AGENDA
ITEM
13 AGENDA
CALEXICO California ITEM
WHERE CALIFORNIA AND MEXICO MECT
13 CITY COUNCIL
AGENDA STAFF REPORT
DATE: November 19, 2025
TO: Mayor and City Council
APPROVED BY: Benjamin A. Martinez, City Manager
REVIEWED BY: Karla Chaparro, Finance Director JU
PREPARED BY: Jesus Villegas, Public Works Director/City Engineer SUBJECT: 46th Annual Farmworker Appreciation Breakfast
a) Approval of $2,366.09 from Fund No. 111 - General Fund and Fund No. 231 - Streets for City Staff In-Kind Services.
======== ===============: SEES====
Recommendation:
It is recommended that the City Council of the City of Calexico review and consider the following:
a) Approval of $2,366.09 from Fund No. 111 - General Fund and Fund No. 231 - Streets for City Staff In-Kind Services.
Background:
On December 5, 2025, the Center for Employment Training will be hosting the 46th Annual Farmworkers Appreciation Breakfast at 301 Heber Avenue from 1:00a.m. to 5:00a.m.
Discussion and Analysis:
On November 4, 2025, the Center for Employment Training submitted a Temporary Use Permit Application for their 46th Annual Farmworkers Appreciation Breakfast. As part of their application, Center for Employment Training is requesting City of Calexico Public Works Department assistance with the following in-kind services:
• 12/04/25 - cleaning parking lot, set up canopies, installation of banners, large trash bins, etc.
• 12/05/25 - cleaning parking lot, removal of canopies, removal of banners, removal of trash bins, etc.
As per Resolution No. 2020-03, Section 3 - Adoption of Fee Waiver Limit, the City Manager or designee can waive any fees owed to the City up to $500.00 if they meet the Fee Waiver Policy guidelines. Seeing that Center for Employment Training does meet the Fee Waiver Policy guidelines but does not meet the $500.00 threshold, City staff is requesting that the City Council review and consider the approval of $2,366.09 from Fund No. 111 - General Fund and Fund No. 231 - Streets for City Staff In-Kind Services.
Fiscal Impact:
Revenue
In-Kind Services (Fund No. 111 - General Fund and Fund No. 231 - Streets $2,366.09 $2,366.09
Expenditure
City of Calexico Administrative Fee $2,366.09
Total $2,366.09
Coordinated With:
City Manager's Office.
Finance Department.
Public Works Department.
Attachments):
46th Annual Farmworkers Appreciation Breakfast Training Temporary Use Permit Application.
2. 46t Annual Farmworkers Appreciation Breakfast Invoice.
Resolution No. 2020-03 - Adopting a Fee Waiver Policy and Setting A Fee Waiver 2 ATTACHMENT NO. 1
RECEIVED
UV 0 4 2029
it
608 Heber Avenue
Calexico, CA 92231 City of Calexico BY:_
(760) 768-2105
Fax # (760) 357-7862 Development Services Department
www.calexico.ca.gov Planning Division
[email protected]
CALEXICO EMPORARY USE PERMI
PPLICATIOR
Request must be submitted a MINIMUM of fifteen (15) days in advance of the event date.
REQUIRED ATTACHMENTS:
1. Submit one (I) site plan depicting use (minimum size 8.5" × 11").
2. Written proof of approval from property owner.
3. Copy of the City of Calexico Business License, if applicable.
4. Non-refundable application filing fee of $135.00.
5. Insurance coverage naming the City as additional insured ($2,000,000 minimum per occurrence).
Applicant Name: Elvira Anaya Date Submitted: 10 / 08 / 2025 Applicant Address: 294 S 3rd St., El Centro, CA 92243 Phone Number: (760 ) 265 - 2780 Company Name: Center for Employment Training Alt. Phone Number: (760 ) 337 - 6565 Location of Event: 301 Heber Ave., Calexico, CA 92231 Business License: #390672 Date of Event: 12 /05 / 2025 to 12 /05 / 2025 Total Days: 1 Time of Event: 01 : 00 a.m. to 05 : 00
a.m.
