Agenda packet — Paradise City Council, September 8, 2026 (part 2 of 2)

their taxes and insurance as part of their monthly mortgage payment.

3. Required Request for Notice of Default:

When the Borrower’s loan is in second position behind an existing primary mortgage, it is the Lender's policy to prepare and record a "Request for Notice of Default" for each senior lien in front of Lender’s loan. This document requires any senior lienholder listed in the notice to notify the Lender of initiation of a foreclosure action. The Lender will then contact the Borrower and assist them in bringing the primary loan current, if possible. The Lender can also monitor the foreclosure process and go through the necessary analysis to determine if the loan can be made whole or preserved. When the Lender is in a third position and receives notification of foreclosure from only one senior lienholder, it is in their best interest to contact any other senior lienholders regarding the status of their loans.

4. Annual Occupancy Restrictions and Certifications:

On owner-occupant loans, the Lender will require that Borrowers submit utility bills and/or other documentation annually to prove occupancy during the term of the loan. Annual occupancy verification will occur between the 1st and 15th of January each year for the term of the loan.

5. Required Noticing and Restrictions on Any Changes of Title or Occupancy:

In all cases where there is a change in title, occupancy, and/or use, the Borrower must notify the Lender in writing of the change.

If a transfer of the property occurs through inheritance, the heir (as owner-occupant) may be provided with the opportunity to assume the loan, provided the heir is income eligible.

If the heir intends to occupy the property and is not low-income, the balance of the loan is due and payable.

If the owner moves out and converts the owner-occupied unit into a rental unit before the end of the HOME Affordability Period, the loan is due in full, unless the owner moves back in immediately.

Conversion to use other than residential use is not allowable where the full use of the property is changed from residential to commercial or other. In some cases, Borrowers may request that the Lender allow for a partial conversion where some of the residence is used for a business, but the household still resides in the property. Partial conversions can be allowed if reviewed and approved by all agencies required by local statute. If the use of the property is converted to a fully non-residential use, the loan balance is due and payable.

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6. Requests for Subordinations:

When a Borrower wishes to refinance their existing primary mortgage, they must submit a subordination request to the Program Lender. Approved refinancing of senior debt will be limited by the Department to circumstances in which the original homebuyer is securing more favorable terms that reduce monthly housing costs, or if sufficient equity exists, to take cash out for only items such as for immediate repairs to the property to correct identified health and safety violations.

There can be no third-party debt payoffs or additional encumbrances on the property. The total indebtedness on the property should not exceed the current market value, except when the borrower is obtaining a federally-sponsored refinance program loan. If said loan is approved and meets all other requirements, Combined Loan-To-Value will not be considered when reviewing the subordination request.

Also, the loan must:

1. be fully amortized and have a fixed interest rate that does not exceed the current market rate, as established by an index identified in these Program Guidelines;

2. not have a temporary interest rate buy-down;

3. have a term “all due and payable” that matures prior to or concurrently with the maturity date of the Promissory Note. Therefore, the maturity date of the existing Promissory Note shall be modified to coincide with the maturity date of the new primary mortgage; and

4. not have a balloon payment due before the maturity date of the Program loan.

Upon receiving the proper documentation from the refinance lender, the request will be considered by the Sponsor’s loan committee for review and approval. Upon approval, the escrow company will provide the proper subordination document for execution and recordation by the Sponsor.

7. Process for Loan Foreclosure:

Upon any condition of loan default, such as non-payment, lack of insurance or property tax payment, change in title or use without approval, or default on senior loans, the Lender will send out a letter to the Borrower notifying them of the default status. If the default status continues, the Lender may start the formal process of foreclosure.

When a senior lienholder starts a foreclosure process and the Lender is notified via a Request for Notice of Default, the Lender, who is the junior lienholder, may cancel the foreclosure proceedings by "reinstating" the senior lienholder. The reinstatement amount or payoff amount must be obtained by contacting the senior lienholder. This amount will include all delinquent payments, late charges, and fees to date. Lender must confer with Borrower to determine if, upon paying the senior lienholder current, the Borrower can provide future payments. If this is the case, then the Lender may cure the foreclosure and add the costs to the balance of the loan with a Notice of Additional Advance on the existing note. HOME funds may not be used for this purpose. 156
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If the Lender determines, based on information on the reinstatement amount and status of Borrower, that bringing the loan current will not preserve the loan, then staff must determine if it is cost effective to protect their position by paying off the senior lienholder in total and restructuring the debt such that the unit is made affordable to the Borrower.

If the Lender does not have sufficient funds to pay the senior lienholder in full, then they may choose to cure the senior lienholder and foreclose on the property themselves. If there is sufficient value in the property, then the Lender can afford to pay for the foreclosure process, pay off the senior lienholder, and retain some or all of its investment.

If the Lender decides to reinstate, the senior lienholder will accept the amount to reinstate the loan until five (5) days prior to the set "foreclosure sale date." This "foreclosure sale date" usually occurs about four (4) to six (6) months from the date of recording of the "Notice of Default." If the Lender fails to reinstate the senior lienholder before five (5) days prior to the foreclosure sale date, the senior lienholder will then require a full payoff of the balance, plus related foreclosure administrative costs, to cancel foreclosure. If the Lender determines the reinstatement and maintenance of the property is not cost effective and allows the senior lienholder to complete foreclosure, the Lender's lien may be released once net available proceeds are received, if any.

Lender as Senior Lienholder
When the Lender is in first position as a senior lienholder, active collection efforts will begin on any loan that is 31 or more days past official notice that the loan is due and payable in full. Attempts will be made to assist the homeowner in regaining compliance with loan terms. These attempts will be conveyed in an increasingly-urgent manner until compliance is achieved or the loan is 90 days in arrears, at which time the Lender may consider foreclosure. Lender’s staff will consider the following factors before initiating foreclosure:
1) Can the loan be cured, and can the rates and terms be adjusted to allow for affordable payments such that foreclosure is not necessary? 2) Can the Borrower refinance with a private lender and pay off the Lender? 3) Can the Borrower sell the property and pay off the Lender? 4) Does the balance warrant foreclosure? (If the balance is under $5,000, the expense to foreclose may not be worth pursuing.)
5) Will the sales price of home "as is" cover the principal balance owing, necessary advances, (maintain fire insurance, maintain or bring current delinquent property taxes, monthly yard maintenance, periodic inspections of property to prevent vandalism, etc.) foreclosure, and marketing costs? 157
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If the balance is more than the cost of foreclosure (including but not limited to insurance, property taxes, hazard mitigation, property maintenance and security, legal fees, and resale closing costs) and all the above factors have been considered, the Lender may opt to initiate foreclosure. The Borrower must receive, by certified mail, a thirty-day notification of foreclosure initiation. This notification must include the exact amount of funds to be remitted to the Lender to prevent foreclosure (such as, funds to bring a delinquent BMIR current or pay off a DPL).

At the end of thirty calendar days, the Lender should contact a reputable foreclosure service or local title company to prepare and record foreclosure documents and make all necessary notifications to the owner and junior lienholders. The service will advise the Lender of all required documentation to initiate foreclosure (Note and Deed of Trust usually) and funds required from the owner to cancel foreclosure proceedings. The service will keep the Lender informed of the progress of the foreclosure proceedings.

When the process is completed, and the property has "reverted to the beneficiary" at the foreclosure sale, the Lender could sell the home themselves under a homebuyer program or use it for an affordable rental property managed by a local housing authority or use it for transitional housing facility or other eligible use. The Lender could contract with a local real estate broker to list and sell the home and use those funds for program income eligible uses.
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ATTACHMENT E
Disclosure to Seller with Voluntary, Arm's Length Purchase Offer

DECLARATION
This is to inform you that would like to purchase the property, located at , if a satisfactory agreement can be reached. We are prepared to pay $____________ for a clear title to the property under conditions described in the attached proposed contract of sale.

Because Federal funds may be used in the purchase, however, we are required to disclose to you the following information:

1. The sale is voluntary. If you do not wish to sell, the buyer, ___________________, through the agency, _____________ will not acquire your property. The buyer does not have the power of eminent domain to acquire your property by condemnation (i.e., eminent domain) and the agency/Sponsor ________________________________ will not use the power of eminent domain to acquire the property.

2. The estimated fair market value of the property is $__________ and was estimated by _______________________________________, to be finally determined by a professional appraiser prior to close of escrow.

Since the purchase would be a voluntary, arm’s-length transaction, you would not be eligible for relocation payments or other relocation assistance under the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (URA), or any other law or regulation. Also, as indicated in the contract of sale, this offer is made on the condition that no tenant will be permitted to occupy the property before the sale is completed.

Again, please understand that if you do not wish to sell your property, we will take no further action to acquire it. If you are willing to sell the property under the conditions described in the attached contract of sale, please sign the contract, and return it to us at:
_______________________________________________. If you have any questions about this matter, please contact __________________________at ______________________.

Sincerely,
___________________________________
Title
_________________________________ _____________________ Buyer Date
_________________________________ _____________________ Buyer Date
Form continues on next page with Seller’s Acknowledgment 159
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Disclosure to Seller with Voluntary, Arm's Length Purchase Offer (Page 2)
Acknowledgement
As the Seller I/we understand that will inspect the property for health and safety deficiencies. I/we also understand that public funds may be involved in this transaction and, as such, if the property was built before 1978, a leadbased paint disclosure must be signed by both the buyer and seller, and that a Visual Assessment will be conducted to determine the presence of deteriorated paint.

As the Seller, I/we understand that under the Town of Paradise’s program, the property must be currently owner-occupied, vacant for three months at the time of submission of purchase offer, new (never occupied), or renter purchasing the unit. I/we hereby certify that the property is:
☐ Vacant at least 3 months; ☐ Owner-occupied; ☐ New; or ☐ Being Purchased by its Occupant
I/we hereby certify that I have read and understand this “Declaration” and:
☐ a copy of said Notice was given to me prior to the offer to purchase.

If received after presentation of the purchase offer, I/We choose:
☐ to withdraw, or ☐ not to withdraw, from the Purchase Agreement. __________________________________ _______________________ Seller Date
__________________________________ _______________________ Seller Date
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ATTACHMENT F
STANDARD CONTRACT LANGUAGE:

ALL CONTRACTS AND SUBCONTRACTS

1. The Civil Rights, HCD, and Age Discrimination Acts Assurances:

During the performance of this Agreement, the Grantee assures that no otherwise qualified person shall be excluded from participation or employment, denied program benefits, or be subjected to discrimination based on race, color, national origin, sex, age, or handicap, under any program or activity funded by this contract, as required by Title VI of the Civil Rights Act of 1964, Title I of the Housing and Community Development Act of 1974, as amended, and the Age Discrimination Act of 1975, and all implementing regulations.

2. Rehabilitation Act of 1973 and the “504 Coordinator” The Grantee further agrees to implement the Rehabilitation Act of 1973, as amended, and its regulations, 24 CFR Part 8, including, but not limited to, for Grantees with 15 or more permanent full or part time employees, the local designation of a specific person charged with local enforcement of this Act, as the “504 Coordinator”.

3. The Training, Employment and Contracting Opportunities for Business and Lower Income Persons Assurance of Compliance:
a) The grant activity to be performed under this Agreement is on a project assisted under a program providing direct federal financial assistance from the Department of Housing and Urban Development and is subject to the requirements of Section 3 of the Housing and Urban Development Act of 1968, as amended, 12 U.S.C 1701u.

Recipients, contractors and subcontractors shall direct their efforts to provide, to the greatest extent feasible, training and employment opportunities generated from the expenditure of Section 3 covered assistance to Section 3 residents in the order of priority provided in 24 CFR 135.34(a)(2).
b) The parties to this Agreement will comply with the provisions of said Section 3 and the regulations issued pursuant thereto by the Secretary of Housing and Urban Development set forth in 24 CFR Part 135, and all applicable rules and orders of the Department issued thereunder prior to the execution of this contract. The parties to this contract certify and agree that they are under no contractual or other disability which would prevent them from complying with these requirements. c) The Grantee will include these Section 3 clauses in every contract and subcontract for Work in connection with the grant activity and will, at the direction of the State, take appropriate action pursuant to the contract or subcontract upon a finding that the Grantee or any contractor or subcontractor is in violation of regulations issued by the Secretary of Housing and Urban Development, 24 CFR Part 135 and, will not let any contract unless the Grantee or contractor or subcontractor has first provided it 161
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with a preliminary statement of ability to comply with the requirements of these regulations.
d) Compliance with the provisions of Section 3, the regulations set forth in 24 CFR Part 135, and all applicable rules and orders of the Department issued thereunder prior to the execution of the Agreement shall be a condition of the federal financial assistance provided to the project, binding upon the Grantee, its successors and assigns. Failure to fulfill these requirements shall subject the Grantee, its contractors and subcontractors, its successors and assigns to those sanctions specified by the grant or contract through which federal assistance is provided, and to such sanctions as are specified by 24 CFR Part 135.

4. Assurance of Compliance with Requirements Placed on Construction Contracts of $10,000 or more
The Grantee hereby agrees to place in every contract and subcontract for construction exceeding $10,000 the Notice of Requirement for Affirmative Action to ensure Equal Employment Opportunity (Executive Order 11246), the Standard Equal Employment Opportunity, and the Construction Contract Specifications. The Grantee furthermore agrees to insert the appropriate Goals and Timetables issued by the U.S. Department of Labor in such contracts and subcontracts.

5. State Nondiscrimination Clause:
a) During the performance of this contract, contractor and its subcontractors shall not unlawfully discriminate, harass, or allow harassment against any employee or applicant for employment because of sex, race, color, ancestry, religious creed, national origin, physical disability (including HIV and AIDS), mental disability, medical condition (cancer), age (over 40) marital status, and denial of family care leave.

Contractors and subcontractors shall ensure that the evaluation and treatment of their employees and applicants for employment are free of such discrimination and harassment. Contractors and subcontractors shall comply with the provisions of the Housing Act (Government Code, Section 12990 (a-f) et seq.) and the applicable regulations promulgated thereunder (California Code of Regulations, Title 2, Section 7258 et seq.) The applicable regulations of the Fair Employment and Housing Commission implementing Government Regulations are incorporated into this contract by reference and made a part hereof as if set forth in full. Contractor and its subcontractors shall give written notice of their obligations under this clause to labor organizations with which they have a collective bargaining or other agreement. b) Contractor shall include the nondiscrimination and compliance provisions of this clause in all subcontracts to perform work under the contract.

6. Labor Standards –Federal Labor Standards Provisions
The Grantee shall cause or require to be inserted in full, in all such contracts subject to such regulations, provisions meeting the requirements of:

Davis-Bacon Act (40 USC 276a-276a-5) requires that workers receive no less than the prevailing wages being paid for similar work in their locality. Prevailing wages 162
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are computed by the Department of Labor and are issued in the form of Federal wage decisions for each classification of work. The law applies to most construction, alteration, or repair contracts over $2,000.

Copeland “Anti-Kickback” Act (47 USC 276(c) requires that workers be paid at least once a week without any deductions or rebates except permissible deductions.

Contract Work Hours and Safety Standards Act – CWHSSA (40USC 327-333) requires that workers receive “overtime” compensation at a rate of 1-1/2 times their regular hourly wage after they have worked 40 hours in one week.

