annual distribution of effort required to service various types of Emergency Medical Services calls as 61.4% Transports - Resident, 18.34% Transports – Non-Residents, 19.57% Treatment Non-Transports, and 0.68% Other Calls. This policy option reduces the estimated cost recovery from $42.4 million to $27.3 million, a loss of $15.1 million.
Type of Service Total Calls Ambulance Engine Total Total - Annual
%
Distribution
Maximum
Cost per
Service
Cost
Distribution
Transport 9,814 2.50 1.12 3.61 35,469 79.78% $ 3,443 $ 33,793,897 Non-Transports 3,435 0.48 2.06 2.53 8,707 19.58% $ 2,415 $ 8,295,291 Other Calls 509 0.23 0.32 0.55 282 0.63% $ 528 $ 268,746 Total 13,758 44,458 100.00% $ 42,357,934
Type of Service Total Calls Ambulance Engine Total Total - Annual
%
Distribution
Maximum
Cost per
Service
Cost
Distribution
Transport - Resident 7,557 2.50 1.12 3.61 27,311 61.40% $ 1,447 $ 10,934,177 Transport - Non-Resident 2,257 2.50 1.12 3.61 8,158 18.34% $ 3,442 $ 7,769,083 Non-Transports 3,435 0.48 2.06 2.53 8,707 19.57% $ 2,414 $ 8,291,542 Other Calls 509 0.23 0.36 0.59 302 0.68% $ 565 $ 287,772 Total 13,758 44,478 100.00% $ 27,282,573
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 14
3.2 Fee Establishment
The Authority’s current fee structure and fee amounts are shown in Table 9 on the following page. As discussed in Section 2.2.2 of this report, the Study’s process provided the opportunity to propose additions and deletions to the fee schedule, as well as to rename, reorganize, and clarify fees imposed.
In general, ambulance fee schedules tend to be standardized across local governments. Fee schedules typically contain the following types of fees for services:
• Transport Fees and treatment without transport services. Fees for transport services also sometimes indicate different fee amounts for residents versus non-residents. • Add-on Charges, for services provided during transport that vary per incident, such as mileage, oxygen, night charge, standby charge, etc.
The Authority’s transport fees are structured within the same standards seen in other agencies. NBS recommends the Authority publish all standard Add-on charges that it intends to bill for on a routine basis in the Master Fee Schedule.
3.3 Cost Recovery Evaluation
Table 9 shows the Total Cost of Service Per Activity calculated by the Study (full cost recovery fee amounts) as compared to the current fees charged by the Authority.
TABLE 9. CURRENT FEE EVALUATION AND PERFORMANCE
As shown, the Authority’s current transport fees recover between 7% and 86% of the total cost of providing each service. Add-on charges were not evaluated on a cost-per-service basis. As shown, the total cost of service per activity for each level of service is as follows:
Fee
No.
Fee Description Fee Unit /
Type
Total Cost
of Service
Per Activity
Cost
Recovery
%
SLEMSA
Current Fee
Existing Cost
Recovery %
1 Resident Ambulance Transport per patient 3,442$ 100% 1,240$ 36% 2 Non-Resident Ambulance Transport per patient 3,442$ 100% 2,949$ 86% 3 Non-Transport (Treat & Release) per patient 2,415$ 100% $ 162 7% 4 Mileage per mile $ 44
5 Oxygen per patient $ 69
6 Night Charge (1900-0700) per patient $ 43
7 Standby Charge per hour $ 256
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 15
• The total cost of service per activity for Transports is $3,442, while the current fee is $1,240 for Authority residents, which yields a 36% recovery rate. The current fee is $2,949 for nonresidents, which yields a 86% recovery rate. • The total cost of service per activity for Non-Transports is $2,415, while the current fee is $162 for Authority residents, which yields a 7% recovery rate.
3.3.1 RECOMMENDED FEES - POLICY APPROACH
The following table shows three options for establishing Transport and Treatment and Release (NonTransport) fees either at or below the 100% full cost of service fee amounts calculated through this Study, based on three benchmark approaches evaluated to provide a range of policy options. • Benchmark 1: Transport fees established at 100% full cost recovery, with policy considerations for resident vs. non-resident transport fees; Add-on charges assumed at no change from current fee amounts
• Benchmark 2: Transport fees and Add-on charges established at the average of the regional comparison
• Benchmark 3: Transport fees and Add-on charges established at the average of the five agencies selected in the comparison survey; Add-on charges assumed at the average of the five comparison agencies.