Please describe IN DETAIL the proposed use of subject property for which the temporary use permit is requested. (Please attach additional sheets if necessary):
We kindly request support from your team from Public Works for the setup and breakdown of the 46th Annual Farmworker Appreciation On the morning of Thursday, December 4, 2025, we will need assistance with cleaning the parking lot, setting up canopies, and placing banners on the building. Breakdown and removal of equipment and banners will take place on Monday, December 8, 2025, unless staff are unavailable on Friday. Please provide two extra-large trash bins, ensuring they are unlocked and emptied prior to delivery, and place four additional trash cans under the canopies for event use. We also request that street barriers be placed to block off the area from December 4 to December 5 until 5:00 a.m.. Please ensure no ticketing occurs in the parking lot during this time. The Heber Avenue/3rd Street lot should remain open for EDD staff, while the One-Stop parking lot will be be closed all day on Thursday, December 4, 2025, for event setup.
Thank you for your continued support in making this event a success. 10/08/2025
Applicant Signature: Date:
(Please read reverse side, Section 17.11.120 "Temporary Use Regulations") Revised 01/2016
DUMPSTERS DUMPSTERS DUMPSTERS
ALLEY
CLEAN UTENCILS
CLEAN UTENCILS
AGENCY AGENCY AGENCY AGENCY AGENCY AGENCY
TAR E TABLE ТАВ:Г TABLE
Restrooms: Gas Burner TABLE AGENCY
Vien & Wamen Men&Women
TABLE AGENCY
obby Area
2 indoors
SIDE ENTRANCE
TABLE AGENCY Icar Port
*
Calexico AJCC (One Stop)
TABLE AGENCY
SIDE WALK
Bathroom Stalls
TABLE AGENCY •04* Space Heaters
HEBER AVENUE Kitchen Sink
Trash Cans
*
TABLE AGENCY
I MAIN ENTRANCE
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TABLE AGENCY
Paw eacell
FOODLINE
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FOOD LINE an buice
STARTS
SIDE WALK
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E. 3RD STREET
PORT-A-POTTIES
FARM WORKER SERVICES
COALITION OF IMPERIAL
COUNTY
"Serving the workers who provide food to the
world"
October 08, 2025
Re: Waiver of Fee for Temporary Use Permit
Dear Ms. Diana Nuricumbo,
The Farm worker Services Coalition of Imperial County is proud to announce the celebration of its 46th Annual Farm Worker Appreciation Breakfast on Friday, December 5, 2025. As it is custom, the event will be held at the America's Job Center at 301 Heber Avenue in Calexico.
I hereby respectfully request that the City of Calexico waive the fee for the Temporary Use Permit as the City of Calexico is a supporter and sponsored of this annual event.
Should you have any questions? Please do not hesitate to contact me at your earliest convenience.
Sincerely,
Elvira Anaya
FWSCIC Chairperson
760-337-6565
APPLICATION FOR FEE WAIVER
The City of Calexico recognizes the value of partnering with other agencies and organizations in providing services that benefit the community and its residents. In an effort to provide support for organizations providing valuable services to the community, specific guidelines have been established for determining when temporary use permit fees, special event permit fees, other permit fees, and facility fees may be waived. In order to request a waiver of fees, please complete this application and submit it with necessary documentation to the address provided on the last page.
ORGANIZATION INFORMATION
Name of Organization: Farmworker Services Coalition Of Imperial County Address: 294 S 3rd St., El Centro, CA 92243 Phone: 760-337-6565 Event Coordinator: Elvira Anaya/ Jesse Aguirre Phone: 760-265-2780/ 760-336-1327 Email: [email protected]/[email protected]
Nonprofit 501(c)3 tax cxempt organization? Please check: M' Yes L No Located in Calexico? Please check: • Yes
Has organization received any other financial assistance from the City of Calexico within the last twelve (12) months?