Title 29, Code of Federal Regulations, Subtitle A, Parts 1, 3 and 5 are the regulations and procedures issued by the Secretary of Labor for the administration and enforcement of the Davis-Bacon Act, as amended.
163

TOWN OF PARADISE
RESOLUTION NO. 2026-____

A RESOLUTION OF THE TOWN COUNCIL OF THE TOWN OF PARADISE AMENDING AND

UPDATING THE HOME INVESTMENT PARTNERSHIPS PROGRAM (HOME) INFILL NEW

CONSTRUCTION FIRST-TIME HOME BUYER PROGRAM GUIDELINES, PREVIOUSLY ADOPTED BY RESOLUTION 2025-64
WHEREAS, the Paradise Town Council adopted Resolution 2025-64, “A resolution of the Town Council of the Town of Paradise adopting the programs guidelines for the Home Investment Partnerships Programs Infill New Construction for First-Time Homebuyers; and WHEREAS, the Paradise Town Council now desires to adopt Resolution 2026-___ “A resolution of the Town Council of the Town of Paradise amending and updating the HOME Investment Partnerships Program (HOME) Infill New Construction for First-Time Homebuyer Program Guidelines, previously adopted by resolution 2025-64.” NOW, THEREFORE, BE IT RESOLVED by the Town Council of the Town of Paradise as follows:

1. The Town hereby amends and updates the HOME Investment Partnerships Programs (HOME) Infill New Construction First-Time Homebuyer Program Guidelines.

2. This resolution is effective immediately upon adoption.

PASSED AND ADOPTED By the Town Council of the Town of Paradise this 8th day of September, 2026, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
_________________________________
Steve Crowder, Mayor
ATTEST:

Melanie Elvis, Town Clerk
APPROVED AS TO FORM:

Scott E. Huber, Town Attorney
164

Town of Paradise
Council Agenda Summary
Date: September 8, 2026
Agenda Item: 5(a)
ORIGINATED BY: Sarah Richter, Housing Program Coordinator REVIEWED BY: Colette Curtis, Recovery and Economic
Development Director
SUBJECT: Public Hearing – 2025-2026 Consolidated Annual Performance and Evaluation Report (CAPER) for the
Community Development Block Grant (CDBG) program

LONG TERM
RECOVERY PLAN:

No
COUNCIL ACTION REQUESTED:

1. Conduct a public hearing to receive comment on the Consolidated Annual Performance and Evaluation Report (CAPER) for the Community Development Block Grant (CDBG) Program; and,

2. Authorize the Town Manager to submit the CAPER to the Department of Housing and Urban Development with any public comments received.

Background:

At the conclusion of each program year, the regulations that govern the Community Development Block Grant (CDBG) Program require the preparation of the Consolidated Annual Performance and Evaluation Report (CAPER). The CAPER outlines CDBG program accomplishments and expenditures, as well as providing an evaluation of the town’s progress toward meeting its community development goals and objectives. The CDBG grant amount for 2025 was $47,069.

Analysis:

The CDBG program has rules in place to prevent jurisdictions from saving up grant funds overtime- no more than 1.5x the annual allocation can remain unspent 60-days prior to the end of the grantee’s fiscal year. Because the Town’s annual allocation was recently and substantially reduced, not exceeding the 1.5x threshold has become more challenging. The Town isn’t able to spend a lot of time trying out new, untested programs and instead needed to prioritize grant compliance. Even with the substantial amendments, the 1.5x threshold was not met prior to HUD’s deadline, but it was met prior to the end of the Town’s fiscal year.

Through the CDBG program, this last year the Town assisted one homeowner with urgent health and safety home repairs, one first-time homebuyer with down payment assistance, and two 165
homeowners with deferred loans to make home energy-efficiency improvements which has reduced their overall housing costs.

Two more homeowners have energy-efficiency improvements projects in the works, but they will be reported on next year.

A copy of the draft CAPER is attached for your review and approval. Any comments received during the hearing will be incorporated into the final document prior to its submittal to HUD regional office.

Financial Impact:

The completion of the report does not require an additional expenditure. Staff time has been covered by CDBG program funds so far. Failure to complete the report could jeopardize future CDBG funding. Though the Town’s grant is the smallest in the country, the designation as a CDBG entitlement city opens the door to other larger funding opportunities and allocations. 166
CAPER 1
OMB Control No: 2506-0117 (exp. 09/30/2021)
Draft 2025-2026 Consolidated Annual Performance and Evaluation Report (CAPER)
for the Community Development Block Grant (CDBG) Program Public Comment period August 24, 2026-September 8, 2026 167
CAPER 2
OMB Control No: 2506-0117 (exp. 09/30/2021)
CR-05 - Goals and Outcomes
Progress the jurisdiction has made in carrying out its strategic plan and its action plan. 91.520(a) This could be an overview that includes major initiatives and highlights that were proposed and executed throughout the program year.

This is the first year of a very ambitious, 5-year Consolidated Plan. Unfortunately, shortly after the program year began, it was made apparent that the Town needed to pivot away from a strageic plan made months earlier, and focus on timely expenditure of grant funds. The Town initiated two Substantial Amendments, re-programming unspent prior year funds into programs that could see more immediate results. While this meant giving up some of the leveraging power the Town was planning on, it furthered the Town's goal of grant compliance, which is also a high priority.

Comparison of the proposed versus actual outcomes for each outcome measure submitted with the consolidated plan and explain, if applicable, why progress was not made toward meeting goals and objectives. 91.520(g) Categories, priority levels, funding sources and amounts, outcomes/objectives, goal outcome indicators, units of measure, targets, actual outcomes/outputs, and percentage completed for each of the grantee’s program year goals.

Goal Category Source /
Amount
Indicator Unit of
Measure
Expected
–
Strategic
Plan
Actual –
Strategic
Plan
Percent
Complete
Expected
–
Program
Year
Actual –
Program
Year
Percent
Complete
Job training and
Job retention
Non-Housing
Community
Development
CDBG:
$
Jobs created/retained Jobs 30 0

0.00%
Preserve
affordable
housing
Affordable
Housing
CDBG:
$
Homeowner Housing
Rehabilitated
Household
Housing
Unit
10 2

20.00%
10 2

20.00%
Preserve
affordable
housing
Affordable
Housing
CDBG:
$
Direct Financial
Assistance to
Homebuyers
Households
Assisted
0 1 2 1

50.00%
168
CAPER 3
OMB Control No: 2506-0117 (exp. 09/30/2021)
Public road and
drainage
improvements
Non-Housing
Community
Development
CDBG:
$
Public Facility or
Infrastructure
Activities other than
Low/Moderate
Income Housing
Benefit
Persons
Assisted
910 0

0.00%
Public road and
drainage
improvements
Non-Housing
Community
Development
CDBG:
$
Other Other 0 0 1 0

0.00%
Support of
Youth Center
Non-Housing
Community
Development
CDBG:
$
Public Facility or
Infrastructure
Activities for
Low/Moderate
Income Housing
Benefit
Households
Assisted
50 0

0.00%
Table 1 - Accomplishments – Program Year & Strategic Plan to Date Assess how the jurisdiction’s use of funds, particularly CDBG, addresses the priorities and specific objectives identified in the plan, giving special attention to the highest priority activities identified.

The highest priority objective identified in the Consolidated Plan was public roads and improvements. However, after the plan was approved, the Town learned that it did not have enough funding to make a meaningful contribution to in-progress infrastructure projects, and in fact, would inadvertantly increase project costs. Another priority objective, job training and job retention, was determined to be infeasible because the community need did not align with the required, documentable, program outcomes. 169
CAPER 4
OMB Control No: 2506-0117 (exp. 09/30/2021)
CR-10 - Racial and Ethnic composition of families assisted Describe the families assisted (including the racial and ethnic status of families assisted).

91.520(a)
CDBG
White 3
Black or African American 0
Asian 0
American Indian or American Native 0
Native Hawaiian or Other Pacific Islander 0
Total 3
Hispanic 1
Not Hispanic 0
Table 2 – Table of assistance to racial and ethnic populations by source of funds Narrative
The racial and ethnic composition information collected represents the head of household only and does not include an option to identify people with more than one race. This information is not an indication of the actual racial and ethnic make-up of the families assisted, resulting in an underrepresentation of minorities and mixed race individuals.
170
CAPER 5
OMB Control No: 2506-0117 (exp. 09/30/2021)
CR-15 - Resources and Investments 91.520(a)
Identify the resources made available
Source of Funds Source Resources Made
Available
Amount Expended
During Program Year
CDBG public - federal 187,158 105,463
Table 3 - Resources Made Available
Narrative
Through two substantial amendments, the Town re-programmed unspent prior year funds. The first substantial amendment created an Energy Efficiency Improvement program, and the second substantial amendment allocated funds for housing assistance programs, such as owner-occupied rehabilitation and down payment assistance for first-time homebuyers.

Identify the geographic distribution and location of investments Target Area Planned Percentage of
Allocation
Actual Percentage of
Allocation
Narrative Description
Paradise 100 100
Table 4 – Identify the geographic distribution and location of investments Narrative
100% of CDBG funding was spent to assist residents of the Town of Paradise. 171
CAPER 6
OMB Control No: 2506-0117 (exp. 09/30/2021)
Leveraging
Explain how federal funds leveraged additional resources (private, state and local funds), including a description of how matching requirements were satisfied, as well as how any publicly owned land or property located within the jurisdiction that were used to address the needs identified in the plan.

CDBG funds that were used as down payment assistance enabled the assisted homebuyer to afford a subsidized first loan from USDA.
172
CAPER 7
OMB Control No: 2506-0117 (exp. 09/30/2021)
CR-20 - Affordable Housing 91.520(b)
Evaluation of the jurisdiction's progress in providing affordable housing, including the number and types of families served, the number of extremely low-income, low-income, moderate-income, and middle-income persons served.

One-Year Goal Actual
Number of Homeless households to be
provided affordable housing units 0 0
Number of Non-Homeless households to be
provided affordable housing units 0 0
Number of Special-Needs households to be
provided affordable housing units 0 0
Total 0 0
Table 5 – Number of Households
One-Year Goal Actual
Number of households supported through
Rental Assistance 0 0
Number of households supported through
The Production of New Units 0 0
Number of households supported through
Rehab of Existing Units 7 2
Number of households supported through
Acquisition of Existing Units 2 1
Total 9 3
Table 6 – Number of Households Supported
Discuss the difference between goals and outcomes and problems encountered in meeting these goals.

The amount of funding available did not extend far enough to reach all of the Town's goals. One homebuyer was assisted with acquisition of an existing unit, one homeowner was assisted with a home repair, and one homeowner was assisted through the Energy Efficiency Improvement program. Two other homeowners had housing rehabilitation projects start (under the Energy Efficiency Improvement Program), and will be reported in the next program year. 173
CAPER 8
OMB Control No: 2506-0117 (exp. 09/30/2021)
Discuss how these outcomes will impact future annual action plans.

Future annual action plans will need to account for the time required for environmental consultations, permitting required from outside agencies, and 30-day retention periods.

Include the number of extremely low-income, low-income, and moderate-income persons served by each activity where information on income by family size is required to determine the eligibility of the activity.

Number of Households Served CDBG Actual HOME Actual
Extremely Low-income 1 0
Low-income 1 0
Moderate-income 1 0
Total 3 0
Table 7 – Number of Households Served
Narrative Information
Funding was allocated to these programs via substantial amendment. The substantial amendment process requires 15 days for public noticing of a public hearing, and 30 days for public comment. In Paradise, because the local newspaper is not published daily, requires several days lead time, and also must align with the Town Council schedule, a 45-day substantial amendment plan actually takes about 60-days, or two full months out of a 12-month program year. This doesn't leave the Town with a lot of time to try out new, untested programs. Instead, the Town continues to invest in already established programs.
174
CAPER 9
OMB Control No: 2506-0117 (exp. 09/30/2021)
CR-25 - Homeless and Other Special Needs 91.220(d, e); 91.320(d, e); 91.520(c) Evaluate the jurisdiction’s progress in meeting its specific objectives for reducing and ending homelessness through:

Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs
The Town's Code Enforcement Department continues to make visits to residents living in temporary shelters, connecting them with resources for permanent housing. With CDBG-DR funds from the state, the Town has completed 150 affordable multifamily units with another 142 more in construction, expected to be finished by the end of 2027.

Addressing the emergency shelter and transitional housing needs of homeless persons Town of Paradise does not have its own emergency shelter nor transitional housing; instead the Town relies on the County's resources. Within the County, there is an emergency shelter and transitional housing is available.

Helping low-income individuals and families avoid becoming homeless, especially extremely low-income individuals and families and those who are: likely to become homeless after being discharged from publicly funded institutions and systems of care (such as health care facilities, mental health facilities, foster care and other youth facilities, and corrections programs and institutions); and, receiving assistance from public or private agencies that address housing, health, social services, employment, education, or youth needs The Town offers assistance to current low-income homeowners to make necessary home repairs and energy improvements, which indirectly benefit the family that reside in those homes - many of whom meet the criteria for one who is likely to become homeless. Due to a lack of funding for housing and social services, there is little the Town can do to assist individuals likely to become homeless without policy and investment changes at the federal level.

Helping homeless persons (especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again
The Town refers people to the Housing Authority of the County of Butte which administers the County Section 8 voucher and VASH programs. With the completion of the CDBG-DR funded multifamily housing 175
CAPER 10
OMB Control No: 2506-0117 (exp. 09/30/2021)
units, Paradise will have more than doubled affordable rental housing options since the Camp Fire. 176
CAPER 11
OMB Control No: 2506-0117 (exp. 09/30/2021)
CR-30 - Public Housing 91.220(h); 91.320(j)
Actions taken to address the needs of public housing
There are no public housing units in the Town of Paradise, however, Town Housing staff does sit on the Housing Authority County of Butte board of commissioners.

Actions taken to encourage public housing residents to become more involved in management and participate in homeownership
Town Housing staff provides a free workshop to prospective homebuyers every other month. Over 100 households have attended one of these workshops in the past year, and multiple residents have exited subsidized rental housing into homeownership.

Actions taken to provide assistance to troubled PHAs
Town of Paradise Housing staff participated in the hiring of a new executive director of the Housing Authority and is a voting member of the board of commissioners. 177
CAPER 12
OMB Control No: 2506-0117 (exp. 09/30/2021)
CR-35 - Other Actions 91.220(j)-(k); 91.320(i)-(j)
Actions taken to remove or ameliorate the negative effects of public policies that serve as barriers to affordable housing such as land use controls, tax policies affecting land, zoning ordinances, building codes, fees and charges, growth limitations, and policies affecting the return on residential investment. 91.220 (j); 91.320 (i) The Town of Paradise has always been and continues to be a very accessible and affordable community to build and live. The Town has no policies that prevent affordable housing. The only ordinances the Town has added over and above the California building codes is wildland urban interface (WUI) standards. The Town's fees are among the lowest in the state. The Town's growth limitations are geographic. One of the Town's biggest barriers to affordable housing is the lack of sewer because it limits housing density. The Town of Paradise has completed a feasibility study and implementation plan for a sewer for the more densely populated areas, including many of the properties that would be suitable for multi-family developments. The public policies that are the greatest barrier to affordable housing exist at the federal level, such as those that incentivize private investment through tax incentives to for-profit corporations rather than direct investment by the government.

Actions taken to address obstacles to meeting underserved needs. 91.220(k); 91.320(j) The Town provides multiple housing programs for low-income households including owner-occupied rehabilitation to assist homeowners with repairs and reconstruction of their residence, downpayment assistance to encourage affordable home ownership, and an Energy Efficiency Improvement program.