Benchmarks 2 and 3 are not recommended because the Transport fee average of the five comparison agencies, and the regional fee average, exceed the Authority’s maximum cost per service. Adopting fees above the Authority’s calculated full cost is not a defensible option and would not align with the cost-ofservice methodology presented in this report.
In addition to establishing updated fees for transport and add-on charges, the Authority currently applies a 3% annual increase effective January 1 of each year. This is an acceptable approach. Alternatively, the Authority may adopt a Consumer Price Index (CPI) inflator to better align annual adjustments with actual cost trends. The Consumer Price Index (CPI-U), Medical Care component, Not Seasonally Adjusted, for the San Diego-Carlsbad area, as published by the U.S. Bureau of Labor Statistics, based on the twelve (12) month period ending in March, is an appropriate measure of changes in the cost of providing ambulance and emergency medical services and may be used to inform future fee adjustments.
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 16
TABLE 10. POLICY OPTIONS
Benchmarks 2 and 3 are not recommended because, the Transport fee average of the five comparison agencies, and the regional fee average, exceed the maximum cost per service. Adopting fees above the calculated full cost is not defensible.
As discussed further in Section 3.3.2, the amount to which any adopted fee increases will affect Authority revenues is difficult to quantify.
3.3.2 PAYER MIX
Understanding the Authority’s payer mix is an important consideration when setting final fee amounts because most bills for ambulance services do not result in full payment. For example, as discussed throughout this report, CMS sets limits, or “caps,” for how much a provider can be reimbursed for ambulance services. CMS, however, does not regulate how much can be charged to private paying patients or commercial insurance companies. Individuals may have issues with their ability to pay the full fee amount, and commercial insurance companies may have their own limits and reimbursement policies.
Actual reimbursements are based upon billing the patient for the medical service provided and dependent on whether the recipient of a bill has private or public insurance, or no insurance. There are four basic categories of reimbursements.
• Medicare – Primary health care coverage for people over the age of 65. • Medi-Cal – Component of the federal Medicaid program that is provided for qualified individuals and families.
• Commercial Insurance – Benefits purchased independently or provided by employers to employees.
• Private Pay - Jail – Under the existing agreement with San Diego County, jail transport services are reimbursed at the Authority’s standard adopted ambulance transport resident rate as set in the Authority’s fee schedule.
• Private Pay - Other – For those without any form of medical insurance.
Fee
No.
Fee Description Fee Unit /
Type
Total Cost
of Service
Per Activity
Cost
Recovery
%
SLEMSA
Current Fee
Existing Cost
Recovery %
Regional Fee
Average
Cost
Recovery
%
Average of
the Five
Comparison
Agencies
Cost
Recovery
%
1 Resident Ambulance Transport per patient 3,442$ 100% 1,240$ 36% 3,705$ 108% 4,897$ 142% 2 Non-Resident Ambulance Transport per patient 3,442$ 100% 2,949$ 86% 3,705$ 108% 4,897$ 142% 3 Non-Transport (Treat & Release) per patient 2,415$ 100% $ 162 7% $ 572 24% 1,069$ 44% 4 Mileage per mile $ 44 $ 52 $ 33
5 Oxygen per patient $ 69 $ 153 $ 89
6 Night Charge (1900-0700) per patient $ 43 $ 58 $ 64
7 Standby Charge per hour $ 256 Variable Variable
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 17
The data in the following tables shows the Authority’s current payer mix based on financial class data and revenues reported by the Authority’s third-party biller, Digitech. While revenue projections are not included in this report, this payor mix data would be useful in understanding the impact on actual reimbursements received after fees are adopted.
TABLE 11. PAYER MIX – NUMBER OF TRANSPORTS
In Table 11, of the 10,323 total transports in FY 2024-25, Medicare is the largest payer category, accounting for 4,917 transports, or 47.63% of the total transport mix. Medi-Cal is the second largest category, with 2,296 transports, representing 22.24% of the total. Commercial Insurance, Private Pay – Other, and Private Pay – Jail are the third, fourth, and fifth largest categories, respectively.
It is important to note that increasing fees does not necessarily translate to a total increase in revenues at the reimbursement/payor level. For example, due to the fee limits set by CMS, one should not expect the collection per transport to increase significantly from what is shown above. Further, Medicare and MediCal are likely to not have any revenue increase due to capped rates. Private Pay – Other may not have any actual revenue collection. Commercial Insurance is the most likely to pay the highest reimbursement rate and exhibit flexibility in its collection as compared to the other categories.
