EAST PALO ALTO
CITY COUNCIL
STAFF REPORT
DATE: January 25, 2022
TO: Honorable Mayor and Members of the City Council
VIA: Jaime M. Fontes, City Manager
BY: Rachel Horst, Housing and Economic Development Manager Karen Camacho, Housing Project Manager
SUBJECT: Introduction of East Palo Alto Opportunity to Purchase Act ("EPA OPA") Ordinance
Recommendation
Waive the first reading and introduce an Ordinance titled “East Palo Alto Opportunity to Purchase Act” (“EPA OPA”), adding Chapter 14.26 to the East Palo Alto Municipal Code.
Alignment with City Council Strategic Plan
This recommendation is primarily aligned with:
Priority No. 6: Create a Healthy and Safe Community
Background
In June 2019, the City Council directed staff to apply for a Partnership for the Bay’s Future Challenge Grant for Housing Protection and Preservation (“Challenge Grant”) to achieve three main goals: (1) Establishing a sustainable funding source for housing preservation; (2) launching a preservation model centered on a Community Land Trust (“CLT”) to acquire, rehabilitate, and redevelop properties; and (3) designing and supporting the passage of a local preservation ordinance- a Tenant Opportunity to Purchase Act/Community Opportunity to Purchase Act (“TOPA/COPA policy”).
After receiving a Challenge Grant award, in January 2020, City staff began researching and developing an East Palo Alto Opportunity to Purchase Act (“EPA OPA,” or “Ordinance”).
Figure 1 lists the major milestones that have occurred in the OPA Process:
Figure 1
EPA OPA Milestones
Date Description
June 4, 2019
Council adopted Resolution No. 5128, authorizing the City Manager to submit an application to the Partnership for the Bay’s Future for a Challenge Grant for Housing Protection and Preservation (“Challenge Grant”).
November 2019
The City was awarded a Challenge Grant. Challenge Grant Fellow began work in February 2020 and continued through 2020 and 2021.
January 2021
City Council adopted as one of its Council Priorities, “Advancing the Concept of TOPA/COPA and Other Homeownership
Opportunities.”
July 20, 2021
Staff provided an update on Challenge Grant progress to City Council and received authorization to apply for a Partnership for the Bay’s Future Breakthrough Grant.
July 2021 –
September 2021
Nine Affinity Group meetings (67 participants) and two Focus Group meetings (19 participants) were conducted to gather community input. Participants consisted of homeowners, tenants, landlords, and real estate agents.
October 5, 2021
Policy & Action City Council item to provide a report on OPA progress and seek direction on development of an ordinance. City staff were directed to bring back a proposed OPA Ordinance for hearing.
November 16,
2021
Public hearing for OPA Ordinance. City Council directed staff to hold a community meeting on OPA and return to the next City Council meeting with an updated Ordinance.
December 1,
2021
Community meeting via Zoom on OPA with 276 participants and 72 speakers.
December 3 & 6,
2021
Staff hosted virtual office hours to provide residents and stakeholders with an additional opportunity to ask questions or express concerns.
December 7,
2021
Public hearing for OPA. Staff presented on recommended
changes to the Ordinance based on City Council direction and extensive community feedback. City Council took over two hours of public comment from 128 speakers and continued the item to December 22.
December 22,
2021
Public Hearing and First Reading of OPA Ordinance. Staff proposed several amendments to the Ordinance based on
extensive public feedback since the first draft was published for consideration at the November 16, 2021 City Council meeting.1 January 13 & 14,
2022
Staff hosted accessible office hours to receive further community input.
This staff report addresses City Council direction to staff at the December 22 Public Hearing to:
1.) return with an amended Ordinance for consideration at the January 18, 2022 meeting;
2.) provide an analysis of the OPA Ordinance by the consulting firm David Rosen & Associates; and
3.) provide further clarification on Qualified Nonprofits and foreclosures.
Analysis
Changes to OPA Ordinance
The Ordinance can be found in Attachment 1. Staff made changes to the Ordinance based on the following City Council direction:
1. Exempt properties from the Ordinance that are owned by East Palo Alto residents.
2. Exempt households with emergency circumstances from the Ordinance.
3. Break down the 30-day Statement of Interest period into two phases of 15 days each, requiring Potential Eligible Purchasers to express interest in exercising their rights under the Ordinance within the first 15 days after receiving a Notice of Intent to Sell, followed by a Statement of Interest 15 days thereafter (if applicable).
