1 City Council Special Meeting Agenda
August 31, 2026
NOTICE IS HEREBY GIVEN THAT A SPECIAL MEETING OF THE
LOS ALTOS HILLS CITY COUNCIL WILL BE HELD ON
MONDAY, AUGUST 31, 2026, AT 3:00 P.M.
Meetings of the City Council are held in-person. As a courtesy, and in compliance with applicable state law, staff and members of the public may participate in the meeting in person at Town Hall or virtually via Zoom Video Conference. Members of the City Council may participate remotely from time to time in accordance with the provisions of Government Code section 54953.
To attend the meeting in person:
City Council Chambers, 26379 Fremont Road, Los Altos Hills, CA 94022 To provide Public Comment in person:
Members of the public wishing to speak are requested to complete a speaker card and submit it to the City Clerk at the meeting.
To participate in the meeting via Zoom Video Conference, please follow the instructions below:
Public comment will also be accepted via email at [email protected] prior to the start of the meeting. Written comments will be posted on the website and distributed to the Council. If you choose to email your comments, please indicate in the subject line “FOR PUBLIC COMMENT” and indicate the item number.
If you wish to submit a public comment during the meeting, please use the following information. Before speaking, please identify yourself by name and where you reside. The City Council meeting will be live streamed on the Town’s website and via zoom at the following location:
https://bit.ly/CCSpecialAug31
Meeting ID: 842 9305 1442
Password: 94022
NOTICE TO PUBLIC
Any writings or documents provided to a majority of the City Council regarding any item on the open session portion of this agenda will be made available for public inspection in the City Clerk’s office located at 26379 Fremont Road, Los Altos Hills, California during normal business hours.
These materials will also be made available on the City website at www.losaltoshills.ca.gov subject to Staff’s ability to post the documents before the meeting.
Town of Los Altos Hills
City Council Special Meeting Agenda
Monday, August 31, 2026, at 3:00 P.M.
Council Chambers, 26379 Fremont Road
Los Altos Hills, California 94022
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2 City Council Special Meeting Agenda
August 31, 2026
CALL TO ORDER (3:00 P.M.)
ROLL CALL
1. PUBLIC COMMENT (Public Comment is Limited to Items which are the Subject of the Special Meeting)
Speakers and members of the audience are reminded that public comments must comply with the Town’s Rules of Decorum. Profane language or disruptive conduct is prohibited under Los Altos Hills Municipal Code Sections 2-1.115(c) and (d).
2. ONGOING BUSINESS
A. Resolution Authorizing the City Manager to Execute a Five-Year Law Enforcement Services Agreement with the Santa Clara County Office of the Sheriff (Staff: C. Einfalt)
3. ADJOURN
Pursuant to Ordinance No. 506, the Council Meeting shall adjourn no later than 10:00 p.m., unless otherwise approved by a majority of the Councilmembers present.
ASSISTANCE FOR PERSONS WITH DISABILITIES
In compliance with the Americans with Disabilities Act, if you need special assistance to participate in the meeting, please contact the City Clerk at 650-941-7222. Notification 48 hours prior to the meeting will enable the City to make reasonable arrangements to ensure accessibility to this meeting.
Copies of all agenda reports and supporting data are available for inspection at Town Hall, 26379 Fremont Road 72 hours in advance of the meeting.
A complete agenda can be found on the Town’s webpage: http://www.losaltoshills.ca.gov. A complete packet of information is available for inspection during the meeting at the table to the back of the Council Chambers and online. Council may take action on any agendized matter in any manner deemed appropriate by Council.
TOWN OF LOS ALTOS HILLS August 31, 2026
Staff Report to the City Council
SUBJECT: RESOLUTION AUTHORIZING THE CITY MANAGER TO EXECUTE
A FIVE-YEAR LAW ENFORCEMENT SERVICES AGREEMENT
WITH THE SANTA CLARA COUNTY OFFICE OF THE SHERIFF
FROM: Cody Einfalt, City Manager
RECOMMENDATION: That the City Council should:
Adopt the attached resolution (Attachment 1) authorizing the City Manager to execute a five-year agreement with the County of Santa Clara for law enforcement services through the Santa Clara County Office of the Sheriff (Attachment 2).
BACKGROUND:
On July 1, 2014, the Town of Los Altos Hills entered into a ten-year law enforcement services agreement with the Santa Clara County Office of the Sheriff. The agreement was subsequently extended for two years through June 30, 2026. Under the 2014 agreement, annual rate increases were limited to the lesser of the change in deputy compensation or the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI/W) plus 2 percent.
As the extended agreement approached expiration, the County advised the contract cities - Cupertino, Saratoga, and Los Altos Hills - that future contracted law enforcement services would be provided under a revised full cost-recovery methodology. The proposed methodology materially changed the prior rate structure by incorporating a broader range of support and overhead costs and eliminating the annual CPI-based cap on rate increases.
In May 2026, the contract cities and County agreed to a second amendment extending the existing agreement for 12 weeks, from July 1 through September 30, 2026. The short-term extension provided additional time for the parties to continue negotiations and for an independent review of the County's proposed overhead methodology. The Los Altos Hills City Council approved the second amendment on June 9, 2026.
At the June 9 special meeting, the City Council also directed that the Town maintain its existing overall level of contracted law enforcement service for FY 2026-27. The Council directed staff to reduce dedicated traffic enforcement from 1,860 hours to 600 hours and transfer the remaining 1,260 hours to general law enforcement service. As a result, the Town's FY 2026-27 service plan includes 6,681 general law enforcement hours and 600 dedicated traffic enforcement hours, for a total of 7,281 contracted deputy hours.
On August 10, 2026, the City Council received a further update on the contract negotiations and reviewed the principal changes from the 2014 agreement. Since that meeting, the County and contract cities have continued to finalize the long-term agreement. The City of Saratoga authorized
Staff Report to City Council
Law Enforcement Agreement
August 31, 2026
2 its City Manager to execute the five-year agreement on August 19, 2026. The proposed Los Altos Hills agreement is expected to be materially consistent with that final contract form, with Townspecific service and cost exhibits.
DISCUSSION:
The proposed agreement would become effective October 1, 2026, immediately following expiration of the Town's current 12-week extension. It continues the Town's longstanding law enforcement partnership with the Sheriff's Office while establishing a new service-planning, reporting, and cost-recovery framework.
Key Provisions of the Five-Year Agreement
• Five-Year Term and Early Termination. The agreement is effective October 1, 2026 and continues for five years, through September 30, 2031, unless terminated earlier. Either the Town or County may terminate the agreement without cause upon one year's written notice. The agreement also allows the parties to mutually agree to amendments or an earlier termination.
• Comprehensive Law Enforcement Services. The Sheriff's Office will continue to provide general patrol and law enforcement, traffic enforcement, investigations, records services, 9-1-1 and emergency dispatch, community engagement, administrative and supervisory support, and other services available through the West Valley Patrol Division.
Supplemental services may be requested for special events, targeted enforcement, or other temporary needs, subject to written Town approval and Sheriff staffing availability. • Annual Plan for Service. Each year, the Sheriff will provide the Town with information regarding service hours, response times, crime trends, and recommended staffing. The Town will identify its desired service levels for the following year, which will be incorporated into an annual Plan for Service. For FY 2026-27, the Town has already established its desired overall service level through the June 9 Council direction described above.
• Full Cost-Recovery Model. The Town will pay fully burdened rates intended to recover the County's actual cost of providing law enforcement services. The rate structure includes direct labor, benefits, pension costs, training, supervision, dispatch and communications, administrative and departmental support, countywide overhead, fleet and equipment, and other applicable cost components. The agreement expressly states that the cost-recovery provisions are governed by Government Code section 51350. • Annual Rate Adjustments; No CPI Cap. Billing rates will be recalculated annually by the County based on its actual costs and incorporated through an updated rate schedule.
Unlike the 2014 agreement, the proposed agreement does not include a CPI-based limit on annual rate increases. If the Deputy Sheriffs' Association labor agreement is unsettled when annual rates are calculated, the County may use a provisional 5 percent salary increase,
Staff Report to City Council
Law Enforcement Agreement
August 31, 2026
3 plus known benefit and pension changes, and later bill the Town for its proportional share of any retroactive labor adjustments.
• Annual Reconciliation / True-Up. Actual law enforcement costs will be reconciled annually against amounts paid by the Town. The County must provide a complete service activity report, including actual staffing levels, deployment hours, overtime usage, and other cost-related service information supporting the reconciliation. Any resulting balance will be invoiced to the Town or credited to the Town's account. • Protection Against Unapproved Service Increases. If service hours are projected to exceed the annual Plan for Service by more than 10 percent, either party must provide written notice and may propose modifications. The Town is not obligated to approve an increase in service levels or associated costs and is not responsible for unapproved services above the approved Plan for Service.
• Enhanced Reporting and Coordination. The Sheriff will provide monthly public-facing reports on crime, calls for service, response times, law enforcement service hours, staffing trends, and estimated costs that may affect the annual reconciliation. The agreement also provides for an annual service consultation and allows the Sheriff or designee to attend City Council meetings at the City Manager's request.
• Unanticipated or Changed Costs. If the County identifies an unanticipated, omitted, or materially changed cost during the term, it must provide written notice identifying the nature and basis of the cost. The parties must negotiate in good faith, and any agreed adjustment must be incorporated by written amendment rather than imposed unilaterally. • Crime Laboratory Services. County Crime Laboratory services will be provided through the District Attorney's Office and billed separately under the agreement. The allocation methodology may be updated periodically by the County with advance notice to participating cities, and the Town is to receive its payment amount in advance of the coming fiscal year for budget planning purposes.
Resolution of Key Negotiation Issues
1. Indemnification. The final contract form uses mutual indemnification tied to the respective duties and obligations of each party. The County indemnifies the Town for claims arising from the County's performance of its duties, and the Town provides corresponding indemnification for claims arising from the Town's performance of its duties.
2. West Valley Substation / Early Termination Costs. If the Town terminates early or elects not to continue the agreement, it remains responsible for its pro rata share of existing West Valley Division substation tenant improvements, moving costs, and lease commitments, including lease payments through the expiration of the existing lease term.
The Town and County must meet and confer and mutually agree before future lease
Staff Report to City Council
Law Enforcement Agreement
August 31, 2026
4 amendments, new tenant improvements, or a replacement or successor lease may create additional obligations under this provision.
3. Cost-Recovery Standard. The agreement expressly provides that Government Code section 51350 governs the cost-recovery framework. At the same time, the agreement continues to include countywide and departmental overhead within the fully burdened rate structure. The absence of an annual cost cap means that future Town costs may fluctuate based on County labor, benefit, staffing, support-service, and allocation changes.
4. Service-Level and Reporting Protections. The annual Plan for Service, 10 percent notification threshold, monthly reporting, annual true-up documentation, and requirement for written amendments to address unanticipated or changed costs provide the Town with substantially more visibility into service delivery and cost changes than under the prior agreement.
Independent Review of County Cost Methodology – Government Code Section 51350 As discussed with the City Council during prior updates on the Sheriff contract negotiations, the three West Valley contract cities retained Vasquez & Company LLP to independently review the County's proposed FY 2026-27 law enforcement cost methodology (Attachment 3). The review evaluated the composition of the proposed charges, the methodologies used to allocate direct and shared costs, the transparency and traceability of supporting documentation, and whether the costs appeared consistent with the requirements of California Government Code Section 51350.
Government Code Section 51350 requires a county to charge a contracting city for costs incurred in providing the contracted service, but prohibits charging a city for general County overhead or costs the County would incur regardless of whether the contracted service was provided. The Vasquez review therefore distinguished between the reasonableness of the County's allocation methodology and the separate question of whether the underlying cost itself is properly chargeable to the contract cities.
The final report raised significant concerns regarding portions of the County's countywide and departmental overhead. The County's FY 2026-27 methodology substantially expands the overhead base to include Investigative Services, Records, Personnel and Training, Information Technology, Sheriff's Office Administration, Fiscal Services, Internal Affairs, and countywide support costs. Vasquez concluded that the fact that a cost can be allocated to the Sheriff's Office, or distributed among the contract cities using a mathematical allocation formula, does not by itself establish that the underlying cost was incurred because of the city contracts.
At a category level, Vasquez identified approximately $10.67 million of the $11.90 million in West Valley countywide and departmental overhead reviewed as not allocable under its comparative analysis. The report's more detailed component-level review is more nuanced and recognizes that certain portions of these categories may represent actual contract-related activity. For example, recruiting, training, information technology, records, fiscal, and investigative functions may include work directly attributable to West Valley operations even though other portions represent baseline County functions that would continue without the contract cities. As a result, the report
Staff Report to City Council
Law Enforcement Agreement
August 31, 2026
5 emphasizes the need to distinguish contract-related costs from continuing County operations rather than treating an entire departmental cost pool as automatically recoverable.
The review also examined the County's own budget assumptions regarding what would occur if the West Valley city contracts were discontinued. That analysis identified reductions in certain staffing, services, supplies, investigations, records, fiscal, data-management, and other support functions, but also showed that many broader County functions would continue even in the absence of the city contracts. Vasquez concluded that, to the extent the contract methodology allocates the standing or baseline costs of those continuing functions to the contract cities, those costs would not appear to be allocable under Government Code Section 51350. The report notes, however, that additional reconciliation would be necessary to determine the precise amount of each broader cost pool that is attributable to the city contracts.
Importantly, the proposed five-year law enforcement agreement expressly provides that “This Agreement is governed by Government Code section 51350.” Accordingly, execution of the agreement does not eliminate or supersede the statutory cost-recovery requirements of Section 51350. Rather, the County's charges and annual cost allocations remain subject to that standard throughout the term of the agreement. The inclusion of this provision was important to the contract cities because rates will be recalculated annually and the agreement provides for an annual reconciliation of actual costs.
Therefore, while staff recommends execution of the five-year agreement to ensure continuity of law enforcement services, execution should not be interpreted as the Town affirmatively agreeing that every component of the County's current or future cost-allocation methodology is necessarily allowable under Section 51350. The Town will continue to review annual rates, supporting documentation, and reconciliation charges against the requirements of the agreement and Government Code Section 51350 throughout the contract term.
The Vasquez report was prepared as a consulting engagement and does not constitute an audit or legal opinion. Its findings nevertheless provide the Town and the other contract cities with an independent analytical framework for evaluating the County's law enforcement charges during the term of the agreement.
ANALYSIS
Approval of the five-year agreement will provide continuity of law enforcement services beyond September 30 and avoid a disruption in the Town's primary law enforcement service model. The agreement preserves the Town's ability to set its annual contracted service level while providing the Sheriff operational authority over deployment and personnel management necessary to deliver the approved service plan.
The proposed agreement represents a material fiscal change from the 2014 contract. Costs are no longer governed by a CPI-based cap, and the Town will assume a greater share of direct and indirect County costs through annual rate adjustments and reconciliation. The agreement, however, includes new reporting, service-planning, approval, and reconciliation provisions intended to
Staff Report to City Council
Law Enforcement Agreement
August 31, 2026
6 improve transparency and reduce the risk that the Town will be charged for service-level increases it did not authorize.
Staff recommends approval of the agreement. The Sheriff's Office remains the Town's established law enforcement provider, the agreement provides a defined five-year framework for continued service, and the negotiated terms include important protections regarding mutual indemnification, service-level approval, reporting, reconciliation, and future changes to West Valley substation obligations. Staff will continue to monitor annual service levels and costs through the Town's budget process and the agreement's annual Plan for Service.
ENVIRONMENTAL REVIEW:
This action does not qualify as a “Project” as defined in California Government Code Section 15378(b) of the Guidelines for California Environmental Quality Act.
CITY COUNCIL WORKPLAN:
Execution of the five-year law enforcement agreement will provide continuity of the Town's public safety services and establish a framework for annual review of service levels, costs, and community public safety priorities.
FISCAL IMPACT:
The County's FY 2026-27 rate projection identifies total annual Sheriff's Office contract costs for Los Altos Hills of $3,379,757, consisting of:
• $1,500,365 in projected direct law enforcement staffing costs • $1,879,392 in direct and indirect support and overhead costs The FY 2026-27 projection is approximately $624,491, or 22.6 percent, above the Town's FY 2025-26 law enforcement cost of $2,755,266. Because the current 12-week extension already applies the FY 2026-27 rate structure beginning July 1, 2026, execution of the five-year agreement is not expected to change the FY 2026-27 Sheriff's Office cost currently budgeted, assuming the Town maintains the service plan directed by the Council.
Future-year costs are not fixed and will be recalculated annually under the County's full costrecovery methodology. In addition, County Crime Laboratory charges are billed separately under the agreement. The materials provided for preparation of this draft do not identify a Town-specific FY 2026-27 Crime Laboratory amount; any such charge should be incorporated into the Town's budget once provided by the County.
ATTACHMENTS:
1. Resolution
2. Proposed 5-year Agreement
3. Vasquez Overhead Assessment
RESOLUTION No. xx-26
RESOLUTION AUTHORIZING THE CITY MANAGER TO EXECUTE A FIVE-YEAR
LAW ENFORCEMENT SERVICES AGREEMENT WITH THE SANTA CLARA
COUNTY OFFICE OF THE SHERIFF
WHEREAS, on July 1, 2014, the Town of Los Altos Hills entered into an agreement with the County of Santa Clara for law enforcement services to be provided by the County Office of the Sheriff; and
WHEREAS, the 2014 agreement was subsequently extended through June 30, 2026, and on June 9, 2026 the City Council authorized a second amendment extending the agreement for an additional 12 weeks through September 30, 2026; and
WHEREAS, the Town has negotiated with the County regarding a new long-term law enforcement services agreement; and
WHEREAS, the proposed agreement will become effective October 1, 2026, continue for a term of five years unless sooner terminated in accordance with its terms, and provide for an annual Plan for Service, annual rate adjustments, service reporting, and reconciliation of actual costs; and WHEREAS, the City Council desires to ensure uninterrupted law enforcement services for the Town and finds that entering into the proposed five-year agreement is in the public interest.
NOW, THEREFORE, BE IT RESOLVED that the City Council of the Town of Los Altos Hills hereby
1. Approves the five-year law enforcement services agreement with the County of Santa Clara, to be performed through the County Office of the Sheriff, in substantially the form presented to the City Council; and
2. Authorizes the City Manager to execute the agreement and to approve non-material revisions necessary to finalize the agreement, subject to approval as to form by the City Attorney.
The above and foregoing Resolution was passed and adopted by the City Council of the Town of Los Altos Hills at a Special meeting held on the 31st day of August 2026 by the following vote:
AYES:
NOES:
ABSTAIN:
ABSENT:
BY: _______________________________
Rajiv Bhateja, Mayor
ATTEST:
______________________________
Arika Miller, City Clerk
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and Town of Los Altos Hills Page 1 of 23
`
AGREEMENT BETWEEN
COUNTY OF SANTA CLARA AND TOWN OF LOS ALTOS HILLS
FOR LAW ENFORCEMENT SERVICES
This Agreement for the performance of law enforcement services (“Agreement”) is made and entered into on this 1st day of October 2026 (“Effective Date”) between the County of Santa Clara (“County”) and Town of Los Altos Hills (“City”). This Agreement specifies the law enforcement services to be provided by the County’s Office of the Sheriff to City and the payment provided to the County by City for those services. County and City may be referred to individually as a “Party” or collectively as the “Parties” to this Agreement.
RECITALS
The following recitals constitute a substantive portion of the Agreement.
WHEREAS, City desires to contract with County for the performance of the law enforcement functions described herein; and
WHEREAS, County, through its Office of the Sheriff, agrees to render such law enforcement services on a full cost reimbursement basis, pursuant to California Government Code section 51300 et seq., and
WHEREAS, County, through its Office of the Sheriff, has the legal authority to provide law enforcement services throughout Santa Clara County, and is equipped and willing to provide these services to City pursuant to the terms set forth in this Agreement.
NOW, THEREFORE, the Parties hereto agree as follows:
AGREEMENT TERMS
1. TERM OF AGREEMENT
This Agreement shall become effective on October 1, 2026. The initial term of this Agreement shall not exceed five (5) years unless sooner terminated in accordance with this Agreement.
2. SERVICES TO BE PROVIDED
A. Law Enforcement Services
County agrees to provide, through its Office of the Sheriff, law enforcement services. The law enforcement services shall be provided in accordance with Exhibit A (Scope of Law Enforcement Services), which is incorporated herein by this reference.
B. County Crime Laboratory Services
County agrees to provide, through the District Attorney’s Office, Crime Laboratory services (County Crime Lab Services). County Crime Laboratory services shall be
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provided in accordance with Exhibit C (County Crime Lab Services), which is incorporated herein by this reference.
3. COMPENSATION
A. Cost Recovery
This Agreement is governed by Government Code section 51350 (“Section 51350”), and nothing shall prevent either Party from pursuing their rights under Section 51350.
B. Law Enforcement Services
The City shall pay the County for Law Enforcement Services in accordance with Exhibit E (Law Enforcement Services Rates), which is incorporated herein by this reference.
C. County Crime Laboratory Services
The City shall pay for County Crime Laboratory Services in accordance with Exhibit C, as incorporated herein by reference.
D. Unanticipated, Omitted, or Changed Costs
The Parties acknowledge and agree that the nature, scope, and demands of modern law enforcement services are dynamic and continually evolving, and that during the term of the Agreement there may be unanticipated, omitted, or materially changed costs, as well as obligations and service needs that cannot be fully identified at the time of execution of the Agreement.
In the event the County incurs such costs, the County shall provide written notice to the City identifying the nature and basis of the additional costs. The parties shall negotiate in good faith to determine appropriate compensation. The adjustment agreed upon shall be incorporated into this Agreement by written amendment.