Category
Number of
Transports
Percentage of
Transports
Medicare 4,917 47.63%
Medi-Cal 2,296 22.24%
Commercial Insurance 1,443 13.98%
Private Pay - Jail 239 2.32%
Private Pay - Other 1,428 13.83%
Totals 10,323 100.00%
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
Ambulance Services Rate and Fee Study 18
CONCLUSION
The findings of the Cost-of-Service Analysis, Fee Establishment, and Cost Recovery Evaluation presented in this Study will inform a proposed schedule of fees, which will be brought forward by staff for Authority Commission consideration.
As discussed throughout this report, the proposed fee schedule intends to improve the Authority’s recovery of costs incurred to provide individual services. The amount to which any adopted fee increases will affect Authority revenues is difficult to quantify.
Experience with the revised fee amounts should be gained first before revenue projections are revised.
However, unless there is significant, long-term change in activity levels at the Authority, proposed fee amendments should enhance the Authority’s cost recovery performance, over time, providing it with the ability to stretch other resources further for the benefit of the public at large.
Disclaimer: In preparing this report and the opinions and recommendations included herein, we relied on several principal assumptions and considerations regarding financial matters, conditions and events that may occur in the future. This information and assumptions, including the Authority’s budgets, time estimate data, and workload information from Authority staff, were provided by sources we believe to be reliable; however, we did not independently verify such information and assumptions. While we believe our use of such information and assumptions is reasonable for the purpose of this report, some assumptions will invariably not materialize as stated herein and may vary significantly due to unanticipated events and circumstances. Therefore, the actual results can be expected to vary from those projected to the extent that actual future conditions differ from those assumed by us or provided to us by others.
60139.00162\45166771.2
B-1
EXHIBIT “B”
SLEMSA Ordinance No. 26-001 and Schedule of Fees
[Insert Ordinance and Schedule of Fees]
Ordinance #:26-001
Date: June 8, 2026
ORDINANCE NO. 26-001
AN ORDmANCE AMENDING THE SCHEDULE OF FEES OF THE
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES
AUTHORITY IN ORDER TO PROVIDE FOR THE RECOVERY OF
ACTUAL COSTS FOR EMERGENCY MEDICAL SERVICES,
AMBULANCE SERVICES, AND OTHER SERVICES RELATING TO
THE PROTECTION OF LIVES
WHEREAS, the Santee-Lakeside Emergency Medical Services Authority ("Authority") established and adopted a Schedule of Fees on December 20, 2022, pursuant to Ordinance No. 22-001 and increased the Resident Ambulance Transport fee on May 17, 2024, pursuant to OrdinanceNo. 24-001.
WHEREAS, notwithstanding the adoption of the Schedule of Fees and the amendment thereto, the Authority has found that it does not have sufficient revenue to provide emergencymedical services, ambulance services, and/or other services relating to the protection of lives that the Authority is charged with providing and wishes to revise the Resident Ambulance Transport fee, the Non-Resident Ambulance Transport fee and adopt an annual increase of all fees based upon the CPI-U, Medical Care Component, Not Seasonally Adjusted, for the San Diego-Carisbad area, as published by the U.S. Bureau of Labor Statistics, ("CPI-U") in connection with said Schedule of Fees; and
WHEREAS, the Authority is authorized under Health and Safety Code Section 13916 to recover its actual costs reasonably borne in providing its services; and WHEREAS, the Authority provides emergency medical services, ambulance services, and other services relating to the protection of lives to both residents living within the geographicalarea of the Authority and to non-residents working in, visiting or travelling through thegeographical area of the Authority; and WHEREAS, the Authority has determined that an annual increase in all fees based on the CPI-U more accurately reflects the increase in actual costs incurred by the Authority rather than the current three percent (3%) annual increase established and adopted by the Authority's Scheduleof Fees, pursuant to Ordinance No.22-001;and WHEREAS, the Authority has made a reasonable calculation of the actual costs it bears in providing emergency medical services, ambulance services, and other services relating to the protection of lives with respect to Resident Ambulance Transport and Non-Resident AmbulanceTransport within its geographical area; and WHEREAS, the Resident Ambulance Transport and Non-Resident Ambulance Transport fees amended by this ordinance are calculated based on recovering no more than the Authority'sactual costs of providing emergency medical services, ambulance services, and other services relating to the protection of lives in connection with both the Resident Ambulance Transport or Non-Resident Ambulance Transport at an incident for which such services are performed by the Authority; and
Ordinance #:26-001
Date: June 8, 2026
WHEREAS, the proposed Resident Ambulance Transport fee and Non-Resident Transport fee amended and adopted by this ordinance is a reasonable charge for a specific local government service or product provided directly to the payor that is not provided to those notcharged, and which does not exceed the actual costs to the Authority of providing the service orproduct; and WHEREAS, the Authority published notice of its intention to amend the Resident Ambulance Transport fee and Non-Resident Transport fee found on the Authority's existing Schedule of Fees and an amendment thereto providing for an annual increase in all fees based on the CPI-U pursuant to Government Code section 6066 at a public meeting to be held on June 8,2026, and made available all data required by law prior to the public meeting; and WHEREAS, the Commission of the Authority heard and considered any objections or protests to the proposed revision to the Resident Ambulance Transport fee, Non-Resident Ambulance Transport fee and annual increase in all fees based on the CPI-U at its public meetingon June 8, 2026.