4. Allow for shortening of the OPA timelines with the consent of both parties in cases where there is only one Potential Eligible Purchaser.
5. Shorten the timelines overall, with the goal of a 90-day maximum timeline for single family dwellings.
Each of these Ordinance changes is discussed in detail below.
1. Exempt properties from the Ordinance that are owned by East Palo Alto residents.
Updated Subsection 14.26.040.A.2
2. Non-Owner-Occupied Residential Property owned by an East Palo Alto resident, when the Owner has occupied a Residential Property within East Palo Alto as the Owner’s Principal Residence for more than one (1) year. This exemption shall not apply when any Residential Property is owned by:
a) A real estate investment trust, as defined in Section 856 of the Internal Revenue 1 The full December 22, 2021 public hearing item can be viewed at:
http://eastpaloalto.iqm2.com/Citizens/FileOpen.aspx?Type=1&ID=1410&Inline=True Code;
b) A corporation; or
c) A limited liability company in which at least one member is a corporation.
The above language exempts properties where the owner is an East Palo Alto resident. To qualify as an East Palo Alto resident for this exemption, the owner must have a principal residence at another property in East Palo Alto for more than one year. This subsection uses the definition of investor-owned properties in CA Civil Code Section 1947.12 (AB 1482) to further clarify that this exemption applies only when both properties are owned by a natural person.
2. Exempt East Palo Alto residents with emergency circumstances.
Updated Subsection 14.26.040.B.10
A transfer of a Residential Property having no more than four (4) Dwelling Units made for the purpose of either: (a) paying for imminently necessary health care expenses of an Owner of the Residential Property, or (b) an emergency circumstance placing the Owner in financial hardship and at imminent risk of foreclosure or bankruptcy and the Owner has occupied the Residential Property as the Owner’s Principal Residence during the prior year. For purposes of this subsection only, “Owner” shall be limited to a natural person having an undivided interest in the Residential Property of at least fifty percent (50%). An Owner may claim this Exempt Transfer within one year of having vacated the Residential Property where the Owner demonstrates the existence of the conditions set forth in (a) or (b) of this subsection.
The prior transfer exemption included health emergencies only-- specifically, sale of the property for the purpose of paying for “imminently necessary” health care expenses.
City Council must be aware that an emergency exemption clause in the Ordinance has the potential to be exploited as a loophole and undermine the Ordinance objectives of preventing displacement and creating affordable homeownership and rental opportunities. However, staff believes that this new proposed subsection has the necessary restrictions and can keep the intended limited involvement of the City by still allowing the exemption to be self-certified by the owner without demanding an administrative certifications process that would increase the implementation costs of the Ordinance and defeat the purpose of an emergency exemption submitted in good faith.
To prevent any kind of abuse of this clause, staff also believes that the one-year residence requirement and the restriction to one year after an Owner moves out of the property are necessary.
The Administrative Guidelines would need to require property owners not only to expressly state the nature of the emergency but also to allege in their self-certification that they would not sell the residential property but for the emergency circumstances that they face.
3. Require Potential Eligible Purchasers to express interest in exercising their rights under the Ordinance within the first 15 days after receiving a Notice of Intent to Sell, followed by a Statement of Interest 15 days thereafter (if applicable).
Updated Section 14.26.080.B
Statement of Interest. Within fifteen (15) days of receiving the Owner’s Notice of Intent to Sell, a Potential Eligible Purchaser shall notify the Owner, at the email address provided by the Owner in the Notice of Intent to Sell, of the Potential Eligible Purchaser’s intent to submit a Statement of Interest, in order to be eligible to submit a Statement of Interest. Prior to the expiration of the Notice Period set forth in Paragraph A of this Section, any Potential Eligible Purchaser defined in Section 14.26.70 may deliver a Statement of Interest to the Owner of the Residential Property (“Statement of Interest”). The Statement of Interest shall notify the Owner of the Potential Eligible Purchaser’s interest in exercising the Right of First Offer and/or Right of First Refusal under this Chapter.
Potential Eligible Purchasers who do not provide any notification to the Owner within 15 days of receipt of the Notice of Intent to Sell-- either by submitting a Statement of Interest directly, or by notifying the Owner via email that they intend to submit a Statement of Interest-- waive their right to submit a Statement of Interest.