4. DEFINITIONS
A. “County Confidential Information” shall include all material, non-public information (including material, non-public County Data) appearing in any form (including, without limitation, written, oral or displayed), that is disclosed, directly or indirectly, through any means of communication by County, its agents or employees, to City, its agents or employees, or any of its affiliates or representatives.
B. “County Data” shall mean data and information received by City from County.
County Data includes any information or data that is transported across a County network, or that resides in a County-owned information system, or on a network or system under the control and management of a contractor for use by County.
As between City and County, all County Data shall remain the property of County.
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and Town of Los Altos Hills Page 3 of 23
C. “City Data” shall mean data and information received by County from City. City Data includes any information or data that resides in a City-owned information system, or on a network or system under the control and management of a contractor for use by City. As between City and County, all City Data shall remain the property of City.
5. ENTIRE AGREEMENT
This Agreement and its attachments constitute the final, complete, and exclusive statement of the terms of the agreement between the Parties related to the provision of these law enforcement services. It incorporates and supersedes all the agreements, covenants, and understandings between the parties concerning the subject matter hereof, and all such agreements, covenants, and understandings have been merged into this Agreement. No prior or contemporaneous agreement or understanding, verbal or otherwise, of the Parties or their agents shall be valid or enforceable unless embodied in this Agreement.
6. THIRD PARTY BENEFICIARIES
This Agreement shall not be construed as conferring upon any third party any right or benefit, and any and all claims which may arise hereunder may be enforced solely by County and the City.
Notwithstanding anything contained herein, or any conduct or course of conduct by any Party hereto, before or after signing this Agreement, this Agreement shall not be construed as creating any right, claim, or cause of action against either Party by any person or entity not a Party to this Agreement.
7. GOVERNING LAW AND VENUE
This Agreement shall be governed by California law. Venue for any action arising from this Agreement shall lie in Santa Clara County, California, except as otherwise required by law.
8. EXECUTION AND COUNTERPARTS
This Agreement may be executed in one or more counterparts, each of which will be considered an original, but all of which together will constitute one and the same instrument. The parties agree that this Agreement, its amendments, and ancillary agreements to be entered into in connection with this Agreement will be considered signed when the signature of a party is delivered by a method described herein.
Unless otherwise prohibited by law or County policy, the parties agree that an electronic copy of a signed contract, or an electronically signed contract, has the same force and legal effect as a contract executed with an original ink signature. The term “electronic copy of a signed contract” refers to a transmission by facsimile, electronic mail, or other electronic means of a copy of an original signed contract in a portable document format. The term “electronically signed contract” means a contract that is executed by applying an electronic signature using technology approved by County.
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9. SEVERABILITY
Should any part of this Agreement between County and the City or any individual contract release purchase order be held to be invalid, illegal, or unenforceable in any respect, such invalidity, illegality, or unenforceability shall not affect the validity of the remainder of the Agreement or any individual contract, release or purchase order which shall continue in full force and effect, provided that such remainder can, absent the excised portion, be reasonably interpreted to give the effect to the intentions of the parties.
10. AMENDMENTS
This Agreement may only be amended by a written instrument signed by the Parties.
11. DATA
A. City shall not acquire any ownership interest in County Data (including County Confidential Information), and County shall not acquire any ownership interest in City Data (including City Confidential Information). Neither party shall, without the other party’s written permission, use or disclose the other party’s data other than in the performance of its obligations under this Agreement.
B. The parties shall be responsible for establishing and maintaining information security programs designed to ensure the security and confidentiality of each other party’s data, protect against any anticipated threats or hazards to the security or integrity of City or County Data, and protect against unauthorized access to or use of City or County Data that could result in substantial harm or inconvenience to the parties or any end users. Upon termination or expiration of this Agreement, the parties shall seek and follow each other’s direction regarding the proper disposition of data owned by the other party.
C. The parties shall take appropriate action to address any incident of unauthorized access to the other party’s data, including addressing and/or remedying the issue that resulted in such unauthorized access, and notifying the other party by phone or in writing within twenty-four (24) hours of any incident of unauthorized access to the other party’s data, or any other breach in security that materially affects the other party or end users. If the initial notification is by phone, written notice shall be provided within five (5) days of the incident. The parties shall be responsible for ensuring compliance by their officers, employees, agents, and subcontractors with the confidentiality, privacy, and information security requirements of this Agreement. Should City or County Confidential Information and/or legally protected City or County Data be divulged to unauthorized third parties, the parties shall comply with all applicable federal and state laws and regulations, including but not limited to California Civil Code sections 1798.29 and 1798.82. The parties shall not be liable to each other for any expenses associated with compliance with these obligations.
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D. Each party shall defend, indemnify and hold the other party harmless against any third party claim, liability, loss, injury or damage arising out of, or in connection with, the unauthorized use, access, and/or disclosure of information by one party and/or its agents, employees or sub-contractors, excepting only loss, injury or damage caused by the sole negligence or willful misconduct of personnel employed by that party.
12. OWNERSHIP OF DATA
Except as otherwise provided for or prohibited by law, all drawings, specifications, reports and other data developed by the County for this Agreement shall become the property of the City.
However, all crime reports shall remain the property of the County of Santa Clara, Office of the Sheriff.
13. DISPUTE RESOLUTION
In the event of any disagreement or dispute arising under this Agreement, the Parties agree to engage in an informal resolution process. The Parties’ representatives shall promptly meet and confer in an effort to resolve the matter within 14 days of a written request for such a meet and confer from one Party to another. If the dispute is not resolved through meet and confer within ten business days of the initial meet and confer meeting, or in a mutually agreed time frame, the Parties agree to promptly submit the matter to non-binding mediation before initiating any legal action. The costs of mediation shall be split equally between the parties. The parties may mutually agree to forego non-binding mediation.
14. ASSIGNMENT
No assignment of this Agreement or of the rights and obligations hereunder shall be valid without the prior written consent of the other Party.
15. INDEMNITY/HOLD HARMLESS
A. The County shall indemnify, defend, and hold harmless the City, its officers, agents, and employees from and against any loss, liability, claim, damage, or expense arising out of or in connection with, performance of the duties and obligations of the County and its employees set forth in this agreement.
B. The Town/City shall indemnify, defend, and hold harmless the County, its officers, agents, and employees from and against any loss, liability, claim, damage, or expense arising out of or in connection with, performance of the duties and obligations of the City and its employees set forth in this agreement.
C. This mutual indemnification agreement is adopted pursuant to Government Code section 895. 4 and in lieu of and notwithstanding the pro rata risk allocation which might otherwise be imposed between the Parties.
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Nothing in this Agreement is intended to expand the liability of any Party beyond standard tort law concepts or waive, impair, or diminish any statutory immunities, defenses, or liability limitations available to either Party under the Tort Claims Act.
16. INSURANCE AND LIABILITY
County and City shall each maintain its own liability insurance coverage, through self-insurance or otherwise, against any claim of liability arising out of the performance of this Agreement.
17. NOTIFICATION AND COOPERATION WITH LITIGATION
Each Party agrees, to the extent permitted by law, to notify the other Party of any complaint, grievance, or claim it receives from a third-party that relates to this Agreement. The Parties agree to cooperate in any investigation of any such complaint, grievance, or claim and in the resolution thereof. Without limiting the generality of the foregoing, at County’s request with reasonable advance notice, City shall make employees available to County, at no cost to County, to testify as fact witnesses, expert witnesses or otherwise in the event of litigation being brought against County with respect to the provision of the services. Furthermore, City shall reasonably cooperate with County in furnishing information, testimony, and other assistance in connection with any litigation, investigations, audits, proceedings, or disputes relating to the Agreement.
18. NOTICES
All notices to the Parties shall, unless otherwise requested in writing, be sent as follows:
To: County addressed to: Office of the Sheriff
55 W Younger Avenue
San José, CA 95110
Attn: Assistant Sheriff Adam Oberdorfer
With a copy to the Office of the County Counsel
70 W. Hedding Street, East Wing, 9th Floor
San José, CA 95110
Attn: Mona M. Williams
Attn: County Counsel
To: City addressed to: Town of Los Altos Hills
26379 Fremont Road
Los Altos Hills, CA 94022
Attn: City Manager
With a copy to Redwood Public Law, LLP
300 Frank H Ogawa Plaza, Suite 430
Oakland, California 94612
Attn: Los Altos Hills City Attorney
Each Party may designate a different person and address by sending written notice to the other
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Party, to be effective no sooner than ten (10) days after the date of this notice.
If notice is sent via email or facsimile, a signed, hard copy of the material shall also be mailed.
The workday the email or facsimile was sent shall control the date notice was deemed given if there is an email or facsimile machine generated document on the date of transmission. An email or facsimile transmitted after 1:00 p.m. on a Friday, Saturday, Sunday, or holiday shall be deemed to have been transmitted on the next business day.
19. TERMINATION OF AGREEMENT
No cause termination with notice. This agreement shall become effective on October 1, 2026, and may be terminated without cause by County or City by giving the other Party one (1) year written notice of such termination. In the absence of such written notice of termination, this agreement shall be effective for a term of five years (5) until September 30, 2031, subject to any modifications which are made in accordance with the terms and conditions of this agreement. At the expiration of this five (5) year Agreement contract, this Agreement may be continued for an additional five (5) year period, or another mutually agreed upon term, upon written notice of continuation by either Party to the other Party, acknowledged and agreed in writing by the receiving Party at least one-hundred eighty (180) days prior to the expiration of this contract.
In the event of an early termination or non-continuation, this Agreement shall remain in full force and effect through the date the termination or non-continuation takes effect, and City shall compensate County, in accordance with the terms of this Agreement, for services rendered and costs incurred until the date the termination or non-continuation takes effect. In addition, City shall compensate County the full amount of its pro-rata share for County tenant improvements, moving costs, and existing lease commitments for the West Valley Division substation, including its pro rata share of all lease payments due through the expiration of the Fourth Amendment to the Lease between the County and Dollinger DeAnza Associates LP for 1601 S. De Anza Boulevard signed April 22, 2025 by the County. The City and County shall meet and confer and mutually agree prior to any subsequent amendment of the existing lease and/or for any new tenant improvements, or a replacement or successor lease. These payment obligations apply notwithstanding the City’s non-continuation or termination of this Agreement.
20. SURVIVAL
All representations, warranties, and covenants contained in this Agreement, or in any instrument, certificate, exhibit, or other writing intended by the parties to survive this Agreement, shall survive the termination or expiration of this Agreement, including but not limited to all terms (1) relating to Ownership of Data; (2) relating to County Data; and (3) relating to the City’s obligations upon termination or expiration of this Agreement.
SANTA CLARA COUNTY SANTA CLARA COUNTY SHERIFF
Agreement between County of Santa Clara
and Town of Los Altos Hills Page 8 of 23
____________________________________
Otto Lee Date Robert Jonsen Date
President Sheriff
Signed and certified that a copy of this document
has been delivered by electronic or other means to
the President, Board of Supervisors.
ATTEST
Curtis Boone Date
Clerk of the Board of Supervisors
Approved as to form and legality.
Stephanie M. Jackson Date
Deputy County Counsel
TOWN OF LOS ALTOS HILLS
Cody Einfalt Date
City Manager
Approved as to form and legality
Steven T. Mattas Date
City Attorney
Agreement between County of Santa Clara
and Town of Los Altos Hills Page 9 of 23
Exhibits To This Agreement:
Exhibit A Scope of Law Enforcement Services
Exhibit B Law Enforcement and Supplemental Law Enforcement Services Payment Exhibit C County Crime Laboratory Services
Exhibit D Plan for Service
Exhibit E Law Enforcement Services Rates
Exhibit F Supplemental Law Enforcement Support Services Rates EXHIBIT A: SCOPE OF LAW ENFORCEMENT SERVICES
The purpose of this Exhibit is to describe and define the type and level of law enforcement
Agreement between County of Santa Clara
and Town of Los Altos Hills Page 10 of 23
services to be performed.
I. SERVICES
A. DELIVERY OF SERVICES
County, through its Sheriff’s Office, shall provide law enforcement services within the incorporated limits of the City as may be required by City and as within the capability of the Sheriff’s Office to provide. The rendering of such services, the standards of performance, the discipline of officers, and other matters incident to the performance of such services remain within the discretion of the Sheriff.
B. LAW ENFORCEMENT SERVICES
Law Enforcement services mean those law enforcement activities the Office of the Sheriff deems necessary to ensure public safety within the City, including but not limited to:
1. General Law Enforcement Services: General law enforcement/policing duties customarily performed by a municipal police department or Sheriff in the State of California, including, but not limited to, routine and directed patrol, enforcement of federal, state, and local laws and ordinances, investigation of criminal acts, prevention and detection of crime, apprehension and detention of suspects, response to emergency and non-emergency calls for service, preparation of incident and arrest reports, public safety and crime prevention education; and any other law enforcement or public safety functions that may be necessary to protect life, property, and the general welfare of the public within the City’s incorporated limits, as determined by the Sheriff in consultation with the City.
General law enforcement service levels and staffing are determined by the annual Plan for Service.
2. Traffic Enforcement Services: The monitoring, direction, and regulation of vehicular and pedestrian traffic within the City's incorporated limits to ensure compliance with state and local traffic laws and ordinances, including, but not limited to, the investigation and reporting of vehicle collisions, enforcement of laws against distracted driving, speed enforcement, red light violations, DUI enforcement, seatbelt compliance, equipment violations, drivers education and safety awareness, reporting collisions to the Statewide Integrated Traffic Records System (SWITRS), and other routine or directed vehicle-related enforcement activities. This may include dedicated traffic deputies assigned to a motorcycle or vehicle, as well as traffic investigators, as determined by the Sheriff in consultation with the City. Traffic enforcement service levels and staffing are determined by the annual Plan for Service.
3. School Resource Officers: Deputies assigned to partner with school districts within the City to provide a visible police presence, foster positive relationships with students and staff, support crime prevention and safety education, and respond to incidents on or near school property. SROs collaborate with administrators to maintain a safe learning environment. SRO FTEs are determined by the annual Plan for Service.
Agreement between County of Santa Clara
and Town of Los Altos Hills Page 11 of 23
4. Direct Law Enforcement Services: Personnel directly assigned to the West Valley Patrol Division to ensure effective delivery of general law enforcement services to each City.
These positions support field operations, administration, planning, coordination, and the operation of the West Valley Substation, and are allocated proportionally based on the City’s share of total hours, as determined by the annual Plan for Service. Staffing shall include the Division Commander (Sheriff Captain), Assistant Division Commander (Sheriff Lieutenant), Patrol Supervisors (Sheriff Sergeants), Administrative Sergeant (Sheriff Sergeant), Traffic Detectives (Sheriff Deputies), Management Analyst, Law Enforcement Records Technicians, Executive Assistant I, and Fleet Maintenance Scheduler, to provide for the administration, supervision, and support of law enforcement services in the City.
5. Investigation Services: Investigate felony and misdemeanor crimes within the City.
Responsibilities include follow-up on investigations and reports completed by patrol deputies, witness and suspect interviews, crime scene processing, evidence collection, report preparation, and collaboration with the District Attorney and other agencies.
Dedicated West Valley detectives focus on property crimes, while specialized units address major crimes, sex crimes, domestic violence, missing persons, on-call detectives, and the Crime Scene Investigation Unit (CSI). Additional functions include property and evidence management, crime scene investigation, and evidence processing and destruction, as determined by the Sheriff in consultation with the City.
6. Law Enforcement Records Services: Provides 24/7 records services, including warrant confirmation, public information, police report record management and processing to support mandated Uniform Crime Reporting (UCR), and state and federal crime reporting on behalf of the City, case sealings/expungements, California Public Records Act requests and processing, vehicle tow processing, public report requests, and other tasks required by law and as determined by the Sheriff in consultation with the City.
7. Emergency Dispatch Services: Handles 9-1-1 and emergency police calls for service, including call intake, prioritization, and rapid deployment of law enforcement resources via radio dispatch. Utilizes Computer Aided Dispatch (CAD) systems to track units and incidents. Service provided by Santa Clara County Communications.
8. Community Engagement: Promotes positive relationships with the public through activities such as attendance by Sheriff's Office and Division leadership, at the discretion of the Sheriff, at community events (e.g., Coffee with a Cop, National Night Out), deployment of Sheriff’s Office Public Information Officers for critical or high-interest events related to the Sheriff’s Office in the City, regular social media communication about matters of public interest or policing in the City, and coordination with each city’s Public Information Officer or designated staff.
C. SUPPLEMENTAL LAW ENFORCEMENT SUPPORT SERVICES
At the request of the City, the Sheriff may provide additional supplemental law enforcement support services from the Sheriff, beyond Law Enforcement Services as described above.
Agreement between County of Santa Clara
and Town of Los Altos Hills Page 12 of 23
Supplemental services may include support for special events, targeted enforcement, focused patrols, or other needs that require a temporary increase in staffing through overtime and cannot be anticipated in the Plan for Service. The cost for supplemental law enforcement services shall be at the rates listed in Exhibit F. Supplemental law enforcement services are subject to the approval of the Sheriff and availability of staff and must be approved in writing by the City before services are provided or may be pre-planned as part of the annual Plan for Service.
II. PLAN FOR SERVICE
Prior to February 1st of each contract year, the County, through the Sheriff, shall provide the City with a comprehensive summary of the prior years’ service hours, response times, crime trends, and a recommendation for staffing allocations for the upcoming year for General Law Enforcement Services, Traffic Enforcement Services, and School Resource Officers, and, as needed, Supplemental Law Enforcement Services. The City shall meet with the Sheriff to review and discuss these recommendations and must submit a written response by February 15th of the contract year, specifying its desired service levels for the following contract year. By April 1st of each contract year, the Sheriff will provide the City with an updated Exhibit D that reflects the selected service hours for each service category and the corresponding rates. If the City fails to submit a written response to the Plan for Service, the Office of the Sheriff may continue to provide the same level of service as delivered in the previous contract year.
III. ADMINISTRATION AND PERSONNEL MANAGEMENT
A. ASSIGNMENT AND TRANSFER POLICY
Sheriff’s deputies assigned to provide General Law Enforcement Services as herein described shall be assigned to City for a period of not less than three years, except when a deputy is reassigned because of promotion or layoff, transfer requested by the deputy, or at the request of the City and with the concurrence of the Sheriff.
Special Assignment personnel (e.g., SRO and Traffic Enforcement) shall be assigned to the City for a period of not less than five years except when a person is reassigned because of promotion or layoff, transfer is requested by the deputy, or by the City and with the concurrence of the Sheriff.
All transfers and assignments shall follow any applicable bargaining agreements or transfer policies of the Sheriff’s Office.
B. DESIGNATION OF CHIEF OF POLICE
If City shall so desire, and County and the Sheriff shall so agree, nothing in the agreement prevents or limits City from designating the Sheriff or their designee as its Chief of Police in order to satisfy the provision of Part I, Division 3, Title 4 of the California Government Code (sections 36501, et seq.). However, this shall not affect the authority of the Sheriff to control and direct employees of this Office in carrying out duties and obligations pursuant to this contract and shall not increase any liability
Agreement between County of Santa Clara
and Town of Los Altos Hills Page 13 of 23
to the County arising from this agreement.
C. PERSONNEL MANAGEMENT
1. Hiring, Training, and Discipline of Staff: The hiring, training, standards of performance, discipline, and/or control of all Sheriff’s Office personnel employed under this Agreement shall remain under the appropriate chain of command with the County Sheriff’s Office.
2. Exclusive Authority: Subject to the terms of this Agreement, the Sheriff shall retain exclusive authority over the activities of their personnel. The planning, organization, scheduling, direction, supervision, standards of performance and discipline of Sheriff’s personnel, and all other related matters incidental to the delivery of general law enforcement services to the City shall be determined by the Sheriff. Nothing herein shall be deemed to limit the Sheriff’s authority, to move, transfer and/or discipline Sheriff’s Office personnel as Sheriff in their discretion deems appropriate.
3. Selection of the West Valley Patrol Captain: The City will be afforded the opportunity to participate in the selection process for the Sheriff's Captain assigned to the West Valley Patrol Division. The City may participate in the interview process and provide a recommendation to the Sheriff regarding the selection; however, the Sheriff retains the authority to select and assign division management.
D. DISASTER RECOVERY PLAN
1. In the event of a major disaster that necessitates the activation of an Emergency Operations Center in City, a Sheriff’s representative shall immediately be dispatched and report to the Director of Emergency Services (City Manager).
2. Initial response by a Deputy Sheriff may be the nearest patrol unit or ablebodied deputy available.
3. A pre-designated Sheriff’s Emergency Operations Center liaison deputy shall be notified as soon as possible to respond to the Emergency Operations Center and coordinate law enforcement responsibilities.
4. The pre-designated Emergency Operations Center liaison deputy shall be maintained on the active call list and shall be available to the Director of Emergency Services.
5. The City and the Sheriff shall exchange relevant emergency contact information annually for the purpose of emergency notification and disaster preparedness.
6. Responsibility for personnel instruction and any specialized training in the Emergency Operations Center shall be provided by City.
Agreement between County of Santa Clara
and Town of Los Altos Hills Page 14 of 23
7. In the event a major disaster occurs, the Sheriff’s Office shall provide documentation support as required to comply with the City’s emergency operations cost recovery efforts.
E. MUTUAL AID
The City acknowledges and agrees that an unplanned event or emergency may require a temporary reallocation of law enforcement services for the purpose of mutual aid, in accordance with the California Emergency Services Act, codified at Government Code section 8550 et seq. Such a decision will be at the Sheriff’s sole discretion.