The Town has identified people who were renting homes at the time of the fire as the largest population that is ineligible for most disaster-related housing programs. The Town has completed 150 affordable rental units with CDBG-DR funding and has over a hundred more under construction.

Actions taken to reduce lead-based paint hazards. 91.220(k); 91.320(j) The Town of Paradise has few homes that did not burn down in the 2018 Camp Fire, and many of those were apartment buildings or homes built since 1978. For those few pre-1978 homes that did survive the fire, the Town offers its Owner-Occupied Housing Rehabilitation program to address lead-paint mitigation.

Actions taken to reduce the number of poverty-level families. 91.220(k); 91.320(j) The Town of Paradise is implementing a workforce development program using CDBG-DR funds.

Actions taken to develop institutional structure. 91.220(k); 91.320(j) 178
CAPER 13
OMB Control No: 2506-0117 (exp. 09/30/2021)
The institutional structure of the Town includes a five-member Town Council. Additionally, the Business and Housing Services staff provide the main administrative and project management duties for the CDBG entitlement. The Town works closely with non-profit organizations in the area to provide programs/services to to very low-, low- and moderate-income residents, including the frail and elderly, mentally disabled, physically disabled, homeless, and at-risk youth. The Town also focuses on collaboration with goverment agencies, community needs organizations and local businesses. Town Housing staff meet quarterly with Housing staff from other local jurisdictions to collaborate and assist each other with obstacles. The Town also has a Community Relations Committee and Housing Advisory Committee that meet quarterly to get community and stakeholder input.

Actions taken to enhance coordination between public and private housing and social service agencies. 91.220(k); 91.320(j)
The Town facilitated affordable housing projects with developers in public and private partnerships. The Town works closely with North Valley Housing Trust, Community Housing Improvement Program (CHIP) and Habitat for Humanity of Butte County on self-help homeownership and reconstruction projects. The Town created a Housing Advisory Committee to bring together public and private housing stakeholders in addition to community members at-large to identify the Town's housing needs and work together to address those needs.

Identify actions taken to overcome the effects of any impediments identified in the jurisdictions analysis of impediments to fair housing choice. 91.520(a) The Town of Paradise completed a feasibility study and implementation plan for a sewer for the more densely populated areas, including many of the properties that would be suitable for multi-family developments. Bringing sewer to the Town will increase the capacity for housing density, making it more economically feasible to build affordable multifamily housing, and should also result in increased investment from businesses, creating jobs and services.

In previous years, the Town increased the maximum subsidy amount available through the Town's down-payment assistance program (funded by CDBG and other funding sources). By increasing the amount of assistance, the Town continues to elimintate the requirement for private mortgage insurance which has a disparate impact on low-income homebuyers who can't afford either a 20% down payment or afford the hundreds of dollars PMI adds to a mortgage payment. 179
CAPER 14
OMB Control No: 2506-0117 (exp. 09/30/2021)
CR-40 - Monitoring 91.220 and 91.230
Describe the standards and procedures used to monitor activities carried out in furtherance of the plan and used to ensure long-term compliance with requirements of the programs involved, including minority business outreach and the comprehensive planning requirements
Organizations receiving CDBG funds are required to report quarterly to the Town and also provide an end of year report which is reviewed and input into IDIS for yearly accomplishments at the close of the program year. Organizations are audited and staff performs site visits when applicable. Staff will monitor the organizations to make sure that HUD regulations are being met or funding is relinquished. At the end of each funding year, staff reviews the accomplishments of community service agencies to determine their ability to serve the low/mod residents of Paradise and meet the program requirements.

Housing applicants are reviewed thoroughly by staff to ensure they have met all eligibility requirements.

Site inspections are utilized to ensure that the housing, whether for purchase or rehabilitation, complies with safety and health requirements of the programs. Recipients are verified annually through utility billing verification to ensure owner occupancy of the property.

Citizen Participation Plan 91.105(d); 91.115(d)
Describe the efforts to provide citizens with reasonable notice and an opportunity to comment on performance reports.

The Town follows its Citizen Participation Plan for all CDBG-related programs. A public notice is published in the local newspaper 15 days prior to the public hearings. The draft document is made available at Town Hall, the Town's Building Resiliency Center, the Butte County Public Library (Paradise Branch) and on the Town's website. All of these locations are known to be accessible to persons with disabilities, persons of low/moderate income, as well as citizens at large who may be interested in participating through public commentary. Public hearings are held for public comment and questions of draft reports. All comments received are presented to Council for consideration of adoption.

CR-45 - CDBG 91.520(c)
Specify the nature of, and reasons for, any changes in the jurisdiction’s program objectives and indications of how the jurisdiction would change its programs as a result of its experiences.
180
CAPER 15
OMB Control No: 2506-0117 (exp. 09/30/2021)
The Town of Paradise was untimely for two consecutive years. "Untimely" means that the Town did not spend down more than 1.5x it's annual grant amount by the May 2nd deadline. One contributing factor to the Town's untimeliness was the reduction in the Town's annual allocation by almost 50% in 2024, which substantially moved the goal post and forced the Town to reconsider program objectives. Instead of using the CDBG funds as originally planned, the Town needs to prioritize program compliance before it can consider untried programs.

The Town of Paradise was untimely for two consecutive years. "Untimely" means that the Town did not spend down more than 1.5x it's annual grant amount by the May 2nd deadline. One contributing factor to the Town's untimeliness was the reduction in the Town's annual allocation by almost 50% in 2024, which substantially moved the goal post and forced the Town to reconsider program objectives. Instead of using the CDBG funds as originally planned, the Town needs to prioritize program compliance before it can consider untried programs.

Does this Jurisdiction have any open Brownfields Economic Development Initiative (BEDI) grants?
No
[BEDI grantees] Describe accomplishments and program outcomes during the last year. 182
CAPER 17
OMB Control No: 2506-0117 (exp. 09/30/2021)
CR-58 – Section 3
Identify the number of individuals assisted and the types of assistance provided Total Labor Hours CDBG HOME ESG HOPWA HTF
Total Number of Activities 0 0 0 0 0
Total Labor Hours 0
Total Section 3 Worker Hours 0
Total Targeted Section 3 Worker Hours 0
Table 8 – Total Labor Hours
Qualitative Efforts - Number of Activities by Program CDBG HOME ESG HOPWA HTF Outreach efforts to generate job applicants who are Public Housing Targeted Workers
Outreach efforts to generate job applicants who are Other Funding Targeted Workers.

Direct, on-the job training (including apprenticeships).

Indirect training such as arranging for, contracting for, or paying tuition for, off-site training.

Technical assistance to help Section 3 workers compete for jobs (e.g., resume assistance, coaching).

Outreach efforts to identify and secure bids from Section 3 business concerns.

Technical assistance to help Section 3 business concerns understand and bid on contracts.

Division of contracts into smaller jobs to facilitate participation by Section 3 business concerns.

Provided or connected residents with assistance in seeking employment including: drafting resumes,preparing for interviews, finding job opportunities, connecting residents to job placement services.

Held one or more job fairs.

Provided or connected residents with supportive services that can provide direct services or referrals.

Provided or connected residents with supportive services that provide one or more of the following: work readiness health screenings, interview clothing, uniforms, test fees, transportation.

Assisted residents with finding child care.

Assisted residents to apply for, or attend community college or a four year educational institution.

Assisted residents to apply for, or attend vocational/technical training.

Assisted residents to obtain financial literacy training and/or coaching.

Bonding assistance, guaranties, or other efforts to support viable bids from Section 3 business concerns.

Provided or connected residents with training on computer use or online technologies.

Promoting the use of a business registry designed to create opportunities for disadvantaged and small businesses.

Outreach, engagement, or referrals with the state one-stop system, as designed in Section 121(e)(2) of the Workforce Innovation and Opportunity Act.
183
CAPER 18
OMB Control No: 2506-0117 (exp. 09/30/2021)
Other.

Table 9 – Qualitative Efforts - Number of Activities by Program Narrative
The CDBG funded rehabilitation activities performed this program year did not exceed $200,000 which is the threshold for Section 3 project requirements per 24 CFR 75.3(a)(2)(i).

CR-60 - ESG 91.520(g) (ESG Recipients only)
ESG Supplement to the CAPER in e-snaps
For Paperwork Reduction Act

1. Recipient Information—All Recipients Complete
Basic Grant Information
Recipient Name PARADISE
Organizational DUNS Number 362314890
UEI
EIN/TIN Number 942621899
Indentify the Field Office SAN FRANCISCO
Identify CoC(s) in which the recipient or
subrecipient(s) will provide ESG
assistance
ESG Contact Name
Prefix
First Name
Middle Name
Last Name
Suffix
Title
ESG Contact Address
Street Address 1
Street Address 2
City
State
ZIP Code
184
CAPER 19
OMB Control No: 2506-0117 (exp. 09/30/2021)
Phone Number
Extension
Fax Number
Email Address
ESG Secondary Contact
Prefix
First Name
Last Name
Suffix
Title
Phone Number
Extension
Email Address

2. Reporting Period—All Recipients Complete
Program Year Start Date 07/01/2025
Program Year End Date 06/30/2026
3a. Subrecipient Form – Complete one form for each subrecipient Subrecipient or Contractor Name
City
State
Zip Code
DUNS Number
UEI
Is subrecipient a vistim services provider
Subrecipient Organization Type
ESG Subgrant or Contract Award Amount
185

Town of Paradise
Council Agenda Summary
Date: September 08, 2026
Agenda Item: 6(a)
ORIGINATED BY: Eric Reinbold, Police Chief
Colette Curtis, Recovery & Economic Development
Director
Brian Solecki, Project Manager
REVIEWED BY: Jennifer Macarthy, Town Manager
SUBJECT: Emergency Warning System Updated Guidelines and Presentation on In-Home Safe Units and Public
Communication Plan

LONG TERM
RECOVERY PLAN:

Yes
COUNCIL ACTION REQUESTED:

1. Hear a presentation on the In-Home Safe Units and the public communication plan for use of the Emergency Warning System Sirens; and,

2. Approved the revised Town of Paradise Emergency Notification System Guidelines; or

3. Provide additional direction to staff (ROLL CALL VOTE) Background:

Following July 16, 2026, Dudley Fire, the Town Emergency Operations Policy Group met to review the Town’s Emergency Notification System and evaluate how the system performed during this real-world, rapidly developing emergency.

The review focused on identifying opportunities to simplify the system for law enforcement and fire personnel, particularly in making activation decisions and identifying the appropriate sirens during an emergency. At the same time, the group recognized the importance of making the system easier for residents and visitors to understand, including clearly communicating what different emergency notifications mean and what the public is expected to do when they receive or hear them.

The revised guidelines are intended to provide a more straightforward framework for emergency personnel while establishing clearer expectations for the public. The changes clarify the purpose of each notification method, simplify siren identification and activation, better align siren activations with evacuation zones, and provide a consistent public message regarding what residents should do when an Emergency Siren is activated.

These changes are intended to improve consistency and reduce confusion during a rapidly developing emergency, while providing the public with a simple and predictable understanding of the Town’s emergency notification system.
186
Town staff is currently working with HQE to update software within the siren system to reflect the modifications to the preprogrammed quick activation scenarios and labeling of the siren towers Analysis:

The revised and attached guidelines make several operational and communication changes to the Town’s Emergency Notification System (ENS). Key revisions include changes to activation procedures, siren identification and grouping, notification terminology, public messaging, and the Emergency Siren activation sequence.

The primary changes are summarized below:

PRIMARY CHANGES
 Activation Decision-Making: Added a clearer process for Incident Command to evaluate evacuation needs, affected areas, and appropriate notification tools throughout an incident.
 Simplified Terminology: Replaced all references to "Early/Emergency Warning Sirens" with "Emergency Sirens" and clarified that sirens are used only when an evacuation order including at least a full zone has been issued.  Notification System: Removed the previous notification hierarchy and clarified the purpose and information provided by each ENS component.  S.I.R.E.N. Campaign: Clarified the public message regarding siren activation as "Seek Information Regarding Evacuations Nearby." The siren is intended to get the public's attention. Due to the reality of sound being able to travel long distances and beyond evacuation zones, hearing a siren does not, by itself, mean that the person hearing it is under an evacuation order. Residents are directed to immediately seek official information to determine whether their evacuation zone is affected and, if their zone is under an evacuation order, evacuate immediately. This provides a simple public message that will be incorporated into Town outreach and emergency preparedness efforts.  Siren Identification: Changed siren tower designations from numbers to letters (A–U) to reduce activation confusion for police dispatch staff.  Evacuation Zone Grouping: Organized predetermined siren activations by the Town's 14 evacuation zones rather than the previously used traffic control evacuation scenarios.
 Activation Protocol: In the event of an Emergency Siren activation, standardized the siren sequence to three one-minute siren/voice cycles followed by a 10-minute pause, with the cycle repeated as necessary.

Financial Impact:

No General Fund impact is anticipated. Changes primarily involve operational procedures, training, and public education.
187
Emergency Notification System Guidelines
September 2026
This document is intended to provide a clear framework for Town First Responders and staff to identify and select the most appropriate communication tools during a developing emergency within the Town of Paradise. Because no single notification method is appropriate for every situation, the guidelines support timely, coordinated use of one or multiple tools based on the nature and progression of an incident.

The document also communicates to the public, in the simplest and clearest manner possible, what to expect during an emergency and how the Town will provide warnings, evacuation instructions, and other critical information.

Sections:

Section 1. Emergency Notification System (ENS)
Section 2. Emergency Siren Locations
Section 3. Emergency Siren Activation
Section 4. Siren Tones and Voice Commands
Section 5. Testing Procedure
Section 1: Emergency Notification System (ENS)
The purpose of the Town of Paradise Emergency Notification System (ENS) is to provide a coordinated and redundant means of informing residents and visitors of hazards that may threaten life and property.

As part of the ENS, the Emergency Sirens are intended to be activated only when an evacuation order has been issued, and Incident Command determines that siren activation is necessary. Emergency Sirens will not be activated for evacuation warnings.

Whenever possible, additional notification and information channels should be used before and in conjunction with the Emergency Sirens to provide timely information and instructions to the public.

Activation of the Emergency Sirens is intended to alert residents and visitors that an immediate evacuation order is in effect within the Town of Paradise and to prompt them to seek additional emergency information through Smart911, radio, television, social media, and other available communication channels.
188
Emergency Notification System Guidelines
September 2026
Figure 1: Sample Public Outreach – Emergency Sirens
The S.I.R.E.N. Public Outreach Campaign provides a simple way for residents to remember what to do when they hear an emergency siren:

S.I.R.E.N. — Seek Information Regarding Evacuations Nearby The siren itself is an alert, not a source of detailed information. When a siren sounds, it means an evacuation order has been issued somewhere within the Town. Residents should not assume that they are personally under an evacuation order simply because they hear the siren. Instead, they should immediately seek official information to determine whether their evacuation zone is affected.

If a resident's zone is under an evacuation order, they should evacuate immediately and follow official evacuation routes and instructions.
189
Emergency Notification System Guidelines
September 2026
Emergency Notification System Components
The following table illustrates the notification tools within the Emergency Notification System (ENS).

The table also includes the Town department responsible for activating each component of the notification system.

