St. Helena City Council
October 8, 2024

 
















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abCAEab GLWNKClLrJVJV]wScVNXLiTLcNWHcZNVdfLVdLcZE^EEDg_A g[gFA abCAEaFjHScLcZNVdnNZWLcZ[GLWNKE^EEbF_A E[FAh
abCAE`b GHdLKGNtLcZ[GLWNKNVdjKNZWJXE^EEaA_h `[g`h abCAE`FjNWWLcVUNtLcZ[GLWNKNVdjKNZWJXE^EEbF_` g[aab abCAEhbwHSVdcPGHKdNVdnHcLUNtLcZE^EEaE_A b[AEA abCAEhF GHKdJV][nHcLUNtJV][NVdnNZWJV]GNXYJVLeLWWLcZ[iTLcNWHcZ[NVdfLVdLcZ[GLE^WbNEKaNhV_A djKNZWJXA[`aa abCAEgb GSKWJTKLGNXYJVLfHHKeLWWLcZ[iTLcNWHcZ[NVdfLVdLcZ[GLWNKNVdjKNZWJXE^bhaF_A A[`Bh abCAbbbfHHKNVdoJLGNtLcZE^EBD`_h b[aaF
abCAbFb sLKdLcZ[nSWWLcZ[eHKdLcLcZ[NVdxcNyLcZE^aAgh_a B[F`` abCAbFF sLKdJV][eHKdLcJV][NVdxcNyJV]GNXYJVLeLWWLcZ[iTLcNWHcZ[NVdfLVdLcZ E^EAAh_a F[BBF abCAbBb MLNWfcLNWJV]QRSJTULVWeLWWLcZ[iTLcNWHcZ[NVdfLVdLcZ[GLWNKNVdjKNZWJX E^EbEg_a E[ADB abCAbBFuNPHSWsHctLcZ[GLWNKNVdjKNZWJXE^EEFg_` E[gaE abCAbBDjKNWJV]GNXYJVLeLWWLcZ[iTLcNWHcZ[NVdfLVdLcZ[GLWNKNVdjKNZWJXE^Ebg`_A `[EgD abCAbBAfHHKvcJVdLcZ[wJKLcZ[NVdeYNcTLVLcZE^EE`g_A g[bD` abCAbBB GLWNKsHctLcZNVdjKNZWJXsHctLcZ[qKKiWYLcE^EFDb_A a[FhE abCabbbjcLTcLZZfLXYVJXJNVZNVdsHctLcZE^EEag_a E[ggh Agenda Item #11.1.

 
















!"#$%&'())*+ ,-./0-1 /234#5 6#78.59/2*7,5- ":5.,.,;+#<./,-/*#2 =(<
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ABCSQVDm[PKkOo[GHKMNKFOIPFLOHYfKHYKFLQRQQQDTV WUS_S ABCSQABmKnKFLUpOHYQRQQBQTW AUVVW
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ABC^B^_pKeNKFLCCEFPYaoIGPH\PF]KFLQRDSAQTV SU^_^ ABC^B^^EFPYaoIGPH\PF]KFLUueeMI[KFQRDlQQTV ^UAVW AWCDQBBuGFeGHKEGePILUdPNGePILUOHYZeGJ[IsHJGHKKFLQRQQQSTD SDUWVW AWCDQBDdPiiKFoGOeEGePILQRQBQVTB V_UBD_
AWCWQBB uitaeOHoKcFGrKFLOHYuIIKHYOHILUsgoKNIsiKFJKHobkKYGoOefKo[HGoGOHL QRQQQ_TW ^UWSS AWCWQWBcFGrKF}mOeKL\PF]KFLQRQA^ATV SU^DQ
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Agenda Item #11.1.

 

