IV. ADMINISTRATION AND REPORTING
A. Required Reporting: The Sheriff shall report all monthly and annually required criminal statistical information for the City, including Uniform Crime Reporting (UCR), to the State of California and the California Department of Justice, as it would for the unincorporated areas of the County.
B. Monthly Reports to the City: The Sheriff shall provide the City with monthly reports, suitable for public release, on crime incidence, calls for service and response times, and General Law Enforcement Service hours, any estimated additional costs that would affect the reconciliation or true up described in Exhibit B, and staffing trends for the month and contract year-to-date. These reports shall be formatted as mutually agreed upon by the Sheriff and the City. The Sheriff shall deliver these monthly reports to the City within thirty (30) days following the last day of each month.
C. Policy Objectives. City may identify public safety policy objectives, community concerns, and municipal priorities through its City Council and City Manager. The Office of the Sheriff may consider those objectives, concerns, and priorities, and may implement them to the extent consistent with law, available resources, officer safety, Office of the Sheriff policies and procedures, County policy, and the discretion of the Sheriff.
D. Operational Information for City Services. Upon the request of the City Manager, and subject to all applicable federal, state, and local confidentiality and disclosure laws, the Office of the Sheriff will make available to the City information regarding services in City. Such information may include data on incident response times and outcomes beyond that information included in required reports described in sections A and B. The Parties may develop mutually agreeable operational reports, dashboards, or other tools.
E. Annual Service Consultation. At least once each contract year, the Sheriff, or designee, and the City Manager, or designee, will consult regarding service delivery, operational trends, and any mutually desired refinements. The parties shall meet in good faith to review and identify service trends, community concerns, operational coordination, technology integration, public safety emergency preparedness coordination, or operational issues likely to affect this Agreement.
F. Attendance at City Council Meetings. Upon the request of the City Manager, the Sheriff, or
Agreement between County of Santa Clara
and Town of Los Altos Hills Page 15 of 23
designee, may attend City Council meetings and present information concerning law enforcement services provided in City during the then-current contract year.
V. OTHER CRIMINAL JUSTICE AND PUBLIC SAFETY COSTS
The City shall be responsible for criminal justice fees applicable to other municipalities as required by law or agreement, including, but not limited to, California Identification System (CAL-ID) costs.
Santa Clara County Crime Laboratory services and costs are detailed in Exhibit C.
EXHIBIT B: LAW ENFORCEMENT AND SUPPLEMENTAL LAW ENFORCEMENT
SERVICES PAYMENT
Agreement between County of Santa Clara
and Town of Los Altos Hills Page 16 of 23
The purpose of this Exhibit is to describe the payment methodology for law enforcement services.
1. In consideration for the law enforcement services provided by the County under this Agreement, the City shall compensate the County at the fully burdened rates set forth in Exhibit E. These fully burdened rates include, but are not limited to, direct labor costs, employee benefits, pension contributions, training, supervision, dispatch and communications support, administrative and departmental overhead, countywide overhead, fleet and equipment support, and any other cost components established by the County’s Office of Budget and Analysis (or Controller‑Treasurer) as necessary to fully recover the County’s actual cost of providing such services as required by Government Code section 51350.
2. The billing rates shown in Exhibit E are developed by the County’s Office of Budget and Analysis in accordance with applicable federal cost principles, including Office of Management and Budget Circular A‑87 (or its successor), to reflect the County’s actual costs related to employee compensation, administration of benefits, service delivery, and overhead associated with the provision of services under this Agreement. These rates are recalculated annually pursuant to the policies and cost‑recovery practices adopted by the County of Santa Clara Board of Supervisors, and are designed to ensure that the County recovers the full actual cost of providing law enforcement services to the City.
3. 4. Billing Rates. The billing rates set forth in Exhibit E shall be readjusted annually by the County’s Office of Budget and Analysis, effective April 1 of each year, to reflect changes in the County’s actual cost of providing services. Upon the County’s approval of revised rates, the Parties shall execute an amendment to this Agreement incorporating the updated billing rates for the applicable fiscal year. The amended Exhibit E shall automatically supersede the prior rate schedule without requiring any additional modification to the remainder of the Agreement.
5. If, during the course of a fiscal year, it appears that the Sheriff’s Office will exceed the hours planned and approved in the annual Plan for Service by more than ten percent (10%) based on monthly reporting and projections, either Party shall notify the other Party in writing as soon as reasonably practicable. Upon such notification, the Sheriff’s Office or the City may propose amendments or modifications to the Plan for Service for the remainder of the fiscal year.
The City shall review any proposed modifications in good faith but shall have no obligation to approve any increase in service levels or associated costs. If the City does not approve the proposed modifications, the Sheriff’s Office shall not be required to provide services in excess of the approved Plan for Service, and the City shall not be responsible for paying for any such unapproved services. The County shall not unilaterally reduce the level of law enforcement services provided to the City without prior consultation and written notice. Notwithstanding the foregoing,
Agreement between County of Santa Clara
and Town of Los Altos Hills Page 17 of 23
the Sheriff retains discretion and operational authority to adjust staffing levels to address emerging issues, workload trends, or to strategically reassign personnel as necessary to meet the approved annual Plan for Service hour allocations for each City.
Any mutually approved increase in services or deployment levels shall automatically and proportionately increase the total compensation due for that fiscal year.
6. In any year during which a labor contract between the County of Santa Clara and the Deputy Sheriffs’ Association is under negotiation and not yet settled at the time annual billing rates must be calculated, the County shall apply a provisional increase of five percent (5%) to salary components of the billing rates, plus any known or approved benefit or pension cost increases, for the purpose of establishing interim rates for services to be provided under this Agreement.
Following settlement and finalization of the applicable labor contract, the County shall notify the City in writing of any resulting adjustments to billing rates within thirty (30) days of contract resolution. The County may thereafter recalculate the billing rates to incorporate all finalized salary, benefit, and pension adjustments arising from the collective bargaining agreement.
If the recalculated rates reflect retroactive increases applicable to service periods already rendered, the City shall pay its proportional share of such retroactive costs.
Such retroactive adjustments shall be invoiced separately or incorporated into the next regular billing cycle, as determined by the County.
7. The City shall pay to the County an amount equal to one‑twelfth (1/12) of the annual projected budget amount for Law Enforcement Services, calculated using the prevailing billing rates shown in Exhibit E. Monthly payments shall be due on the tenth (10th) day following the last day of each month during the contract year. Each monthly invoice and payment shall reflect one‑twelfth of the projected annual cost unless otherwise adjusted pursuant to this Agreement.
8. The cost for supplemental law enforcement services shall be invoiced in the following monthly invoice as applicable. Costs and expenses arising from any optionaladditional-services or from supplemental law enforcement services shall be invoiced separately from the fees associated with the Law Enforcement Services set forth in this Agreement and in accordance with the rates set forth in Exhibit F.
9. BASE RENT AND OPERATING COSTS OF WESTSIDE STATION
A. The City and County shall share the Operating Costs of the West Valley Division substation based on the percent allocations to each jurisdiction set forth in Exhibit E. The City shall pay to the County an amount equal to one‑twelfth (1/12) of the annual projected budget amount, calculated using the prevailing billing rates shown in Exhibit E. Monthly payments shall be due on the tenth (10th) day following the last day of each month during the contract year. Each monthly invoice and payment shall reflect one‑twelfth of the
Agreement between County of Santa Clara
and Town of Los Altos Hills Page 18 of 23
projected annual cost unless otherwise adjusted pursuant to this Agreement.
B. Payments, or any portion thereof, not received by the County within thirty (30) days of the due date shall accrue interest at a rate of ten percent (10%) per annum, or the maximum rate permitted by law, whichever is lower. Interest shall accrue from the day following the due date until the date payment is received. Accrued interest shall be included on the last invoice issued in the month in which interest is assessed, or on a supplemental invoice if necessary.
C. City shall pay County monthly that portion of the substation operating costs attributable to City. Any change to the location of the substation, or the cost of the facility over and above the contract language, shall be mutually agreed to by the parties to this agreement.
D. For the purposes of this provision of the Agreement, "Operating Costs" are defined as the cost of rent, janitorial services, minor repairs, and utilities and all other costs the County is required to pay under the lease agreement for the substation.
10. RECONCILIATION OR TRUE UP
The Parties acknowledge that certain costs subject to this Agreement, including but not limited to labor costs, overtime, benefits, insurance, and other pass through or reimbursable expenses, may be based on estimates, assumptions, forecasts, or standard rates, that differ from actual amounts incurred. A reconciliation of actual law enforcement costs shall be conducted each year of the Agreement as follows:
A. The County shall provide the City with a complete service activity report for the prior contract year no later than September 30 following the end of such contract year. The report shall include actual staffing levels, deployment hours, overtime usage, and any other cost‑related service metrics necessary to support the reconciliation.
B. The County shall determine the difference between (1) the actual cost of law enforcement services for the prior contract year, based on the actual level of service reflected in the service activity report and fully burdened rates applicable to that year, and (2) the total amount paid by the City to the County for that year. Any resulting balance shall be either invoiced to the City or credited to the City’s account, as appropriate. Any amount owed by either Party shall be paid or credited within sixty (60) days of issuance of the reconciliation statement.
Agreement between County of Santa Clara
and Town of Los Altos Hills Page 19 of 23
EXHIBIT C: COUNTY CRIME LABORATORY SERVICES
Crime Laboratory services shall include and be defined as review and analysis of any of the following:
Audio Analysis
Bloodstain Pattern Analysis
DNA/Forensic Biology
Computer Forensics (including Cell Phones)
Firearms Examinations
Impression Evidence
Latent Print Processing, excluding analysis, identification, and CalID Trace Evidence
Video Analysis
Toxicology
Controlled Substances Analysis
Each calendar year, the total cost of running the Crime Laboratory is determined. The cost includes Crime Laboratory personnel salaries and benefits, supplies, and other operating costs (including equipment and maintenance) associated with providing Crime Laboratory services.
Also, each calendar year, statistics are generated on the total number of Major Case submissions to the Crime Laboratory. The number of Major Case submissions by each law enforcement agency is expressed as a percentage of the total number of Major Cases submitted by all law enforcement agencies in the County. Major Case submissions are defined as cases requiring Audio Analysis, Bloodstain Pattern Analysis, DNA/Forensic Biology Analysis, Computer Forensics (including Cell Phones), Firearms Examinations, Impression Evidence, Latent Print Processing, Trace Evidence Analysis, or Video Analysis, that are assigned a single laboratory number by the Crime Lab, and assuch different Major Cases may have widely different numbers of individual evidence items requiring a wide range of analyses. Note: Toxicology and Controlled Substances Analysis are not considered Major Cases.
The County will recover a portion of the Crime Laboratory’s operating costs from participating cities. Each CITY’s share will be based on a combination of factors that generally reflect both service utilization and community characteristics. The specific allocation formula may be updated periodically by the County to maintain fairness and account for changes in workload, operational needs, or demographic shifts. The County shall provide notice to each city in advance of any such updates to the allocation formula.
CITY shall be notified of its payment amount in advance of the coming fiscal year to allow adequate budget planning and will be receiving the invoice from the District Attorney’s Office to provide payment to the District Attorney’s Office.
EXHIBIT D: PLAN FOR SERVICE
Town of Los Altos Hills
Annualized Law Enforcement Service Staffing Levels
Service Type Position Hours/FTE
General Law Enforcement Services Deputy Sheriff 6,681
Traffic Enforcement Deputy Sheriff 600
Traffic Sergeant Sheriff Sergeant 0
School Resource Officer (SRO) Sheriff Deputy 0
Fiscal Year 2026-2027
Law Enforcement Prior Service Staffing Levels (July 1, 2026 – June 30, 2027) Service Type Position Rate Hours/
FTE Sub-Total
General Law
Enforcement Services Deputy Sheriff $ 206.08 6,681 $ 1,376,717.00 Traffic Enforcement Deputy Sheriff $ 206.08 600 $ 123,648.00 Traffic Sergeant Sheriff Sergeant $ 360,985.00
0 $ 0.00
School Resource
Officer (SRO) Sheriff Deputy $ 336,731.00 0 $ 0.00
Exhibit D-1: Staffing Plan by Assignment (July 1, 2026 - June 30, 2027) Exhibit D-2: Staffing Plan by Assignment for Reduced Service Level (October 1, 2026 - June 30, 2027)
Rates Amount
DIRECT LAW ENFORCEMENT STAFFING COST
General Law Enforcement Services (Primary Rate)
Proposed Hours 6,681
Projected Costs FY26-27 @ $206.08 $1,376,717
Supplemental Services - Traffic Enforcement - Day
Proposed Hours - Enforcement Vehicle - Deputy Sheriff - Proposed Hours - Motorcycle - Deputy Sheriff 600
Total Proposed Hours 600
Projected Costs FY26-27 @ $206.08 $123,648
Traffic Sergeant
Projected Costs FY26-27 @ $360,985 $0
School Resources Officer
Projected Costs FY26-27 @ $336,731 $0
Subtotal $1,500,365
Operating Costs Of West Valley Substation
Proposed Hours General/Supplemental Services 7,281
Traffic & School Officer -
FY26-27 14,562 7,281
Percentage 7.1%
DIRECT LAW ENFORCEMENT SUPPORT SERVICES
Support Staff - Salaries & Benefits $5,348,552 $405,008 Services & Supplies
IC-Dispatch Services - Internal 4,324,600 327,471
IC-Automobile Services - Internal 1,571,823 119,023
IC-Insurance 1,025,102 77,624
IC-Office Rents 637,350 48,262
IC-Fuel - Internal 312,329 23,650
Bodyworn Camera & Dashcam 305,959 23,168
IC-Radio Maintenance - Internal 48,571 3,678
Communications and Telephone Svcs 37,380 2,831
IC - Wireless Voice & Data Services 35,543 2,691
Others 357,486 27,070
$8,656,142 $655,468
INDIRECT COUNTYWIDE SUPPORT $580,573 $43,963
Subtotal $14,585,267 $1,104,439
INDIRECT DEPARTMENT SUPPORT
Investigative $5,531,736 $364,509
Records $2,832,389 $186,638
Personnel & Training $1,057,612 $80,085
IT Services $997,556 $75,538
SO Admin $349,433 $26,460
Fiscal Services $298,434 $22,598
Internal Affairs $253,085 $19,164
Subtotal $11,320,245 $774,993
Total Projected Contract Costs FY26-27 $3,379,797
Exhibit E
West Valley Patrol
Santa Clara County - Sheriff's Office
PROJECTED CONTRACT COSTS - FULL COSTS - LOS ALTOS HILLS Fiscal Year 2026-2027
Agreement between County of Santa Clara
and Town of Los Altos Hills Page 23 of 23
EXHIBIT F: SUPPLEMENTAL LAW ENFORCEMENT SUPPORT SERVICES RATES Santa Clara County - Sheriff's Office
West Valley Patrol
SUPPLEMENTAL LAW ENFORCEMENT SUPPORT SERVICES
Fiscal Year 2026-2027
Assignment Description Hourly Rate
Deputy Sheriff $206.08
Sheriff's Sergeant $219.57
Sheriff's Lieutenant $256.70
20319364.30
Sheriff Contract Cost Allowability and Compliance
with Government Code §51350
Fiscal Year 2026-27
Prepared for
City of Cupertino
Prepared by
Vasquez & Company LLP
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 Table of Contents
PAGE
BACKGROUND ............................................................................................................................................ 1 OBJECTIVES, SCOPE AND METHODOLOGY........................................................................................... 2 EXECUTIVE SUMMARY .............................................................................................................................. 3
1. Understanding Santa Clara County Sheriff Service Delivery Model ...................................................... 6
2. Direct Law Enforcement Costs ............................................................................................................... 7
3. Evaluation of Patrol and Station-Level Cost Allocation (Direct Law Enforcement Support Services) ... 8
4. Review of Contract Law Enforcement Overhead (Indirect Countywide and Department Support) ....... 9
5. Countywide Cost Allocation Plan Support............................................................................................ 12
6. Evaluation of Cost Transparency and Supporting Documentation ...................................................... 13
7. Review of the County's Historical Public Protection Functional Cost Based on the County's Published ACFR ................................................................................................................................... 13
8. Comparative Analysis of Other Contract-City Arrangements............................................................... 14
9. Comparative FTE-Based Allocation Analysis....................................................................................... 27
10. Recommended Budget Analysis of Contract-Related Cost Changes .................................................. 29
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 1 REPORT ON THE CITY OF CUPERTINO’S REVIEW OF
PROPOSED SHERIFF CONTRACT COSTS
Vasquez & Company LLP (Vasquez) was engaged by the City of Cupertino to evaluate Santa Clara County’s proposed FY 2026-27 charges for contract law-enforcement services provided by the Santa Clara County Sheriff’s Office. The engagement focused on the composition of the proposed charges, the methodologies used to allocate direct and shared costs, the transparency and traceability of the supporting documentation, and the comparability of the proposed costs to selected California sheriff contract-city arrangements.
BACKGROUND
The City of Cupertino (Cupertino or the City) was incorporated in 1955 and is in Santa Clara County (the County) at the western edge of Silicon Valley, adjacent to the foothills of the Santa Cruz Mountains. The City has a population of approximately 60,000 to 64,000 residents. Cupertino is internationally recognized as a center of technology and innovation and is home to Apple Inc. and other technology companies.
The City operates under a council-manager form of government. The five-member City Council establishes municipal policy, while the City Manager oversees the administration of City programs, services, and operations.
The City provides and coordinates a range of municipal services, including community development, public works, parks and recreation, transportation programs, emergency preparedness, code enforcement, housing programs, and administrative services. Certain public services are provided through contracts, cooperative arrangements, special districts, or other governmental agencies rather than through City-operated departments. The City describes this model as combining municipal operations with partnerships involving key service agencies and local organizations.
Cupertino is a predominantly residential community with a significant technology and business presence. The City emphasizes education, innovation, collaboration, community engagement, and the maintenance of a high quality of life. Its residents participate in municipal governance through the City Council and various commissions and committees addressing planning, housing, parks and recreation, public safety, technology, transportation, and other community matters.
The City of Cupertino, the City of Saratoga, and the Town of Los Altos Hills purchase municipal lawenforcement services from Santa Clara County through the Sheriff’s Office. The West Valley Division also provides law-enforcement services to the adjacent unincorporated area. The model combines city-specific patrol and traffic commitments with shared command, dispatch, station support, vehicles, facilities, Records, Investigative, training, technology, fiscal, Internal Affairs, and administrative resources.
The City requested an independent consulting review to better understand the proposed charges and evaluate whether the underlying costs, assumptions, allocation methods, and supporting documentation were sufficiently transparent and supportable.
The engagement also considered the proposed West Valley cost structure compared with sheriff contract-service models used by other California counties and cities. Comparing cost structures and overhead allocation methodologies with other California counties will provide valuable insight into how counties calculate, evaluate, and apply overhead costs to comply with California Government Code Section 51350. The project was initiated in response to several circumstances, including:
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 2 • The significant increase in Cupertino’s proposed FY 2026–27 contract cost; • The County’s change in methodology for allocating shared and departmentwide costs; • The need to distinguish services from regional, shared, baseline, and Countywide functions; • Questions regarding the relationship between budgeted staffing, assigned staffing, and citypurchased service levels; • Inclusion of investigative, records, dispatch, administrative, technology, equipment, and other support costs in the proposed charges;
• The need for greater transparency and traceability between the proposed amounts and the supporting cost records; and
• The City’s interest in comparing the proposed West Valley cost structure with other California sheriff contract-city arrangements.
Vasquez’s procedures were performed as a consulting engagement in accordance with the American Institute of Certified Public Accountants’ Statement on Standards for Consulting Services during the month of July, and encompassed existing conditions, activities and processes. Should additional information become available following the date of this report, our analysis and observations could be affected by such information.
OBJECTIVES, SCOPE AND METHODOLOGY
The primary objective of the engagement was to assist the City of Cupertino in evaluating Santa Clara County’s proposed FY 2026–27 charges for contract law-enforcement services. The engagement focused on the composition of the proposed costs, the allocation methodologies applied, the transparency and traceability of the supporting documentation, the treatment of direct and shared service components, and the comparability of the proposed charges to other California sheriff contractcity arrangements.
The approach and methodology employed in conducting the engagement included the following:
• Participated in interviews and discussions with representatives of the City of Cupertino, the other West Valley contract cities, Santa Clara County, and the Santa Clara County Sheriff’s Office. • Read and analyzed the existing law-enforcement services agreements, proposed successor agreement materials, County correspondence, City correspondence, presentations, meeting materials, and related contract documents.
• Reviewed the County’s FY 2025–26 cost allocation worksheets and FY 2026–27 cost proposals, rate calculations, staffing schedules, allocation schedules, personnel-cost projections, servicesand-supplies calculations, and supporting cost-allocation documentation. • Reconciled material amounts among the County’s source schedules and compared the FY 2026– 27 proposal with the prior-year methodology and proposed costs. • Evaluated the composition of direct staffing, direct support, shared West Valley services, investigative and records functions, dispatch, administrative support, and departmentwide overhead included in the proposed charges.
• Assessed the allocation bases used to distribute shared and departmentwide costs among Cupertino, Saratoga, Los Altos Hills, and the West Valley unincorporated area.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 3 • Reviewed staffing information to evaluate the relationship among budgeted positions, assigned positions, city-purchased service levels, and positions classified as shared or overhead. • Analyzed the component-level cost classifications and identified costs that were treated as allocable, partially allocable, or not allocable in the supporting analyses. • Compared the West Valley contract structure, staffing presentation, cost methodology, and fully burdened cost measures with selected California sheriff contract-city arrangements. • Considered relevant statutory, contractual, and legal materials, including California Government Code section 51350 and related authorities, in evaluating the nature and treatment of the proposed cost components.