4. Allow shortening of timelines with consent of both parties in cases where there is only one Potential Eligible Purchaser.
Updated Section 14.26.130.D
Any agreement between the Owner and a Potential Eligible Purchaser to shorten the time periods provided for exercise of any right afforded under this Chapter is prohibited unless all other Potential Eligible Purchasers have waived their rights under this Chapter. Notwithstanding the foregoing, any Potential Eligible Purchaser may affirmatively indicate that they have no interest in a Residential Property prior to the expiration of any deadlines and in accordance with the Administrative Guidelines.
Nothing in this Paragraph shall prohibit an agreement to extend the deadlines set forth herein.
5. Shorten the timelines overall, with the goal of a 90-day maximum timeline for single family dwellings.
Proposed Changes
As noted above, the Statement of Interest period has been split into two stages of 15 days each, allowing the Owner to proceed to list or market and sell the property to any third party if the Potential Eligible Purchasers indicate no interest in purchasing within the first 15 days.
In the timeline amendments below, the Right of First Refusal period for single family dwellings is reduced from 10 days to 5 days (see Figures 2 and 3), and for multifamily dwellings of 2 or more it is reduced from 30 days to 20 days (see Figure 4). This reflects stakeholder input to shorten the Right of First Refusal period.
The time to close for single family dwellings is reduced from 40 days to 30 days (see Figure 2). There is a 60-day extension to close if a Potential Eligible Purchaser indicates they are receiving a commercial loan, as loan approval and release of funds to a borrower typically takes 90-120 days (see Figure 3). For multifamily, time to close is kept the same, as loans typically take between 90-120 days depending on the property size (see Figure 4).
Note that the amendments to the Ordinance ensure that all properties owned by East Palo Alto residents are exempt, and these timelines therefore only apply to properties owned by non-East Palo Alto residents and corporate or investor entities.
Figure 2
EPA OPA Timelines for Non-Exempt Single-Family Dwellings (Tenant as Potential Eligible Purchaser)
Statement of Interest
Time for Tenant to submit a statement indicating
interest in purchasing.
30 days
15 days (additional 15 days
if applicable)
Initial Offer
Time for tenant to submit an Offer to Purchase.
30 days
Right of First Refusal/Offer to Purchase
Time for Owner to send a copy of Third-Party
Purchaser’s Offer.
0-2 days
Right of First Refusal/Match 3rd Party Offer
Time for Tenant to match the Third-Party Purchaser’s
Offer.
10 days
5 days
Close
Time for the Tenant and the Owner to close the
transaction.
40 days
30 days
Total 30 – 112 days
15 – 97 days
Figure 3
EPA OPA Timelines for Non-Exempt Single-Family Dwellings (Qualified Nonprofit or City as Potential Eligible Purchaser) Statement of Interest
Time for QNP or City to submit a statement indicating
interest in purchasing.
30 days
15 days (additional 15 days if
applicable)
Initial Offer
Time for QNP or City to submit an Offer to Purchase.
30 days
Right of First Refusal/Offer to Purchase
Time for Owner to send a copy of Third-Party
Purchaser’s Offer.
0 – 2 days
Right of First Refusal/Match 3rd Party Offer
Time for QNP or City to match the Third-Party
Purchaser’s Offer.
10 days
5 days
Close
Time for the QNP or City and the Owner to close the
transaction.
90 days
30 days (60-day extension if
applicable)
Total 30 – 162 days
15 – 127 days (extension
included)
Figure 4
EPA OPA Timelines for Non-Exempt Multi-Family Dwellings (Qualified Nonprofit or City as Potential Eligible Purchaser) Statement of Interest 30 days
Time for QNP or City to submit a statement indicating
interest in purchasing.
15 days (additional 15 days if
applicable)
Disclosure Package
Time for Owner to send Potential Eligible Purchasers
a disclosure package with information about the
property.
0 – 5 days
Initial Offer
Time for QNP or City to submit an Offer to Purchase.
60 days (2-3 units)
90 days (4+ units)
Right of First Refusal/Offer to Purchase
Time for Owner to send a copy of Third-Party
Purchaser’s Offer.
0 – 2 days
Right of First Refusal/Match 3rd Party Offer
Time for QNP or City to match the Third-Party
Purchaser’s Offer.