Please check: • Yes MNO
Fee waiver amount request: $TBD- City of Calexico Cost
EVENT INFORMATION
Name of Event: 46th Annual Farmworker Appreciation Breakfast Type of Event (i.e., parade, street party, etc.): Farmworker Appreciation Breakfast/ Celebration Facility Requested or Event Location: 301 Heber Ave., Calexico, CA 92231 Date of Event: 12/05/2025 Event Hours: 1:00 am - 5:00 am On which dates and at what times are you requesting permission to setup and cleanup? Setup: 12/04/2025 07:00 AM To: 11:00 PM
Date: From:
Cleanup: Date: 12/05/2025 From: 05:00 AM To: 08:00 AM
In-kind services offered: Trash Bins, Banners Placed and Reroved from Building, Barriers to block street, and Parking Lot parking -1-
81211.00100132585485.2
Please describe the event, its purpose, and the activities that will take place:
A breakfast as a thank you for local Farmworkers, they will be served a complete breakfast, live band will be playing music, certain farmworkers will be recognized.
Dancing contest between farmworkers, resource tables with crucial resources for farmworkers, and prize give aways for farmworkers.
Is this event open to the public? Please check: D Yes • No Estimated number of participants/spectators: 2500
Is this event a fundraiser? Please check: • Yes & No
Will there be an admission, entrance, user fee, or cover charge for the event? If so, please explain:
How will the event benefit the Calexico community?
Tested nare as a pold toilet the dedcaten and hard work of tammodes, hote for emus bed che eurtifice easy dry. By houng that-stal galey for mary tomsder come cal-the thy has unique deportety to teners serteens Has your organization put on this same event in the past? Please check: / Yes LI No If not, has your organization put on other events in Calexico? Please indicate which ones:
This event has taken place in the City of Calexico for over 35 years.
Explain how imposition of fees would create financial hardship on the organization or would have a detrimental effect up on the services provided to the public:
The organization is a non-profit coalition and depends on sponsors to make this event a reality. /e
Signature of Applicant: Date: 10/02/2025
Please deliver completed applications to City of Calexico, 608 Heber Avenue Calexico, California (760) 768-2110 along with a copy of your organization's IRS 501(c) determination letter or Calexico business license of state seller's permit, financial statements from the prior year's event, and proposed budget for the current year's event. Applicants sponsoring an event for the first time will only be required to submit the current year's proposed budget.
Please note that applications must be submitted at least twenty one (21) days prior to the event, but not more than six (6) months prior to the event. Incomplete applications or requests made within less than 21 days of an event will not be considered. - 2-
81211.00100132585485.2
ACORD® DATE (MM/DD/VYYY)
CERTIFICATE OF LIABILITY INSURANCE
11/4/2025
THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS
CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURERS), AUTHORIZED
REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER
IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the pollcy(les) must have ADDITIONAL INSURED provisions or be endorsed If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsements).
PRODUCER CONTACT HIB Cert Team
NAME
(SM) Heffernan Insurance Brokers HONE
1820 Gateway Drive, #330 AIG. No. Ext): 650-842-5200 FAG, No): 650-842-5201 E-MAIL
San Mateo CA 94404 ADDRESS: [email protected]
INSURERS) AFFORDING COVERAGE NAIC #I
icense#: 0564249 INSURERA: Philadelphia Indemnity Insurance Company 18058 INSURED :ENTFO-28
INSURER B: Berkshire Hathaway Homestate Insurance Company 20044 Center for Employment Training
701 Vine St INSURER C: Travelers Casualty and Surety Company 19038 San Jose CA 95110 INSURER D:
INSURERE:
INSURER F:
CERTIFICATE NUMBER: 1571137737 REVISION NUMBER:
THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOL
INDICATED, NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS
INSE TYPE OF INSURANCE
POLICY NUMBER
A X | COMMERCIAL GENERALLIABILITY PHPK2649495-014 1/26/2026
EACH OCCURRENCE
CLAIMS-MADE X OCCUR DAMAGE TO RENTED
PREMISES (Ea occurrence | $ 300,000
I MED EXP (Any one porson |$ 15,000
PERSONAL & ADV INJURY $ 1,000.000
GEN'L AGGREGATE LIMIT APPLIES PER: GENERALAGGREGATE. 32,000,000 X POLICY PEO /LOC PRODUCTS- COMPOP AGG | $2,000,000
OTHER:
A AUTOMOBILE LIABILITY PHPK2649495-014 1/26/2025 1/26/2026 COMBINED SINGLE LIMIT $ 1,000,000 (En accident).