• Documented Vasquez & Company LLP’s analytical observations and discussed relevant factual matters with City representatives to improve accuracy and consistency. • Prepared this report presenting the engagement procedures, analyses, calculations, and observations.
EXECUTIVE SUMMARY
Santa Clara County's FY 2026-27 proposal introduces changes to both the composition of overhead costs and the methodology used to allocate those costs. Historically, overhead allocations were limited primarily to costs incurred by the West Valley Station / Patrol operation and select countywide support functions, such as Personnel and Training, Fiscal, Records, and Information Systems, which were reflected in the hourly billing rates for assigned personnel. The proposed FY 2026-27 allocation shifts to an annual cost-per-position allocation approach for Personnel and Training, Fiscal, and Information Systems, Internal Affairs, and Sheriff’s Office (SO) Admin, and a caseload approach for records and investigative divisions costs. It also expands the overhead base to include countywide Investigation Division costs, SO Admin, and Internal Affairs costs. This change increases overhead allocated to the West Valley Station by approximately $6.0 million compared to the prior year.
The central question in this review is whether the costs included in the County’s proposed charges were incurred in providing contracted law-enforcement services to the West Valley cities. The reasonableness of an allocation formula, by itself, does not establish that the underlying cost is chargeable under Government Code section 51350. Costs that the County would continue to incur regardless of the city contracts may constitute general County overhead and therefore may not be chargeable to the contract cities. This review therefore evaluates both whether the underlying costs are attributable to the contracted services and, separately, whether the methodology used to distribute allowable costs among jurisdictions reasonably reflects the services provided.
Key observations
Direct staffing. Cupertino’s purchased patrol hours, traffic-enforcement hours, traffic-sergeant position, and two school-resource-officer positions are directly associated with the City’s contracted service levels. The related costs are supported by contracted hours or dedicated positions, projected salary and benefit information, and the County’s productive-hour calculation.
Regional service model. The West Valley Division serves Cupertino, Saratoga, Los Altos Hills, and the West Valley unincorporated area. The staffing schedule lists 89 budgeted FTE and 84 assigned FTE. It also labels 17 positions as “Overhead.” Those 17 positions include station command, supervision, administration, records, and other operational-support functions. Support staff salaries and benefits related to 17 overhead positions are allocated to contract cities using a blended methodology consisting of 50% Records Management System (RMS) case counts (caseload) and
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 4 50% service hours. In addition, direct operating costs are attributable to the West Valley Division, including dispatch, automotive services, insurance, rent, fuel, radio maintenance and communications, wireless voice and data services, and body-worn and dash camera programs, and are allocated using the same 50/50 caseload and service-hour allocation method. This approach incorporates both workload and service utilization in distributing overhead and operating costs among contract cities.
Allocation of County-wide incurred costs. The County also allocates several shared division and departmental support cost pools to contract cities. These countywide support functions include the Investigations Division, Records Division, Personnel and Training, Information Technology Services, Sheriff's Office Administration, Fiscal Services, and Internal Affairs. Costs associated with the Investigations and Records Divisions are allocated based on a three-year average of RMS case counts, while the remaining support division costs are allocated using a blended methodology consisting of 50% caseload and 50% service hours.
The County's allocation calculations can be independently recalculated using the data presented in the supporting schedules. However, the methodology applies to the same allocation basis across various cost categories that perform substantially different functions and may be driven by varying workload factors, such as service hours, case activity, staffing levels, transaction volume, or other measures of resource consumption. In addition, the use of caseload as an allocation factor does not distinguish between cases based on the complexity of work performed, staff time required, or level of effort expended. As a result, case counts may not fully reflect the actual demand placed on certain support services. Case counts do not capture differences in case complexity, staff time or effort required to provide services. The County has not provided data regarding the complexity of cases, staff hours incurred, or effort associated with the cases attributed to West Valley Station. Without such information, caseload cannot be substantiated as a reasonable, equitable or cost-causative basis for allocating general operating or overhead costs.
Benchmark cost comparison. The projected FY 2026–27 cost for Cupertino, Saratoga, and Los Altos Hills totals $40,370,815. The three cities have 54 direct-service FTE, consisting of 33 for Cupertino, 16 for Saratoga, and 5 for Los Altos Hills. This produces an unadjusted fully loaded cost of $747,608 per FTE. The category-level review classified $10,667,109 of the full West Valley cost as not allocable, including the portion assigned to the West Valley unincorporated area. Refer to Table 4-2. Applying the County’s jurisdiction allocation percentages produces a three-city amount of $9,518,457. Removing that amount from the three-city projected cost produces an adjusted amount of $30,852,358, or a fully loaded cost of $571,340 per FTE.
Comparison after adjustment. The adjusted West Valley amount of $571,340 per FTE is 10.5% above Lake Forest, 11.5% above the source-reported West Hollywood amount, 11.5% above Woodside, 12.6% above Portola Valley, 18.6% above San Carlos, 18.9% above Danville, 21.6% above Diamond Bar, and 21.5% above Rancho Santa Margarita. The adjustment reduces approximately 48% to 78% of the original difference between West Valley and the benchmark jurisdictions presented. After the adjustment, the remaining difference is smaller for Lake Forest, West Hollywood, Woodside, and Portola Valley than for San Carlos, Danville, Diamond Bar, and Rancho Santa Margarita. The reported benchmark amounts are based on the staffing and contract-cost information available for each jurisdiction.
Comparative FTE-based allocation. An illustrative reallocation of the costs already assigned to West Valley, using each city’s assigned FTE share while leaving direct patrol, traffic, and school-resource staffing costs unchanged, reduced the three-city total from approximately $40.4 million to $33.9 million—a reduction of approximately $6.5 million, or 16.1%. The largest decreases were in station and countywide support, Investigative Services, and Records Services. This staffing-based approach is generally more consistent with the benchmark contracts reviewed; however, the analysis does not
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 5 establish the required allocation method, determine the actual support provided to each city, or assess whether every cost included in the County’s proposal is allocable.
Recommended County budget with West Valley closure. The County’s Recommended Budget provides a separate County-developed estimate of how staffing and operating costs would change if the West Valley city contracts were discontinued. The County specifically identifies $2.18 million of services-and-supplies costs that would be reduced, providing evidence that these costs are associated with the contract services rather than costs the County would incur regardless of the contracts. The Recommended Budget also identifies reductions in Investigations Headquarters, Records, Fiscal Administration, Data Management, and other support functions, while indicating that these broader County functions would continue in some form. Accordingly, the continuing baseline components of these functions may represent costs the County would incur regardless of the city contracts. However, because the Recommended Budget does not reconcile these reductions and continuing costs to the cost pools in the FY 2026-27 contract proposal, the amounts attributable or not attributable to the contract cities cannot be determined without a detailed reconciliation. The absence of a reconciliation supports the classification of the $10,667,109 in overhead costs as non-allocable, as the Recommended Budget reflects no corresponding reduction or elimination of these expenditures. As a result, the evidence indicates that the costs are general County operating costs that would be incurred irrespective of the contract with the three cities and would not be allocable under Government Code Section 51350.
Limitations and Disclaimer
This engagement was conducted in accordance with AICPA Statement on Standards for Consulting Services No. 1, CS section 100. It was not an audit, review, examination, or agreed-upon procedures engagement. Accordingly, Vasquez does not express an audit opinion, attestation conclusion, or other form of assurance regarding the County’s financial information, cost methodology, internal controls, or compliance with Government Code section 51350.
The information presented in this report is derived from materials gathered during the engagement, records and explanations provided by the City and the County, and publicly available information reviewed through the report date. Vasquez did not audit or independently verify all information provided or obtained from public sources, except for the specific recalculations, reconciliations, comparisons, and other procedures described in the report. The completeness and accuracy of the report depend on the completeness and accuracy of the information made available. Additional, revised, or subsequently available information could affect the information, observations, and overall evaluation presented in the report.
The evaluation of allocability of costs in accordance with Government Code section 51350 is conducted based on information, cost allocation and classification used in the file: West Valley FY 27 Rate Projection and the FY 2025-26 Cost Allocation Plan provided by the County and any additional information provided as of the date of this report.
This report does not constitute legal advice or legal opinion. The interpretation and application of Government Code section 51350 are matters for the City and its legal counsel.
This report was prepared for the City of Cupertino for the purposes described in the report. Its distribution is limited to authorized representatives of Cupertino, Saratoga, Los Altos Hills, and the County of Santa Clara. Distribution to these parties does not create a professional duty or responsibility to any party other than the City of Cupertino. The report is not intended for use or reliance by any other party without Vasquez’s prior written consent.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 6 1. Understanding Santa Clara County Sheriff Service Delivery Model The records considered in this section included current and proposed agreement materials, the West Valley staffing and service schedules, the April 2026 rate-projection records, the May revised jurisdiction schedule, the County process walkthrough, the January methodology presentation, and County and city correspondence. Together, these records describe a regional/shared policing model rather than three stand-alone municipal departments.
City-purchased direct services consist of general law enforcement patrol, traffic enforcement, a traffic sergeant where purchased, and school resource officers. Supplemental traffic hours and similar additive services use the direct hourly rate. Shared services include West Valley station command and professional support, dispatch, vehicles and supplies, Records, Investigative, and departmental support divisions. The unincorporated area receives a separate allocation in the proposal and therefore remains visible in the shared-pool denominator.
Table 1-1. FY 2026-27 projected West Valley costs by jurisdiction Jurisdiction Direct Staffing Direct Support
County
Department
Support
Total Projected
Cost
Cupertino $11,159,246 $7,149,023 $7,105,328 $25,413,597 Los Altos Hills $1,500,348 $1,104,406 $774,986 $3,379,740 Saratoga $5,335,216 $3,529,956 $2,712,306 $11,577,478
Unincorporated area $3,028,517 $2,801,882 $1,145,832 $6,976,231 Total $21,023,327 $14,585,267 $11,738,452 $47,347,046
Source: County of Santa Clara, West Valley FY 27 Rate Projection - 04-13-2026.xlsx, worksheet “10 - Projected Costs.”
FY 2026-27 calculation changes
Under the prior approach, direct and support costs were converted into a blended hourly rate. The revised approach converts only direct field staffing to an hourly or annual-position rate and allocates the remaining station and departmental pools based on caseload and service hours. Investigative and Records move to three-year RMS case shares; countywide and departmental support costs are first applied to West Valley using FTE measures and then distributed among jurisdictions.
Table 1-2. Principal stated rate drivers
Driver Prior Basis Revised Basis Stated Effect
Productive
hours
1,820 hours 1,634 hours Approximately 11.4% upward
effect on the hourly rate before
other changes.
Deputy
compensation
Contract-capped
rate
Projected average
current salary and
benefits
Approximately 9.6% stated effect
on the FY 2025-26 presentationbasis hourly rate.
Records Prior
limited/historical
basis
Three-year RMS case
share applied to a
broader pool
Approximately $1.52 million
increase in total West Valley costs,
including approximately $1.47
million attributable to the three
cities.
Investigative Captured hours or
assigned staff
Three-year RMS case
share applied to a
broader division
Approximately $3.50 million
increase in total West Valley costs,
including approximately $3.12
million attributable to the three
cities.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 7 Source: County of Santa Clara, West Valley FY 27 Rate Projection - 04-13-2026.xlsx; County January 2026 Law Enforcement Contract Rate Calculation presentation; and County process walkthrough.
Observation: The service model itself did not change from a regional / shared operation. The principal FY 2026-27 change is financial: direct field staffing is separated from fixed support pools, broader Investigative and Records populations are allocated by RMS cases, and additional departmental support categories are separately charged.
2. Direct Law Enforcement Costs
The direct-cost analysis used the Personnel Expenditure Projection (PEP) records, position schedules, benefit-rate schedules, productive-hour workpaper, contracted service hours, direct-rate calculation, and final proposal. The deputy rate is built from a population of 73 Deputy Sheriff positions and divides projected average salary and benefits by approximately 1,634 productive hours.
The April 2026 rate-projection records produce a direct rate of approximately $206.08 per hour, which supports the purchased-service summarized below.
Table 2-1. Cupertino direct law enforcement staffing
Service Volume Rate Basis
Proposed
Cost
General law enforcement
patrol
41,881 hours $206.08 per hour $8,630,836
Traffic enforcement 7,250 hours $206.08 per hour $1,494,080 Traffic sergeant 1 dedicated position $360,985 annual projected cost $360,985 School resource officers 2 dedicated positions $336,731 annual projected cost $673,462 Direct staffing subtotal $11,159,364
Source: County of Santa Clara, West Valley FY 27 Rate Projection - 04-13-2026.xlsx, worksheets “9 - WV Deputy Sheriff Cost” and “10 - Projected Costs.”
The rate build uses the position population's projected average cost rather than a rounded top-step salary. Salary, health insurance, retirement, retiree health, workers' compensation, Medicare, and other employer-paid benefits are included through the County's PEP and benefit schedules. The reviewed proposal did not present a separate Cupertino overtime line; the direct schedule is based on purchased hours and dedicated annual positions. Equipment, vehicles, cameras, fuel, communications, and related supplies are included in the station support schedule analyzed in Section 3 rather than in the direct staffing subtotal.
The amounts remain projections, and the proposal schedule itself does not show actual delivered hours, actual payroll by jurisdiction, or a separately quantified city-specific overtime population for fiscal year 2026-27 because that period had not occurred when the proposal was prepared.
Observation: Direct staffing has the strongest source of attribute in the proposal. The City contract specifies the service volume or dedicated position, and the rate is supported by position-level salary and benefit projections and a documented productive-hour calculation.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 8 3. Evaluation of Patrol and Station-Level Cost Allocation (Direct Law Enforcement Support Services)
The patrol and station analysis considered the West Valley staffing schedule, shift and service-hour information, PEP records, call and RMS-case measures, station support schedules, substation costs, mileage and fuel support, and the jurisdiction allocations in the projected-cost schedule. The West Valley staffing schedule identifies 89 budgeted FTE and 84 assigned FTE. The five-position difference consists of budgeted Deputy Sheriff positions not assigned within the staffing categories displayed.
Table 3-1. West Valley staffing reconciliation
Classification
Budgeted
FTE
Assigned
FTE Source Description
Captain 1 1 Station command
Lieutenant 1 1 Station command
Sergeant 8 8 Patrol and traffic supervision
Deputy Sheriff 73 68 Patrol, school resource officers, traffic detectives; five budgeted positions not
assigned
Executive Assistant 1 1 Station support
Fleet Maintenance Scheduler 1 1 Fleet coordination
Law Enforcement Records
Technician
3 3 Station records support
Management Analyst 1 1 Administrative and analytical support Total 89 84 Five budgeted Deputy Sheriff positions not
assigned
Source: County of Santa Clara, West Valley FY 27 Rate Projection - 04-13-2026.xlsx, worksheet “WP5 - WV Staffing.”
The staffing schedule labels 17 positions as "Overhead": one captain, one lieutenant, seven sergeants, two traffic detectives, three records technicians, one executive assistant, one fleet maintenance scheduler, and one management analyst. That label is an internal schedule grouping. The listed functions include station command, supervision, investigations, records processing, fleet coordination, and analytical support and therefore do not have one uniform cost behavior or one uniform treatment under Government Code section 51350.
Table 3-2. Cupertino, Los Altos Hills, and Saratoga’s share of station support and services Category Cupertino
Los Altos
Hills Saratoga
Allocation Basis Shown
In Proposal
Support staff salaries
and benefits
$2,621,612 $404,996 $1,294,467 50% service-hour share
and 50% RMS-case
share
Dispatch $2,119,719 $327,461 $1,046,649 50% service-hour share and 50% RMS-case
share
Automobile services $770,435 $119,019 $380,416 50% service-hour share and 50% RMS-case
share
Insurance $502,457 $77,621 $248,097 50% service-hour share and 50% RMS-case
share
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 9 Category Cupertino
Los Altos
Hills Saratoga
Allocation Basis Shown
In Proposal
Office rent $312,399 $48,261 $154,253 50% service-hour share and 50% RMS-case
share
Fuel $153,089 $23,650 $75,590 50% service-hour share
and 50% RMS-case
share
Body-worn camera and
dashcam
$149,967 $23,167 $74,049 50% service-hour share
and 50% RMS-case
share
Radio, telephone, and
wireless services
$59,550 $9,200 $29,404 50% service-hour share
and 50% RMS-case
share
Other services and
supplies
$175,223 $27,069 $86,520 50% service-hour share
and 50% RMS-case
share
Station support and
services subtotal
$6,864,451 $1,060,444 $3,389,445
Source: County of Santa Clara, West Valley FY 27 Rate Projection - 04-13-2026.xlsx, worksheet “10 - Projected Costs.”
The combined 50/50 driver recognizes both scheduled service presence and incident / report workload. The available records did not include a cost-behavior study demonstrating that equal weighting reflects dispatch, vehicles, insurance, rent, fuel, cameras, communications, professional staff, and countywide support in the same manner. The driver is consistently applied and separately assigns an unincorporated-area share, but it is not category-specific.
Observation: The shared-station concept is consistent with the regional model, and the proposal separately assigns the unincorporated area. The 89-to-84 staffing difference and the use of one common driver for cost categories with different operational causes remain material to the interpretation of projected station costs. Because these costs support West Valley Division operations, they have an operational relationship to West Valley service delivery. The amount appropriately attributable to each jurisdiction, however, depends on the nature of the individual cost and the basis used to allocate it. Allocating them among the three cities is also consistent with the regional service model employed by the other California counties.
4. Review of Contract Law Enforcement Overhead (Indirect Countywide and Department Support)
This section compares the West Valley overhead cost schedules with the review of individual cost components, position records, cost-center records, and explanations provided by the County. The analysis considers whether each cost is associated with providing law-enforcement services to Cupertino, Saratoga, and Los Altos Hills or represents general County overhead that would have been incurred without the city contracts.
California Government Code section 51350 states that a county must charge a city the costs incurred in providing contracted services and may not include general County overhead costs that would have been incurred regardless of the contract. An allocation formula shows how a cost is distributed among jurisdictions; the formula does not show that the cost was incurred in providing services to contract cities.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 10 Table 4-1. Treatment of Overhead Cost Categories
Overhead
Cost Category Component Level Treatment
Countywide
Cost Allocation
The detailed component-level analysis
excludes baseline County executive, budget,
controller, counsel, enterprise administration,
and countywide functions that persist without
the contracts. The County source schedules
also zeroed specified countywide program,
communications, facilities / fleet, and
building/equipment lines.
The comparative overhead analysis
classifies the full $580,573 West
Valley share as not allocable. This
consists of countywide allocated
costs such as county counsel,
finance, and technology related
costs. These costs are included in
the countywide cost allocation plan
and are further allocated to West
Valley. The component analysis
supports exclusion of identified
baseline components but evaluates
any contract-created central-service
transaction separately. They are
costs which are attributable to
services available to all portions or
departments of the County and
therefore, the County would incur
regardless.
Personnel and
Training
Custody/Department of Corrections (DOC)
academy, recruitment and background,
training and staff development, and baseline
recruitment/training capacity are unrelated or
baseline components. City-specific recruiting,
academy, training, and personnel workload
may be mixed where it is caused by West
Valley staffing. The cost is allocated to West
Valley based on the station’s total number of
FTE.
The comparative overhead analysis
classifies the full $1,057,612 as not
allocable; the detailed componentlevel analysis is more granular and does not treat every contract-related
personnel transaction as excluded.
Direct operating costs such as
recruitment and training may be
allocable to the extent they are
related to West Valley staffing.
Fiscal Services DOC Fiscal Services and baseline
accounting/administrative capacity are
excluded or unrelated. Actual contract billing,
payroll, and accounting transactions are
mixed where specifically supported.
The comparative overhead analysis
classifies the full $298,434 as not
allocable; the component analysis
distinguishes custody-only and
baseline work from contract-created
fiscal activity.
IT Services DOC Data Management, custody IT, and
baseline enterprise-system capacity are
excluded or unrelated. Contract-specific
devices, licenses, users, and support
transactions may be attributable to the
service.
The comparative overhead analysis
classifies the full $997,556 as not
allocable; the component analysis
supports exclusion of unrelated /
baseline elements rather than an
automatic exclusion of every IT
transaction.
Internal Affairs BU235 / BU240 custody and DOC Internal Affairs units and baseline governance
capacity are excluded or unrelated. Cityservice incidents may create some mixed workload.
The comparative overhead analysis
classifies the full $253,085 as not
allocable; the detailed componentlevel analysis identifies custody-only and baseline components and
separately assesses city-created
workload.
Sheriff
Administration
Sheriff and Undersheriff positions were
excluded by the County. The detailed
The comparative overhead analysis
classifies the full $349,433 West
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 11 Overhead
Cost Category Component Level Treatment
component-level analysis also identifies
baseline executive / general administration
and newly included CC3900 functions
without a demonstrated West Valley nexus
for exclusion or restricted treatment.
Valley share as not allocable. The
three-city portion in the projectedcost schedule is $282,306.
Investigative
Services
West Valley detective work and city cases
create actual workload. The County has
stated that contract-city cases are also
supported by Investigative Services Division
headquarters and specialized functions,
including Major Crimes, Sexual Assault,
Domestic Violence, property and evidence
management, and crime-scene investigation.