!"#$%&'())*+ ,-./0-1 /234#5 6#78.59/2*7,5- ":5.,.,;+#<./,-/*#2 =(<
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@ 6#
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ABCAD[[\PK^dJHPQSePJKQMfK^MJHDWDDEEYZ aNZ[D
ABCADE[_PgRPKQHNePRMHNPQShK^dRHd`iPRMJjMHHM^HDWDDEXY[ [BNDEk ABCADEE edRdJldPRfgMJPRdJHDWDD[DYZ ANcEa
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ABCZDA[OJPQHgdJRPRKdQTQHgMURdJHDWDDBEYc ANZA[
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ABCcDB[IJMSnMfgMJPRdJHDWDD[XYc [NccD
ABCcDa[tdKHRPQSiKQU]fgMJPRdJHDWDDDZYA [NaZX
ABCcDA[TQSGHRJKP^OJGUpPQSOJPURdJfgMJPRdJHDWaEDZYA DNAcB ABCcDZ[_^MPQMJHd`jM]KU^MHPQSmuGKgrMQRDWDXkZYa DNDka ABCcDZEoPldJMJHPQSvJMKn]RN\RdUpNPQSePRMJKP^edLMJHNtPQS[Wk[kXYa BNXDk ABCcDZB ePU]KQMvMMSMJHPQSf``lMPJMJHDWDAakYa AN[ZE ABCcDZahPUpMJHPQShPUpPnMJHNtPQSDWacBBYB ZNkXB ABCcDZA\RdUpMJHPQSfJSMJvK^^MJHDWBAcAYa ENE[c
ABCcDcEhGrgfgMJPRdJHNmbUMgRiM^^]MPShGrgMJHDWDDaZYA XNaDX ABCcDX[wM`GHMPQSwMUVU^Pl^MePRMJKP^_d^^MURdJHDW[EckYZ aNaZA ABCc[E[OPQp_PJNOJGUpNPQS\]KgodPSMJHDWDD[aYA XNDaa ABCc[kk ePRMJKP^edLKQnidJpMJHNq^^fR]MJDWDDXDYa kNcZ[ \dGJUMHx_qmIINfUUGgPRKdQP^mrg^dVrMQRyePVEDEEz{iPnMyEDEBC[HR|GPJRMJzIPRPW  
Agenda Item #11.1.

 
















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Agenda Item #11.1.

 
















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Agenda Item #11.1.

APPENDIX

CITY OF ST HELENA

AFFORDABLE HOUSING

DEVELOPMENT IMPACT FEE

FINANCIAL FEASIBILITY ANALYSIS
OCTOBER 1, 2024
Oakland Office Corporate Office Other Regional Offices
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Tel: (510) 832-0899 Tel: (800) 755-6864 Plano, TX
Fax: (888) 326-6864 Seattle, WA
Washington, DC
Agenda Item #11.1.

www.willdan.com
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Agenda Item #11.1.

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TABLE OF CONTENTS
EXECUTIVE SUMMARY............................................................................2 Methodology Overview 3

1. INTRODUCTION .............................................................................6 Purpose 6
Assumptions 6

2. FEASIBILITY ANALYSIS...................................................................7 Feasibility Analysis Methods 7
Land Residual Analysis 7
Structure and Inputs 8

3. IMPACT ON LAND VALUE..............................................................10 Factors Affecting Feasibility 10
Feasibility Results 11

4. APPENDIX ..................................................................................12 Appendix A: Proposed Affordable Housing Impact Fees 12
Appendix B: Development Prototype Pro Formas 13
Agenda Item #11.1.

2 Executive Summary
The primary purpose of this report is to estimate the impact on development financial feasibility of the imposition of an affordable housing fee by the City of St. Helena. The analysis examines the economics of six prototypes:

In a nexus study, dated May 22, 2024, Willdan has calculated the maximum justified for each development type and included them in the pro forma analysis contained in this report. These fees are detailed in the tables below. The table includes both the maximum justified fees as well as two alternatives of reduced fees presented earlier to accommodate project feasibility.

Table 1
Development Prototypes
St. Helena Feasibility Analysis
SF
Residential
MF
Residential Office Retail
Industrial/
Warehouse Hotel
Density (FAR) 0.29 0.76 0.28 0.33 0.17 0.13
Density (Units/Acre) 33
Form Factor single 3-5 stories 1 story 1 story 1 story Multi Residential Units/Rooms 1 33 65
Unit/Room Size 3,780 1,000 500
Residential SF 3,780 33,000 32,500
Commercial SF 3,597 2,847 1,500 21,097
parcel size (acres) 0.3 1 0.30 0.2 0.2 9.72
Willdan Financial Services, 2024
Agenda Item #11.1.

City of St. Helena Development Impact Fee Financial Feasibility Analysis 3 Methodology Overview
The financial feasibility analysis uses a pro forma approach to calculate the projected return that the six development prototypes are likely to generate. Each protype’s pro forma estimates the residual land value, a method of estimating the value of land for a project that calculates the total revenue generated by a project (either in the form of sales price or the present value of projected lease income) and subtracts the costs of developer and operations (as applicable) to arrive at a net amount that is attributable to the land under the project. The analysis assumes that all development protypes are rental or lease property, except for the single-family prototype.

The analysis assumes that if a residual land value is negative, the project is not feasible.

A low land value means a project is challenging to develop and may not be feasible.