X ANY AUTO BODILY INJURY (Por person)
OWNED
AUTOS ONLY AUTOS BODILY INJURY (Par accidenl) S
HIRED
AUTOS ONLY
Comp/Coll Deductible $1,000
| UMBRELLALIAB OCCUR PHUB898557-014 1/26/2025 1/26/2026 EACH OCCURRENCE $5.000,000 EXCESS LIAB CLAIMS-MADE AGGREGATE 55,000,000
DED | X RETENTIONS 11,000.
B WORKERS COMPENSATION CEWC667905 711/2025 714/2026
AND EMPLOYERS' LIABILITY
ANYPROPRIETOR/PARTNER/EXECUTIVE XIN
OFFICERMEMBEREXCLUDED? NIA E.L. EACH ACCIDENT $1,000,000 EL. DISEASE - EA EMPLOYEE $ 1,000.000
DESCRIPTION RATIONS below! ELOISEASE- POLICY LIMIT $1.000.000 HPK2649495-014 26/20 1/26/2026 TOMSBOK
064526 26/20 1/26/2026
Fe: AS Per of ad or Agreement on File i sure in unrela rail is neera abir policy as per the policy forms, if required, This certificate supersedes and replaces any previously issued certificate.
CERTIFICATE HOLDER CANCELLATION
SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE
THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN ACCORDANCE WITH THE POLICY PROVISIONS.
City of Calexico
608 Heber Avenue AUTHORIZED REPRESENTATIVE
Calexico, CA 92231
1988-2015 ACORD CORPORATION. All rights reserved.
ACORD 25(2016/03) The ACORD name and logo are registered marks of ACORD ATTACHMENT NO. 2
CITY OF CALEXICO INVOICE NO. 2025-01
PUBLIC WORKS DEPARTMENT
FARMWORKERS BREAKFAST
DEC. 5, 2025
1:00A.M. TO 5:00A.M
ESTIMATED HOURLY ESTIMATED
HOUR(S) RATE COST
CATEGORY A - ADMINISTATION
Task 1: Project Management
Public Works Manager - Admin 51.33
Water System Supervisor 10240 g 47.75
Sub-Total 99.08
CATEGORY B - ASSISTANCE SETTING UP FOR THE EVENT 12/04/2025 Task 4: Personnel
Water System Supervisor 2 $ 95.49 $ 190.98
Laborer 6 $ 45.41 $ 272.46
Laborer 6 $ 29.45 $ 176.70
Laborer 6 $ 29.45 $ 176.70
Laborer 6 $ 29.45 $ 176.70
Laborer 6 $ 29.45 $ 176.70
Task 5: Equipment
Reach Lift 5 $ 40.00 $ 200.00
Medium Truck 2$ 40.00 $ 80.00
Medium Truck 2$ 40.00 $ 80.00
Sub-Total $ 1,530.24
CATEGORY C - REMOVAL OF BANNERS 12/05/2025
Task 6: Personnel
Water System Supervisor 1 $ 95.49 $ 95.49
Laborer 3$ 45.41 $ 136.23
Laborer 29.45 $ 88.35
Laborer m m es es 29.45 $ 88.35
Laborer 3 $ 29.45 $ $8.35
Task 7: Equipment
Reach Lift 2$ 40.00 $ 80.00
Medium Truck 2$ 40.00 $ 80.00
Medium Truck 2$ 40.00 es is 80.00
Sub-Total 736.77
Total $ 2,366.09
ATTACHMENT NO. 3
RESOLUTION NO. 2020-03
A RESOLUTION OF THE CITY COUNCIL OF THE CITY
OF CALEXICO, CALIFORNIA, ADOPTING A FEE
WAIVER POLICY AND SETTING A FEE WAIVER LIMIT.