South County Investigations (cost center
3931; two FTE; approximately $706,929 in
component evidence) is unrelated to West
Valley. For the remaining headquarters and
regional costs, the RMS case-volume
allocation does not identify the staff time,
case complexity, or resources associated
with each jurisdiction; accordingly, a
documented West Valley service nexus
remains necessary.
The comparative overhead analysis
identifies that only $1,233,709 of the
$5,531,736 West Valley Investigative
amount is allocable, leaving
$4,298,027 classified as not
allocable.
Records
Services
City reports create records-processing
transactions. The detailed component-level
analysis identifies baseline management /
platform capacity and a Records Sheriff
overhead allocation of approximately
$1,492,651 as second-order mixed
overhead, while Records Technicians and
Office Specialist transaction work may be
attributable in part.
The comparative overhead analysis
classifies the full $2,832,389 as not
allocable. The detailed componentlevel analysis supports a narrower component-level split between city
transactions and baseline / overhead
capacity.
Source: Vasquez analysis of County information, including West Valley FY 27 Rate Projection - 04-13- 2026.xlsx, supporting cost schedules, position and cost-center records, and County explanations.
Table 4-2. Amount classified as not allocable in the overhead classification analysis Underlying Category West Valley Share
Amount Not
Allocable
Countywide Cost Allocation, Personnel and
Training, Fiscal, IT, Internal Affairs, and Sheriff
Administration
$3,536,693 $3,536,693
Records Services $2,832,389 $2,832,389
Investigative Services $5,531,736 $4,298,027
Total $11,900,818 $10,667,109
Source: Vasquez overhead classification analysis based on County information, including West Valley FY 27 Rate Projection - 04-13-2026.xlsx and supporting cost, position, and cost-center records.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 12 The $10,667,109 amount reflects the classification of entire overhead categories as not allocable. The more detailed cost-component review provides additional context because several of those categories include both activities that may relate to the West Valley contract cities and activities that may not.
The Personnel and Training cost pool includes academy, recruitment, background, training, and staffdevelopment costs associated with the Department of Correction, together with broader Sheriff personnel and training functions. Department of Correction Academy and training costs relate to custody operations rather than law-enforcement services provided through the West Valley Division.
Recruitment, background, academy, training, and personnel-administration costs associated with West Valley positions are separately distinguishable from Department of Correction costs and baseline departmentwide training capacity.
Section 8 of this report uses the $10,667,109 category-level amount solely to measure its effect on the benchmark comparison.
Observation: The detailed cost-component review separately identifies costs associated with custody operations, the Sheriff’s South County investigative unit, baseline Sheriff executive management, departmentwide administrative functions, and overhead included through other overhead allocations.
The component-level detail provides more specific information about the individual activities and costs included within the broader overhead categories.
5. Countywide Cost Allocation Plan Support
We reviewed the indirect Countywide support categories using the Countywide Cost Allocation Plan and the Sheriff’s financial schedules provided for the engagement. The review included tracing the reported amounts to those records, recalculating the allocation formulas, and examining the exclusions and year-to-year adjustments reflected in the schedules.
The Countywide Cost Allocation Plan includes central-service functions such as County executive administration, budget, controller, County Counsel, technology, facilities, and other County administrative services. The amounts allocated to the Sheriff and the related allocation calculations were traceable to the records reviewed. The Countywide Cost Allocation Plan explains how these central-service costs were distributed to the Sheriff. For purposes of this report, those amounts are presented as County-allocated support costs and are distinguished from costs directly tied to West Valley staffing, purchases, transactions, or service activity.
Observation: The Countywide Cost Allocation Plan supports the allocation and traceability of centralservice costs to the Sheriff. That allocation does not, by itself, determine whether a particular cost is attributable to law-enforcement services provided under the West Valley city contracts. For purposes of this report, these are separate considerations: the Cost Plan addresses how central-service costs are distributed to the Sheriff, while the contract-cost analysis considers whether the underlying cost is attributable to the contracted services rather than to general County operations that would continue regardless of the contracts.
The County asserts that its CAP and allocation methodologies are consistent with the Office of Management and Budget (OMB) Uniform Guidance (2 CFR Part 200 and 45 CFR Part 95) and have been accepted by the California State Controller's Office. While an approved CAP or federal indirect cost rate provides evidence that costs were allocated in accordance with federal cost principles, it does not, by itself, establish compliance with California Government Code § 51350.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 13 Uniform Guidance and Government Code § 51350 serve different purposes and apply different standards. Under Uniform Guidance, a cost may be recoverable as an indirect cost if it is equitably and consistently allocated across the County’s various grant and non-grant activities. In contrast, Government Code Section 51350 prohibits counties from charging contract cities for general county overhead costs or for costs that would have been incurred regardless of whether the city contract existed. As a result, a cost may be allowable under Uniform Guidance and included in a CAP, yet remain unallowable under Section 51350 if it represents general county operations or baseline administrative functions that are not incurred as a direct consequence of providing contracted services to the city. Accordingly, compliance with federal cost allocation requirements does not, in itself, demonstrate compliance with Section 51350.
6. Evaluation of Cost Transparency and Supporting Documentation We reviewed the fiscal workbooks, proposal schedules, position and cost-center records, staffing schedules, benefit support, services-and-supplies detail, case data, allocation formulas, County correspondence, and explanations provided during the County walkthrough.
The records reviewed were sufficient to reconstruct the principal FY 2026–27 proposal calculations, identify the cost pools used in the proposal, and understand the primary allocation methods. The records also showed that Sheriff and Undersheriff costs and certain unrelated cost centers were excluded from the calculations. For cost pools that included multiple functions, the schedules generally presented the combined pool rather than separately identifying baseline County operations and the portion associated with West Valley contract services. The County schedules show the service-hour percentages and the resulting weighted allocation percentages used to distribute shared West Valley support costs among Cupertino, Saratoga, Los Altos Hills, and the West Valley unincorporated area.
We recalculated the weighted allocation using the figures shown in those schedules.
7. Review of the County's Historical Public Protection Functional Cost Based on the County's Published ACFR
An analysis of the County’s historical public protection expenditures will provide a basis for understanding year-over-year cost growth and evaluating the extent to which increases in costs allocated to contract cities are supported by corresponding changes in overall departmental expenditures.
The historical analysis used Santa Clara County’s Annual Comprehensive Financial Report (ACFR) data for public-protection expenses for fiscal years 2016 through 2025 and General Fund publicprotection expenditures for fiscal years 2021 through 2025. Government-wide public-protection expense increased from $915.449 million in fiscal year 2016 to $1.464 billion in fiscal year 2025, an increase of 60.0% and a compound annual growth rate of approximately 5.4%. General Fund publicprotection expenditures increased from $940.891 million in fiscal year 2021 to $1.194 billion in fiscal year 2025, an increase of 26.9% and a compound annual growth rate of approximately 6.1%.
The decline in government-wide public-protection expense in fiscal year 2022 was affected by pension and other postemployment-benefit investment-related amounts. Accordingly, annual changes in the reported expense do not reflect only changes in staffing, service levels, or operating activity. The public-protection category also includes functions beyond West Valley law-enforcement services, including detention and criminal-prosecution activities. The historical trend provides context regarding broader County public-safety cost growth but does not explain the composition of the West Valley cost pools, the allocation methods applied to those pools, or the increase in Cupertino’s proposed contract amount.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 14 Observation: Historical public-protection costs increased over the periods reviewed, reflecting broader growth in County public-safety expenditures. The increase in Cupertino’s proposed FY 2026– 27 contract amount is primarily a result of specific changes in the West Valley cost methodology and the allocation of shared and departmentwide support costs.
8. Comparative Analysis of Other Contract-City Arrangements Comparative Sheriff Contract Models
For benchmarking purposes, the sheriff contract models in Orange, Los Angeles, San Bernardino, San Diego, San Mateo, Contra Costa, and Santa Clara Counties are similar in that cities reimburse the county for law-enforcement services. Important differences exist, however, in contract structure, staffing exhibits, pricing methods, and governance.
County Contract Structure Staffing Exhibit Pricing Method Typical Cities Los
Angeles
Municipal Law
Enforcement
Services Agreement
between the
contract cities and
the County
Detailed
deployment
schedules and
annual service
levels
Full cost recovery
using Countyapproved billing
rates
Diamond Bar, West
Hollywood,
Lakewood, Rolling
Hills Estates, and
others
Orange Municipal contract
with the Orange
County Sheriff’s
Department
Service levels
customized by city
Cost reimbursement
for personnel,
equipment,
overhead, and
special services
Rancho Santa
Margarita, Lake
Forest, Dana Point,
and San Juan
Capistrano
San
Bernardino
Sheriff’s Law
Enforcement
Services Contract
Schedule A listing
staffing, vehicles,
dispatch, support
services, and
annual costs
Annual Schedule A
cost allocation,
frequently amended
during the year
Yucaipa, Highland,
Rancho
Cucamonga,
Victorville, and
Twentynine Palms
San Diego Sheriff’s Municipal
Services
Agreements
Annual staffing
schedules and
service plans
Cost recovery based
on staffing
assignments and
support services
Encinitas, Poway,
Santee, Solana
Beach, and Vista
San Mateo Municipal
agreements with the
County for Sheriffprovided lawenforcement
services
Assigned
personnel and
service levels
established by
contract and
updated annually
Cost recovery based
on assigned
personnel, operating
costs, support
services, and other
specifically identified
costs
Woodside, Portola
Valley, and San
Carlos
Contra
Costa
Sheriff-staffed
municipal police
department
City-funded
Sheriff staffing
organized by
police function
City-funded Sheriff
positions and related
operating and
support costs
Danville
Santa Clara Individual contract
with the Sheriff’s
Office
Negotiated
staffing levels
tailored to each
city
Direct
reimbursement of
Sheriff’s costs plus
overhead
Cupertino, Los Altos
Hills, and Saratoga
Source: Law-enforcement service agreements, staffing exhibits, rate schedules, and related contract materials reviewed for Los Angeles, Orange, San Bernardino, San Diego, San Mateo, Contra Costa, and Santa Clara Counties; Vasquez comparative analysis.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 15 Overhead Allocation Methodology
Our review of the sheriff contract, rate calculations and cost allocation methodology used by the County of Los Angeles, Orange, San Diego, San Bernardino, San Mateo and Contra Costa indicates the following:
Los Angeles – Regional or station overhead specific costs are built into the annual rate per position, which varies by service code and relief factor. Vehicles are priced and incorporated into the contract based on actual cost while equipment is billed based on annual billing rates, which vary based on the type and cost of equipment. The County also adds 12.5% to the total contract amount, which represents contribution to the contract cities’ liability trust fund (LTF). The total overhead cost allocated is not presented in the County's rate schedule, and therefore, the overhead rate cannot be calculated.
Based on the review of the County’s master rate schedule and contract with certain Los Angeles County cities, it appears that the County does not allocate countywide overhead costs.
San Diego – Cost model includes direct staffing charges, including additional services which are priced per position at an annual rate. Other charges include station support staff costs, law enforcement direct costs, and other overhead allocated based on the number of deputies, detectives and other officers assigned to the city. Overhead costs include supplies, vehicles, space, management and support and ancillary support. Crime prevention, crime analysis, communications center, domestic violence and other case-specific costs are part of Ancillary support costs. The cost model and allocation methodology are very similar to Orange County. Direct staffing is priced per position, which consists of staff costs including benefits. Overhead is allocated based on FTE and represents approximately 34% of direct costs. The County does not allocate countywide costs.
Orange – The costs of services include the full cost of employees, which include wages and benefits, and overhead costs such as mileage, services, supplies, equipment, divisional, departmental and County General overhead. Costs of investigative personnel are allocated as part of regional shared costs. Regional shared costs range from 3% to 4% of direct costs, while other county overhead ranges from 21% to 22% of direct costs for a total overhead allocation of 24% to 26%.
San Bernardino – Cost model includes direct staffing charges, including additional services which are priced per position at an annual rate. Personnel costs include salary and benefits and are subject to change by the Board of Supervisors’ action. Changes in salary and benefit costs are billed to the city on a quarterly invoice. Overhead charges include vehicles and other equipment, dispatch services, insurance, IT (automation) and administrative support, which represent approximately 25% of direct personnel costs. Vehicle costs do not include fuel and maintenance. Cities are responsible for fuel, repair and maintenance of all contract vehicles, including collision damage. The County allocates a minimal county administrative cost of around 2% of direct personnel costs.
San Mateo – Cost model includes direct staffing charges based on personnel assigned to each contract city, together with separately identified operating and support costs. Woodside and Portola Valley reflect additional costs of approximately 18% and 16% of direct policing costs, respectively. The San Carlos FY 2026-27 agreement similarly identifies assigned staffing and separately calculates personnel and operating costs. San Carlos is assigned 30 FTEs, with approximately $11.7 million of personnel costs and $2.7 million of operating costs, including equipment, training, communications, technology, vehicles, HR and risk management, and centralized Sheriff support services. Certain technology, vehicle, HR, risk management, and Controller costs are identified as direct pass-through charges. The San Carlos agreement also provides for annual rate adjustments and an actual-cost reconciliation under which amounts collected in excess of the actual cost of services are retained for or returned to the City.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 16 Contra Costa – Danville operates a municipal police department staffed through the Contra Costa County Office of the Sheriff. The model is organized around city-funded Sheriff staffing and related police operations rather than a shared regional-station allocation comparable to West Valley. The comparative materials reviewed reflect additional costs of approximately 24% of direct policing costs.
Because the Danville model and cost presentation differ from the West Valley methodology, this percentage is best viewed as a comparative cost ratio rather than a confirmed Contra Costa County overhead allocation rate.
The review noted the materials examined did not identify caseload as a basis for allocating general operating or overhead costs in any of the six comparative counties reviewed. Instead, the methodologies primarily use assigned staffing or FTEs, defined service levels, separately identified support costs, and / or predetermined overhead allocation percentages.
Scale of Contract Operations
Los Angeles County has one of the largest contract-city programs in the nation, with the Sheriff’s Department seeking approval of agreements with 42 contract cities for the 2024–2029 term. Orange County also has a long-standing contract model that began in 1961 and expanded to numerous cities.
Access to Specialized Resources
Across all counties, contract cities generally receive access to countywide resources such as:
─ SWAT
─ Air support
─ Major crime investigations
─ Specialized units
─ The Orange County Sheriff’s Department specifically identifies access to broader Sheriff’s resources as a principal benefit of the contract model.
High-Level Comparison of Contract Features
The following table summarizes the principal contract features identified in the sources reviewed.
Topic
Los Angeles
County Orange County
San
Bernardino
County
San Diego
County
San Mateo
County
Contra
Costa
County
Santa Clara
County
Primary
agreement
Standardized
countywide
Municipal
Law
Enforcement
Services
Agreement
Contract lawenforcement
agreement with
the Orange
County Sheriff’s
Department
Law
Enforcement
Services
Contract with
the Sheriff’s
Department
Municipal
services
agreement
under a
county
sheriff
model
City-specific
agreements
for lawenforcement
services
provided by
the San Mateo
County
Sheriff’s Office
Sheriff-staffed
municipal
policeservices
model
Agreement with
the three
contract cities
Number of
contract cities
42 contract
cities under
the 2024–
2029
agreement
framework
13 contract cities
and agencies
participating in
the program
11 contract
cities with
dedicated city
stations
9 contract
cities
3 contract
cities
reviewed:
Woodside,
Portola Valley,
and San
Carlos
1 contract city
reviewed:
Danville
3 contract
cities:
Cupertino, Los
Altos Hills, and
Saratoga
Staffing exhibit Service levels
and
deployment
schedules
incorporated
Customized
service levels by
city
Detailed
Schedule A
incorporated
into the
contract,
similar in
Service
plans and
staffing
schedules
Assigned
personnel and
service levels
identified by
contract; San
Carlos
City-funded
Sheriff
staffing
identified
through the
municipal
Negotiated cityspecific staffing
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 17 Topic
Los Angeles
County Orange County
San
Bernardino
County
San Diego
County
San Mateo
County
Contra
Costa
County
Santa Clara
County
into the
agreement
structure to Los
Angeles
County
identifies 30.0
assigned
FTEs for FY
2026-27
policeservices
model
Cost
methodology
Countyapproved
billing rates
and full cost
recovery, with
the ability to
adjust service
levels
Reimbursement
of personnel,
equipment,
overhead, and
specialized
service costs,
with the ability to
adjust service
levels
Annual
Schedule A
cost allocation
based on
positions and
support
services
Staffingbased cost
recovery,
with the
ability to
adjust
service
levels
Assigned
personnel
costs together
with
separately
identified
operating and
support costs;
rates are
updated
annually, and
the San
Carlos
agreement
provides for
reconciliation
when actual
costs are
below
amounts
collected
City-funded
Sheriff
positions and
related
operating and
support costs
reflected
through the
municipal
policeservices
arrangement
Direct
reimbursement
of negotiated
Sheriff’s costs
Administrative
overhead
charged
Yes, through
the billing-rate
and full-costrecovery
structure
Yes, through
contract
reimbursement
of overhead
costs
Yes, through
Schedule A
administrativesupport and
related charges
Separate
overhead
allocation
formula
Support and
administrative
costs are
charged
through
separately
identified
operating and
support costs;
the San
Carlos
agreement
does not state
a single
overhead
percentage
Support costs
are included
in the cityfunded
policeservices
model; the
materials
reviewed do
not identify a
separate
countywide
overhead
formula
comparable
to West
Valley
Yes, as
allocated by the
County
Specialized
resources
available
County
Sheriff
resources
available
through the
contract
model
Access to
specialized
countywide
resources and
services
County Sheriff
resources
incorporated
into the service
model
Expected
under the
Sheriff
model, but
not verified
in the
retrieved
sources
County Sheriff
resources are
available
through the
contractservice model
Danville’s
local police
operation is
staffed by the
Sheriff and
supported by
County
Sheriff
infrastructure
City-specific
arrangement
Source: Law-enforcement service agreements, staffing exhibits, rate schedules, and related contract materials reviewed for Los Angeles, Orange, San Bernardino, San Diego, San Mateo, Contra Costa, and Santa Clara Counties; Vasquez comparative analysis.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 18 Best Comparable Cities for Cupertino
For benchmarking Cupertino’s contract with the Santa Clara County Sheriff’s Office, the comparables identified for contract structure, staffing, and cost treatment include:
Comparable City County Approximate Similarity
Encinitas San Diego Affluent suburban or coastal city with a Sheriff contract West Hollywood Los Angeles Affluent California City; comparable contract-city model Rancho Santa Margarita Orange Contract-city model (30 assigned FTEs) with limited municipal staff
Diamond Bar Los Angeles Affluent suburban contract city Lake Forest Orange Large suburban community contracting for police services San Carlos San Mateo Sheriff contract with 30 assigned FTEs and separately identified personnel, operating, and support costs
Danville Contra Costa Suburban Sheriff-staffed municipal police model with cityfunded personnel and support costs Woodside San Mateo Smaller contract city for comparison of assigned staffing and separately identified support costs
Portola Valley San Mateo Smaller contract city for comparison of assigned staffing and support-cost treatment
Source: Vasquez comparative analysis based on reviewed law-enforcement service agreements, staffing and service structures, and community characteristics of the identified contract cities.
Additional publicly available comparables identified for the review include Diamond Bar in Los Angeles County because of its sheriff contract-city model; Rancho Santa Margarita and Lake Forest in Orange County because of the Orange County Sheriff’s Department contract model; and Encinitas and Poway in San Diego County because of their sheriff contract model. The review also includes Woodside, Portola Valley, and San Carlos in San Mateo County and Danville in Contra Costa County. Woodside and Portola Valley provide smaller-city examples of assigned Sheriff staffing and support costs, while San Carlos provides a larger San Mateo County example with detailed assigned staffing, operating costs, support services, and an actual-cost reconciliation mechanism. Danville provides a different model in which the municipal police department is staffed through the Contra Costa County Sheriff.
The benchmark counties use similar contract-service models, but the presentation of staffing, support services, and annual charges varies materially.
San Bernardino County provides the most detailed presentation through its Schedule A staffing exhibits and amendments. Los Angeles County uses a standardized countywide contract framework with published billing rates. Orange County uses flexible, city-specific service packages and a costreimbursement model. San Diego County appears to use a structure similar to Orange County, often organized around station-specific municipal service plans. San Mateo County uses city-specific Sheriff service agreements based on assigned staffing and separately identified operating and support costs.
San Carlos also provides for annual rate updates and reconciliation of collections to actual costs.
Contra Costa County’s Danville model operates as a Sheriff-staffed municipal police department with city-funded positions and support through County Sheriff infrastructure. Santa Clara County generally negotiates individually with Cupertino, Los Altos Hills, and Saratoga rather than operating a larger countywide contract-city program.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 19 These differences affect the transparency and comparability of contract costs. In particular, the degree to which dedicated staffing, vehicles, dispatch, administrative support, technology, equipment, and specialized services are separately identified varies among the counties. As a result, comparisons of total contract cost or cost per position should consider differences in contract structure, including services, and the level of detail provided in the applicable staffing and cost exhibits.
The preceding comparison describes how other counties structure and present contract-city lawenforcement services. The following analysis narrows that comparison to available budget, staffing, and overhead data to evaluate how the West Valley proposal compares with selected benchmark jurisdictions on a cost-per-FTE basis.
The comparative analysis reconciles jurisdiction-level cost and staffing information, supporting budget records, the comparative overhead classifications, the County process walkthrough, the California contract-city county summary, the San Carlos FY 2026-27 law-enforcement agreement and budget, and reviewed agreement materials. The comparison uses the comparative jurisdiction analysis's definition of fully burdened cost per deputy: total budgeted amount for county contract services divided by total staffing identified in the applicable contract or source record.
