September 2025
SJCOG, Inc.
STAFF REPORT
SUBJECT: Approval of San Joaquin Multi-Species
Conservation an Open Spaces Plan
(SJMSCP) Five-Year Financial Analysis
Update and 2026 SJMSCP Development
Fee
RECOMMENDED ACTION: 1) Adopt the SJMSCP Five-Year Financial Analysis Update and 2) Approve 2026
SJMSCP Development Fees as Adjusted
Pursuant to the Financial Analysis Model
DISCUSSION:
SUMMARY:
Over the last many months, SJCOG, Inc. staff, Willdan and the Habitat Technical Advisory Committee (HTAC) Financial Subcommittee have engaged in the required five-year
financial update to the San Joaquin County Multi-Species Habitat Conservation and Open Space Plan (SJMSCP). The
last review was in 2020. For the current 2025 update, the main areas of focus were the categories of the fee model regarding land costs to be used for mitigation (Category A), required restoration/enhancement costs on preserve lands (Category B), and monitoring, management and
administration of the program and preserves (Category C).
During the current review, the Financial Sub-committee kept the previously adopted financial model with the following minor alterations to the fee model and process. A summary of these changes is below; a more detailed explanation is provided in the Background section of the staff report
Category A:
1) Removal of “outliers” from comparable land sales data (those sales more than three standard deviations from the mean per acre price).
2) Easement purchase values are estimated to be 55% of full fee title land sale values (sales of land without habitat easements in place). This is a reduction from the previous assumption of 56% and is subject to review midway through the next five-year cycle.
Category B:
1) Updated with the most recent SJMSCP reporting from 2024 Annual Report, including updated cost values for habitat enhancement projects on preserves, and review of the allocation of preserve land types purchased to meet the required mitigation under the habitat plan to ensure that development fees provide maximum value for fee payers and conservation.
Category C:
1) Updates to the administrative aspects of the plan, updated biological costs for project review, and updating of endowment account policy with investment strategies (e.g. a more diversified portfolio for higher yield on investment) for preserve funds.
The proposed 2026 SJMSCP development fees were adjusted using the recommended SJMSCP five-year financial model update for the respective categories and are compared to the 2025 SJMSCP Development fees (Table 1) in the most common habitat categories under the plan. The change is an overall increase of 8.3% in the most impacted categories of Agricultural and Natural Habitat Classifications from the prior year.
Table 1- Compared 2026 & 2025 SJMSCP Development Fees – Most Common Fee Habitat Types 2026 Fee Proposed 2025 Fee Adopted Difference Percent Change Agricultural/Natural $17,868 $16,492 $1,376 8.3%
The increase is due primarily to a rise in the land acquisition component (Category A) for agricultural land values of comparable sales and updating of current costs for land management and enhancement activities for on-going preserves (Category B).
RECOMMENDATION:
SJCOG, Inc. staff and the Habitat Technical Advisory Committee (HTAC) recommend 1) Adopt the SJMSCP Five-Year Financial Analysis Update and 2) Approve 2026 SJMSCP Development Fees as Adjusted Pursuant to the Financial Analysis Model FISCAL IMPACT:
Development fees provide funding for SJCOG, Inc. to provide biological coverage and mitigate project impacts covered under the SJMSCP permits for the subsequent calendar year beginning January 1, 2026. The resulting increase in fee revenue will offset increasing costs to acquire and manage preserve lands.
BACKGROUND:
For the current SJMSCP five-year financial analysis update review, SJCOG, Inc. staff, Willdan and the HTAC Financial Subcommittee (Table 2) reviewed the currently adopted model which estimates the costs of implementation for fulfillment of the SJMSCP permits and defines the three fee categories:
Category A – Acquisition
Category B - Enhancement
Category C - Land Management, Monitoring & Administration).
The three main areas of focus were the categories of the fee model regarding land costs to be used for mitigation, required restoration/enhancement costs on preserve lands, and monitoring, management and administration of the program and preserves.
The HTAC Financial Subcommittee maintained the formula model for fee calculations to allow for response to market fluctuations and cost changes which need to be reflected in the mitigation fee. The formula is still categorized into three distinct components to better calculate an accurate fee per acre [FEE = Category A (acquisition) + Category B (assessment & enhancement) + Category C (management, monitoring & administration)].
Category A (acquisition) – Comparable Land Sales
This category is directly related to land valuation based on comparable land sales in San Joaquin County in specific zones of the plan area (Central Zone, Central Southwest Transition Zone and Delta Zone) over an established 2-year period
meeting the established criteria used for comparable land sales (attachment 1). Cost estimates for this category will continue to be evaluated on a yearly basis by taking all qualified fee title comparable sales in each zone to set a weighted cost per acre like the methodology in the financial analysis updates prior but excluding any outliers (costs above or below 3 standard deviations of the mean).