System: Who: Purpose: Information Level:

Emergency Sirens PPD Get your attention Alert Only — Signals that an evacuation order has been issued somewhere in the Town. Does
not identify the affected zone or provide
incident details. Residents should immediately
seek additional information.

Smart911/SAFE

UNITS/IPAWS/WEA
PPD Details about what is
happening
Concise & Specific — Provides the affected
evacuation zone, evacuation status, and
immediate instructions when available.

Designed for rapid delivery of critical
information.

AM 1500 PIO Keep you informed General Updates — Provides current conditions, evacuation information, safety
instructions, and updates as information
becomes available. Particularly useful for
residents who may not have internet or
cellular service.

Press Release PIO Explain the situation Detailed Information — Provides incident status, what happened, areas affected, actions
being taken, evacuation information, and
other important context. Best suited for
significant or slower-moving incidents.

Social Media/Website PIO Additional Updated
Information
Detailed & Ongoing — Provides incident
updates, evacuation information, maps or
links, safety information, frequently asked
questions, and other details as an incident
develops and is available.

Section 2: Siren Locations
Siren locations were chosen after analysis of the topography and geography of the Paradise ridge. The 21 sirens are located in public rights of way, or on public property, with the goal of providing audible alerts within Paradise Town limits.

Eight siren locations will also have traffic cameras installed. These cameras are for Town of Paradise internal use only to monitor traffic and conditions during emergencies. Cameras with visibility to private property will have active private property permanently masked from view of the camera. 190
Emergency Notification System Guidelines
September 2026
The traffic cameras will allow access to direct live-feed video to Town of Paradise emergency personnel..

This video is not recorded by the Town. Upon a reasonable belief that some video footage may hold evidentiary value, the Town Manager or his/her designee may endeavor to obtain that video footage from the camera itself. In the event that video footage with evidentiary value is obtained, it shall be retained pursuant to Government Code section 34090 and shared to the appropriate party or agency SITE DESCRIPTION LATITUDE LONGITUDE Camera
A Clark & YSK Trail ROW 39°47'45.56"N 121°35'6.62"W Yes B Gregory & Waggoner ROW 39°46'44.00"N 121°36'47.90"W
C Rocky Ln. & YSK Trail ROW 39°46'53.51"N 121°35'53.68"W D Pentz & Ely ROW 39°46'36.30"N 121°34'47.03"W Yes
E Bille & West Wagstaff ROW 39°46'13.42"N 121°37'48.39"W F Clark & Bille ROW 39°46'17.52"N 121°35'47.31"W Yes
G Crestmore & Rose ROW 39°45'38.00"N 121°38'18.70"W
H Maxwell & Fairview ROW 39°45'47.99"N 121°36'44.46"W
I Police Department – TOP Property 39°45'15.54"N 121°37'27.86"W J Pearson & Clark ROW 39°45'7.77"N 121°36'23.77"W Yes
K Sawmill & Nunneley ROW 39°45'21.00"N 121°35'20.80"W
L Pentz & Peach ROW 39°45'30.40"N 121°34'20.90"W
M Skyway & Russell Drive ROW 39°44'42.60"N 121°39'8.53"W Yes N Paradise Town Hall TOP Property 39°44'57.10"N 121°38'0.70"W Yes O Pentz & Pearson ROW 39°44'52.00"N 121°34'23.30"W Yes
P Neal & Grinding Rock ROW 39°43'57.97"N 121°39'4.61"W
Q Foster & Apple ROW 39°43'59.55"N 121°38'10.12"W
R Roe & Scottwood ROW 39°44'28.26"N 121°37'18.28"W
S American Way TOP Property 39°44'12.60"N 121°36'36.76"W Yes T Bennett & S. Libby ROW 39°44'15.75"N 121°35'38.06"W
U Pentz & Water Tower ROW 39°44'3.05"N 121°34'24.84"W
191
Emergency Notification System Guidelines
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Section 3: Emergency Siren Activation
Emergency Siren Activation Procedure
In the event of an unfolding incident, the Paradise Police Chief or their designee, in coordination with Incident Command and other emergency personnel, will continuously evaluate conditions and determine the appropriate emergency notification and evacuation measures. This evaluation will occur throughout the incident and will guide decisions regarding whether to issue evacuation warnings or orders, activate the Emergency Sirens, and/or utilize other notification tools. The following determinations should be considered:
• Evacuation Determinations: Does the developing scale of the incident require any evacuation warnings or evacuation orders?
• Geographic Determinations: Which streets, partial zones, or full evacuation zone(s) will be issued an evacuation warning or which, if any, will be issued an evacuation order? • Public Works Evacuation Scenario Determination: Which/if any of the 8 Evacuation Scenarios best reflect the current emergency and may be activated by Incident Command if determined to be necessary as a tool for public works and first responders.

The determinations above will be utilized by incident command to determine what/if any level of Emergency Siren Towers are to be activated by the Town of Paradise Police Department Dispatch Center upon approval of the Police Chief or their designee:
• Level 0 Emergency Siren Activation: No Towers are identified for activation. • Level 1 Emergency Siren Activation: Towers proximate to the incident and determined by Incident Command are to be activated.
• Level 2 Emergency Siren Activation: If an entire zone or multiple zone evacuation is ordered, towers predetermined for that zone or zones will be activated. Additional towers may be activated if determined necessary by Incident Command. • Level 3 Emergency Siren Activation: If scale of incident is determined by Incident Command to warrant full town awareness, all towers would be activated.

All Evacuation Zone Tower Activations will be pre-programmed into the Paradise Police dispatch control system for quick activation in the event of an emergency as noted in the following pages. 192
Emergency Notification System Guidelines
September 2026
Evacuation Zone 1
Towers A, B, C, E
Evacuation Zone 2
Towers A, B, C, D, F
Evacuation Zone 3
Towers A, D
Evacuation Zone 4
Towers E, G, H
Evacuation Zone 5
Towers F, H, I, J
Evacuation Zone 6
Towers F, J, K
Evacuation Zone 7
Towers D, F, K, L, O
Evacuation Zone 8
Towers D, L, O
Evacuation Zone 9
Towers M, N, I
Evacuation Zone 10
Towers M, N, P, Q
Evacuation Zone 11
Towers I, N, R, Q
Evacuation Zone 12
Towers J, R, S, T
Evacuation Zone 13
Towers O, S, T, U
Evacuation Zone 14
Towers O, T, U

193
Emergency Notification System Guidelines
September 2026

Activation of the Emergency Siren System is an indication of an evacuation emergency within the Town requiring residents to immediately seek additional information; it does not, by itself, constitute an evacuation order for the entire Town or for the specific location where the Siren may be heard.
194
Emergency Notification System Guidelines
September 2026
Section 4: Siren Tones and Voice Commands
Any activation of the Emergency Sirens will include both siren tone and voice command. It is understood that sirens may be audible for a distance beyond the immediate area for which the notification is intended, and clear instruction through the voice commands and on other communication channels will be important for the system to be used effectively.

Emergency Activation Siren and Voice
Only Immediate Evacuation Orders will prompt the activation of the Emergency Sirens if determined to be necessary by Incident Command. A 1-minute-long siren tone will indicate residents should evacuate immediately. The siren tone will then be followed by a Voice Command telling residents to evacuate. The default voice command will be “An evacuation order has been issued within the Town of Paradise.” The protocol will be as follows:

Siren Tone for a 1-minute duration
Voice Command:

Siren Tone for a 1-minute duration
This sequence will repeat three times, followed by a 10-minute pause. The entire cycle will then repeat until suspended by order of the Police Chief.

Section 5: Testing Procedures
The Emergency Sirens will be tested both internally and externally. The Emergency Siren towers have built in internal testing that occur regularly and additional Internal-only tests will be performed periodically and will be done silently to test functionality but will not be audible to the public.

Audible tests will be performed monthly, on the 15th of each month at 12:00 pm. The public will be notified of these tests in advance, with press releases, social media posts, website information, and Smart911 notifications sent prior to testing. The testing protocol will be as follows:

Voice Command: This is a test of the Paradise Emergency Sirens, This is only a test.

Siren Tone for a 30-second duration
Voice Command: This was a test of the Paradise Emergency Sirens. 195

Town of Paradise
Council Agenda Summary
Date: September 8, 2026
Agenda Item: 6(b)
ORIGINATED BY: Aimee Beleu, Finance Director
Jason Finney, Fire Chief
REVIEWED BY: Jennifer Macarthy, Town Manager
Scott Huber, Town Attorney
SUBJECT: Establishment of the Fire Apparatus Replacement Reserve Fund and Adoption of Related Policy

LONG TERM
RECOVERY PLAN:

No
COUNCIL ACTION REQUESTED:

1. Adopt Resolution No. 2026-___, “ A Resolution of the Town Council of the Town of Paradise Establishing the Fire Apparatus Replacement Reserve Fund and Directing Assistance by Hire revenues and Proceeds from the Disposition of Town-Owned Fire Apparatus to the Fund”, and,

2. Approve the Fire Apparatus Replacement Reserve Fund Policy governing the use and administration of the Fund; or,

3. Provide alternate direction to Town staff.

Background:

The Town of Paradise participates in California’s statewide mutual aid system and may receive Assistance by Hire (“ABH”) reimbursement when Town-owned fire apparatus is used during eligible emergency assignments.

ABH reimbursements help offset increased mileage, operating hours, wear and tear, maintenance, depreciation, damage, and reduced service life associated with these deployments.

Currently, ABH revenues are deposited into the General Fund. This is consistent with the current funding model, as the General Fund supports the ongoing maintenance and repair of the Town’s fire apparatus and keeps the equipment in proper working order.

Since 2019, the Town has received approximately $1 million in ABH apparatus reimbursements.

However, ABH revenue is not guaranteed or predictable. Apparatus is deployed based on emergency activity and statewide need, and both the frequency and duration of those assignments can vary significantly from year to year. As a result, ABH revenues should be viewed as an opportunity-based funding source rather than a reliable annual revenue stream.

Analysis:

Staff recommends establishing a Fire Apparatus Replacement Reserve Fund to provide a dedicated, long-term funding source for future fire apparatus needs. 196
The Fund would receive:
 Eligible ABH apparatus revenues;
 Proceeds from the sale, auction, trade-in, or other disposition of Town-owned fire apparatus; and
 Other revenues authorized by the Town Council.

The Fund could be used for apparatus replacement, major repairs or refurbishment, ABH-related damage or excessive wear, major component replacement, and grant matching funds.

Funds would carry forward from year to year, and all expenditures would remain subject to Town Council approval.

The Fund would supplement, not replace, other available funding sources such as General Fund contributions, Measure V revenues, grants, and financing. Because ABH revenues are variable and dependent on emergency deployments, the Fund should be considered one component of the Town’s overall long-term apparatus replacement strategy rather than a sole or predictable funding source.

Financial Impact:

Future ABH apparatus revenues and proceeds from the disposition of fire apparatus would be deposited into the Fire Apparatus Replacement Reserve Fund rather than the General Fund.

ABH revenues are variable and cannot be reliably projected, as they depend on emergency activity and apparatus deployment.

While the General Fund would no longer retain these revenues for general fire apparatus maintenance, the reserve would provide a dedicated funding source for future major repairs, replacement, and other approved apparatus needs.

ATTACHMENTS:

1. Resolution No. 2026-___

2. Fire Apparatus Replacement Reserve Fund Policy
197

TOWN OF PARADISE
RESOLUTION NO. 2026-____

A RESOLUTION OF THE TOWN COUNCIL OF THE TOWN OF PARADISE ESTABLISHING

A FIRE APPARATUS REPLACEMENT RESERVE FUND AND DIRECTING ASSISTANCE BY HIRE REVENUES TO THE FUND AND PROCEEDS FROM THE DISPOSITION OF TOWNOWNED FIRE APPARATUS TO THE FUND WHEREAS, the Paradise Fire Department participates in California’s statewide mutual aid system and the use of Town-owned fire apparatus may qualify for reimbursement through the State of California Assistance by Hire (“ABH”) Program; and WHEREAS, ABH reimbursements help compensate the Town for increased mileage, operating hours, wear and tear, maintenance, depreciation, damage, and reduced service life associated with emergency deployments; and
WHEREAS, the Town Council desires to dedicate future ABH apparatus revenues to the replacement, rental-related repairs, refurbishment, and long-term maintenance of Town-owned fire apparatus; and
WHEREAS, establishing a Fire Apparatus Replacement Reserve Fund will allow the Town to accumulate resources over multiple fiscal years and reduce the financial impact of future apparatus replacement and major repair costs;
NOW THERFORE, BE IT RESOLVED by the Town Council of the Town of Paradise as follows:

SECTION 1. Establishment of Fund
The Town Council hereby establishes the Fire Apparatus Replacement Reserve Fund as a dedicated fund of the Town of Paradise for the purpose of accumulating financial resources for the replacement, acquisition, repair, refurbishment, maintenance, and life extension of Townowned fire apparatus.

SECTION 2. Assistance by Hire Revenues
Beginning upon the effective date of this Resolution, all future Assistance by Hire revenue received by the Town from the State of California attributable to the reimbursable use or rental of Town-owned Paradise Fire Department apparatus shall be deposited into the Fire Apparatus Replacement Reserve Fund.

SECTION 3. Use of Funds
Amounts deposited into the Fire Apparatus Replacement Reserve Fund shall remain available from year to year and may be used for purposes including, but not limited to:

1. The purchase or replacement of Town-owned fire engines and other major fire apparatus;

2. Major refurbishment or life-extension projects for existing Town-owned fire apparatus;

3. Repair, maintenance, or restoration of damage, excessive wear, or other impacts resulting from the use or deployment of Town-owned fire apparatus during Assistance by Hire assignments or other reimbursable emergency response events; 198

TOWN OF PARADISE
RESOLUTION NO. 2026-____

4. Local matching funds required for grants or other funding opportunities associated with the purchase, replacement, repair, refurbishment, or life extension of fire apparatus; and

5. Other fire apparatus-related capital expenditures approved by the Town Council.

SECTION 4. Council Approval
Expenditures from the Fire Apparatus Replacement Reserve Fund shall be subject to appropriation and approval by the Town Council through the annual budget process or by separate Town Council action.

SECTION 5. Other Funding Sources
Nothing in this Resolution shall prohibit or limit the Town from using General Fund contributions, Measure V revenues, grant proceeds, financing, or other legally available funding sources for fire apparatus replacement, repair, refurbishment, maintenance, or related capital needs.

The Fire Apparatus Replacement Reserve Fund is intended to serve as an additional longterm funding source and is not intended to be the sole source of funding for future fire apparatus needs.

SECTION 6. Administration
The Finance Director is authorized and directed to establish the appropriate fund and accounting structure necessary to implement this Resolution and to ensure that revenues and expenditures associated with the Fire Apparatus Replacement Reserve Fund are separately accounted for in the Town’s financial records.

SECTION 7. Effective Date
This Resolution shall take effect immediately upon its adoption.

PASSED AND ADOPTED by the town council of the Town of Paradise on this 8th day of September 2026 by the following vote:

AYES:

NOS:

ABSENT:

ABSTAIN:
___________________________
Steve Crowder, Mayor
ATTEST:
____________________________
Melanie Elvis, Town Clerk
APPROVED AS TO FORM:
_____________________________
Scott E. Huber, Town Attorney
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TOWN OF PARADISE

FIRE APPARATUS REPLACEMENT RESERVE FUND POLICY

1. PURPOSE
The Fire Apparatus Replacement Reserve Fund is established to provide a dedicated, long-term funding source for the replacement, incident-related repair, refurbishment, and life extension of Town-owned fire apparatus.