Willdan and staff have reviewed transactions in St. Helena in the past ten years and estimate that a value below $25 per square foot (psf), or $1.1 million per acre, indicates a low feasibility and low probability of completion for the prototype development in question. This number can vary by land entitlement, with generally higher valuations for single family land and downtown parcels, and lower values for industrial and other less intensive uses.

Table 2
Proposed Fees (per square foot, except where noted)
St. Helena Feasibility Analysis
Maximum
Justified
Max Estimated
Feasibility (1) 15% of Max 10% of Max
Residential
Rental Unit $135 NA $20 $14
For Sale Unit $196 $168 $29 $20
Non-Residential
Hotel (per room) $41,797 $41,797 $6,270 $4,180
Commercial $141 $20 $21 $14
Office $176 NA $26 $18
Industrial $67 NA $10 $7
(1) Max Estimated Fee at $1.1 million per acre residual value.

Willdan, 2024
Agenda Item #11.1.

City of St. Helena Development Impact Fee Nexus Study Update 4 As shown in Table 3 below, considering the $1.1 million benchmark described above, the analysis finds that single family residential, hotel and retail development appear feasible in current market conditions, and multifamily and office development are near the threshold of feasibility. Industrial uses appear infeasible, although industrial may in fact be feasible given that it typically has lower land valuations to meet. It is important to note that this feasibility analysis reflects current market conditions, and especially the historic increases in construction costs during and after the COVID epidemic. Willdan expects that market factors will return to a more historic balance in the future and that other development types will become feasible. It is also important to note that this analysis reflects a very generalized example, and that individual projects have their own economics and may in fact be feasible even in current market conditions.

Table 3 also shows the per acre cost of the 10%, 15% and 100% affordable housing fee alternatives to evaluate their effect on feasibility. It appears that the affordable housing fee would make little difference to feasibility for single family development but could pose a significant burden to the feasibility of retail. Office, MF residential and Industrial would be rendered even more infeasible, although the relative burden on industrial is small enough that it might make little material difference. For each development category the analysis has also calculated the maximum fee per acre, given the threshold value of $1.1 million.

The residual land values are affected by each of the inputs and assumptions contained in the pro formas and are particularly sensitive to capitalization rates, parking requirements, construction costs, and lease rates. The analysis identified reasonable ranges for these factors, given current market conditions, and tested the sensitivity to the factors to financial feasibility for each of the prototypes.

Table 3
Residual Value Summary
St. Helena Feasibility Analysis
Item
SF
Residential
MF
Residential Office Retail
Industrial/
Warehouse Hotel
Residual Land Value Per Acre 3,213,756 928,200 893,627 1,386,326 568,714 1,713,457 Residual Land Value Per land SF $74 $21 $21 $32 $13 $39 Porential Fees
10% Fee Per Acre $246,960 $646,800 $211,024 $200,714 $50,250 $27,951 15% Fee Per Acre $370,440 $970,200 $316,536 $301,070 $75,375 $41,926 100% Fee Per Acre $2,469,600 $6,468,000 $2,110,240 $2,007,135 $502,500 $279,507 Max Fee at Threshold $2,113,756 NA NA $286,326 NA $613,457 Willdan, 2024
Agenda Item #11.1.

City of St. Helena Development Impact Fee Nexus Study Update 5 Willdan believes it is important to consider that the impact fees are a cost recovery mechanism, not an assessment or tax. The impact fees are a calculation of the costs incurred by the City to provide affordable housing in connection with development. At the full calculated fee, the City “breaks even” on the revenue received and the costs of new facilities needed to serve development. Any reduction of the fees results in the need to outside revenues to make up the difference or a reduction in the provision of affordable housing. This analysis examines the proposed fees in comparison to estimated project feasibility, but that does not mean that the fees are responsible for the feasibility of projects, or that they should be set at a level that assists project feasibility.

This is a policy judgement to be made by elected officials, with the input of members of the community and other stakeholders.

Agenda Item #11.1.

City of St. Helena Development Impact Fee Nexus Study Update 6 1. Introduction
Purpose
The primary purpose of this report is to analyze the effect on financial feasibility of the proposed updated impact fees on six residential and commercial prototypes. These prototypes are summarized in Table 1, below:
• Residential: For-Sale Townhomes/Single-Family Detached • Multifamily: Multifamily Residential/3-5 Story Building • Office/single story building
• Retail / single story building
• Industrial (warehouse)/Single Story Building
• Hotel (65-room resort hotel)
The Nexus Study calculates the maximum justified fee that will be considered by the City Council. The nexus study documents the necessary data and calculations to establish nexus and proportionality.