This fee model update also revises the fee title/easement valuation percentage method for determining the cost of easement acquisition in the model to be lowered to 55% with a mid-term cycle review during the five-year term between updates, based on the easement data collected by SJCOG, Inc. staff.
Table 2- Financial Subcommittee and Consultants
John Beckman, BIA of the Great Valley
Dan Gifford, Conservation
Hailey Donaldson/Mia Bianchi, CA Department of Fish and Wildlife, HCP Representatives SJCOG, Inc. staff (Steven Mayo, Laurel Boyd)
Legal Counsel for SJCOG, Inc.: Andy Pinasco & Tooba Naveed, Neumiller & Beardslee Consultant for SJCOG, Inc.: Carlos Villarreal & James Edison, Willdan Consultant for SJCOG, Inc.: Doug Leslie, ICF
The model update results in a 15.1% increase in the Agricultural/Natural Habitat types of Category A (Acquisition) component to be $11,056.00. The reason for the increase is the rise in comparable fee title land sale values.
Category B (assessment & enhancement) – Refined Cost Factors The recommended changes to this category include updated and refined cost factors for biological site assessment, preserve enhancement and management planning, and preserve enhancement unit costs. These unit costs reflect current assessment of enhancement practices for different types of preserve lands. In addition, the updated analysis redistributes preserve acres between grasslands and agricultural land types to more accurately reflect the mitigation purposes described in the adopted SJMSCP with the application of California CPI as an adjustment mechanism.
However, the total cost for Category B is also a function of the SJMSCP Annual Report data updated annually with the acres remaining to be acquired and the number of years remaining in the permit term. The fee per acre is a function of those total calculated costs and the land conversion acres remaining.
The model update results in a 2% increase in the Agricultural/Natural Habitat types of Category B (Assessment & Enhancement) component to be $6,185.00.
Category C (Management, Monitoring & Administration) – Refined Cost Factors/Long Term Investment
The recommended changes to this category include refined monitoring cost factors and updated management and administration cost factors that are based on analysis of SJCOG, Inc. spending in these categories. The update includes refinement of the postpermit endowment costs and continuing with a more robust diversified endowment investment strategy for a higher return on investment yield that provides for a net annual yield of 3.66% after absorbing inflation and management costs.
Annual cost updates will continue to use the California Consumer Price Index (CPI), as reported by the California Department of Finance, for the preceding 12-month fiscal year (e.g. June – June) to keep up with inflation on an annual basis.
The model update results in a 23.3% decrease in the Agricultural/Natural Habitat types of Category C (Management, Monitoring & Administration) component from prior years to be $627.00.
In summary, the 2026 SJMSCP fees (Attachment 2 - SJMSCP Cost and 2026 Fee Analysis) are calculated using the updated financial analysis formula model as displayed in the graphic below:
Table 4 below shows the proposed 2026 SJMSCP development fees in each habitat type category. The overall result in the fee analysis is an 8.3% increase in the most impacted classifications (Agricultural and Natural Habitat Classifications) fees for 2026.
Table 4 - 2026 SJMSCP Development Fees - Proposed
Habitat Type Category A Category B Category C Total Fee Rounded Fee Other Open Space $5,528 .00 $3,093.00 $314.00 $ 8,935.00 $8,935 Ag/Natural Lands $11,056.00 $6,185.00 $627.00 $17,868.00 $17,868 Vernal Pool
Grasslands $55,474.00 $15,764.00 $1,424.00 $72,662.00 $72,662 Vernal Pool Wetted $54,519.00 $127,980.00 $1,395.00 $183,894.00 $183,894 COMMITTEE ACTIONS:
Habitat Technical Advisory Committee (HTAC): Recommend Approval Management & Finance: Information
Exec Committee: Information
NEXT STEPS:
Should the staff recommendation be approved by the SJCOG, Inc. Board at the September 25th Board meeting, staff will work with local jurisdictions to adopt the 2026 SJMSCP development fees pursuant to the newly adopted financial analysis model.
ATTACHMENTS:
1. 2026 Fee Study Property List
2. SJMSCP Cost and 2026 Fee Analysis Model
Prepared by: Steven Mayo, Program Manager
Attachment 1 – 2026 Fee Study Property List - Props 24 Month 3 Stand Dev Attachment 2 – SJMSCP Cost and 2026 Fee Analysis Model