The Fund is intended to offset the financial impact of future apparatus needs and recognize the additional wear, damage, maintenance, and reduced service life associated with Assistance by Hire (“ABH”) deployments.

2. FUNDING
All ABH revenue received by the Town attributable to the reimbursable use of Townowned Paradise Fire Department apparatus shall be deposited into the Fire Apparatus Replacement Reserve Fund.

All proceeds received from the sale, auction, trade-in, or other disposition of Townowned fire apparatus shall also be deposited into the Fire Apparatus Replacement Reserve Fund.

The Town Council may authorize other revenues or transfers to the Fund.

3. ALLOWABLE USES
The Fund may be used for:

1. Purchase or replacement of Town-owned fire engines and other major fire apparatus;

2. Major refurbishment or life-extension work;

3. Repair or restoration of damage resulting from ABH deployments;

4. Repair or maintenance associated with excessive wear resulting from ABH deployments, including increased mileage, operating hours, or unusually demanding operating conditions;

5. Replacement or repair of major apparatus components;

6. Local matching funds for grants related to apparatus purchase, replacement, repair, refurbishment, or life extension; and

7. Other fire apparatus-related capital expenditures approved by the Town Council.

Routine operating and maintenance costs that are not attributable to an ABH deployment are not intended to be paid from the Fund.
200

4. ABH-RELATED DAMAGE AND WEAR
When the Fund is proposed to be used for ABH-related repair or maintenance, the Fire Department shall provide sufficient documentation to demonstrate the relationship between the expenditure and the ABH deployment.

Documentation should identify the apparatus, deployment, nature of the damage or excessive wear, and estimated or actual repair cost.

5. APPROPRIATION OF FUNDS
Expenditures from the Fire Apparatus Replacement Reserve Fund require Town Council appropriation through the annual budget, budget amendment, or separate Council action.

Amounts not appropriated or expended shall remain in the Fund and carry forward from year to year.

6. APPARATUS REPLACEMENT PLANNING
The Fire Department shall maintain a long-term apparatus replacement schedule identifying major apparatus, anticipated replacement timing, and estimated replacement costs.

The schedule shall be used in conjunction with the available Fund balance, grant opportunities, and other available funding sources to assist with long-term capital planning.

7. FUND BALANCE
The Fund is intended to accumulate resources over multiple fiscal years.

ABH revenues are not intended to be the sole funding source for fire apparatus needs.

The Town may combine Fund resources with General Fund contributions, Measure V revenues, grants, financing, or other eligible funding sources.

8. ADMINISTRATION
The Finance Director shall maintain the Fire Apparatus Replacement Reserve Fund as a separate accounting fund and ensure that revenues and expenditures are appropriately recorded.

The Fire Chief and Finance Director shall periodically review the Fund balance, anticipated apparatus needs, and replacement schedule and make funding recommendations through the Town’s budget process.

9. POLICY REVIEW
This policy may be amended by the Town Council as necessary to address changes in apparatus needs, ABH reimbursement practices, or Town financial priorities. 201
Adopted: September 8, 2026
Resolution No.: 2026-___
202

Town of Paradise
Council Agenda Summary
Date: September 8, 2026
Agenda Item: 6(c)
ORIGINATED BY: Marc Mattox, Assistant Town Manager
REVIEWED BY: Jennifer Macarthy, Town Manager
SUBJECT: 2025 Building Division Audit Corrective Action Plan (CAP) Quarterly Update

LONG TERM
RECOVERY PLAN:

Yes – Building Codes and Standards
COUNCIL ACTION REQUESTED:

1. Receive and file the second quarterly update to the 2025 Building Division Audit Corrective Action Plan, covering the period June 1 through August 31, 2026; and,

2. Affirm or provide alternative direction regarding the proposed implementation guardrails and ordinance refinements for the Building Code Complaint process described in the quarterly update.

Background:

In August 2025, in response to ongoing community concerns about permitting consistency, inspection reliability, and accountability during the post-Camp Fire rebuilding period, the Town of Paradise commissioned an independent operational audit of the Building Division. The audit found no illegal wrongdoing but identified areas warranting correction, including permit intake procedures, inspector training, internal oversight, and documentation practices.

The 2025 Building Division Audit Corrective Action Plan was prepared by Assistant Town Manager Marc Mattox and adopted by the Town Council on February 10, 2026. The CAP translates audit findings, along with additional improvement opportunities identified through internal review, into specific, trackable corrective actions organized across five functional areas.

The CAP was designed as a living document to be updated quarterly with implementation occurring in four phases spanning November 2025 through February 2027.

This is the second quarterly update to the adopted CAP. It covers implementation activity from June 1 through August 31, 2026. It does not replace the original CAP — it updates it. The update documents continued implementation of the corrective action framework, early experience with the Building Code Complaint process, ongoing quality assurance activities, operational performance metrics, and recommended refinements based on lessons learned during implementation. The full adopted CAP and all related materials are publicly available at https://www.townofparadise.com/building/page/building-code-complaint-corrective-action-plan.

Analysis:

CAP implementation continues to advance across the remaining active phases. Phase 1 (Stabilization) is complete, Phase 2 (Infrastructure Build-Out) is nearing completion, and Phases 3 (Public Interface Improvements) and 4 (Quality Assurance Integration) remain underway. 203
Below is a summary of the major developments reflected in the attached Quarterly Update:
 Completed Town Council response to the 2025–2026 Butte County Civil Grand Jury reports. On July 29, 2026, the Town Council approved its formal response to 11 findings and 11 recommendations concerning Building Division operations. Staff subsequently reviewed the Grand Jury recommendations against the adopted CAP and determined that applicable recommendations are already addressed through CAP actions, have otherwise been implemented, or were expressly declined by the Council. No additional Table E corrective actions are recommended as a result of the Grand Jury reports.  Advanced implementation of the Building Code Complaint Ordinance and Independent Review process. Ordinance No. 655 became effective June 11, 2026. As of August 31, the Town had received 22 complaints: three were withdrawn, one was unrelated to the ordinance, one could not proceed because it was anonymous, and 17 were determined to be actionable. Fourteen actionable complaints have received an initial site visit from the Independent Reviewer and three remain in initial review.  Identified recommended implementation guardrails for the Building Code Complaint process. Based on early implementation experience, staff recommends limiting the post-construction complaint process to completed projects with a Certificate of Occupancy; maintaining the process's focus on Building Code compliance rather than workmanship, construction quality or private contractual disputes; maintaining accountability and Strikes with the applicable permit applicant rather than non-permitholding subcontractors; and requiring documented notice and a reasonable opportunity for the permit applicant to address alleged deficiencies before Independent Review is initiated.
 Recommended a limited ordinance amendment for extraordinary life-safety circumstances. Staff recommends retaining the existing two-Strike framework while authorizing the Independent Reviewer to identify an egregious violation presenting a serious and immediate threat to life or safety as an extraordinary circumstance. Following Council direction, staff would work with the Town Attorney, Independent Reviewer and CAP Ad Hoc Advisory Committee before returning with any necessary ordinance amendment.
 Continued independent quality assurance review of permit intake and Building inspections. Bureau Veritas completed permit-intake QA reviews for June and July, finding that standardized procedures were being consistently applied and supporting uniform documentation and accountability. Building Inspection QA reviews for the same period found that inspection procedures were consistently followed and appropriately documented.
 Advanced final-inspection quality controls. Bureau Veritas completed Final Inspection QA reviews for June and July. The July review found that standardized final-inspection procedures have improved consistency, documentation and accountability, with inspectors demonstrating understanding of established procedures and consistently documenting final inspection activities. Full implementation of the final-inspection accountability framework remains targeted for December 2026.  Continued professional development for Permit Technician, Building Inspection and Plan Review staff. During the reporting period, Permit Technicians completed additional structural plan review training, while Building Inspection staff received training addressing truss calculations, residential fire sprinklers, shipping-container homes, 204
energy-storage systems, residential decks, and electric vehicle charging requirements.

Additional CALBO Training Institute coursework is planned.  Completed the expanded public-information resource initiative. More than 25 publicfacing documents have now been developed, updated and published, including community guidance and CAP intake materials, contractor and owner-builder resources, buyer and pre-construction guidance, plan and site checklists, and code-compliance references. This CAP action was designated complete in August 2026.  Continued public reporting through the Community Development performance dashboard. Through July 2026, the Building Division completed 8,778 inspections, performed 1,596 plan checks and issued 655 permits. Inspection pass rates remained relatively stable during the most recent three months at 70% to 76%. Median permit issuance time increased from 25 days in May to 36 days in July and will continue to be monitored. During the same three-month period, Code Enforcement closed 173 cases while opening 145, reducing the active caseload by a net 28 cases.

The attached quarterly update continues to use the Corrective Action Matrix as the CAP's primary accountability tool. Each action is updated based on its current implementation status, with Table E remaining reserved for supplemental recommendations identified through expanded analysis, quality assurance review and stakeholder feedback.

Financial Impact:

Implementation of CAP corrective actions during this reporting period continues to be supported through previously authorized consulting, training and professional services, including Bureau Veritas quality assurance services and Interwest Consulting Group's independent review and CAP advisory functions.

As implementation continues through Phases 2–4, ongoing costs associated with quality assurance sampling, Independent Review of Building Code complaints, staff training, ombudsman support and public-facing reporting will continue. Staff will return to Council as necessary with budget adjustment requests to sustain these functions through the corrective action period. No additional appropriations are requested with this quarterly update.

Attachments:
2025 Building Division Audit Corrective Action Plan – Quarterly Update No. 2 205
2025 Building Division Audit
Corrective Action Plan
Quarterly Update

RESTORING COMMUNITY CONFIDENCE THROUGH IMPLEMENTATION
FOR TOWN COUNCIL REVIEW SEPTEMBER 8, 2026
Prepared by:

Marc Mattox
Assistant Town Manager
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Table of Contents

1. Background and Context..................................................................................................................... 2

2. Major Milestones & Accomplishments ................................................................................................. 3

2.1 Grand Jury Report & Town Council Response .............................................................................. 3

2.2 Building Code Complaint Update & Independent Reviewer.......................................................... 3

2.3 Community Development Performance Dashboard .................................................................... 6

3. Corrective Action Framework and Implementation Matrix Updates ....................................................... 8

4. CAP Timeline Update ........................................................................................................................ 23 207
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Quarterly Update September 8, 2026

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1. Background and Context
In August 2025, in response to ongoing community concerns about permitting consistency, inspection reliability, and accountability during the post–Camp Fire rebuilding period, the Town of Paradise commissioned an independent operational audit of the Building Division. The audit was conducted to evaluate permitting and inspection practices and identify opportunities for process improvement.

The audit found no illegal wrongdoing. It did identify areas warranting correction, including permit intake procedures, inspector training, internal oversight, and documentation practices. The Town accepted the findings and committed to addressing them in a structured, transparent, and public-facing way.

The 2025 Building Division Audit Corrective Action Plan was prepared by Assistant Town Manager Marc Mattox and adopted by the Town Council on February 10, 2026. The CAP translates audit findings — along with additional improvement opportunities identified through internal review — into specific, trackable corrective actions organized across five functional areas.

The CAP was designed with the understanding that some corrective actions could be initiated immediately, while others would require additional time, contractual arrangements, staff training, or coordination with labor representatives. A phased implementation timeline was included in the original document, ranging from Phase 1 (Stabilization, November 2025–February 2026) through Phase 4 (Quality Assurance Integration, April 2026–February 2027).

It is important for readers of this update to understand the environment in which these corrective actions are being implemented. Since the Camp Fire in 2018, the Town of Paradise has managed one of the largest residential rebuilding efforts in California history. Since rebuilding began in earnest in early 2020, the Building Division has processed more than 3,890 single-family residential permit applications and issued more than 3,190 Certificates of Occupancy, in addition to more than 1,000 multi-family unit applications and 755 Certificates of Occupancy. This volume is without precedent in the Town's history.

The 2025 audit was not a comprehensive evaluation of all Building Division activity. It reviewed a defined set of escalated concerns and was intended to identify process gaps and near-term improvements. The Town has committed to supplementing the audit with broader data-driven analysis — including a manual review of a sample of 148 permits — to establish statistically meaningful performance metrics, evaluate trends across permitting and inspection categories, and provide a more complete picture of operational performance over time. That expanded review is currently underway; findings will be incorporated into future CAP updates and Table E as they become available.

This document is the second quarterly update to the adopted CAP. It covers the period from June 1 through August 31, 2026. It does not replace the original CAP — it updates it. Each quarterly update will follow this same structure, reporting new activity in each Matrix ID alongside the original commitments, so that progress is visible and cumulative over time.

A full copy of the adopted CAP is available at https://www.townofparadise.com/building/page/buildingcode-complaint-corrective-action-plan. 208
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2. Major Milestones & Accomplishments

2.1 Grand Jury Report & Town Council Response
Related CAP Matrix IDs: Multiple
In June 2026, the Butte County Civil Grand Jury released its 2025–2026 Final Report, which included two reports concerning the Town’s Community Development Department Building Division. Collectively, the reports contained 11 findings and 11 recommendations addressing employee qualifications and training, inspection and permit-processing practices, communication, organizational oversight, public access to the Building Division audit, and verification of permit applicants.

On July 29, 2026, the Town Council approved its formal response to the Grand Jury. The Council agreed with or agreed in part with several findings regarding past inspection and permit-intake deficiencies, while disagreeing with findings that were unsupported, inconsistent with Town records, or did not accurately reflect the Town’s organizational structure and staff qualifications. The Council’s response also noted that many of the Grand Jury’s recommendations had already been implemented through the Building Division Audit and Corrective Action Plan, including:
• Structured employee training, certification tracking and professional development; • Updated inspection protocols, checklists and quality-assurance measures; • Discontinuation of “courtesy inspections”;
• Standardized permit-intake procedures and checklists; • Verification of applicant authority, contractor licensing and workers’ compensation coverage; and • Public quarterly reporting on CAP implementation.

The Council declined recommendations to release confidential attorney work product associated with the independent investigation and to reconsider previously rejected CAP organizational changes. The Council determined that the publicly released Audit Memo identifies the operational findings and recommendations resulting from the investigation and that the organizational structure adopted with the CAP appropriately supports its implementation.

The 2025–2026 Butte County Civil Grand Jury Final Report and the Town Council’s July 29, 2026 formal response are available for public review through the Town’s Building Code Complaint and Corrective Action Plan webpage.

Staff reviewed the Grand Jury findings, recommendations and Council responses in relation to the existing CAP. Because the applicable recommendations are already addressed through adopted CAP actions, have otherwise been implemented, or were expressly declined by the Town Council, staff does not recommend adding any Table E actions in response to the Grand Jury reports or the Town Council’s response.

2.2 Building Code Complaint Update & Independent Reviewer Ordinance No. 655, codified as Paradise Municipal Code § 15.02.065, became effective June 11, 2026. The ordinance establishes a formal process for property owners to submit complaints alleging that a permit applicant failed to comply with applicable Building Code requirements. Eligible complaints are referred to an Independent Reviewer for records review, site inspection and written determination. 209
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As of August 31, 2026, the Town had received 22 complaints. Of these, three were withdrawn, one was determined to be unrelated to the ordinance, one could not proceed because it was submitted anonymously and 17 were determined to be actionable. Of the actionable complaints, 14 have received an initial site visit from the Independent Reviewer and 3 remain in the initial review process. Initial implementation has demonstrated that the ordinance provides a structured and independent process for evaluating eligible complaints, notifying permit applicants and encouraging corrective action. It has also identified opportunities to clarify the ordinance’s scope, prioritize appropriate cases for independent review and encourage resolution before initiating the Town’s formal process.