Table 8-1A. Contract-city comparison from the comparative jurisdiction analysis - community, budget, and staffing data
City County Population
Area
(Sq.
Mi.) Crime Rate
Density
(/Sq. Mi.)
Police
Contract
Budget Staffing Stated In Source
Diamond
Bar
Los
Angeles
55,072 14.9 78/100,000
residents
3,700 $9,400,000 20 assigned patrol FTE; 1
forty-hour deputy, 10 fifty-sixhour deputies, 5 forty-hour no-relief deputies, and 1
community services assistant
with vehicle.
Lake Forest Orange 86,333 16.7 146/100,000
residents
5,170 $24,300,000 47 patrol deputies plus 1 in
FY 2027.
Rancho
Santa
Margarita
Orange 47,949 12.9 605/100,000
residents
(source text)
3,718 $14,102,000 30
Encinitas San Diego 62,000 18.8 170-
200/100,000
residents
3,253 $20,844,000 Total staffing not stated; FY
2026-27 budget includes
start-up costs for two new
traffic deputies and
continuation of a second
Homeless Outreach Program
for Encinitas (HOPE) team.
Cupertino Santa
Clara
58,333 11.3 112/100,000
residents
5,330 $25,413,597 33
Saratoga Santa
Clara
31,000 12.4 N/P N/P $11,600,000 16
Los Altos
Hills
Santa
Clara
8,500 8.8 N/P N/P $3,400,000 5
West
Hollywood
Los
Angeles
35,000 1.9 884/100,000
residents
N/P $28,700,000 55; source description
consists of 21 seventy-hourunit, 10 non-relief, and 9
supplemental positions.
Highland San
Bernardino
57,000 18.6 535/100,000
residents
3,050 N/P N/P
Woodside San Mateo 5,309 11.5 N/P 463 $3,588,158 7 FTEs; the comparative service analysis identifies
24/7 deputy coverage plus
two motorcycle deputies.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 20 City County Population
Area
(Sq.
Mi.) Crime Rate
Density
(/Sq. Mi.)
Police
Contract
Budget Staffing Stated In Source
Portola
Valley
San Mateo 4,456 9.1 N/P Approxim
ately 490
$2,536,757 5 FTEs; the comparative
service analysis identifies
one deputy providing 24/7
coverage.
San Carlos San Mateo 30,722 5.4 20/1000
residents
5,677 $14,455,499 30 assigned FTEs, consisting
of 22 sworn positions and 8
professional / support
positions.
Danville Contra
Costa
43,582 18.0 N/P 2,411 $11,533,458 24 FTEs used in the
comparative overhead
analysis; other project
materials use different
staffing counts depending on
the staffing definition.
Source: Population and crime rates are based on 2020 Census and FBI 2024 statistics; City FY 2026-27 Adopted Budgets; Contracts with respective Counties; San Carlos FY 2026-27 Law Enforcement Services Agreement and budget; and Vasquez comparative jurisdiction analysis for Woodside, Portola Valley, and Danville.
Note: Police contract budget amounts for Rancho Santa Margarita, Diamond Bar and West Hollywood are based on the city-adopted budget for FY 2026-27 sheriff contract. These amounts are generally higher than the total contract amount per agreement with respective counties. For Woodside, Portola Valley, and Danville, the amounts shown are the total policing costs used in the comparative jurisdiction analysis and have not been normalized for differences in service scope.
Table 8-1B. Contract-city comparison from the comparative jurisdiction analysis - deputy rates, fully burdened cost, overhead, and notes
City
Day /
Non-relief
Rate
Night /
Relief
Rate
Fully
Burdened
Cost per
Deputy
Overhead
as % of
Direct
Cost
Liability
Surcharge Benchmark Context
Diamond
Bar
$335,385 $368,924 $470,000 N/A 12.5% The Municipal Law
Enforcement Services
Agreement uses annual
personnel and equipment
billing rates that include stationlevel administrative overhead.
The comparative jurisdiction
analysis indicates that Los
Angeles County does not
separately charge countywide
overhead.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 21 City
Day /
Non-relief
Rate
Night /
Relief
Rate
Fully
Burdened
Cost per
Deputy
Overhead
as % of
Direct
Cost
Liability
Surcharge Benchmark Context
Lake
Forest
N/P $341,519-
$352,115
$517,021 26% None The comparative jurisdiction
analysis lists leave paydowns,
cameras, contract
administration, data, supplies,
helicopter services, e-citation,
facility lease, holiday pay,
justice-system fees, mobile
data computers, overtime,
patrol training, premiums, and
transportation as additional
charges. It indicates that no
separate countywide overhead
charge is included.
Rancho
Santa
Margarita
N/P $341,519-
$352,115
$470,067 24% N/P The comparative jurisdiction
analysis identifies the same
Orange County additionalcharge categories described for Lake Forest and indicates that
no separate countywide
overhead charge is included.
Encinitas $244,833 $244,833 $378,892 33.7% None; fixed
staffing-based
allocation
San Diego County uses a
single annual deputy rate rather
than separate day, night, or
relief rates. Encinitas’s FY
2026-27 adopted lawenforcement contract budget is
$20.84 million. The reconciled
staffing count is 55 sworn
positions: 51 identified in the
agreement, two additional
HOPE patrol positions, and two
additional traffic deputies. The
agreement separately identifies
station support, ancillary
support, supplies, vehicles,
space, management support,
and liability costs.
Cupertino $331,871 $341,439 $770,109 128% None The County's FY 2026-27 contract proposal increases
Cupertino's annual contract
amount from approximately $19
million to approximately $25.4
million. The proposal identifies
the revised FY 2026-27
allocation of shared and
departmentwide support costs
as the principal driver of the
increase.
Saratoga $331,871 $341,439 $725,000 117% None The County’s FY 2026-27 contract proposal for Saratoga
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 22 City
Day /
Non-relief
Rate
Night /
Relief
Rate
Fully
Burdened
Cost per
Deputy
Overhead
as % of
Direct
Cost
Liability
Surcharge Benchmark Context
applies to the same revised
support-cost allocation used for
Cupertino.
Los Altos
Hills
$331,871 $341,439 $680,000 125% None The County's FY 2026-27 contract proposal for Los Altos
Hills applies to the same
revised allocation of shared
and departmentwide support
costs used for Cupertino.
West
Hollywood
N/P N/P $512,500 N/A 12.5% The comparative analysis
reports a fully burdened
amount of $512,500. The
displayed $28.7 million budget
and staffing count of 55
produce $521,818, so the
displayed inputs do not
reproduce the reported amount.
Highland N/P N/P N/P N/P None The available comparative information does not provide
both a police-services budget
and a corresponding staffing
count needed to calculate a
fully burdened cost per deputy.
Woodside N/P N/P $512,594 18% N/P The comparative analysis identifies 7 FTEs,
approximately $3.04 million of
direct policing costs, and
approximately $0.54 million of
additional costs, for total
policing costs of approximately
$3.59 million. The percentage
is a comparative cost ratio and
is not a standardized San
Mateo County overhead rate.
Portola
Valley
N/P N/P $507,351 16% N/P The comparative analysis
identifies 5 FTEs,
approximately $2.18 million of
direct policing costs, and
approximately $0.36 million of
additional costs, for total
policing costs of approximately
$2.54 million. The percentage
is a comparative cost ratio and
is not a standardized San
Mateo County overhead rate.
San
Carlos
N/P N/P $481,850 23% No separate
surcharge
stated; liability
and riskmanagement
Cost model include direct
staffing charges including
additional services which are
priced per position at annual
rate. Other operating charges
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 23 City
Day /
Non-relief
Rate
Night /
Relief
Rate
Fully
Burdened
Cost per
Deputy
Overhead
as % of
Direct
Cost
Liability
Surcharge Benchmark Context
charges are
included
within
operating
costs
include station support staff
costs, uniform allowances,
radio and communications,
information services, supplies,
vehicle maintenance and
replacements costs, HR and
support services. The contract
does not indicate the basis of
allocation of operating costs,
which represent approximately
23% of direct staffing costs.
Danville N/P N/P $480,561 24% N/P Danville operates a municipal police department that is
staffed through the Contra
Costa County Sheriff. The
comparative analysis uses 24
FTEs, approximately $9.32
million of direct policing costs,
and approximately $2.21 million
of additional costs, for total
policing costs of approximately
$11.53 million. The cost
presentation differs from the
shared West Valley station
model, and the 24% represents
a comparative cost ratio rather
than a confirmed County
overhead rate.
Source: Applicable county law-enforcement service agreements and rate schedules; FY 2026-27 adopted city budgets and staffing records; California State Controller compensation information; San Carlos FY 2026-27 Law Enforcement Services Agreement and budget; comparative jurisdiction schedules for Woodside, Portola Valley, and Danville; and Vasquez calculations.
Note: Deputies’ annual compensation information was compared with the information published in SCO’s website and deemed comparable for each County.
Supporting Budget Records Incorporated Into The Comparison The Diamond Bar Supporting budget records image reports a fiscal year 2026-27 adopted Law Enforcement total of $9,418,290. Of that amount, $8,888,490 is the Sheriff's Department contract line; the balance includes Sheriff special events, parking-citation administration, crossing-guard services, supplies, equipment maintenance, rewards, and public-safety outreach. The $9.4 million comparison numerator is therefore a total law-enforcement budget measure rather than a contract-only amount.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 24 The West Hollywood Supporting budget records image reports fiscal year 2027 Sheriff and Protective Services of $28,710,733, consisting of $28,675,533 contracted services and $35,200 of other operating costs. Its numerator is therefore substantially contracting services, with a small additional operating-cost component. These budget-source differences affect comparability even before differences in investigations, records, dispatch, facilities, relief staffing, pension burden, and technology are considered.
Table 8-2. Summary of direct, overhead, and support costs from the comparative overhead classification analysis
Cost Category Total Cost
West Valley
Share
West
Valley % Comments
Allocability
Classification
West Valley Division -
Direct Costs
$13,592,497 $13,592,497 100.00% Station / department
specific
Allocable
Countywide Cost
Allocation
$56,764,560 $580,573 1.02% Countywide costs Not allocable Personnel and Training $19,089,028 $1,057,612 5.54% Countywide costs Not allocable Fiscal Services $5,487,495 $298,434 5.44% Countywide costs Not allocable IT Services $18,342,696 $997,556 5.44% Countywide costs Not allocable Internal Affairs $4,653,638 $253,085 5.44% Countywide costs Not allocable Sheriff Administration $4,396,442 $349,433 7.95% Countywide costs Not allocable Overhead subtotal $108,733,859 $3,536,693 3.25%
Investigative Services $16,082,396 $5,531,736 34.40% Caseload-based; source comment
states 43 of 49
headquarters FTE
and only four West
Valley FTE totaling
$1,233,709.
Only
$1,233,709 is
allocable to
West Valley
Records Services $8,234,594 $2,832,389 34.40% Countywide Records department cost
allocated by
caseload.
Not allocable
Support-services subtotal $24,316,990 $8,364,125 34.40% Total $146,643,346 $25,493,315 17.38%
Source: Vasquez overhead classification analysis based on County information, including West Valley FY 27 Rate Projection - 04-13-2026.xlsx, tabs “OH Summary” and “8 - West Valley OH.” The $13,592,497 shown on the “OH Summary” tab reflects the combined West Valley Division direct-cost components detailed on the “8 - West Valley OH” tab: Support Staff – Salaries & Benefits ($5,348,552), Services & Supplies ($7,952,555), and Body-Worn Camera/Dashcam costs ($291,390), and supporting cost, position, and cost-center records.
The overhead classification analysis further states that West Valley has 89 total positions, 17 of which are labeled Overhead; that West Valley represents approximately 5 percent of the Sheriff Department staffing population while the displayed West Valley share of the summarized cost pools is 17.38 percent; and that countywide costs would continue if the three cities obtained service from other providers. The analysis also states that a caseload allocation alone does not represent actual service hours, and information regarding the extent of work required per case was not available. As a result, the available information does not demonstrate that the allocation reflects the level of services performed.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 25 Adjusted Contract Cities Fully Burdened Cost Per Deputy For the primary comparison, the total projected FY 2026–27 cost for Cupertino, Saratoga, and Los Altos Hills is $40,370,815. The staffing denominator is 54 direct-service FTE, consisting of 33 for Cupertino, 16 for Saratoga, and 5 for Los Altos Hills. Dividing the combined three-city cost by the combined direct-service staffing produces an unadjusted cost of $747,608 per FTE. The calculation excludes the West Valley unincorporated area from both the cost numerator and the staffing denominator.
The category-level cost review classified $10,667,109 of the full West Valley cost as not allocable.
Because that amount includes costs assigned to the West Valley unincorporated area, the portion associated with the three city contracts was calculated using the jurisdiction allocation percentages shown in the County’s projected-cost schedule. A combined city share of 80.79% was applied to six overhead cost categories, while a combined city share of 93.42% was applied to Investigative and Records costs. This calculation produced a three-city amount of $9,518,457.
Subtracting $9,518,457 from the combined three-city projected cost of $40,370,815 produces an adjusted cost of $30,852,358. Dividing that amount by the same 54 direct-service FTE produces an adjusted cost of $571,340 per FTE.
Table 8-3A. Contract Cities Cost Per FTE Adjustment Calculation Measure
Total
Amount
Staffing
Basis
Cost Per
FTE Calculation / Interpretation
Contract cities cost
before adjustment
$40,370,815 54 direct
staffing
FTE
$747,608 $40,370,815 ÷ 54 FTE
Full contract cities
costs classified as not
allocable
$10,667,109 Not
applicable
Not
applicable
Includes the portions assigned to the
three contract cities and the
unincorporated area.
Contract cities share
of costs classified as
not allocable
$9,518,457 Not
applicable
Not
applicable
Amount attributable to Cupertino,
Saratoga, and Los Altos Hills using the
jurisdiction allocation shares reflected in
the projected-cost schedule.
Adjusted contract
cities cost
$30,852,358 54 direct
staffing
FTE
$571,340 ($40,370,815 − $9,518,457) ÷ 54 FTE
Source: County of Santa Clara, West Valley FY 27 Rate Projection - 04-13-2026.xlsx, worksheet “10 - Projected Costs”; Vasquez overhead classification analysis; and Vasquez calculations.
Table 8-3B. Adjusted Contract Cities Cost Per FTE Compared With Benchmark Jurisdictions Benchmark
Jurisdiction
Benchmark
Cost Per
FTE
Adjusted
Contract
Cities
Cost Per
FTE
Contract
Cities
Amount
Above
Benchmark
Contract
Cities %
Above
Benchmark
Initial Gap
Explained
By
Adjustment Observation
Diamond Bar $470,000 $571,340 $101,340 21.6% 63.5% Adjusted contract cities remains
materially above
the reported
benchmark.
Lake Forest $517,021 $571,340 $54,319 10.5% 76.4% Adjusted contract cities is
reasonably
comparable at a
screening level,
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 26 Benchmark
Jurisdiction
Benchmark
Cost Per
FTE
Adjusted
Contract
Cities
Cost Per
FTE
Contract
Cities
Amount
Above
Benchmark
Contract
Cities %
Above
Benchmark
Initial Gap
Explained
By
Adjustment Observation
subject to
service-scope
differences.
Rancho
Santa
Margarita
$470,067 $571,340 $101,273 21.5% 63.5% Adjusted contract cities remains
materially above
the reported
benchmark.
Encinitas $378,892 $571,340 $192,448 50.8% 47.8% Adjusted contract cities remains
materially above
the Encinitas
benchmark.
West
Hollywood -
reported
$512,500 $571,340 $58,840 11.5% 75.0% Adjusted contract cities is
reasonably
comparable at a
screening level;
however, the
available staffing
count and
reported ratio do
not reconcile.
Woodside $512,594 $571,340 $58,746 11.5% 75.0% Adjusted contract cities is
reasonably
comparable at a
screening level,
subject to
differences in
staffing and
service scope.
Portola
Valley
$507,351 $571,340 $63,989 12.6% 73.4% Adjusted contract cities is relatively
close to the
reported
benchmark at a
screening level,
subject to
differences in
staffing and
service scope.
San Carlos $481,850 $571,340 $89,490 18.6% 66.3% Adjusted contract cities remains
above the San
Carlos
benchmark. The
comparison is
less direct
because the San
Carlos
denominator
includes both
sworn and
professional/supp
ort personnel.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 27 Benchmark
Jurisdiction
Benchmark
Cost Per
FTE
Adjusted
Contract
Cities
Cost Per
FTE
Contract
Cities
Amount
Above
Benchmark
Contract
Cities %
Above
Benchmark
Initial Gap
Explained
By
Adjustment Observation
Danville $480,561 $571,340 $90,779 18.9% 66.0% Adjusted contract cities remains
above the
Danville
benchmark;
however, Danville
operates under a
Sheriff-staffed
municipal police
model that differs
from the shared
contract cities
station structure.
Source: FY 2026-27 adopted budgets and applicable sheriff contract, rate, and staffing records for the benchmark jurisdictions; County of Santa Clara, West Valley FY 27 Rate Projection - 04-13-2026.xlsx; San Carlos FY 2026-27 Law Enforcement Services Agreement and budget; comparative jurisdiction information for Woodside, Portola Valley, and Danville; and Vasquez calculations.
Note: “Initial gap explained by adjustment” measures the portion of the original difference between the unadjusted West Valley cost per FTE and each benchmark that is eliminated by removing the three-city share of costs classified as not allocable. Benchmark comparisons remain sensitive to differences in service scope, staffing definitions, and included cost categories. The Woodside, Portola Valley, and Danville benchmark costs per FTE are calculated by dividing the total policing costs reflected in the comparative analysis by 7, 5, and 24 FTEs, respectively. The San Carlos benchmark is calculated using the $14,455,499 gross cost of basic law-enforcement services divided by 30 assigned FTEs.
Observation: Removing the amounts classified as not allocable in the overhead classification analysis substantially narrows the West Valley contract cities gap and explains approximately 48 percent to 78 percent of the initial difference across the benchmark jurisdictions presented. The adjusted $571,340 per FTE is reasonably comparable to the upper-range Lake Forest and West Hollywood benchmarks at a screening level and is approximately 11.5 percent above Woodside and 12.6 percent above Portola Valley. It remains approximately 18.6 percent above San Carlos and 18.9 percent above Danville, and approximately 21.6 percent above Diamond Bar and 21.5 percent above Rancho Santa Margarita. The available comparative data therefore supports the observation that the classified overhead explains a substantial portion, but not all, of the cost gap.
9. Comparative FTE-Based Allocation Analysis
This section presents an alternative allocation of the amounts the County’s proposal assigns to the West Valley contract cities. Direct patrol, traffic, and school-resource staffing costs remain unchanged.
The analysis reallocates West Valley station and countywide support and department support costs using each city’s assigned FTE as a share of the 89 budgeted West Valley FTEs. It shows how the three-city allocation changes when assigned staffing is used instead of the County’s combination of service-hour and RMS case allocation measures.
Cost Category Pool Scope
Cost
Pool
FTE
Base
Cupertino
Los Altos
Hills Saratoga 3 City
Current
3 City
FTE Cost FTE Cost FTE Cost FTE Cost Cost Change
Direct staffing City direct
cost
33 $11.2 5 $1.5 16 $5.3 54 $18.0 $18.0 $0.0
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 28 Cost Category Pool Scope
Cost
Pool
FTE
Base
Cupertino
Los Altos
Hills Saratoga 3 City
Current
3 City
FTE Cost FTE Cost FTE Cost FTE Cost Cost Change
Station and
countywide
support
West Valley $14.6 89 33 $5.4 5 $0.7 16 $2.6 54 $8.7 $11.8 ($3.1) Personnel and
Training
West Valley $1.1 89 33 $0.4 5 $0.1 16 $0.2 54 $0.7 $0.9 ($0.2) IT Services West Valley $1.0 89 33 $0.4 5 $0.1 16 $0.2 54 $0.7 $0.8 ($0.1) SO
Administration
West Valley $0.3 89 33 $0.1 5 $0.0 16 $0.1 54 $0.2 $0.3 ($0.1) Fiscal Services West Valley $0.3 89 33 $0.1 5 $0.0 16 $0.1 54 $0.2 $0.2 $0.0 Internal Affairs West Valley $0.3 89 33 $0.1 5 $0.0 16 $0.0 54 $0.1 $0.2 ($0.1) Investigative
Services
West Valley $5.8 89 33 $2.2 5 $0.3 16 $1.0 54 $3.5 $5.4 ($1.9) Records
Services
West Valley $3.0 89 33 $1.1 5 $0.2 16 $0.5 54 $1.8 $2.8 ($1.0) Totals $21.0 $2.9 $10.0 $33.9 $40.4 ($6.5)
Source: County of Santa Clara, West Valley FY 27 Rate Projection - 04-13-2026.xlsx, worksheets “WP5 - WV Staffing” and “10 - Projected Costs”; Vasquez FTE-based allocation calculations.
Note: Dollar amounts in millions; FTEs are stated as positions.
The revised analysis keeps each city’s direct patrol, traffic, and school-resource staffing costs unchanged and reallocates West Valley station support, countywide support, and department support costs using each city’s assigned FTE as a percentage of the 89 budgeted West Valley FTEs. Under this approach, the three-city total decreases from approximately $40.4 million to $33.9 million, a reduction of approximately $6.5 million, or 16.1%.