NOW, THEREFORE, the Commission of the Santee-Lakeside Emergency Medical Services Authority ordains as follows:
SECTION 1. FINDINGS
The above recitals are true and correct and incorporated herein as findings as though set forthin full.
SECTION 2. STATUTORY AUTHORITY
This ordinance is enacted pursuant to California Health and Safety Code Sections 13910 through 13919.
SECTION 3. APPLICABILITY
This ordinance amends the cost-recovery fee for Resident Ambulance Transports and NonResident Ambulance Transports found in the Authority's Schedule of Fees (EXHIBIT A)and charged by the Authority in accordance with Health and Safety Code Section 13916. Byadopting this ordinance, the Authority is adopting reasonable user fees to recover the actualcosts associated with providing emergency medical services, ambulance services, and otherservices relating to the protection of lives. The cost-recovery fees are charged solely to the user of such services. In addition, this ordinance amends the Authority's Schedule of Fees to include an annual increase in all fees based on the CPI-U which more accurately reflects the increase in actual costs incurred by the Authority in providing said emergency medical services, ambulance services, relating to the protection of lives.
Ordinance #:26-001
Date: June 8, 2026
SECTION 4. AMENDED FEE FOR RESIDENT AMBULANCE TRANSPORT AND NONRESIDENT AMBULANCE TRANSPORT AND ANNUAL INCREASE IN
ALL FEES BASED ON THE CPI-U FOR EMERGENCY MEDICALSERVICES, AMBULANCE SERVICES, AND OTHER SERVICES
RELATING TO THE PROTECTION OF LIVES
(a) The fee for Resident Ambulance Transport found in the Schedule of Fees relates to the protection of lives and is intended to recover the actual and reasonable costs borne by the Authority in providing such services to each person. The fee for Resident Ambulance Transport found in the Schedule of Fees is hereby amended from the amount of $1,240.00 to the amount of $2,800.00 effective 30 days from the date of final passage. (b) The fee for Non-Resident Ambulance Transport found in the Schedule of Fees relates to the protection of lives and is intended to recover the actual and reasonable costs borne bythe Authority in providing such services to each person. The fee for Non-ResidentAmbulance Transport found in the Schedule of Fees is hereby amended from the amount of $2,949.00 to the amount of $3,442.00 effective 30 days from the date of final passage. (c) The Authority has determined that an annual increase in all fees, effective July 1 of each year, based on the CPI-U more accurately reflects the increase in actual costs incurred by the Authority rather than the current three percent (3%) annual increase established and adopted by the Authority's Schedule of Fees (EXHIBIT A). (d) Fees for emergency medical services, ambulance services, and/or other services relating to the protection of lives shall be charged to each person who receives such Authorityprovided services. (e) The Authority, or its designee, is authorized to revise the Authority's Schedule of Fees adopted on December 20, 2022, and as amended on May 17, 2024, solely with respect tothe amended Resident Ambulance Transport fee, Non-Resident Ambulance Transport feeand annual increase in all fees based on the CPI-U adopted in this ordinance and to takeall actions necessary to update and charge said amended fees upon the effective date. Theannual increase in all fees based upon CPI-U will be applicable to the amended Resident Ambulance Transport fee and Non-Resident Ambulance Transport fee adopted in this ordinance just as it will be applied to all other fees in the Authority's Schedule of Fees.
SECTION 5. FEE COLLECTION(a) If the Authority provides emergency medical services, ambulance services, and/or other services relating to the protection of lives to a person, the Authority, or its designee, will sendan invoice seeking payment of the appropriate fee(s) to the person who received the serviceand to the insurance company that provides insurance coverage for the person (the "insurer"),if the person, or his or her representative, has identified to the Authority the insurer to which the invoice should be sent.