Feedback Regarding the Scope of the Process
During implementation, some participants have requested that the Town expand the complaint process to address two additional areas:
• Construction quality or craftsmanship concerns that may not constitute Building Code violations; and
• Direct accountability for subcontractors in circumstances where the permit applicant or prime contractor did not select, contract with or supervise the subcontractor.

Staff does not recommend expanding the ordinance into either area. The Town Council established the complaint process to determine compliance with applicable adopted building codes—not to adjudicate construction-quality, workmanship or contractual disputes.

Building codes establish minimum requirements intended to protect health and safety. Work may comply with those minimum requirements while still failing to meet an owner’s expectations, contractual specifications or preferred standards of workmanship. Those concerns generally remain private matters between the property owner and the contractors involved.

Similarly, the Town’s regulatory relationship is with the applicant identified on the building permit. The Town does not interpret private contracts or determine the contractual allocation of responsibility among property owners, prime contractors and subcontractors. When a permit applicant accepts responsibility for a permit, that party remains accountable to the Town for the permitted work regardless of separate private arrangements concerning who selected or contracted with individual subcontractors.

If a property owner separately retains a contractor to perform distinct work outside the prime contractor’s permitted scope, a separate permit may be required. When that contractor obtains the permit, the contractor assumes responsibility to the Town as the permit applicant for that work.

Limitations of the Independent Review
The complaint process is not a comprehensive evaluation or reinspection of the residence. The Independent Reviewer evaluates the specific Code allegations identified in an eligible complaint based on available permit records and visual, non-destructive observations.

The process does not:
• Reinspect the entire residence;
• Perform destructive testing or authorize removal of completed construction; 210
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• Determine the underlying cause of a concealed condition without supporting evidence; • Evaluate general construction quality or craftsmanship; • Interpret or enforce private contracts, warranties or scopes of work; or • Determine civil liability among owners, contractors and subcontractors.

A property owner seeking a broader evaluation, destructive investigation or assessment of workmanship may retain an appropriately licensed contractor, engineer, architect or other qualified professional. Any resulting evidence relating to a specific allegation of noncompliance with an applicable building code may be submitted for consideration through the complaint process, subject to the ordinance’s eligibility and procedural requirements.

The Council’s existing direction limiting the complaint process to Building Code compliance remains appropriate. Staff does not recommend expanding the ordinance to include workmanship, construction quality or private contractual disputes.

Recommended Ordinance and Implementation Refinements
Based on experience to date, staff recommends developing amendments to the ordinance and seeking Town Council affirmation or alternative direction regarding the following implementation guardrails.

Implementation Guardrails
Completed projects only. Limit the ordinance to projects that have received final approval from the Town and a Certificate of Occupancy. Complaints involving active permits or projects still under construction would be referred to Building Division staff for review through the regular inspection and enforcement process. Unresolved matters would follow the established escalation protocols, including review by the Assistant Town Manager when appropriate.

No involvement in private contractual agreements. The complaint process would not interpret or enforce private contracts, warranties or scopes of work, or determine how responsibility is allocated among property owners, prime contractors and subcontractors. Those matters remain outside the Town’s regulatory authority and must be resolved by the parties or through other available administrative, licensing or civil remedies.

No review of quality or craftsmanship complaints. Independent review would remain limited to specific allegations of noncompliance with applicable building codes. The process would not evaluate general construction quality, craftsmanship or whether completed work satisfies an owner’s expectations, contractual specifications or preferred industry standards when those concerns do not constitute code violations.

No Strikes for non-permit holders. Notices of Complaint, Notices of Determination and Strikes would continue to be issued only to the permit applicant responsible to the Town for the permitted work. The Town would not assign Strikes to subcontractors or other parties who did not hold the applicable permit, regardless of private arrangements concerning who selected, contracted with or supervised the work. If a separately retained contractor obtained an individual permit for distinct work, that contractor would be treated as the permit applicant responsible for that permitted scope.
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Minimum documented communication. Before initiating an Independent Reviewer site inspection, require the property owner to provide evidence that the permit applicant received written notice describing the alleged deficiencies and a reasonable opportunity to inspect and address them. This requirement would be generally modeled on the notice-and-opportunity-torepair principles of California’s Right to Repair Law (SB 800), without requiring the Town to administer or adjudicate that separate civil process.

Independent review could proceed when the permit applicant declines to address the concern, fails to respond within the established period or the parties remain unable to resolve the alleged code issue.

Ordinance Modifications
Extraordinary life-safety circumstances. Retain the existing two-strike framework while authorizing the Independent Reviewer to designate a substantiated allegation as an extraordinary circumstance when the violation is egregious and presents a serious and immediate threat to life or safety.

Staff recommends that the Town Attorney develop language amending the ordinance to address extraordinary circumstances, including the potential assignment of two Strikes upon issuance of a Notice of Determination, subject to appropriate notice and appeal procedures.

Recommended Next Steps
These proposed refinements would:
• Distinguish active construction oversight from the post-completion complaint process; • Encourage property owners and permit applicants to attempt resolution before Town intervention; • Preserve the process’s focus on objectively reviewable building code requirements; • Affirm that private contracts, workmanship and civil liability remain outside the Town’s review; • Maintain accountability with the party responsible to the Town as the permit applicant; • Clarify the limitations of visual, non-destructive independent review; and • Provide a stronger enforcement option for rare but exceptionally serious life-safety violations.

Staff recommends that the Town Council affirm or provide alternative direction regarding the proposed implementation guardrails. Following that direction, staff would consult with the Town Attorney, Independent Reviewer and CAP Ad Hoc Advisory Committee before returning to the Council with any necessary ordinance amendments.

2.3 Community Development Performance Dashboard
The Town’s monthly CDD Activity Summaries provide ongoing public reporting of permit, inspection and Code Enforcement performance. The following table summarizes the highest-level metrics included in the January through July 2026 reports, the latest monthly reports available at the time this quarterly update was prepared.
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Month Building
Inspections
Inspection
Pass Rate
Plan
Checks
Total
Permits
Issued
Median
Issuance
Time
Code
Cases
Opened
Code
Cases
Closed
January 1,069 73% 324 74 22 days 34 36
February 979 68% 134 88 15 days 25 42
March 1,584 66% 233 94 25 days 48 45
April 1,331 73% 216 102 25 days 56 58
May 1,159 70% 208 89 25 days 37 53
June 1,183 76% 210 91 35 days 65 63
July 1,473 71% 271 117 36 days 43 57
YTD 8,778 ≈71% 1,596 655 N/A 308 354
Through July, the Building Division completed 8,778 inspections, performed 1,596 plan checks and issued 655 permits. During the most recent three months, inspections increased from 1,159 in May to 1,473 in July, while plan checks increased from 208 to 271 and permits issued increased from 89 to 117. Inspection pass rates remained relatively stable, ranging from 70% to 76%.

Median permit-issuance time increased from 25 days in May to 36 days in July and will continue to be monitored as workload increases. Code Enforcement closed 173 cases while opening 145 during the same three-month period, resulting in a net reduction of 28 cases. 213
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3. Corrective Action Framework and Implementation Matrix Updates The Corrective Action Matrix is the primary accountability tool for this CAP. It translates audit findings and internally identified improvements into discrete, trackable actions organized across five functional tables (Table E remains reserved for supplemental recommendations to be identified through expanded analysis and quality assurance reviews):
• Table A — Community Development Administration
• Table B — Permit Counter Process Improvements
• Table C — Building Inspection Process Reforms
• Table D — Public Support & Complaint Resolution
• Table E — Future Supplemental Recommendations (reserved for actions identified through expanded analysis, quality assurance review, and stakeholder feedback) Each matrix entry documents the original recommendation, the implementation phase, and a current status narrative. The matrix is a point-in-time snapshot — entries reflect conditions as of the date of this update and may describe completed steps, ongoing activities, or planned milestones. Completion of individual milestones does not indicate closure of an entire corrective action unless explicitly stated.

A corrective action may be considered substantially complete when it has been implemented, embedded in standard operations, and supported by documentation — not solely dependent on interim measures or individual assignments. Items designated as complete will also be independently reviewed by Interwest in the next reporting period.

A full copy of the adopted CAP, including the complete Corrective Action Framework, is available at https://www.townofparadise.com/building/page/building-code-complaint-corrective-action-plan. 214
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Table A: Community Development Administration
ID# Recommendation Phase Current Status & Actions
A-1
Hire a dedicated
Community
Development Director.

Completed
December 2025
Prior to adoption of the CAP, the Town strengthened its administrative oversight structure by restructuring the Assistant Town Manager role to include direct responsibility for preparing and implementing the CAP, ombudsman functions, and public accountability reporting.

The Town maintains two Community Development Directors:

Planning/Wastewater, and Building/Code Enforcement/Fire Prevention — providing focused leadership across the full scope of community development operations.

In addition, the Town engaged Interwest Consulting Group to provide independent quality assurance sampling, technical advisory support, and quarterly validation of CAP implementation progress, further strengthening the oversight structure with an Independent Reviewer separate from Building Division staff and Town management.

A-2
Consider the use of an
interim Community
Development Director
via a consulting firm.

Completed
December 2025
The interim Community Development Director consulting
arrangement with BPR Consulting Group has concluded. The oversight functions originally contemplated under this action have been incorporated into the restructured Assistant Town Manager role described in A-1 and are further supported by the
independent quality assurance engagement with Interwest Consulting Group.

A-3
Consider moving Code
Enforcement under the
Planning Division.

Completed
December 2025
No change. Code Enforcement remains aligned with Building and Fire Prevention under the Community Development Director. In responding to the 2025–2026 Butte County Civil Grand Jury report, the Town Council considered the Grand Jury’s recommendation to revisit this organizational structure and, by majority vote, declined to change its prior direction. The Council’s decision is documented in the Town’s formal response to the Grand Jury.

A-4
Consider reclassifying
the Community
Development Director –
Building/Code
Enforcement/Fire
Prevention to Building
Official / Fire Marshal.

Complete
December 2025
No change. In responding to the 2025–2026 Butte County Civil Grand Jury report, the Town Council considered the Grand Jury’s recommendation to revisit this classification and, by majority vote, declined to change its prior direction. The Council’s decision is documented in the Town’s formal response to the Grand Jury.

The current classification and oversight structure remain in place. 215
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A-5
Develop a performance
dashboard for permits,
inspections, and
complaints.

Complete
Staff has implemented monthly public reporting as the
performance dashboard called for under A-5. CDD Monthly Activity Summary reports are published on the Town’s website and provide consistent reporting across all six divisions, including customer contacts, inspections, permit activity, processing times, plan reviews, code enforcement and defensible space operations.

Monthly reporting is now established as a standard operational practice and will continue throughout the CAP implementation period. A summary of year-to-date performance metrics and recent operational trends is provided in Section 2.3 of this report.

A-6
Establish formal
escalation protocols for
elevated Building
Division matters
requiring management
review.

Completed
May 2026
Formal escalation protocols have been established for elevated Building Division matters requiring management review before any determination outside normal code administration is
communicated to an applicant or party. The protocols do not create additional appeal rights or diminish the statutory authority of the Building Official.

Five categories of circumstances trigger mandatory escalation:
expedited processing requests; fee disputes or waiver requests; permit and inspection determination disputes; requests for deviations from standard procedures; and matters involving legal threats or suspected improper influence. For permit and inspection disputes, the CDD Director provides a first level of review; unresolved matters escalate to the Assistant Town Manager, who may refer technical determinations to the Town's Independent Reviewer in an advisory capacity.

Formal appeals of Building Official decisions remain governed by the Building/Fire Code Board of Appeals under PMC Title 15.

A-7
Establish advisory
committee for CAP
progress monitoring
(Council-authorized).

Ongoing
The CAP Ad Hoc Advisory Committee has been established and seated. The Committee is composed of the following members:
• Steve Crowder, Mayor
• Heidi Lange, Councilmember
• Jennifer Macarthy, Town Manager
• Marc Mattox, Assistant Town Manager
• Tony Lindsey, Community Development Director
• Bill Hayes, Interwest
• Bill Carter, Interwest (added)
• Dave Anderson, Contractor
• James Frost, Contractor
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• Jarrod Holliday, Engineer
• Donna Vairo, Community Member
The Committee's membership reflects a cross-section of
municipal leadership, technical professionals, and community representation, consistent with the CAP's intent to support transparency and organized stakeholder engagement during the corrective action period.

The Committee's charge has been expanded to include oversight of the building code complaint process recently adopted by the Town Council through a new ordinance adding Section 15.02.065 to the Paradise Municipal Code. Under that ordinance, the Committee serves as an advisory and oversight body for the complaint review process — supporting implementation of independent reviews and monitoring overall implementation — while the substantive determinations of Building Code
compliance remain with an Independent Reviewer. The
Committee does not serve in a decision-making or adjudicatory capacity.

The Committee will continue to review CAP implementation progress, engage with performance metrics and stakeholder feedback, and provide structured advisory input throughout the corrective action period. Updates on Committee activity will be reflected in subsequent CAP reports.
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Table B: Permit Counter Process Improvements
ID# Recommendation Phase Current Status & Actions
B-1
Provide in-person
training for permit staff
on ethics, best
practices, and legal
requirements.

Completed
March 2026
In-person ethics and professional conduct training was
completed in March 2026. On March 11 and 12, 2026, the Town hosted two days of on-site training delivered by Gerry Preciado of 34th Street Training, covering two required subject areas:

Workplaces That Work for All of Us — Harassment Prevention, satisfying the requirements of AB1825 (supervisory), SB1343 (nonsupervisory), and AB1661 (local agency officials); and Preserving the Public Trust: Ethics for Public Entity Officials, satisfying the requirements of AB1234.

Sessions were held at both the Building Resiliency Center and Town Hall Council Chambers to accommodate all available staff.

Training was conducted in an interactive, in-person format rather than the online format typically used for state-mandated training, consistent with the audit's recommendation for more engaging and effective delivery. Sign-in sheets and training materials are on file.

B-2
Assign two dedicated
permit technicians for
permit intake and
issuance.

Completed
December 2025
This corrective action was implemented effective December 1, 2025, and the dedicated permit technician staffing model has remained in place. Two permit technicians continue to be assigned exclusively to permit intake and issuance, supporting consistency in application processing, reducing turnaround times, and allowing other building division staff to focus on plan review, inspections, and customer support functions.

B-3
Provide classroom
training for permit
technicians and
supervisors.

Ongoing
Two full days of onsite classroom training were completed February 10–11, 2026, delivered by Steve Burger, CBO, of Bureau Veritas. The Complete Permit Technician curriculum covered code history, overview and use, legal aspects of code
administration, and the permitting process.

During this reporting period, two Permit Technicians also attended the Basic Steps in a Structural Plan Review course to further strengthen plan review knowledge and technical skills. Permit Technician staff are additionally scheduled to attend upcoming California Building Officials (CALBO) Training Institute Education Weeks for continued professional development on current California Building Code requirements and plan review
procedures.
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Staff will continue to seek and document ongoing professional development opportunities throughout the CAP implementation period, with additional training informed by quality assurance findings and operational needs.