Assumptions
The financial feasibility analysis assumes all development prototypes are rentals or leases, except for single-family residential. The analysis includes other assumptions about the development prototypes which are documented in Table 4 and individual pro formas in the Appendices.
.

Agenda Item #11.1.

City of St. Helena Development Impact Fee Nexus Study Update 7 2. Feasibility Analysis
The feasibility analysis of St. Helena’s proposed development impact fees uses a pro forma approach to calculate the projected financial return that six development prototypes are likely to generate for developers. The analysis assumes a standard set of assumptions and then estimate potential revenues, costs and a net financial return for the real estate developer.
.

Feasibility Analysis Methods
In classical real estate economics, development value is created when existing land or buildings can be improved by the investment of financial capital. Two main types of financial calculations are used by developers and policy makers to understand the financial feasibility of a particular development concept or project. The first and simplest type of financial feasibility analysis can be expressed by this basic equation:

Development Value – (Development Costs + Land) = Profit In this case profit can be expressed as total dollars or more typically as a percent return on money invested or costs. Assuming a positive return, this percent return is then compared to typical returns in the marketplace to assess the viability of a particular development versus other potential investment and development opportunities.

The second type of financial feasibility analysis is called a “land residual method” and can be expressed by the following simple equation:

Development Value – (Development Costs + Profit) = Land Residual This type of analysis is often preferred by urban economists as a means of clarifying the value generate by a proposed project under different planning and development scenarios and with validated cost and revenue assumptions. Assuming that the land residual is positive, the land value created by a development is compared to recent land sales for comparable parcels of land to further evaluate the relative feasibility of the development concept compared to other opportunities in the marketplace. Effectively, the land residual is the amount the developer can afford to pay for the land. If this amount is above prevailing land costs, the project is generally feasible.

This analysis uses the land residual method for determining financial feasibility. .

Land Residual Analysis
As a policy tool for helping to understand the potential for value capture related to new zoning and/or planning permissions in each area, a land residual methodology is often a Agenda Item #11.1.

City of St. Helena Development Impact Fee Nexus Study Update 8 preferable approach for illustration the potential increase in underling land values associated with different policy interventions. This report uses a land residual analysis to estimate the value of land for each of the six development prototypes that relies on the net operating income and value of improvements.

Structure and Inputs
Table 4 details the key assumptions used as inputs into the pro forma model, as well as a summary of calculated residual land values.

Agenda Item #11.1.

City of St. Helena Development Impact Fee Nexus Study Update 9 Table 4
Feasibility Model Assumptions
St. Helena Feasibility Analysis
SF Residential MF Residential Office Retail Industrial Hotel Development/Construction Costs ($/sf)
Residential Construction Costs 240 310
Commercial Construction Costs 250 250 125 650
Commercial Tenant Improvements (PSF) Landlord Allowance 50 75 0 0 Soft Costs
Soft Costs (% of hard costs) 25.00% 25.00% 25.00% 25.00% 25.00% 25.00% Developer Profit 12.00% 12.00% 12.00% 12.00% 12.00% 12.00% Vacancy Rate
Residential Vacancy NA 5.00%
Commercial Vacancy 5.00% 2.50% 5.00% 20.00%
Operating Expenses (% of revenue)
Residential Operating Expenses NA 25.00%
Commercial Operating Expenses 20.00% 20.00% 15.00% 25.00% Financing
% of Construction Cost 5.0% 5.0% 5.0% 5.0% 5.0% 5.0%
Revenue
Residential Lease Rate (psf) $2.60
Commercial Lease Rate (psf) $3.30 $3.40 $2.00
For Sale Market Rate Residential Price Per Unit $2,457,000 Commercial Cap Rate 7.00% 7.00% 7.00% 8.00%
Residential Cap Rate 5.50%
Hotel ADR $1,000
hotel occupancy 80%
hotel revpar $800
Results: Residual Land Values (per acre)
Residual Land Values $3,213,756 $928,200 $893,627 $1,386,326 $568,714 $1,713,457 Willdan, 2024
Agenda Item #11.1.

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3. Impact on Land Value
The residual land values are affected by each of the inputs and assumptions contained in the pro formas, and are particularly sensitive to capitalization rates, parking requirements, construction costs, and lease rates. However, in all cases the impact fees charged by the City do not have a major effect on feasibility, and in no case do they transform a prototype project from feasible to infeasible.

Factors Affecting Feasibility
If a residual land value is negative, the project is not feasible. Alternatively, low land values indicate a low feasibility for a project. Willdan estimates that generally land values below $25 per square foot indicate a low feasibility and low probability of completion for the prototype developments.