This approach is generally more consistent with the benchmark contracts reviewed, which allocate shared support and overhead primarily by authorized staffing, assigned personnel, or contracted service levels rather than RMS caseload. The analysis therefore shows how West Valley city costs would change if shared costs were allocated using the same general staffing-based approach. It does not determine the exact level of support provided to each city, establish the required allocation method, or address whether every cost included in the County’s proposal is allocable. Instead, it provides a more directly comparable basis for evaluating the West Valley methodology against the benchmark jurisdictions.
Illustrative FTE-Based Allocation of West Valley Shared Costs The following analysis compares the County’s current proposal with an alternative allocation based on assigned staffing. Direct patrol, traffic, and school-resource staffing costs remain unchanged. The West Valley station and countywide support, departmental support, Investigative Services, and Records Services amounts, including the agreed 5% increase to the West Valley Investigative and Records amounts – are allocated among Cupertino, Los Altos Hills, and Saratoga using each city’s assigned FTE as a share of the 89 West Valley FTE. The analysis does not reallocate countywide Investigative or Records costs to West Valley or determine the exact level or allocability of support provided to each city; it illustrates how the amounts already assigned to West Valley would change under a staffing-based allocation method generally consistent with the benchmark contracts reviewed.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 29 West Valley Contract-City Cost Comparison — Current vs. FTE-Based Allocation Current three-city proposal ($) $40.4 Current cost per city FTE ($) $0.7 FTE-based three-city cost ($) $33.9 FTE-based cost per city FTE ($) $0.6 Reduction ($) $6.5 Reduction per city FTE ($) $0.1
Reduction (%) 16.1% Three-city assigned FTE 54
Comparison by City
City
Current
Proposal
($)
FTEBased
Cost ($)
Reduction
($)
Reduction
(%)
Assigned
FTE
Cupertino $25.4 $21.0 $4.4 17.3% 33
Los Altos Hills $3.4 $2.9 $0.5 14.7% 5
Saratoga $11.6 $10.0 $1.6 13.8% 16
Three-City Total $40.4 $33.9 $6.5 16.1% 54
Comparison by Cost Category — Three Cities Combined
Cost Category
Current
Proposal
($)
FTEBased
Cost ($)
Change
($)
Change
(%)
Direct staffing $18.0 $18.0 $0.0 0.0%
Station and countywide support $11.8 $8.7 ($3.1) -26.3% Personnel and Training $0.9 $0.7 ($0.2) -22.2%
IT Services $0.8 $0.7 ($0.1) -12.5%
SO Administration $0.3 $0.2 ($0.1) -33.3%
Fiscal Services $0.2 $0.2 ($0.0) -0.0%
Internal Affairs $0.2 $0.1 ($0.1) -50.0%
Investigative Services $5.4 $3.5 ($1.9) -35.2%
Records Services $2.8 $1.8 ($1.0) -35.7%
Total $40.4 $33.9 ($6.5) -16.1%
Source: County of Santa Clara, West Valley FY 27 Rate Projection - 04-13-2026.xlsx, worksheets “WP5 - WV Staffing” and “10 - Projected Costs”; Vasquez FTE-based allocation calculations.
Note: Dollar amounts in millions; FTEs are stated as positions.
10. Recommended Budget Analysis of Contract-Related Cost Changes Santa Clara County provided Vasquez with its Fiscal Year 2026-27 Recommended Budget. In subsequent correspondence, the County identified the Recommended Budget for Budget Unit 230 – Office of the Sheriff as its best estimate of what the Sheriff’s Office budget would look like if the contracts with the West Valley cities did not exist. The Recommended Budget therefore provides a separate, County-developed basis for evaluating which staffing and operating costs the County expects to change if law enforcement services to Cupertino, Saratoga, and Los Altos Hills are discontinued.
The Recommended Budget assumes that the city contracts are not renewed and provides for the dissolution of the West Valley Patrol and West Valley Investigations Divisions. It also identifies reductions from supporting functions, including Investigations Headquarters, Records, Fiscal Administration, Data Management, County Communications, Fleet, Facilities, and technology-related services. These budget actions are informative because they reflect the County’s own estimate of how staffing and expenditures would change in the absence of the city contracts, rather than an allocation derived from service hours, RMS cases, FTEs, or another comparative methodology.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 30 Staffing Effect of the No-Contract Scenario
The Recommended Budget identifies 88 Office of the Sheriff positions for removal from the West Valley service structure and 17 County Communications positions assigned to West Valley dispatch for deletion. Of the 88 Sheriff positions, 33 Deputy Sheriff positions and one Sheriff Sergeant position are recommended for reallocation to Court Security. Accordingly, 105 positions are affected before reallocation; 34 positions are reassigned to another County function, leaving a net reduction of 71 FTEs.
Recommended Budget Staffing Action FTE
Office of the Sheriff positions removed from West Valley 88 County Communications positions identified for deletion 17 Total positions affected before reallocation 105
Sheriff positions re-allocated to Court Security (34)
Net positions deleted 71
Source: County of Santa Clara, Fiscal Year 2026-27 Recommended Budget, Budget Unit 230 – Office of the Sheriff, “West Valley Patrol – Eliminate Service to Cities,” “Summary of Position Changes” and related Recommended Action (pages 309–310).
The 34 positions re-allocated to Court Security are therefore different from the 71 positions eliminated.
The Recommended Budget states that the court system has capacity to accommodate the 33 deputies and one sergeant and that Court Security provides a reimbursement structure so that the reallocated employee costs would not affect the General Fund. For purposes of this analysis, the 34 positions are treated as continuing County positions reassigned from West Valley to another function, consistent with the County’s Recommended Budget, rather than as additional position eliminations.
This distinction is relevant to the interpretation of the no-contract scenario. The reallocation does not represent elimination of those employees or their associated compensation costs because they would continue to be employed by the County. It does, however, indicate that the County no longer expects those positions to be required for West Valley operations if the city contracts are discontinued.
Quantified Expenditure Reductions
The Recommended Budget identifies a $21,412,967 decrease in salaries and benefits and a $2,180,583 decrease in ongoing services and supplies associated with discontinuing West Valley city services, for a combined budgeted expenditure reduction of $23,593,550.
The $2,180,583 services-and-supplies reduction is further identified by the County as follows:
Services and Supplies Reduction Amount
Contract dispatch costs $100,000
Contract fleet fuel costs $285,749
Contract fleet procurement and maintenance costs $1,394,330 Contract technology support costs $81,373
Contract software license costs $35,120
Contract telecom service costs $27,967
Other contract services and supplies $256,044
Total $2,180,583
Source: County of Santa Clara, Fiscal Year 2026-27 Recommended Budget, Budget Unit 230 – Office of the Sheriff, “West Valley Patrol – Eliminate Service to Cities,” “Summary of Other Costs” (page 309).
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 31 The fleet-related reductions total $1,680,079, consisting of fuel and fleet procurement and maintenance. The technology-support, software-license, and telecom reductions total $144,460.
These amounts reconcile to the fleet and technology reductions identified in the Recommended Budget; they are components of the $2,180,583 services-and-supplies reduction and should not be added again when evaluating the total budget impact.
Because the County identifies the $2,180,583 of services-and-supplies expenditures as costs that would be reduced if the West Valley city contracts were discontinued, these costs provide evidence of a direct relationship to the contract services and do not appear to represent costs the County would incur regardless of the contracts.
The Recommended Budget also identifies a $27,796,974 decrease in contract revenue and a $10,931,693 increase in Court Security reimbursement in the financial summary at the conclusion of the “West Valley Patrol – Eliminate Service to Cities” budget action. After considering the expenditure and revenue changes, the County reports ongoing net General Fund savings of $6,728,269. The Recommended Budget narrative identifies contract revenue of $27,796,976, a $2 difference from the $27,796,974 amount shown in the financial summary at the conclusion of that budget action; the financial summary amount reconciles with the stated $6,728,269 of ongoing net savings.
The $6,728,269 net savings amount is not a measure of costs attributable to the city contracts. It reflects both expenditure changes and changes in County revenue, including the loss of city contract revenue and the additional Court Security reimbursement associated with the reassigned positions.
The more relevant information for evaluating the relationship of costs to the city contracts is the specific staffing, services, supplies, and support activities the County identifies as changing under the nocontract scenario.
Dispatch
Dispatch provides a particularly useful example of the distinction between an allocation methodology and the County’s own estimate of cost changes. The Recommended Budget identifies the elimination of the County Communications unit assigned to West Valley dispatch, consisting of 17 positions: 11 Communications Dispatcher III positions, one Communications Dispatcher II, two Senior Communications Dispatchers, one Supervising Communications Dispatcher, one Communications Systems Technician, and one Administrative Assistant.
The Recommended Budget separately identifies a reduction in County Communications Dispatch Services of $4,142,305 (page 198). Because the 17 County Communications positions are also included in the Recommended Budget’s overall staffing action, the dispatch amount should be considered in conjunction with the consolidated salaries-and-benefits reduction rather than automatically added to the other no-contract amounts without a line-item reconciliation. Similarly, the $100,000 “Contract Dispatch Costs” reduction included within the $2,180,583 services-and-supplies total is separately identified by the County and should not be assumed to represent the same costs as the County Communications staffing reduction without a detailed crosswalk.
The elimination of a specifically identified 17-position West Valley dispatch unit nevertheless provides County-generated evidence that a portion of dispatch staffing and capacity changes directly with the city contracts. This is consistent with the treatment of dispatch in Section 3 as a West Valley support activity associated with the city contracts. It does not establish that all County Communications costs are attributable to the city contracts, as the County would continue to maintain communications and dispatch functions for its remaining law enforcement responsibilities.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 32 Investigative, Records, and Other Department Support The Recommended Budget states that the no-contract scenario would result in the complete dissolution of the West Valley Investigations Division and additional reductions within Investigations Headquarters, Records, Fiscal Administration, Data Management, and other County departments supporting West Valley operations. It also identifies reductions in Facilities, Fleet, network and hardware technology, software licensing, and telecommunications.
This information is relevant to the indirect department support categories evaluated in Section 4 of this report. In particular, it demonstrates that Investigative, Records, fiscal, data-management, technology, and other support functions are not uniformly fixed in the absence of the city contracts; the County itself expects some level of these activities to decrease when West Valley city services are discontinued.
The Recommended Budget, however, does not separately quantify each of these reductions using the same cost-pool definitions included in the County’s FY 2026-27 contract proposal. The contract proposal combines cost centers, staffing, Countywide allocations, and operating expenditures into categories such as Investigative Services, Records Services, Personnel and Training, IT Services, Fiscal Services, Internal Affairs, Sheriff Administration, and Indirect Countywide Support. The Recommended Budget is organized by budget action, position, department, and expenditure category.
Accordingly, amounts appearing in the two documents are not directly interchangeable without reconciling the underlying cost populations.
For the same reason, differences between amounts appearing in the Recommended Budget for Information Systems, Internal Affairs, or other support functions and the amounts used in the County’s contract-cost calculations do not, by themselves, establish an additional reduction or an error in the County’s proposal. A direct adjustment would require a component-level reconciliation showing which positions, expenditures, internal charges, and Countywide allocations are included in each amount.
Accordingly, the difference between the support and overhead amounts included in the FY 2026-27 contract proposal and the separately identified reductions in the Recommended Budget should not be interpreted as a measure of costs that necessarily continue in the absence of the city contracts, because the two documents use different cost populations and the identified reductions have not been fully reconciled to the contract proposal cost pools.
Relationship to Overhead Analysis
The Recommended Budget provides additional County-generated information relevant to the cost categories evaluated in Section 4. Its no-contract scenario identifies reductions in Investigations Headquarters, Records, Fiscal Administration, and Data Management, while the separately quantified services and supplies reduction of $2,180,583, includes dispatch, fleet, technology, software, telecommunications, and other contract related operating costs.
Conversely, the Recommended Budget indicates that broader County functions continue after the West Valley city contracts are discontinued, even where some contract-related activity within those functions is reduced. These continuing functions include County Communications, Investigations Headquarters, Records, Fiscal Administration, Data Management, facilities, fleet, technology, and other departmentwide or countywide support activities. To the extent the FY 2026-27 contract proposal allocates the standing or baseline costs of these continuing functions to West Valley, those components appear to represent costs the County would incur regardless of the city contracts and therefore would not be allocable to the contract cities under Government Code section 51350. The Recommended Budget does not quantify those continuing components using the same cost-pool definitions as the contract proposal, so the amount cannot be determined without a detailed reconciliation of the two cost populations.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 33 The Recommended Budget therefore supports the observation in Section 4 that broader support cost pools may contain both contract-related costs that decrease when the contracts are removed and baseline or continuing costs that remain with the County. It does not independently validate the specific component classifications in Section 4 or establish the amount of any broader cost pool that is allocable or not allocable to the contract cities.
The Recommended Budget does not provide a complete reconciliation between the costs eliminated, reduced, or reassigned under the no-contract scenario and each cost pool included in the County’s FY 2026-27 contract proposal. It therefore does not establish the precise amount of each broader support pool attributable to the city contracts and does not resolve the limitations identified in Section 4 for cost pools that continue to include mixed, baseline, countywide, custody-related, or otherwise insufficiently segregated components.
Government Code section 51350 provides “A county which provides services through its appropriate departments, boards, commissions, officers or employees, to any city pursuant to contract or as authorized by law, shall charge the city all those costs which are incurred in providing the services so contracted or authorized. A county shall not charge a city contracting for a particular service, either as a direct or an indirect overhead charge, any portion of those costs which are attributable to services made available to all portions of the county, as determined by resolution of the board of supervisors, or which are general overhead costs of operation of the county government. General overhead costs, for the purpose of this section, are those costs which a county would incur regardless of whether or not it provided a service under contract to a city.
Any determination of general overhead costs shall be subject to court review as to the reasonableness of such determination.”
Observation: The Recommended Budget provides a separate County-developed source of information regarding how the County expects its staffing and operating costs to change if the West Valley city contracts are discontinued. It is consistent with the report’s observations that direct West Valley staffing and specifically identified operational and support resources are associated with the city contracts, and it identifies reductions in several broader support functions under the no-contract scenario. However, because the Recommended Budget does not reconcile those reductions to each cost pool in the FY 2026-27 contract proposal, it is most informative as corroborating evidence of cost behavior and contract-related activity rather than as a standalone calculation of the amount attributable to the contract cities. The absence of a reconciliation supports the classification of the $10,667,109 in overhead costs as non-allocable, as these costs were not reduced or eliminated in the Recommended Budget. This demonstrates that the costs continue to be incurred regardless of the contract and therefore do not represent costs attributable to, or caused by, the services provided to the cities.
City of Cupertino
Sheriff Contract Cost Allowability and Compliance with Government Code §51350 34 Additional Sources/References:
- Los Angeles County Sheriff's Department FY 2025-2029 Boilerplate Agreement for Contract Cities Approved by the Board of Supervisors
- Law Enforcement Services Agreement between the City of Lake Forest and the County of Orange - Law Enforcement Services Agreement between the City of Santa Margarita and the County of Orange - Law Enforcement Services Agreement between the City of West Hollywood and the County of Los Angeles
- Law Enforcement Services Agreement between the City of San Carlos and the County of San Mateo - Law Enforcement Services Agreement between the Town of Woodside and the County of San Mateo - City of Diamond Bar, CA FY 2026-27 Budget
- City of West Hollywood, CA FY 26-27 Budget
- City of Encinitas, CA FY 26-27 Budget
- 2026-2027 Portola Valley Budget
www.vasquez.cpa
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Private and Confidential
CITY OF CUPERTINO
Cost Allowability and Compliance with Government
Code §51350
Fiscal Year 2026-27
Sheriff Contract Cost
Review
2 EXECUTIVE SUMMARY
The County's FY 2026-27 proposal changes both the composition of overhead and the method used to allocate it. Departmental support moves to an annual cost-per-position basis, Records and Investigations move to a three-year RMS caseload share, and the overhead base expands to include countywide Investigations, Sheriff's Office Administration, and Internal Affairs. $6.0M
Increase in overhead allocated to the
West Valley Station compared with
the prior year
$40.4M
Projected FY 2026-27 cost for
Cupertino, Saratoga, and Los Altos
Hills combined
$10.7M
West Valley cost classified as not
allocable in the category-level
overhead review
128%
Cupertino overhead as a percentage
of direct cost, against 16%-34% for
the benchmark cities
Principal observations
Common allocation basis. A single 50% caseload / 50% service-hour driver is applied across cost categories that perform substantially different functions, and caseload does not distinguish among cases by complexity or effort.
Alternative allocation. Reallocating the same West Valley amounts on assigned FTE reduces the three-city total from $40.4 million to $33.9 million, a decrease of $6.5 million or 16.1%.
County's own estimate. The FY 2026-27 Recommended Budget identifies $23.6 million of expenditure reductions and a net 71-position decrease if the city contracts were discontinued.
Benchmark position. Removing the three-city share of costs classified as not allocable lowers the fully loaded cost from $747,608 to $571,340 per FTE — explaining 48% to 78% of the gap to the benchmark jurisdictions, but not all of it. / What Changed, and What It Costs the Three Cities
3 Government Code section 51350. A county must charge a city the costs incurred in providing contracted services and may not include general County overhead costs that would have been incurred regardless of the contract.
What an allocation formula establishes
• How a cost pool is distributed among Cupertino, Saratoga, Los Altos Hills, and the unincorporated area
• That the distribution can be independently recalculated from the supporting schedules
• That the same basis has been applied consistently across the categories presented
What it does not establish
• That the cost was incurred in providing services to the contract cities
• That the chosen driver reflects how each function consumes resources
• That case counts capture complexity, staff time, or level of effort per case
The analysis therefore evaluates each component on whether it is associated with providing law-enforcement services to the three cities, rather than on whether it can be distributed by formula.
SECTION 4 - CONTRACT LAW ENFORCEMENT OVERHEAD
/ The Standard Applied to Each Cost Component
4 Overhead category West Valley
share Component-level considerations Classification
Countywide Cost Allocation $580,573 County counsel, finance, and technology costs allocated through the Countywide Cost Allocation Plan; attributable to services available to all County departments.
Not allocable
Personnel and Training $1,057,612 Custody academy, recruitment, and baseline training capacity are unrelated or baseline; recruiting and training caused by West Valley staffing may be allocable in part.
Not allocable
Fiscal Services $298,434 Custody fiscal services and baseline accounting capacity are excluded; actual contract billing, payroll, and accounting transactions are mixed where specifically supported.
Not allocable
IT Services $997,556 Custody IT and baseline enterprise-system capacity are excluded; contract-specific devices, licenses, users, and support may be attributable to the service.
Not allocable
Internal Affairs $253,085 Custody units and baseline governance capacity are excluded or unrelated; city-service incidents may create some mixed workload.
Not allocable
Sheriff Administration $349,433 Sheriff and Undersheriff positions were excluded by the County; baseline executive functions and newly included CC3900 functions lack a demonstrated West Valley nexus. Three-city portion is $282,306.
Not allocable
Subtotal $3,536,693 Category-level classification; the component review shows several pools contain both contract-related and baseline activity.
$3,536,693
Observation. These pools are presented as combined amounts rather than separately identifying baseline County operations and the portion associated with West Valley contract services. The component-level review distinguishes custody operations, the Sheriff's South County investigative unit, baseline executive management, and departmentwide administrative functions within the broader categories.
SECTION 4 - COUNTYWIDE AND DEPARTMENT SUPPORT
/ Treatment of the Departmental Overhead Categories
5 Investigative Services $5,531,736
West Valley share
• Only $1,233,709 is identified as allocable to West Valley; $4,298,027 is classified as not allocable.
• South County Investigations (cost center 3931; two FTE; approximately $706,929) is unrelated to West Valley.
• Other headquarters and regional positions require a documented West Valley service nexus.
• The source comment reflects 43 of 49 headquarters FTE against only four West Valley FTE.
Records Services $2,832,389
West Valley share
• The full amount is classified as not allocable at the category level. • A Records Sheriff overhead allocation of approximately $1,492,651 represents second-order mixed overhead.
• Records Technician and Office Specialist transaction work may be attributable in part.
• The component review supports a narrower split between city transactions and baseline capacity.
$11,900,818
West Valley share of the overhead and
support pools reviewed
$10,667,109
Classified as not allocable in the categorylevel review The $10,667,109 reflects classification of entire categories.
Because several of those categories include activities that may relate to the contract cities as well as activities that may not, the amount is used in Section 8 solely to measure its effect on the benchmark comparison.
SECTION 4 - INVESTIGATIVE AND RECORDS SERVICES
/ The Two Largest Support Pools Drive the Classification
6 County Contract structure Staffing exhibit Pricing method Los Angeles Standardized countywide Municipal Law
Enforcement Services Agreement
Detailed deployment schedules and annual
service levels Full cost recovery using County-approved billing rates Orange Municipal contract with the Sheriff's Department Service levels customized by city Cost reimbursement for personnel, equipment, overhead, and special services
San Bernardino Sheriff's Law Enforcement Services Contract Schedule A listing staffing, vehicles, dispatch, support services, and annual costs
Annual Schedule A cost allocation, frequently
amended during the year
San Diego Sheriff's Municipal Services Agreements Annual staffing schedules and service plans Cost recovery based on staffing assignments and support services
San Mateo Municipal agreements for Sheriff-provided
services
Assigned personnel and service levels set by
contract, updated annually
Cost recovery based on assigned personnel, operating
costs, and support services
Contra Costa Sheriff-staffed municipal police department City-funded Sheriff staffing organized by police function
City-funded Sheriff positions and related operating and support costs
Santa Clara Individual contract with the Sheriff's Office Negotiated staffing levels tailored to each city
Direct reimbursement of Sheriff's costs plus
overhead
Observation. The materials examined did not identify caseload as a basis for allocating general operating or overhead costs in any of the six comparative counties. Those methodologies use assigned staffing or FTEs, defined service levels, separately identified support costs, or predetermined overhead percentages.