30 days
20 days
Close
Time for the QNP or City and the Owner to close the
transaction.
90 days (2-3 units)
120 days (4+ units)
Total 30 – 217 days (2-3 units)
15 – 207 days (2-3 units)
30 – 277 days (2-3 units)
15 – 267 days (4+ units)
Updated Section 14.26.090.B
Acceptance of Offer of Purchase. Upon acceptance of an offer to purchase a Residential Property made pursuant to Paragraph A of this Section, the Potential Eligible Purchaser shall make reasonable and good faith efforts to close the transaction. A Potential Eligible Purchaser shall have thirty (30) days to close the transaction for the sale of a Single-Family Dwelling. A Qualified Nonprofit and/or the City shall have ninety (90) days to close the transaction for the sale of a two to three (2-3) unit Multi-Family Dwelling, and one hundred and twenty (120) days to close the transaction for the sale of a four or more (4+) unit Multi-Family Dwelling. The deadline to close a transaction for the sale of a Single-Family Dwelling shall be extended for an additional sixty (60) days if the Potential Eligible Purchaser provides written documentation that its lender will require a commercial loan for the purchase of the property (for a total of 90 days to close). Nothing in this Paragraph shall prevent the Owner and the Potential Eligible Purchaser from agreeing to further extend the deadline to close the transaction.
Updated Section 14.26.100.C
Time to Exercise Right of First Refusal. The Owner shall provide any Potential Eligible Purchaser that submits a Statement of Interest and an offer at least five (5) days to accept the Offer to Purchase for a Single-Family Dwelling, or at least twenty (20) days to accept the Offer to Purchase of a two or more (2+) unit Multi-Family Dwelling. The acceptance of an Offer to Purchase by any Potential Eligible Purchaser extinguishes any Right of First Refusal of other Potential Eligible Purchasers.
Updated Section 14.26.100.D
Time to Close. Upon acceptance of the Offer to Purchase, the Potential Eligible Purchaser shall have at least thirty (30) days to close the transaction for the sale of a Single-Family Dwelling, or a total of ninety (90) days if the Potential Eligible Purchaser provides written documentation that its lender will require a commercial loan for the purchase of the property; at least ninety (90) days to close the transaction for the sale of a two or three (2-3) unit Multi-Family Dwelling; and one hundred and twenty (120) days to close the transaction for the sale of a four or more (4+) unit Multi-Family Dwelling.
Nothing in this Paragraph shall prevent the Owner and the Potential Eligible Purchaser from agreeing to further extend the deadline to close the transaction.
East Palo Alto Market
According to MLS data (August 2021), the average amount of days that an East Palo Alto single-family residential property remains on the market (from listing to closing) is approximately 66 days. With the proposed amendments, EPA OPA provides no more than a 97-day process if the owner rejects the Tenant’s initial offer, and a 62-day process if the owner accepts the initial offer.
The purpose of these timelines is to give Potential Eligible Purchasers meaningful time to organize, express interest, submit an offer, secure financing, and to close, while also balancing the Owner’s need to sell. If the Potential Eligible Purchasers do not exercise their rights within these timelines, the Owner may proceed to sell on the open market. Note that nothing in the Ordinance prohibits both parties from agreeing to reduce or increase the closing timeline.
Additional Recommended Changes to the Ordinance
In addition to the above, staff recommend the following changes to the Ordinance to achieve consistency and fulfill the intent of key provisions:
1. Add language (Section 14.26.110E) that explicitly allows parties to agree to a nonrefundable deposit as is typically agreed upon in real estate transactions.
Updated Section 14.26.110.E
Deposit. The Owner shall not require the Potential Eligible Purchaser to pay a deposit of more than three percent (3%) of the contract sales price to make a contract. The deposit is refundable in the event of a good faith failure of the Potential Eligible Purchaser to perform under the contract unless otherwise provided in the contract.
2. Remove language from the section on Termination of Right of First Offer (Section
14.26.090) to clarify that an Owner may list and market a residential property and conditionally accept Third-Party Offers upon 1.) rejection of an offer by a Potential Eligible Purchaser or 2.) upon expiration of the Notice Period.
Updated Section 14.26.090.C
Termination of Right of First Offer. Upon (1) rejection of all offers to purchase made within the Notice Period, or (2) the expiration of the Notice Period, or (3) the failure to close the transaction within the time period set forth in Paragraph B of this Section, the Owner may list and market for sale the Residential Property and may solicit and conditionally accept offers from a Third-Party Purchaser, subject to the requirements of Section 14.26.100.