B-4
Provide two weeks of
embedded trainer
support at the permit
counter.

Completed
April 2026
The embedded trainer support has been implemented and
sustained well beyond the initial two-week threshold. Jessie Oswald with Bureau Veritas, maintained an ongoing embedded presence with the Town between December 2025 to April 2026, providing direct in-person oversight and support across building division operations, including the permit counter.

B-5 Revise the permit
procedures manual.

Completed
February 2026
Effective December 1, 2025, the services of Jessie Oswald of Bureau Veritas were engaged to revise and update the Town of Paradise permit procedures manual, with a target completion date of January 31, 2026. This initiative was undertaken to ensure that all procedural documentation is current, accurate, and aligned with best practices.

The revised Permit Technician Manual has been completed and reflects current operations across all key functional areas of the Building Division. The manual includes step-by-step guidance on GovWell record types and workflows, building permit submittal requirements for residential, manufactured home, and
commercial projects, plan review routing procedures, fee calculation and invoicing processes for plan review, issuance, and development impact fees, wastewater application review and clearance-to-record procedures, and signature verification and contractor license requirements for permit issuance.

The manual serves as a comprehensive operational reference for permit technicians and supports consistency, accountability, and quality in permit counter operations going forward.

B-6
Require ICC Permit
Technician Certification
for classification.

Ongoing
Any changes to the minimum qualification requirements for employees in the Permit Technician classification trigger meetand-confer obligations between the Town and Union representatives. Human Resources & Risk Management Director has initiated coordination of this process. Meet-and-confer scheduling is underway and more information will be included in future updates to the CAP.

B-7 Provide updated public
informational materials.

Completed
August 2026
A comprehensive suite of more than 25 public-facing documents has been developed, updated, and published, spanning
community guidance and CAP intake, contractor and ownerbuilder resources, buyer and pre-construction guidance, plan and site checklists, and code compliance references.
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During this reporting period, staff developed and published a new Accessory Structures Informational Handout, including a Quick Reference Guide to assist customers in understanding permit requirements and applicable code provisions. These materials supplement the Community Resource Guide, CAP Community
Intake Form, and existing residential, commercial, WUI, solar, and CalGreen guidance.

These materials are available at the Building Resiliency Center and on the Town’s Building webpage and will continue to be updated as procedures and code requirements evolve.

B-8
Establish
comprehensive permit
applicant verification
and supervisory
authorization controls
for business entities,
contractors, and ownerbuilder applicants.

Completed
June 2026
Standardized permit applicant verification controls have been integrated into building division operations during this quarter through two primary mechanisms.

First, contractor information verification has been embedded as a standard first-line requirement across all 2026 inspection checklists developed under C-7. Every inspection type — from underground plumbing and electrical through framing, insulation, drywall, roofing, and final — requires documented confirmation of contractor information before the inspection proceeds. This systematically anchors verification to each stage of the permit lifecycle rather than solely at intake.

Second, staff received targeted professional development directly relevant to owner-builder and contractor authorization
requirements. The April 2, 2026 Shasta Cascade Chapter ICC monthly meeting featured a presentation by Hal Clay, Special Investigator with the California Contractors State License Board, covering owner-builder provisions and B contractors working out of class — two of the specific compliance areas identified in the original audit findings.

Additionally, the updated public-facing materials completed under B-7 — including the Owner-Builders Pamphlet, What is an Owner-Builder, Before Hiring a Contractor, Checklist for Prescreening Contractors, CSLB Ten Tips, and ADV Contractor guide — support applicant-side awareness of legal requirements consistent with Business and Professions Code section 7044 and Labor Code section 2750. Verification requirements have been incorporated into formal permit procedures and quality220 2025 Building Division Audit Corrective Action Plan
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assurance reviews and will continue to be monitored through the ongoing permit-intake QA process described under B-9.

B-9
Establish a quality
assurance function for
permit intake oversight.

Ongoing
The permit intake quality assurance function has advanced from framework development into active review. Standardized intake procedures and verification requirements provide the procedural foundation for periodic sampling and oversight.

Bureau Veritas completed Permit Intake QA reviews for both June and July 2026. The reviews confirmed that standardized permit intake procedures are being consistently applied, support uniform documentation, improve accountability, and promote a
consistent permitting process.

Ongoing QA reviews will continue to be used to identify training needs, procedural refinements, and opportunities for continuous improvement.
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Table C: Building Inspection Process Reforms
ID# Recommendation Phase Current Status & Actions
C-1
Provide in-person, in
lieu of existing onlineonly, ethics training for
inspectors.

Sessions were held at both the Building Resiliency Center and Town Hall Council Chambers to accommodate all available staff.

C-2
Provide classroom
training for inspection of
residential buildings,
plan reading, and
calculation
interpretation.

Ongoing
Classroom training for inspection and plan review staff remains active. Building Division staff attended the 2026 SVABO Training Institute, completing courses addressing the 2025 California Building Code, Energy Code requirements, structural plan review, Mechanical and Plumbing Code changes, generators and
transformers, and residential plumbing and mechanical
inspection and plan review.

During this reporting period, Building Inspection staff completed additional professional development addressing truss
calculations, residential fire sprinkler systems, shipping container homes, Energy Storage System requirements, residential deck installation and code requirements, and Electric Vehicle charger and battery charging requirements.

Building Inspection and Plan Review staff are also scheduled to attend upcoming CALBO Training Institute Education Weeks for continued training on current California Building Code
requirements, inspection practices, and plan review procedures.

Training will continue to be documented and informed by QA findings and operational needs.
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C-3
Employ a Field Training
Officer (FTO) for at least
six months.

Completed
April 2026
The six-month FTO engagement was completed in April 2026 through three progressive phases designed to provide inspectors with field coaching and exposure to multiple professional perspectives.

Phase 1, from October 2025 through January 2026, provided embedded field oversight through BPR Consulting. Phase 2, from February through March 2026, transitioned to a Bureau Veritas FTO team that conducted weekly ride-alongs with all three building inspectors, covering foundation, framing, mechanical, electrical and plumbing rough-in, roofing, solar and final inspections. Phase 3, completed in April 2026, included off-site ride-alongs at active inspection sites in Rocklin, exposing inspectors to commercial, multistory and other complex
inspection types not routinely encountered during Paradise’s residential rebuilding.

The program documented improvement in plan referencing, inspector confidence and code-specific knowledge, including Wildland-Urban Interface requirements, corrugated stainless steel tubing gas piping, Title 24 energy compliance and truss calculations. Continued professional development and qualityassurance reviews are addressed under C-2, C-4 and C-6.

C-4
Provide off-site
professional training for
inspectors.

Ongoing
Off-site professional development remains an active component of the Building Division’s training program. Staff continue to participate in Shasta Cascade Chapter of the International Code Council activities and regional training opportunities that support code consistency and peer collaboration.

During this reporting period, staff completed additional training in residential fire sprinkler systems, shipping container homes, Energy Storage System requirements, residential deck installation and code requirements, and Electric Vehicle charger and battery charging requirements. Building Inspection and Plan Review staff are also scheduled to attend upcoming CALBO Training Institute Education Weeks.

Fire Prevention Inspector Shane DeValera was elected Education Chair for the Shasta Cascade Chapter of the International Code Council. He will support the Chapter’s professional development and educational programs alongside Town Building Plan Reviewer Patti Samons, who currently serves as Chapter President. 223
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C-5
Require Building
Inspector II to obtain a
second certification
within 90 days of return.

Completed
January 2026 Second ICC certification obtained for the position.

C-6
Establish a quality
assurance function for
inspection oversight.

Ongoing
The quality assurance function for inspection oversight remains active through Bureau Veritas. The 2026 Building Inspector Quality Assurance Checklist provides the structured framework for permit and plan verification, code compliance, inspection execution, documentation and photo verification, consistency review, customer communication, and professional conduct.

Bureau Veritas completed Building Inspection QA reviews for both June and July 2026. The July review found that inspection procedures were consistently followed and appropriately documented. Inspection records demonstrated adherence to established Town inspection protocols, with sufficient
documentation to support inspection results and code
compliance determinations.

QA findings will continue to be used to validate implementation, identify training needs, and support ongoing procedural improvement.

C-7
Implement uniform
inspection checklists
and photo
documentation.

Completed
June 2026
As reported when the CAP was adopted, photographic inspection procedures had already been implemented, while uniform
inspection checklists were being developed in collaboration with Bureau Veritas. The checklists have since been finalized, and both requirements are now fully implemented as standard Building Division practices.

The 2026 Residential Stick-Built Building Inspection Checklists, 2026 Manufactured Residential Building Inspection Checklists, and all over-the-counter inspection checklists for electrical, plumbing, mechanical, solar, pools, and fire systems have been finalized and adopted. Each checklist includes a photo
documentation requirement specific to the inspection type, with required photos called out at the checklist level — for example, test gauge readings, trench routing, rebar and anchor details, and key structural elements — ensuring photographic evidence is captured systematically rather than at inspector discretion.

Photo documentation requirements are also formally embedded in the 2026 Building Inspector Quality Assurance Checklist under Section 4 — Documentation and Photo Verification, which 224
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requires inspection results to be entered into GovWell and clear, labeled photos taken of the overall work area, key inspected components, and any deficiencies. Notes must be complete, professional, and objective, with corrections referencing applicable code sections.

The FTO program reinforced photo-documentation practices during its six-month engagement through real-time field coaching, and these requirements are now functioning as standard
operational practice across the inspection team.

C-8
Implement inspection
performance
accountability and final
inspection controls.

Ongoing
Formal inspection performance accountability protocols and final inspection controls are now in active implementation, supported by Bureau Veritas quality assurance reviews, standardized inspection checklists, photo documentation requirements, and procedures requiring verification that prior correction notices are resolved before final approval.

Bureau Veritas completed Final Inspection QA reviews for both June and July 2026. The July review concluded that standardized final inspection procedures have improved consistency,
documentation, and accountability throughout the final
inspection process. Inspectors demonstrated a thorough
understanding of established procedures and consistently documented final inspection activities.

These controls continue to build on the standardized inspection checklists under C-7 and the inspection QA framework under C-6.

Full implementation remains targeted for December 2026. 225
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Table D: Public Support & Complaint Resolution
ID# Recommendation Phase Current Status & Actions
D-1
Establish an
ombudsman role to
support homeowners
navigating construction
concerns.

Ongoing
The ombudsman function is active and operational through the Assistant Town Manager's office. The CAP Complaint Ordinance has been formally adopted and launched, providing a structured pathway for community members to submit building-related concerns for review and tracking.

Homeowners and community members are encouraged to engage directly with the Assistant Town Manager, who is available for walk-in ombudsman office hours every Wednesday and Thursday from 11:00 a.m. to 1:00 p.m. at Town Hall, 5555 Skyway, Paradise, CA 95969. Appointments outside of office hours are also available Monday through Thursday during normal business hours and may be scheduled by emailing [email protected].

The ombudsman role is designed to help homeowners understand their concern, identify the appropriate resolution pathway, and navigate available resources — whether those resources are within Town authority or through external agencies such as CSLB, civil court, or state licensing boards. This function is informational and navigational in nature; it does not adjudicate disputes, reopen inspections, or assign liability.

D-2
Improve transparency
regarding complaint
pathways and available
resources.

Ongoing
The Town continues to provide a clear, publicly accessible process for submitting Building Code complaints and CAP feedback. Ordinance No. 655, codified as Paradise Municipal Code Section 15.02.065, established the formal complaint process described in Section 2.2 of this report.

A combined Building Code Complaint and CAP Feedback Form serves as both the formal complaint-submission mechanism and the general stakeholder-feedback channel for CAP monitoring.

The Town has also published a Community Resource Guide
addressing concerns outside Town authority, including contractor disputes, CSLB processes, civil remedies, the Right to Repair Law, other professional licensing agencies, consumer protection and manufactured housing oversight.

The complaint form, Community Resource Guide, ordinance, independent audit, adopted CAP and quarterly reports are available on the Town’s dedicated Building Code Complaint and Corrective Action Plan webpage.
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Table E: Future Supplemental Recommendations
ID# Recommendation Implementation
Phase
Current Status & Actions
N/A
Current Status: No supplemental recommendations are proposed during this reporting period. Findings from the expanded permit analysis and future quality-assurance reviews will be evaluated for potential inclusion in Table E.
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4. CAP Timeline Update
The following timeline provides a high-level sequencing framework for implementation of the corrective actions identified in this Corrective Action Plan. It is intended to communicate the Town's anticipated approach to prioritization, coordination, and phased execution rather than to establish rigid deadlines for individual actions.

The timeline reflects the reality that corrective actions vary in complexity, resource requirements, and dependency on external factors such as recruitment, training availability, contractual services, and policy adoption. Accordingly, the phases identified below represent logical groupings of work designed to stabilize operations, strengthen institutional capacity, and integrate long-term improvements in a deliberate and sustainable manner.

As corrective actions progress, timelines may be refined to reflect actual implementation conditions, evolving priorities, or additional findings from expanded analysis. Any such adjustments will be documented in subsequent CAP updates to maintain transparency and accountability.

As of this reporting period, Phase 1 is complete, Phase 2 is nearing completion, and Phases 3 and 4 remain underway.

Phase Period Primary Activities
Phase 1: Stabilization November 2025 to
February 2026
Staff reinstatement (completed); FTO engagement
(completed), continued supplemental staffing (ongoing), initiation of training (completed); organizational
restructuring decisions (completed); Corrective Action Plan adoption and initiation (completed).

Phase 2: Infrastructure
Build-Out
December 2025
to November 2026
(updated from
August 2026)
Development of revised procedures (complete); permit and inspection procedure rollouts (complete); adoption of new manuals (complete); implementation of certification
requirements (ongoing); expanded statistical analysis of inspections (ongoing), themes and programmatic needs
(ongoing). Initial advisory review of CAP implementation progress by Council-authorized Ad Hoc Committee
(completed).

Phase 3: Public Interface
Improvements
February 2026 to
February 2027
Ombudsman role implemented through the Assistant Town
Manager (ongoing); expanded public guidance (ongoing);
transparency reporting (ongoing).

Phase 4: Quality
Assurance Integration
April 2026 to
February 2027
Long-term QA/oversight (ongoing); system improvements;
metrics reporting; close-out of corrective items (ongoing). 229

Town of Paradise
Council Agenda Summary
Date: September 08, 2026
Agenda Item: 6(d)
ORIGINATED BY: Colette Curtis, Recovery and Economic
Development Director
REVIEWED BY: Jennifer Macarthy, Town Manager
SUBJECT: Town Population Update

LONG TERM
RECOVERY PLAN:

No
COUNCIL ACTION REQUESTED:

1. Authorize the Town Manager to enter into an agreement with the North State Planning and Development Collective to produce an updated population estimate for the Town of Paradise. (ROLL CALL VOTE)
Background:

Accurate population data is important to the Town for long-range planning, economic development, grant applications, infrastructure and service planning, housing analysis, and measuring the progress of the community's ongoing recovery from the 2018 Camp Fire.

The California Department of Finance (DOF) prepares annual population estimates for cities and counties throughout California. These estimates provide a standardized statewide measure of population; however, they are estimates developed through demographic and mathematical methodologies and are not based on a direct annual count of residents or actual year-over-year changes within individual communities.