(b) The Authority, or its designee, will apply the Authority's policies and procedures for invoicing, billing, and receiving payments for each fee charged under this ordinance.
Ordinance #:26-001
Date: June 8, 2026
SECTION 6. ADMINISTRATION OF THE FEES
The Authority, or its designee, may delegate to any public or private entity all or some of thetasks required for the administration of the fees. Administration of the fees will consist oftasks including, but not limited to, tracking of applicable services provided by the Authority, identification of financially responsible parties, calculation of total fees to be charged, invoicing and payment collection, and the processing of waiver requests and appeals.
SECTION 7. NO EFFECT ON SERVICES BASED ON ABILITY TO PAY Emergency medical services, ambulance services, and/or other services relating to the protection of lives will continue to be provided without regard to whether a person is insured by an insurer, without regard to whether a person has the ability to pay the fee(s), and without regard to whether a person has or has not paid the fee(s) in the past.
SECTION 8. NO WAIVER OF OTHER MEANS OF COST RECOVERY
This ordinance does not preclude the Authority from recovering its emergency response costs in any other manner authorized by law.
SECTION 9. SEVERABILITY
If the amended Resident Ambulance Transport fee, Non-Resident Ambulance Transport fee, annual increase in all fees based on the CPI-LJ or any provision of this ordinance is heldinvalid or unenforceable by a court of competent jurisdiction, that holding shall not affect the validity or enforceability of the remaining fees or provisions of this ordinance or in the previously adopted Schedule of Fees with Ordinance No. 22-001 and as amended in Ordinance No. 24-001. The Commission declares that it would have adopted each remaining part of this ordinance irrespective of any such invalidity. Additionally, this ordinance solely amends the Resident Ambulance Transport fee in the Schedule of Fees as adopted inOrdinance No. 24-001, the Non-Resident Ambulance Transport fee in the Schedule of Feesas adopted in Ordinance No. 22-001 and amends the Schedule of Fees to include an annual increase on July 1 of each year in all fees based on the CPI-U rather than the current three percent (3%) annual increase established and adopted by the Authority's Schedule of Fees (EXHIBIT A). As such, no other provision or fee of Ordinance No. 22-001 or Ordinance No. 24-001 is amended by this ordinance and all the other fees and provisions of OrdinanceNo. 22-001 and Ordinance No. 24-001 continue to be in full force and effect.
SECTION 10. EFFECTIVE DATE
Pursuant to Section 25123 of the Government Code of the State of California, the ordinance shall take effect and be in full force and effect 30 days from the date of final passage.
SECTION 11. PUBLICATION
The Clerk of the Commission shall cause this ordinance to be published in accordance with the requirements of Section 25124 of the Government Code of the State of California.
Ordinance #:26-001
Date: June 8, 2026
INTRODUCED AND READ at a regular meetmg of the Commission of the SanteeLakeside Emergency Medical Services Authority, County of San Diego, State of California, on the 8th Day of June 2026, and thereafter PASSED AND ADOPTED at a regular meeting of theCommission of the Santee-Lakeside Emergency Medical Services Authority, County of San Diego,State of California.
AYES:
NOES:ABSTAIN:ABSENT:
Clerk of the Commission
Janise Bocskovits
None.
Bingham, Minto, Robles, Trotter.
None.
None.
Fee Study Rate increase as of July 8, 2026 per Ordinance # 26-001 Description FeeResident Ambulance Transport $ 2,800.00Non-Resident Ambulance Transport $ 3,442.00 Non-Transport (Treat & Release) $ 162.00Mileage $ /mile (minimum 1 mile) 44.00 Oxygen $ 69.00
Night Charge (1900-0700) $ 43.00
*Standby Charge $ /hour 256.00
2026
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
SCHEDULE OF FEES
Exhbit A to Ordinance 26-001
Rates increase July 8, 2026 by CPI-U, Medical Care Component per Ordinance # 26-001 Description FeeResident Ambulance Transport $ 2,948.00Non-Resident Ambulance Transport $ 3,624.00 Non-Transport (Treat & Release) $ 170.00Mileage $ /mile (minimum 1 mile) 46.00 Oxygen $ 72.00
Night Charge (1900-0700) $ 45.00
*Standby Charge $ /hour 269.00
2026
SANTEE-LAKESIDE EMERGENCY MEDICAL SERVICES AUTHORITY
SCHEDULE OF FEES