3. Add definition of Non-Exempt to clarify which types of properties and transfers are subject to the Ordinance.
Updated Section 14.26.020
“Non-Exempt” means a residential property or a transfer that is not exempt under Section 14.26.040 of this Chapter.
4. Consolidate paragraphs and update language in Section 14.26.070 (“Tenant, Qualified Nonprofit and City Opportunity to Purchase”) to clarify which residential properties the Ordinance applies to.
These changes were made to paragraphs B-D and reflect updates made elsewhere in the Ordinance, including expanded exemptions. In addition to utilizing the newly-added “NonExempt” definition, subsections were added to this section to further specify the residential property types subject to the Ordinance.
Economic Analysis of OPA
As directed by City Council, an analysis of OPA by the David Rosen & Associates consulting firm accompanies the updated Ordinance and addresses the following:
• Trends in the local and regional real estate market;
• Capital resources required for nonprofits to acquire single family dwellings; • Calculation of any potential loss in property tax revenue due to purchase of single-family dwellings by nonprofits; and
• 1031 Exchanges.
The analysis by David Rosen & Associates is provided as Attachment 2. Findings from the analysis include:
• The residential market in East Palo Alto has seen significant housing price appreciation in recent years, particularly since the Great Recession, with a 261% increase in single family home sales prices from 2012-2021. A lack of housing supply and continued growth of the Bay Area economy drive housing sales prices and rents in East Palo Alto, and these trends are expected to continue.
• The potential property tax revenue decrease associated with the purchase of (nonexempt) single-family homes and condominiums by nonprofits in a “worst case” scenario is estimated at $67 million, or 1.8% of the City’s total assessed valuation, over 5 years. However, this “worst case” calculation assumes that all non-exempt single family dwellings in East Palo Alto are sold to nonprofits and that all of those units are exempt from all property taxes as qualifying low-income rental units. This is offset by an increase in assessed valuation in the City from the resale of existing owner-occupied units, estimated at $138 million over the next five years, in addition to $560 million to $800 million over the next five years estimated from the City’s pipeline of market-rate units.
• The total subsidy required to purchase and make affordable at 80% AMI or below all non-exempt single-family dwellings and condominiums in East Palo Alto sold over the next five years is estimated to be $97 million to create owner housing and $115 million to create renter housing. [Per-unit costs at 50%, 80%, and 120% AMI are summarized in Table 4 of Attachment 2.] Lowering the income targeting to 50% AMI increases the subsidy required to $131 million to create affordable owner housing and $145 million to create affordable renter housing.
• 1031 Exchanges allow for deferment of capital gains and related federal income tax liability and only apply to sale of an investment property and replacement purchase of another like-kind investment property of equal or greater value. Since 1031 Exchange time limits are measured from when the property to be sold (“relinquished property”) closes, only East Palo Alto residents who are selling one investment property and purchasing a replacement investment property in East Palo Alto are affected by the OPA. The Ordinance’s timelines allow sufficient time to identify and acquire a replacement property, which must be completed within 180 days.
Qualified Nonprofits (“QNPs”)
The City Council requested clarification at the December 22 public hearing on the definition of Qualified Nonprofits (“QNPs”) and the process by which QNPs will be selected if an OPA Ordinance is adopted.
Staff previously recommended language in the Ordinance that sets a baseline for nonprofit housing organizations to apply for certification as QNPs and exercise the right of first offer and right of first refusal under EPA OPA. As currently defined in the Ordinance, eligible nonprofit housing organizations are 501(c)(3) organizations that demonstrate capacity to acquire, provide, and manage affordable housing and a commitment to preventing displacement and community engagement.
The Ordinance states that QNPs must follow an application process outlined in the Administrative Guidelines and that all QNPs must be certified by the City Council. This process is designed to maintain transparency in the selection of QNPs, as development of the Administrative Guidelines will be an extensive public process following the potential adoption of an OPA Ordinance in East Palo Alto, with refinement over time.
Staff propose language for the Administrative Guidelines in Attachment 3. This language may be updated throughout the process of developing the Administrative Guidelines. Staff do not recommend placing this language in the Ordinance due to the fact that City Council would be unable to refine or otherwise alter this section pertaining to QNPs without amending the full Ordinance.