This presents a particular challenge for Paradise. Since the Camp Fire, the Town has experienced significant and ongoing changes in its housing stock, occupancy, household composition, and population. The pace and nature of Paradise's recovery are unique and may not be fully reflected through methodologies designed to estimate population across communities statewide.

Additionally, DOF's methodology incorporates assumptions regarding persons per household.

Staff has concerns that the household size currently used for Paradise does not adequately reflect current local demographic trends. Because the Town's housing stock and population continue to change rapidly as rebuilding progresses, these assumptions can have a significant impact on the resulting population estimate.

Analysis:

Staff proposes contracting with the North State Planning and Development Collective (Collective), in partnership with Economic Forensics and Analytics, Inc. (EFA) and Dr. Robert Eyler, to develop a locally informed population and demographic analysis for Paradise.

Rather than relying exclusively on statewide estimates, the project will combine official Census and DOF information with locally available data to develop a more refined estimate of the Town's 230
current population. Local indicators to be evaluated may include housing permits and completions, utility hookups and usage, school enrollment, vehicle registrations, satellite imagery, cell phone data, and other available information.

The analysis will establish a pre-2019 baseline and evaluate the number and type of occupied housing units, persons per household, and other demographic characteristics. Using this information, the project will develop an alternative population estimate that can be compared with DOF's annual estimates. The methodology will also be used to estimate population through 2035 and establish an annual dataset that can be updated as new Census, DOF, and local information becomes available.

The project will result in two primary deliverables:
 A Population and Demographic Report describing the methodology used for official population estimates and the alternative methodology developed using more specific local data for Paradise; and
 A Paradise Databook linking historical information with the most current available data and providing annual population information from 2015 through 2035, as data availability allows.

The purpose of this work is not to replace the State's official population estimate, but to provide the Town with an additional, locally informed planning tool that more closely reflects the unique conditions of Paradise's recovery. The analysis will also provide a methodology for tracking future population changes and comparing the locally developed estimate against future DOF and Census updates.

A more refined understanding of the Town's population will support infrastructure and service planning, economic development efforts, housing and workforce analysis, grant applications, and the Town's ability to accurately communicate the pace of Paradise's recovery.

Financial Impact:

In the 2026-27 Fiscal Year Budget, Council included $15,000 in the Recovery and Economic Development Department Budget to provide an updated population assessment. The total cost of the described project is $6,675, which includes project management, local data collection and analysis, GIS and data support, and development of the final deliverables. Technical analysis and consulting services provided by EFA and Dr. Robert Eyler are included within the project scope at no additional cost to the Town. The anticipated project completion date is December 31, 2026. 231
Scope of Work
Town of Paradise Demographic Data
North State Planning and Development Collective
with Economic Forensics and Analytics, Inc. / Dr. Robert Eyler Project Overview
The Town of Paradise continues to welcome back a growing population following the devastating effects of the Camp Fire. Because of the significant changes to Paradise’s population and housing since the fire, official estimates of population, housing mix, occupied housing units, and demographic characteristics may not fully capture current conditions. There has also been local concern regarding annual state and federal population estimates and their ability to reflect the pace of Paradise’s recovery.

The North State Planning and Development Collective (the Collective), in partnership with Economic Forensics and Analytics (EFA) and Dr. Robert Eyler, will work with the Town of Paradise to develop a locally informed population and demographic analysis. The project will combine official estimates with local data to better understand Paradise’s current population and provide an alternative methodology for tracking population changes as the community continues to rebuild.

Approach
Using local data on housing units permitted and completed, utility accounts and usage, and other information obtained directly from the Town, local agencies, and available data sources, the project will focus on determining the number and types of occupied homes and developing a more refined estimate of Paradise’s population.

The Collective will serve as the lead contractor and primary point of contact for the Town, coordinating local data collection, project management, data analysis and GIS support, and work with EFA. Dr. Eyler will provide the demographic and economic expertise necessary to develop and test the alternative population estimation methodology.

The project will:
• Use U.S. Census Bureau and California Department of Finance (DOF) data to establish a pre-2019 population baseline for Paradise and comparison areas within Butte County, including Chico, Oroville, Biggs, Gridley, and unincorporated areas. • Compile and evaluate locally available information including school enrollment, housing permits and completions, vehicle registrations, satellite imagery, cell phone data, utility hookups and usage, and other available indicators to refine estimates of Paradise’s occupied housing and population.
• Use available information to evaluate population and demographic characteristics, including age, gender, race and ethnicity.
232
• Develop an alternative population estimate that can be compared with DOF’s annual estimates and use current housing permits, occupancy information, persons per household, and other available indicators to estimate population through 2035. • Incorporate current K–12 attendance estimates for Butte County and district-level data as available.
• Combine official data, local data, and forecasts to establish an annual dataset that can be used to track population change and test the alternative methodology against future DOF and Census updates.

Deliverables
Based on data availability, the project will produce:

Population and Demographic Report: A report describing the methodology used for official population estimates and the project methodology for incorporating more specific local population and demographic data for Paradise.

Paradise Databook: A databook linking historical information to the most current available data, including both official population estimates and the alternative methodology developed through this project. Data will be provided annually from 2015 through 2035, as data availability allows.

Budget and Timeline
The total cost for this project will be $6,675. This budget will support the Collective’s project management, coordination with the Town of Paradise, local data collection and analysis, GIS and data support, coordination with Economic Forensics and Analytics (EFA) and Dr. Robert Eyler, and development of the final project deliverables. EFA and Dr. Eyler’s technical analysis and consulting services will be provided within the overall project scope at no additional cost to the Town of Paradise.

The anticipated project completion date is December 31, 2026. The 2025 American Community Survey data are anticipated to be available in December 2026. If relevant data are released after January 1, 2027, the Collective and Town of Paradise can determine whether the analysis should be updated at that time.

Submitted by:

Courtney Farrell, Assistant Director
North State Planning & Development Collective
California State University, Chico
233
Town of Paradise
5555 Skyway
Paradise, CA 95969
(530) 872-6291
Working together to rebuild a thriving community.

September 8, 2026
The Honorable Gavin Newsom
Governor of California
1021 O Street, Suite 9000
Sacramento, CA 95814
RE: Town of Paradise Support for AB 2700 and Full, Fair, and Timely Restitution for Wildfire Survivors
Dear Governor Newsom:

On behalf of the Town of Paradise and our residents who continue to recover from the devastating Camp Fire, I respectfully urge you to sign AB 2700 into law and support the transparent process it establishes through the California Public Utilities Commission (CPUC).

AB 2700 has received unanimous, bipartisan support throughout the legislative process. This strong support reflects a shared understanding that wildfire recovery and fair restitution are not partisan issues. They are matters of justice, accountability, and the long-term resilience of communities throughout California.

For the Town of Paradise, these issues are deeply personal. Our community continues to rebuild following the Camp Fire, and many residents, families, businesses, and property owners continue to experience the financial and emotional consequences of that disaster. While significant progress has been made, recovery is not complete, and many survivors continue to face losses that have not been fully addressed.

We appreciate your recognition of the prolonged struggle experienced by wildfire survivors and your commitment to ensuring that victims are not forgotten. As you have previously stated, the focus must remain on the victims who have endured years of uncertainty and hardship.

AB 2700 provides an important pathway toward addressing these ongoing challenges. The legislation does not seek to undermine existing recovery programs or shift restitution costs onto ratepayers or taxpayers. Instead, it establishes a focused and transparent process for the CPUC to identify verified restitution shortfalls and consider lawful mechanisms to help ensure that victims of utility-caused wildfires are fully, fairly, and timely compensated.

This is particularly important for communities such as Paradise, where recovery from a catastrophic wildfire extends far beyond the initial emergency response. Families have faced rebuilding costs, insurance challenges, business losses, medical expenses, and other financial burdens. A truly resilient recovery system must recognize these continuing impacts and ensure that survivors are not left behind.
234
Town of Paradise
5555 Skyway
Paradise, CA 95969
(530) 872-6291
Working together to rebuild a thriving community.

We also respectfully ask that your Administration continue engaging directly with wildfire survivors and affected communities as California considers broader wildfire recovery and resiliency legislation.

The voices of communities that have experienced catastrophic wildfire firsthand are essential to developing policies that protect future victims while also addressing the needs of those who are still recovering today.

California must not create a system that protects future victims while leaving current wildfire survivors undercompensated. True resiliency means ensuring that families, local businesses, ratepayers, and communities have a meaningful opportunity to recover.

The Town of Paradise believes that investor-owned utilities must be held accountable for the consequences of catastrophic fires they cause. Supporting the financial stability of California's utilities and protecting ratepayers are important goals; however, those goals should not come at the expense of wildfire victims who continue to wait for full and fair restitution.

AB 2700 represents an important step toward a more equitable wildfire recovery system. It provides an opportunity to evaluate lawful mechanisms for addressing restitution shortfalls while protecting ratepayers and strengthening accountability.

On behalf of the Town of Paradise and our residents, I respectfully request that you:

1. Sign AB 2700 into law; and

2. Support the transparent, survivor-centered CPUC process established by the legislation.

Our community knows firsthand that recovery takes years and that the impacts of a catastrophic wildfire do not end when the flames are extinguished. We remain committed to working with your Administration, the Legislature, wildfire survivors, and communities throughout California to develop solutions that provide fair, full, and timely compensation while strengthening the resilience of communities facing future disasters.

Thank you for your continued attention to the needs of wildfire survivors and for your leadership on these important issues. We respectfully ask that you stand with the survivors of the Camp Fire and other utility-caused wildfires by signing AB 2700.

Sincerely,
Steve Crowder
Mayor, Town of Paradise
235

Town of Paradise
Council Agenda Summary
Date: September 8, 2026
Agenda Item: 7(b)
ORIGINATED BY: Town Council
REVIEWED BY: Jennifer Macarthy, Town Manager
SUBJECT: Town Council Committee Reports

LONG TERM
RECOVERY PLAN:

No
COUNCIL ACTION REQUESTED:

1. Council Members’ written reports on standing, external and ad hoc committee representation.

Background:

During the May 12, 2026, Council meeting, the Council approved changing Council reports on committee representation from verbal reports to written reports. The Councilmembers submitted the following reports for September 2026.

Standing Committee Reports
Economic Development Committee:

Mayor Crowder: Attended the Economic Development Committee meeting.

Insurance Advocacy Committee:

Council Member Bolin: Attended the Insurance Advocacy Committee meeting.

Ad Hoc Committee Reports
Building Division CAP Committee
Mayor Crowder: Attended the CAP Committee meeting.

Paradise Sewer Project
Mayor Crowder: Attended the Sewer Committee meeting.
236
External Committee Reports
Butte County Air Quality Management District
Council Member Lassonde:

The BCAQMD Governing Board met on August 27, 2026, at the BCAG Board Room.

The following summary of Board actions is provided FYI.

1. Approved the following on Consent:
 Minutes of July 23, 2026 Meeting of the Board of Directors.  Activity Report on Butte County Air Quality Management District Activities.  Financial Status Report for Fiscal Year 2025-26.
 Status Report on Calendar of Events.
 Status Report on Communications.
 Memorandum of Understanding Cost of Living Adj. (Resolutions 2026-18 & 2026-19).  CalPERS CCR 570.5 Compensation Schedule-COLA (Resolution 2026-17).

2. Approved Proposed CAP Support Grant Projects.

3. Approved the Climate Heat Impact Response Program (CHIRP) P&Ps and Resolution 2026-

21. 4. Approved the Final 2025-2026 Budget Amendments.

5. Item 8 was held over.

6. Update on the Lawn and Garden Voucher Program was presented.

7. Other Business – None.

8. Public Comment None.

9. Closed Session – APCO performance evaluation and Contract Renewal.

10. Closed Session report – The Board extended the Air Pollution Control Officer’s contract.

11. The next Board Meeting is scheduled for September 24, 2026, at 10:00 a.m. at the BCAG Board Room, 326 Huss Drive, Suite 100, Chico.

Butte County Association of Governments
Council Member Lassonde:

Approved the Butte Regional Transit Mobility Aid Policy update.

BACKGROUND: In September 2025, a rider request was filed to modify the policy allowing riders with child occupied strollers to board the bus and for the child to remain seated in the stroller while the bus is in motion and physically hold the stroller. Based on discussion of the current and perceived safety issues of changing the policy, no changes to the policy were made at that time. The complainant filed an appeal and subsequently attended the December 2025 Board meeting, addressed the Board, and demonstrated the procedure required to follow the current policy. The Board requested staff look at what would be required to modify the modify the policy and any effects the changes might have. At the January 22, 2026 Board meeting, staff presented the policies in place at the time and the intent to review and develop a policy to accommodate the request while maintaining current standards of practice, state and federal laws while also addressing liability for the Operator, Transdev.

UPDATE: The update to the policy will now allow children to remain in strollers while onboard and the use of the securement area on the Bus. Placards will be posted with the rules that must be complied with if this option is utilized. 237
LAFCo
Council Member Bolin: Attended the monthly LAFCo meeting.

Additional Community Activities:

Mayor Crowder:

August 6th Phone conversation with Altadena leaders after SEC was found liable for their fires.

Questions such as what steps should come next, what did PG&E do for your community, and what can be expected from State and Federal Government
August 10th Was in Sacramento Capital for a 9:00am press conference and a 10:00am hearing on AB2700. The Senate Appropriations Committee with no opposition sent the bill to a suspense file to go to the senate floor for a vote.

August 10th Special Council meeting for Long-Term Recovery Plan Working Session August 10th Did a live 6:00pm Action News update on AB2700 August 11th USDA regional director, his staff, and Congressman Gallagher came and spent the afternoon in Paradise. They spoke with staff, got updates on our progress and needs and may be able to locate some additional funding for our recovery August 13th Zoom call with Hayley Watts with Action News about the process of the final payout and shutdown of the Fire Victim’s Trust (FVT).

August 17th KPAY radio interview about the FVT, AB2700 and other progress in our town.

August 17th KRCR interview about the FVT shutdown.

August 18th Met with citizen that was not getting any return calls from his FVT attorney is regards to a check that was made out incorrect for eight months and I got it to the FVT Trustee who has since gotten it corrected.

August 19th Met with citizen about a drainage issue from neighbors’ property. Also present at meeting were our TM, CDD director, assistant TM. There were three issues and I believe we have a resolution going forward.

August 20th Attended a press conference with Congressman Gallagher as he is introducing a bill to stop both parties from redistricting strictly for political gain as it has a horrible effect on the communities and takes away their voice.

August 24th Met with a candidate running for town council and listened and exchanged ideas.

August 27th Attended the promotion of Officer Diaz to SGT Diaz, always great to see our department flourish.

August 29th Worked via email with a former PD officer who moved out of state and with the FVY 238
shutdown he is concerned about his minor child’s trust and again can’t get information from his attorney, so he contacted me and I have the trust doing the work that should be up to his attorney which unfortunately this law group does all the time.

Council Member Lassonde:
 August 24 – Attended the Ribbon Cutting for the Noble Orchard Cold Storage facility  August 27 – Attended BCAG & BCAQMD meetings
 August 27 – Attended the Promotion for Sergeant Gustavo Diaz  September 1 – Attended the TOP Candidate Orientation
 September 3 – Reviewed the Town Council Agenda with Town Manager 239

Paradise City CouncilSeptember 8, 2026

Paradise City Council
September 8, 2026