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California Public Policy Issues and Resources
Page Last Updated 2/6/2012
Proposed Fees for Camps in State Regulated Areas for Fire Protection
Download a copy of these Key Messages
During summer 2011, an emergency bill ABX1 29 (Blumenfield) was attached to the California state budget bill that addressed emergency fees for fire protection of property within the areas defined as the “State Regulated Area” (SRA). This bill passed and the State Board of Forestry and Fire Protection has now drafted regulations that would implement that bill. The American Camp Association (ACA) became aware of these proposed regulations within the last week and submitted a response letter during the short five-day comment period. When reviewing a map of the SRA, it is evident that many camps could be impacted by the new regulations.
Key Elements of the Proposed Regulation
The regulations would impose an annual fee of $150 per “habitable structure” for those properties within the SRA.
Definition of a Habitable Structure
- A building that contains one or more dwelling units or that can be occupied for residential use. Such structures provide independent living facilities for one or more persons including provisions for living, sleeping, eating, cooking and sanitation.
- Examples would include single-family homes, multi-dwelling structures, mobile and manufactured homes, and condominiums.
- Habitable structures do not include incidental buildings such as detached garages, barns, outdoor sanitation facilities and sheds.
- ACA has been told a habitable structure does not include dormitories, cabins, etc. that are used only for sleeping or buildings that do not contain all elements of the definition (provisions for living, sleeping, eating, cooking and sanitation).
- ACA projects that many camps could have a number of structures that meet the definition of a habitable structure.
Relationship to Local Fire Protection Agencies
- According to the proposed regulations, if the SRA property owner also pays for local fire protection services rather than State services, the fee could be reduced by $35 per habitable structure.
- The State’s rationale for this double charge is that the activities of the state fire prevention services are what keep wild land fires from approaching too close to those areas.
Key Messages in ACA’s Response Letter
- ACA supports and values the work of the California state fire prevention and protection services.
- ACA camps are diligent about defensible space and fuel reduction on their sites working closely with fire protection personnel.
- We asked for further clarification and interpretation of a “habitable structure” understanding there are a wide variety of facilities in camps.
- We noted that, depending upon the interpretation of a habitable structure, the proposed fees could have a tremendous financial impact on camps and their ability to continue to offer programs for the children and families of California.
- We offered some alternatives to the proposed fee structure:
- Deem a camp to be one entity, and only assess one fee per camp
- Where there are multiple habitable structures in one camp, assess a reduced fee per structure
- Develop a sliding fee scale based on number and type of structures located at a camp
- Exempt camps from the fees entirely
Further Anticipated Action from the Forestry and Fire Protection Board
- The Resource Protection Committee of the Board will meet and review the comments in order to make decisions about how to proceed.
- We believe that a number of other organizations may have submitted comments, since many were not aware of the proposal until after the written regulations were issued.
Further Opportunity for ACA to have Input
- ACA has offered to provide more detail to the Board about the impact of the proposed regulations.
- ACA will also be working closely with our camp allies, through the California Collaboration for Youth (“CCFY”) which includes Boy Scouts of America, Western Association of Independent Camps, Christian Camp and Conference Association, YMCA, and Guided Discoveries, to be sure the needs of camps are recognized, while the Board considers these important fire prevention issues.
Please complete the survey at this link http://www.surveymonkey.com/s/G99RNFT We need to know immediately how many camps are impacted by virtue of being located within the SRA. (We will not use camp names when we share aggregated information). Visit this link to determine if your camp is located within the SRA.
Have questions or want further information, contact the ACA, Northern California or Southern California/Hawaii Field Office.