The below chart, which was discussed at the October 5, 2021 and November 16, 2021 City Council meetings, compares TOPA/COPA programs in other cities and their QNP criteria with those proposed for East Palo Alto. Note that staff has added a five-year development experience requirement to these recommendations.
Qualified Nonprofit Criteria Comparisons
Washington, DC TOPA
(1980)[1]
San Francisco COPA (2019)[2] East Palo Alto OPA
• Right of First Offer and
Right of First Refusal given
to tenants; assignment of
rights to any party is at the
sole discretion of tenant(s)
• Commitment to affordable
housing preservation and antidisplacement
• Evidence of relationships with
community orgs (experience
with at least 3 neighborhoodbased or tenant counseling orgs)
• Demonstrated financial and
legal capacity to acquire and
manage any multi-family
residential building in the City
• Requisite of development
experience (experience
acquiring or partnering with
organizations that acquired at
least 2 residential buildings
within the last 5 years)
• QNP certification valid for 3
years with renewal if there is no
information raising doubts
about an existing nonprofit
organization’s entitlement to
certification as a QNP
• 501(c)(3) or California
cooperative corporation that
demonstrates capacity to
acquire, provide, and manage
affordable housing for low,
very-low, and extremely lowincome households
• Commitment to affordable
housing and preventing
displacement
• Commitment to community
engagement and experience
working in East Palo Alto or
with East Palo Alto-based
organizations
• Five-year track record of
development experience; can
partner with another
organization to meet this
experience requirement
• Annual certification of QNPs
with approval of City Council
• QNP certification valid for 5
years
• City Manager or designee will
investigate complaints
alleging QNP failure to comply
[1] Subchapter IV. Opportunity to Purchase. | D.C. Law Library (dccouncil.us) [2] COPA - Final Program Rules-09-03-2019.pdf (sfmohcd.org) with requirements, and may
recommend Council limit,
suspend, or revoke
organization’s certification as
QNP
Foreclosures
Current state law covers financial emergencies due to foreclosure proceedings. SB 10792, which is in effect until January 1, 2026, allows for residents living in 1 to 4-unit buildings facing foreclosure to have the right of first offer. SB 1079 requires that a notice of sale under a mortgage or deed of trust (i.e. foreclosure process) also contain a specific notice to a tenant about their right to purchase a property containing from 1 to 4 single-family residences.
Aside from SB 1079, residents undergoing a foreclosure process may also use the Foreclosure Intervention Housing Preservation Program (FIHPP), which provides $500 million in loans and grants to nonprofits purchasing and rehabilitating 1 to 25-unit buildings at foreclosure auction, in the foreclosure process, or at risk of foreclosure. “At risk of foreclosure” can mean 90-day mortgage delinquency, delinquency on 2 or more property tax payments, that the owner is in bankruptcy, that there is tenant-initiated litigation over lack of habitability, that local government found the building to be partially or fully inhabitable, or more.3 Due to current and future state regulations on foreclosures, the City must exempt Ordinance applicability on the transfer by foreclosure sale or deed in lieu of foreclosure. The Ordinance states that the exemption set forth on foreclosures does not supersede any rights to purchase afforded to Potential Eligible Purchasers under the California Civil Code Sections 2924(f)-(h), 2924(m)-(n), or 2929.3 (or SB 1079).
Next Steps
If directed, staff will return for the second reading of the Ordinance at the next regular City Council meeting, as early as February 1, 2022.
Fiscal Impact
There is no fiscal impact associated with this staff report.
Public Notice
The public was provided notice via publication in the Palo Alto Daily News on January 7, 2022, and by making the agenda and report available on the City’s website and at the San Mateo Co.
Library located at 2415 University Avenue, East Palo Alto.
Environmental
The action being considered does not constitute a “Project” within the meaning of the 2 See Senate Bill No. 1079 on Residential Property: Foreclosure, at https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201920200SB1079. 3 CACLTN Overview of FIHPP program presentation, August 17, 2021.
California Environmental Quality Act (CEQA), pursuant to CEQA Guideline section 15378 (b)(5), in that it is a government administrative activity that will not result in direct or indirect changes in the environment.
Attachments
1. Ordinance
2. David Rosen & Associates EPA OPA Analysis
3. Qualified Nonprofit Criteria for Administrative Guidelines