WHEREAS, the City of Calexico, California ("City") often receives requests for fee waivers from charitable, nonprofit, and other service-oriented organizations operating within the City; and, WHEREAS, the City would like to establish an administrative process for such organizations to request and obtain fee waivers from the City; and,
WHEREAS, the envisioned administrative process will generate records for the City, such that the City can monitor the fiscal impact of allowing fee waivers; and, WHEREAS, the purpose of this Resolution is for the City Council of the City of Calexico, California ("City Council"), to adopt a Fee Waiver Policy.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Calexico, California, as follows:
SECTION 1. Recitals. The City Council hereby finds that the foregoing recitals are true and correct and are incorporated herein as substantive findings of this Resolution.
SECTION 2. Adoption of Fee Waiver Policy. The Fee Waiver Policy attached hereto and incorporated herewith as Exhibit "A" is approved and may be amended from time to time.
SECTION 3. Adoption of Fee Waiver Limit. The City Council hereby authorizes the City Manager, or designee, to waive any fee owed to the City, up to five hundred dollars ($500.00), as provided for in the Fee Waiver Policy.
SECTION 4. CEQA. The City Council hereby finds and determines that this Resolution relates to organizational or administrative activities of governments that will not result in direct or indirect physical changes in the environment, and therefore is not a project within the meaning of the California Environmental Quality Act ("CEQA") and the State CEQA Guidelines, section 15378(b)(5).
SECTION 5. Severability. If any provision of this Resolution or the application thereof to any person or circumstance is held invalid, such invalidity shall not affect other provisions or applications of the Resolution which can be given effect without the invalid provision or application, and to this end the provisions of this Resolution are severable. The City Council hereby declares that it would have adopted this Resolution irrespective of the invalidity of any particular portion thereof.
SECTION 6. Effective Date of Resolution. This Resolution shall take effect immediately upon its adoption.
Resolution No. 2020-03
PASSED, APPROVED, AND ADOPTED by the City Council of the City of Calexico, California, at a regular meeting held on this 22 day of January, 2020.
AYES: Hodge, Romero, Arreola-Fernandez, Reisin, Pacheco NOES: None
ABSENT: None
ABSTAIN: None
Bise Forky
Bill Hodge, Mayor
ATTEST:
Gabripta T: Garcia, City Clerk
APPROVED AS TO FORM:
Carlos Campos, City Attorney
81211.00100132595008.1 -2-
Resolution No. 2020-03
State of California
County of Imperial ) SS.
City of Calexico
I, Gabriela T. Garcia, City Clerk of the City of Calexico, California do hereby certify the above Resolution No. 2020-03 was approved at a regular City Council meeting held on the 22nd day of January 2020, by the following vote to wit:
AYES: Hodge, Romero, Arreola-Fernandez, Reisin, Pacheco NOES: None
ABSTAIN: None
ABSENT: None
Garcia, City Clerk
81211.00100132595008.1 -3-
Resolution No. 2020-03
EXHIBIT "A"
FEE WAIVER POLICY
81211.0010032595008.1 -4.
FEE WAIVER POLICY
This policy establishes parameters for waiving fees associated with special events (i.e., permit fees, facility fees) or temporary uses.
1. PURPOSE
The purpose of this policy is to provide an equitable means for charitable, community, and service-related organizations to access fee waivers.
2. BACKGROUND
Fee waivers are an expense to the City's General Fund. Fees are established to pay for the cost of a service provided by a City department. When a fee waiver is granted, the City General Fund pays the department in an amount equal to the fee waived.
3. RESPONSIBILITY
Fee waivers are determined by the City Manager, or designee, who shall ensure that department staff follow the procedures set forth in this policy.
4. POLICY
A. Eligible Events, Uses, and Activities
Fee waivers are available to wide variety of events including sporting, tourism, cultural, and community events.
Fee waivers will be considered for:
• Non-profit entities that have a documented federal tax exempt status; • Other governmental agencies; and
• Charitable, community, and service-related organizations that demonstrate that fees will cause a financial hardship.
The following projects and organizers, for example, are ineligible:
• For-profit organizations;
• Vendors; and
• Fundraising events where attendees pay a fee for admission to the event or, in the case of festivals, where vendors pay to participate in the event.
