Proposed State EMSA regulations could have HUGE negative impact on fire service EMS

By Scott Clough, CSFA EMS Chair            

As you may have seen, the State EMS Authority “EMSA” has released their proposed regulations for how ambulance zones and EMS are going to be managed into the future.  From a historical perspective public providers, primarily fire agencies, receive their authority to provide EMS services via 2.5 of the California Health and Safety Code and more specifically 1797.201.

These regulations if adopted have a significant negative impact to all of us (.201 or not) on a major scale.

If your agency has been around since before 1980 your authority to provide EMS services is currently guaranteed by statute.  If the proposed regulations that have been put forth are adopted, these changes will limit your ability to provide EMS services to your jurisdictions.  Supervision and oversite would be taken out of your hands and placed with the County LEMSA to manage.  Below are just a few of the examples of how these proposed regulations would affect your agencies. 

  • Response; the LEMSA would determine which EMS calls you respond to, the mode you are responding and how and when you are dispatched.This means that if the LEMSA has determined that there is no need to respond an engine or truck to a particular incident type then you will not be permitted to respond to those incident types.The LEMSA will also determine the mode you respond meaning that the LEMSA will determine which calls you respond to code-3 or code-.
  • Ambulances; currently the majority of fire departments operate their ambulances under 1797.201.This statute mandates that .201 providers must provide those services within their jurisdictions.These regulations would remove the .201 provisions and force departments to competitively bid for the rights to provide ambulance services.
  • Contracting for services; across the state there are a number of agencies that provide ambulance services via contract. These regulations would disallow the ability for agencies to contract for ambulance services on their behalf.1797.201 specifically allow contracting for ambulance services.This means agencies like Anaheim, Costa Mesa, Contra Costa, Santa Monica, Sacramento Metro and many others would not be allowed contract for their ambulance service or even augment their current deployment with another fire agency or private ambulance provider.
  • ALS and BLS services; if your agency is a .201 provider then your ability to increase or decrease your level of service is currently protected by statute.If your agency is operating under an agreement to provide ALS services it is probably due to the fact that your elected officials have determined that the level of service either ALS or BLS is appropriate for your jurisdiction.Under these proposed regulations the decision on whether you operate ALS or BLS services is determined by the LEMSA not your governing board or your citizens you serve.

  Questions you should be asking yourself

  • Who is best positioned to know the service needs of your community?The County LEMSA or the agency the tax payers trust to protect them?
  • If your agency is providing ALS service are you comfortable with the LEMSA deciding that is no longer needed?Are your tax payers comfortable with throwing out the tax payer investment into your department (monitors, medications, paramedics and jobs)
  • As a paramedic or EMT are you comfortable with the LEMSA deciding it’s time for you to stop your profession, that your education and training are no longer needed or relevant?Shouldn’t the tax payers paying your salary determine when your services are no longer needed?
  • If your LEMSA determined that your agency only needed to respond to the most critical of incidents and the occasional fire how that would affect your jobs?Would the public see the same value if your agency’s call volume dropped 50, 60 or 70 percent?
  • Would your paycheck look the same if your EMT or paramedic license was no longer a factor or even needed?
  • Are you comfortable relinquishing control for the safety and care of YOUR community, YOUR taxpayers and potentially YOUR jobs to the county LEMSA?

What are the next steps

  • Stay active with CSFA and participate!!!
  • Educate yourself with the proposed regulations and the Cal Chiefs legal response to the State
  • Contact your CSFA representative or the EMS chair with your questions
  • Educate your elected boards or city council’s as to the impacts these regulations have on your community, taxpayers, and firefighter jobs
  • Address your elected officials during public comment to keep them informed (if you’re not comfortable we can provide you talking points or even attend your meeting as CSFA reps)
  • Inform your local and state representatives as to the major impact these proposed regulations have on public safety

These issues are not to be taken lightly.  Our ability to provide the best services possible regardless of whether they are EMS, rescue, TEMS, fires, Haz Mat, etc. should be determined by the people that pay for the services.  Not the bureaucrats at the LEMSA level.  Your partners at Cal Chiefs have estimated that if these proposed regulations were to be passed as written the financial impact to local fire agencies across the state would be well above the billion dollar mark and would likely result in the loss of thousands of firefighter jobs.  Fire agencies that transport now would need to competitively bid for the right to provide transport.  Every decade or so these agencies would need to repeat that competitive process.  If not successful in subsequent bids would your agency be able to absorb those ambulance positions? If your agency was to lose the first bid for service how many of your brother and sisters would be terminated?  These are the facts if these proposed regulations were to become reality.

I urge you to educate yourselves, your elected officials, your community, and commit to be active in this fight to preserve public safety where it belongs which is with a public safety organization US!  

About the author: Scott Clough is a CSFA Life member and Chair of the CSFA EMS Committee. He may be reached at (916) 207-9075 or


Follow this link to make public comments on the Chapter 13 EMS system regulations. Deadline for comments is June 8, 2020.


Follow this link to read a copy of the formal request from the California Fire Chiefs Association legal counsel requesting that the California Emergency Medical Services Authority (EMSA) withdraw the proposed Chapter 13 Regulations for failure to comply with certain substantive and procedural requirements for rulemaking under the Administrative Procedures Act.