SECTION 8 - COMPARATIVE ANALYSIS
/ How Other California Counties Structure Contract Services
7 16% 18%
23% 24% 24% 26%
34%
117%
125% 128%
0 20
40 60
80 100
120
140 By county methodology
Los Angeles — station overhead built into the annual rate per position, plus 12.5% for the liability trust fund; countywide overhead does not appear to be allocated.
Orange — regional shared costs of 3% to 4% and, other
county overhead of 21% to 22%, for a total of 24% to 26%.
San Diego — overhead allocated on FTE at approximately
34% of direct costs; no countywide costs allocated.
San Bernardino — overhead of approximately 25% of direct personnel costs, plus roughly 2% county administrative cost.
San Mateo — separately identified operating and support costs of approximately 16% to 23% of direct policing costs.
Contra Costa — additional costs of approximately 24% of direct policing costs under a Sheriff-staffed municipal model.
SECTION 8 - OVERHEAD ALLOCATION METHODOLOGY
/ Overhead as a Percentage of Direct Cost
8 Direct patrol, traffic, and school-resource staffing costs remain unchanged. West Valley station, countywide, and department support costs — including Investigative and Records Services — are reallocated using each city's assigned FTE as a share of the 89 budgeted West Valley FTE. $11.8
$5.4
$2.8
$0.9 $0.8
$0.3 $0.2 $0.2
$8.7
$3.5
$1.8
$0.7 $0.7
$0.2 $0.2 $0.1
$0M
$2M
$4M
$6M
$8M
$10M
$12M
Station and
countywide
support
Investigative
Services
Records
Services
Personnel and
Training
IT Services SO
Administration
Fiscal Services Internal Affairs
Current proposal FTE-based allocation
$6.5M · 16.1%
Generally, more consistent with the benchmark contracts reviewed. The analysis illustrates how the amounts already assigned to West Valley would change; it does not establish the required allocation method or whether every cost in the proposal is allocable.
City Current FTEbased Change % FTE
Cupertino $25.4 $21.0 $4.4 17.3% 33
Los Altos Hills $3.4 $2.9 $0.5 14.7% 5
Saratoga $11.6 $10.0 $1.6 13.8% 16
Three-city total $40.4 $33.9 $6.5 16.1% 54
SECTION 9 - COMPARATIVE FTE- BASED ALLOCATION
/ Reallocating the West Valley Costs on Assigned Staffing (FTE-Based)
9 What it supports
• Direct West Valley staffing and specifically
identified operational resources are
associated with the city contracts.
• Investigative, Records, fiscal, datamanagement, and technology support are not uniformly fixed; the County expects
some level of these activities to decrease.
• A specifically identified 17-position West
Valley dispatch unit is eliminated,
evidencing that dispatch capacity changes
with the contracts.
What it does not establish
• The precise amount of each broader
support pool attributable to the contract
cities.
• That all County Communications costs are
attributable to the contracts; the County
would continue to maintain dispatch for its
remaining responsibilities.
• That differences between Recommended
Budget amounts and contract-cost
calculations represent an error or an
additional reduction.
Reconciliation
• The contract proposal combines cost
centers, staffing, Countywide allocations,
and operating expenditures into support
categories.
• The Recommended Budget is organized by
budget action, position, department, and
expenditure category.
• Amounts in the two documents are not
directly interchangeable without a
component-level crosswalk of the
underlying cost populations.
Observation. To the extent the FY 2026-27 proposal allocates the standing or baseline costs of functions that continue after the contracts end, those components appear to represent costs the County would incur regardless and would not be allocable under section 51350. Because the Recommended Budget does not reconcile its reductions to each cost pool in the proposal, it is most useful as corroborating evidence of cost behavior rather than as a standalone calculation of the amount attributable to the cities.
SECTION 10 - RECOMMENDED BUDGET
/ What the No-Contract Scenario Budget Does and Does Not Establish
10 Allocation basis
A single 50/50 caseload and service-hour driver is
applied across functions with different cost
behavior, and no benchmark county reviewed uses
caseload for general operating or overhead costs.
Category classification
$10,667,109 of the West Valley cost is classified as
not allocable at the category level, concentrated in
Investigative Services, Records Services, and
countywide support.
Benchmark position
Removing the unallowed overhead cost of
$10,667,109, adjusted fully loaded cost to $571,340
per FTE, West Valley is comparable to the upperrange benchmarks at a screening level but remains
10.5% to 50.8% above the jurisdictions presented.
Alternative allocation
Assigned FTE-based reallocation of the same West
Valley amounts reduces the three-city total by $6.5
million, or 16.1%, and aligns more closely with the
benchmark contracts.
County corroboration
The Recommended Budget identifies $23.6 million
of expenditure reductions and a net 71-position
decrease under a no-contract scenario, evidencing
contract-related cost behavior.
Reconciliation
A component-level reconciliation between the
Recommended Budget and each contract cost pool
is required to quantify the amounts attributable to
the contract cities.
SUMMARY OF OBSERVATIONS
/ Where the Analysis Leaves the Proposed FY 2026-27 Charges
11 Government Code section 51350
A county which provides services through its appropriate departments, boards, commissions, officers or employees, to any city pursuant to contract or as authorized by law, shall charge the city all those costs which are incurred in providing the services so contracted or authorized. A county shall not charge a city contracting for a particular service, either as a direct or an indirect overhead charge, any portion of those costs which are attributable to services made available to all portions of the county, as determined by resolution of the board of supervisors, or which are general overhead costs of operation of the county government. General overhead costs, for the purpose of this section, are those costs which a county would incur regardless of whether or not it provided a service under contract to a city.
Any determination of general overhead costs shall be subject to court review as to the reasonableness of such determination.
SUMMARY OF OBSERVATIONS
/ Matters Requiring County Action – Not Allocable OH Costs
12 The burden of proof rests with the County. These cost components were not eliminated in the Recommended Budget and therefore, represent costs the County would incur regardless and would not be allocable under section 51350.
County Action Required:
To support its position, the County must provide persuasive and substantiated evidence that the $10.667 million in costs identified as not allocable are not general costs of County operations and would be avoided if the contracts with the three cities were discontinued.
SUMMARY OF OBSERVATIONS
/ Matters Requiring County Action – Not Allocable OH Costs
13 The burden of proof rests with the County. West Valley’s staffing allocation of 89 FTEs represents only approximately 5% of the combined staffing of the Sheriff’s Department and Department of Corrections (BUs 230, 235, and 240), which total 1,768 FTEs, and approximately 12% of BU230’s 720 FTEs. The 89 FTEs assigned to West Valley include three Law Enforcement Records Technicians; however, West Valley is also allocated an additional 34.4% share of countywide records services overhead costs based on caseload.
Similarly, of the 49 FTEs assigned to BU230’s Investigative Divisions, only 4 FTEs (8%) are dedicated to West Valley. Despite this limited staffing assignment, West Valley is allocated 34.4% of countywide investigative costs under the caseload-based allocation methodology.
None of the benchmark counties reviewed use caseload to allocate general operating or overhead costs. While West Valley Station represents 34.40% of the Countywide caseload based on case counts, case volume alone does not measure the level of resources consumed. Case counts do not capture differences in case complexity, staff time or effort required to provide services.
The County has not provided data regarding the complexity of cases, staff hours incurred, or effort associated with the cases attributed to West Valley Station.
Without such information, caseload cannot be substantiated as a reasonable, equitable or cost-causative basis for allocating general operating or overhead costs.
County Action Required:
The County should provide data supporting the relative complexity of cases, staff hours expended, and level of effort associated with the cases attributed to West Valley Station to demonstrate that caseload is an appropriate allocation methodology.
This presentation was prepared for the City of Cupertino for the purposes described in the related report. Its distribution is limited to authorized representatives of Cupertino, Saratoga, Los Altos Hills, and the County of Santa Clara. Distribution to these parties does not create a professional duty or responsibility to any party other than the City of Cupertino. The presentation is not intended for use or reliance by any other party without Vasquez’s prior written consent.
SUMMARY OF OBSERVATIONS
/ Matters Requiring County Action – Use of Caseload
From:
To: Arika Miller; City Council
Subject: Sheriff Contract Meeting - Supplement
Date: Sunday, August 30, 2026 10:04:29 AM
Arika, Please provide the letter below as a supplement to the Sheriff contract meeting on Monday. Thank you, Jim Waschura
===
As the town works through the County's proposed contract costs, the issue I keep coming back to is reporting — not crime statistics, but performance against budgets and financial expectations.
The contract as structured lets the County total everything it spends or allocates and charge us even when that exceeds budget, and the budget itself resets upward every year. It also runs one-way: overruns are passed through to us, but nothing entitles us to a credit when they spend under budget. Given that asymmetry, I suggest we press for at least quarterly financial reporting by budgeted category, showing forecast against budget and actuals against budget, with deviations highlighted, reviewed by a competent person in the Sheriff's office, and presented at a quarterly standing meeting of the three cities — likely the city managers, potentially mayors or an ad hoc committee. We should have transparency into how the budgets we're liable for, including overheads, are built and how they're performing, including an itemization of the charges and allocations flowing from county-shared functions and their own performance to budget.
Second, I'd like the County to apply a continuous-improvement discipline to the cost of these services. What actions and programs are planned to reduce costs, are they succeeding, and what is the outlook? Are they on track? Since we pay whatever the number turns out to be, the County has no built-in incentive to economize, and structured reporting on cost-reduction efforts is a minimum mechanism for creating that pressure.
Third, I'd like to explore whether the County could provide our future CSO person/team at a price no greater than 1.5x what it would cost us to stand the service ourselves. They should welcome the added revenue and the larger base over which to amortize their overheads, and there is natural synergy between CSO work and functions they already operate — synergy we would not capture doing this internally. The demand profile probably supports a single shift, five days a week: parking on pathways and around construction sites, noise and cleanliness at construction sites, neighbor issues, daytime vacation checks, and neighborhood drivethroughs projecting presence. These are visible services residents would feel directly, while ITEM 2A, Supplement 1
Jim Waschura
shifting work off patrol-officer time billed at a much higher rate.
I hope you find these suggestions helpful.
As a Los Altos Hills Resident,
Jim Waschura
ITEM 2A, Supplement 2
The Caseload Formula and Allocation of Countywide Sheriff Costs to LAH Roughly 70% of the Town’s contract increase traces to changes in how the County allocates Investigative and Records services. The Vasquez review classified these caseload-based charges as unsupportable.
By Resident Jim Waschura (with help from Claude AI)
The charge in question
Of the $3.38 million the County proposes to charge Los Altos Hills for FY 2026–27, $774,993 is "indirect department support" — the Town’s share of countywide Sheriff’s Office divisions rather than of anything stationed in or dedicated to West Valley. The two largest pieces, Investigative Services ($364,509) and Records Services ($186,638), are allocated by a method the independent Vasquez review found no basis to support, and they are the subject of this memo.
Countywide cost pool Department-wide
total
West Valley share WV % of
pool
Los Altos Hills
charge
LAH %
Five administrative pools
(Personnel & Training, IT, SO
Admin, Fiscal, Internal Affairs)
$51,969,299 $2,956,120 5.4% - 8.0% $223,846 7.57%
Investigative Services $16,082,396 $5,531,736 34.40% $364,509 6.59% Records Services $8,234,594 $2,832,389 34.40% $186,638 6.59% Indirect department support
subtotal
$11,320,245 $774,993
Source: County of Santa Clara FY 2026–27 contract schedule; Vasquez & Company LLP review, Table 8-2. The West Valley shares of Investigative and Records are set by three-year RMS case counts; the administrative pools are allocated by FTE measures.
How the percentages get built
The County first assigns each countywide division a West Valley share, then splits that share among the three cities and the unincorporated area. For the Investigative and Records Divisions, the West Valley share is set by case counts in the Records Management System, averaged over three years, and under that measure West Valley, with about 5 percent of the department’s staffing, is assigned a 34.4 percent allocation of both divisions. The gap between those two figures reflects the structure of the department: most of the Sheriff’s Office serves custody, court-security, and administrative functions, while nearly every other resident of the county lives in a city with its own police department, so West Valley is one of the few areas the Sheriff routinely patrols. Activity recorded in the case-count system is therefore concentrated in the contract areas, and our share of total cases runs well above our share of the department’s staffing and resources. The size of the charge is the product of these two elements — a cost pool scoped to the countywide mission, and a percentage shaped by where patrol activity happens to occur.
What the formula charges us for: a detective example
The Investigative Services pool is $16.1 million and includes headquarters units — Major Crimes, sexual assault, evidence management, crime-scene investigation — sized for the department’s entire countywide mission. County records show only 4 of the 49 headquarters positions are dedicated to West Valley. Consider a Major Crimes homicide detective costing roughly $330,000 loaded per year: that detective works murders arising elsewhere in the county, yet because the position sits in the pool and West Valley’s caseload share is 34.4 percent, the contract jurisdictions pay about $113,000 of that salary annually whether the detective ever opens a West Valley file. The formula also counts every case equally regardless of complexity, so routine incidents requiring no detective time carry the same weight in the allocation as investigations consuming hundreds of staff hours; the County has not provided case-complexity or staff-hour data that would connect the counts to actual resource use.
Investigative Services: what exists vs. what is charged Amount Investigations Headquarters staffing 49 FTE
Positions dedicated to West Valley 4 FTE
Cost of those dedicated positions (allocable) $1,233,709 Charged to West Valley by caseload formula $5,531,736
ITEM 2A, Supplement 2
Excess classified not allocable by Vasquez $4,298,027
Los Altos Hills share of the identifiable service (6.59% of $1.23M) ~$81,000 Los Altos Hills actual charge $364,509
Source: Vasquez review, Sections 4 and 8; Los Altos Hills figures computed from the County’s 6.59% allocation share.
The Records pool: paying twice
The Records charge involves an additional layer: the cities already fund three records technicians at the West Valley station — the staff who actually process our incident reports — through the separate station-support allocation. The $186,638 countywide Records charge comes on top of that, and Vasquez found roughly $1.5 million of the $8.2 million countywide pool is not records labor at all but Sheriff overhead allocated into the Records Division from elsewhere, riding out to the cities at the caseload rate. The rest is management and platform capacity serving the department’s whole paper flow — warrants, custody documentation, court filings — work arising largely from the department’s custody and court responsibilities rather than from contract-city patrol activity.
How much these issues contribute to the increase
Both consequences of the caseload formula can be sized from the Vasquez classifications. For Investigative Services, the review found $1,233,709 of West Valley-dedicated resources supportable and classified the remaining $4,298,027 of the caseload-driven charge as not allocable; for Records Services it classified the full $2,832,389 as not allocable. The rows below show the savings if each charge were limited accordingly, with the three-city amounts derived from the jurisdictions’ 93.42 percent combined share and the Town’s amounts from its
6.59 percent share. Because the two rows involve separate cost pools, they are independent and their total is additive.
The Town’s contract history puts the total in context: costs ran $2.467 million in FY 2023–24, $2.656 million in FY 2024–25, and about $2.7 million in FY 2025–26, so the FY 2026–27 proposal of $3.38 million represents an increase of roughly $680,000, or 25 percent, after two years of low-single-digit growth. The ~$470,000 of caseload-related charges shown below accounts for roughly 70 percent of that increase, and removing them would reduce the year-over-year increase to approximately $210,000, or 8 percent.
Category of disconnect Three-city savings % of $40.4M
proposal
Los Altos Hills
savings
% of $3.38M
proposal
Investigative Services caseload charge in
excess of identifiable West Valley
resources
~$4,015,000 9.9% ~$283,000 8.4%
Records Services caseload charge,
classified not allocable in full
~$2,646,000 6.6% $186,638 5.5%
Total (independent, additive) ~$6,661,000 16.5% ~$470,000 13.9% Sources: Vasquez review, Sections 4 and 8. West Valley not-allocable amounts of $4,298,027 (Investigative) and $2,832,389 (Records) multiplied by the combined three-city share of 93.42% and the Town’s share of 6.59%; the Records amount for the Town is its full charge.
Options for moving forward
Here are some possible options moving forward: The Council could seek to renegotiate the allocation method, directing staff to propose to the County that shared costs follow assigned staffing or documented service levels rather than caseload. It could require documentation before acceptance, submitting a written request for staff-hour, case-complexity, and reconciliation data and deferring the disputed charges until that support is provided. It could coordinate with Cupertino and Saratoga, whose contracts apply the same formulas, convening the three cities to align positions and to pursue joint terms such as budget-to-actual reporting and cost reconciliation. It could refer the classification questions to counsel, since Government Code §51350 makes the County’s overhead determinations reviewable by a court. Or it could accept the proposal as presented, in whole or with negotiated adjustments, weighing the amounts at issue against the costs of contesting them.
Five-Year Law Enforcement
Services Agreement
SPECIAL CITY COUNCIL MEETING
AUGUST 31, 2026
HOW WE GOT HERE
2014
10-year
agreement
begins
2024
2-year
extension
Dec. 2025
New cost
proposal
May–Jun.
2026
12-week
extension
+ overhead
review
Aug.
2026
Final agreement
for consideration
Oct. 1
2026
New term
begins
The current 12-week extension expires September 30, 2026.
PROPOSED FIVE-YEAR AGREEMENT: AT A GLANCE
TERM
5 years
EFFECTIVE
Oct. 1, 2026
TERMINATION
1-year written notice
COST MODEL
Full cost recovery
Annual Plan for Service
Town identifies desired
service levels each year.
Reconciliation of Hour
Actual costs reconciled
with supporting service
data.
No CPI Cap
Future rates are
recalculated annually by
the County.
The agreement continues the Town’s existing law enforcement partnership while establishing a new cost-recovery and reporting framework.
2014 AGREEMENT VS. PROPOSED 2026 AGREEMENT
TOPIC 2014 MODEL PROPOSED 2026 MODEL
Cost basis Hourly service rates Full cost recovery
Annual increases CPI + 2% cap County-calculated actual/projected costs; no annual cap Overhead Generally embedded in hourly rate Separated into station and departmentwide support costs Investigations Hourly billing Shared support cost based largely on case volume Scalability Costs generally moved with purchased hours Substantial portion does not scale directly with patrol hours Central shift: direct staffing is now only one component of the Town’s annual charge.
FY 2026-27 SERVICE LEVEL: COUNCIL DIRECTION
June 9 direction: maintain the same total number of contracted deputy hours, but shift traffic hours to general law enforcement.
Prior Allocation General: 5,421 Traffic: 1,860
FY 2026-27 General: 6,681 Traffic:
600
TOTAL SERVICE HOURS:
7,281
No change in overall contracted
hours
1,260 traffic-enforcement hours are transferred to general law enforcement.
FY 2026-27 PROJECTED FINANCIAL IMPACT
FY 2025-26
$2.76M
+22.6
%
FY 2026-27
$3.38M
Direct Staffing $1.50M (44%) Direct + Indirect Support $1.88M (56%) The total number of contracted patrol hours is unchanged; the increase is driven primarily by the revised rate and support-cost structure.
COMPONENTS OF THE AGREEMENT
Monthly/Weekly Reporting
Crime, calls for service, response times, hours,
staffing trends, and cost estimates.
Reconciliation
Direct staffing, deployment hours, and overtime
10% Service Threshold
If projected hours exceed the approved Plan by
more than 10%, written notice and modification
process are required.
Written Amendments
Unanticipated or changed costs must be noticed
and negotiated; they are not imposed unilaterally.
KEY NEGOTIATION ISSUES RESOLVED OR ADDRESSED
1 Indemnification Mutual indemnification tied to each party’s duties and obligations. 2 West Valley
Substation
Early termination obligations limited to existing pro rata lease / move / tenant improvement costs.
3 Cost-Recovery
Standard
Agreement expressly governed by Government Code §51350. 4 Service-Level
Protections
Plan for Service, 10% threshold, monthly/weekly reporting These terms provide more visibility and process than the 2014 agreement, but future costs still require active review.
INDEPENDENT REVIEW: VASQUEZ & COMPANY
REVIEW FOCUS
• Allocation of direct and
shared costs
• Transparency and
traceability
• Consistency with
Government Code §51350
MAJOR FINDING
$10.67M
of $11.90M in West Valley
countywide and departmental
overhead was identified as not
allocable at a category level.
IMPORTANT NUANCE
The report is not an
audit or legal opinion,
and the componentlevel review recognizes
some contract-related
activity may exist within
broader cost pools.
The key issue is distinguishing contract-related costs from baseline County costs that continue regardless of the cities’ contracts.
GOVERNMENT CODE §51350: MAIN TAKEAWAY
“This Agreement is governed by Government Code section 51350.”
WHAT SIGNING DOES
• Provides continuity of law enforcement
services
• Establishes a five-year framework
• Accepts the agreement structure and
process
WHAT SIGNING DOES NOT DO
• Does not waive Section 51350
• Does not bless every cost category forever
• Does not end annual review of rates
The Town will continue reviewing annual rates, support documentation, and reconciliation charges during the life of the contract.
STAFF RECOMMENDATION
Adopt the resolution authorizing the City Manager to execute the fiveyear law enforcement services agreement with the County of Santa Clara Office of the Sheriff.
Continuity
Avoids disruption after the current extension expires
September 30.
Service Level
Maintains the total contracted deputy hours
previously directed by Council.
Contract Protections
Adds reporting, annual plan, 10% threshold, and
written amendment process.
Ongoing Oversight
Costs remain subject to agreement terms and
Government Code §51350.
Requested Council action: approve the resolution.