B. Fee Waivers
Fee waivers are available for special event permit fees, temporary use permit fees, other permit fees, facility fees, and may include direct costs, such as staff time.
Any applicant may have its permit and/or facility fees waived if the said organization or entity provides an in-kind or other contribution of goods, services, or programs that will benefit the City of Calexico or its residents. All proposed special consideration must be equal to or exceed the value of the reduced fee or provide a substantial but immeasurable benefit. - 1-
81211.00100\32585485.2
Any waiver of permit or facility fees allowed above will not affect the obligation of a permittee to comply with the remaining qualifications, restrictions, and criteria of this policy or to pay other costs or to provide insurance as required by this policy or by ordinance. Business license, health permit, fire permit, and liquor license fees will not be waived or reduced.
C. Guidelines
Scheduling and use of City facilities are subject to the availability of the requested facilities.
Decisions made by the City Manager, or designee, may be appealed to City Council.
Applicants are required to adhere to all applicable rules, regulations, laws, and ordinances of the City of Calexico and other applicable governmental entities.
Applicants that fail to abide by the policy and procedures set forth in this policy will be ineligible to request a fee waiver for a period of at least one (1) year.
PROCEDURES
Requests for fee waiver must be made in writing by using the attached application and delivered to the City Manager, or designee, along with a copy of the organization's IRS 501(c) determination letter (if applicable), financial statements from the prior year's event (if applicable), and the proposed budget for the current year's event.
Applications must be submitted at least twenty one (21) days prior to the event, but not more than six (6) months prior to the event. Requests made within less than twenty one (21) days of an event will not be considered.
The City Manager or designee will forward the request to the appropriate departments to evaluate eligibility and estimate the fee waiver.
- 2-
81211.0010032585485.2
APPLICATION FOR FEE WAIVER
The City of Calexico recognizes the value of partnering with other agencies and organizations in providing services that benefit the community and its residents. In an effort to provide support for organizations providing valuable services to the community, specific guidelines have been established for determining when temporary use permit fees, special event permit fees, other permit fees, and facility fees may be waived. In order to request a waiver of fees, please complete this application and submit it with necessary documentation to the address provided on the last page.
ORGANIZATION INFORMATION
Name of Organization:
Address: Phone:
Event Coordinator: Phone:
Email:
Nonprofit 501(c)3 tax exempt organization? Please check: • Yes • No Located in Calexico? Please check: • Yes • No
Has organization received any other financial assistance from the City of Calexico within the last twelve (12) months?
Please check: • Yes • No
Fee waiver amount request: $
EVENT INFORMATION
Name of Event:
Type of Event (i.e., parade, street party, etc.):
Facility Requested or Event Location:
Date of Event: Event Hours:
On which dates and at what times are you requesting permission to setup and cleanup? Setup: Date: From: To:
Cleanup: Date: From: To:
In-kind services offered:
- 1 -
81211.00100132585485.2
Please describe the event, its purpose, and the activities that will take place:
Is this event open to the public? Please check: • Yes • No Estimated number of participants/spectators:
Is this event a fundraiser? Please check: • Yes • No
Will there be an admission, entrance, user fee, of cover charge for the event? If so, please explain:
How will the event benefit the Calexico community?
Has your organization put on this same event in the past? Please check: • Yes • No If not, has your organization put on other events in Calexico? Please indicate which ones:
Explain how imposition of fees would create financial hardship on the organization or would have a detrimental effect up on the services provided to the public:
Signature of Applicant: Date:
Please deliver completed applications to City of Calexico, 608 Heber Avenue Calexico, California (760) 768-2110 along with a copy of your organization's IRS 501(c) determination letter or Calexico business license ot state seller's permit, financial statements from the prior year's event, and proposed budget for the current year's event. Applicants sponsoring an event for the first time will only be required to submit the current year's proposed budget.
Please note that applications must be submitted at least twenty one (21) days prior to the event, but not more than six (6) months prior to the event. Incomplete applications or requests made within less than 21 days of an event will not be considered. - 2 -
81211.00100\32585485.2