A developer’s selection of real estate product type and location depends on various factors. The past, current, and projected future demand for a certain prototype in the area are weighed against the existing and projected future supply of these development types in the local and surrounding areas.

Potential factors affecting financial feasibility include the following:
• Capitalization rate – lower capitalization rates increase financial feasibility. Based on current and anticipated market conditions and assessment of relative market risk associated with St. Helena, this analysis assumes capitalization rates of 7.0 percent for non-residential development and 5.5 percent for multifamily residential development. • Construction costs – lower construction costs increase financial feasibility. Based on current market conditions, this analysis assumes base construction costs of $250 per square foot for retail and office development, $240 per square foot for residential development, $310 per square foot for multifamily development, and $125 per square foot for industrial developments.
• Operating expenses – operating costs include utilities, common area maintenance, security, and property taxes. The financial feasibility analysis uses 25% of revenue for multifamily residential and 15 to 20% for commercial prototypes. • Lease rates – higher lease rates and dependent on building features and market conditions but increase financial feasibility. Based on current and expected market conditions, this analysis assumes a lease rate of between $2.60 per square foot for residential development, $3.30 per square foot for office development, $3.40 per square foot for retail development, and $2.00 per square foot for industrial development. • Tenant improvement costs – passing improvement costs to tenants or amortizing costs increase financial feasibility. This analysis assumes a commercial tenant improvement landlord allowance of $50 psf for office and $75 psf for retail developments. • Profit margin – lower profit margins return less to developers but increase apparent financial feasibility of a project. This analysis assumes a developer profit of 12 percent (of costs) on each development project.
• Density – the floor area ratio (FAR) of a development project affords financial feasibility because it allows for a higher number of square feet of development on a given parcel.

There is a tradeoff, however, in that a higher FAR can result in a change in construction type which can lead to higher costs per square foot. The analysis assumes varying FARs to explore this dynamic.

Refer to Table 4 for a master list of pro forma inputs and assumptions.

Agenda Item #11.1.

City of St. Helena Development Impact Fee Feasibility Study 11 Feasibility Results
The residual land values are affected by each of the inputs and assumptions contained in the pro forma and are particularly sensitive to capitalization rates, parking requirements, construction costs, and lease rates. The analysis identified reasonable ranges for these factors, given current and likely market conditions, and tested the sensitivity of the factors of financial feasibility for each of the six development prototypes.

As shown in Table 3, above, initial results indicate that some of the development types are feasible under current market conditions, and that single family development, retail development and hotel development appear able to bear the burden of an affordable housing impact fee to varying degrees.

Agenda Item #11.1.

City of St. Helena Development Impact Fee Feasibility Study 12 4. Appendix
The appendix provides detailed and supporting tables for the summary analysis described above.

Appendix A: Proposed Affordable Housing Impact
Fees
The following tables detail the maximum justified fees for the City calculated in the recent Nexus Study, dated May 22, 2024.
.

Table A.1
Proposed Fees (per square foot, except where noted)
St. Helena Feasibility Analysis
Maximum
Justified
Max Estimated
Feasibility (1) 15% of Max 10% of Max
Residential
Rental Unit $135 NA $20 $14
For Sale Unit $196 $168 $29 $20
Non-Residential
Hotel (per room) $41,797 $41,797 $6,270 $4,180
Commercial $141 $20 $21 $14
Office $176 NA $26 $18
Industrial $67 NA $10 $7
(1) Max Estimated Fee at $1.1 million per acre residual value.

Willdan, 2024
Agenda Item #11.1.

City of St. Helena Development Impact Fee Feasibility Study 13 Appendix B: Development Prototype Pro Formas
Single Family

DEVELOPMENT PROGRAM ASSUMPTIONS ASSUMPTION/FACTOR TOTAL Development Site (Square Feet) 0.3 Acres 13,068
Dwelling Units 3.3 DU/Acre 1
Gross Building Area (Square Feet) 3,780 GBA/DU 3,780
Net Habitable Square Feet 100% 3,780

BUILDING INCOME AND VALUE ASSUMPTION/FACTOR PER GBA TOTAL Net Operating Income (NOI) $0 $0
Project Market Value $2,457,000 per DU $650 $2,457,000
Project Sale Cost 7.0% Value 46 171,990
Net Project Value $605 $2,285,010

PROJECT DEVELOPMENT COSTS ASSUMPTION/FACTOR PER GBA TOTAL Construction Cost
Building Direct Cost (includes site development) $240 Cost/SF (GBA) $240 $907,200 Total Construction Cost $240 $907,200
Soft Costs
Financing 5% of Construction Costs $12 $45,360
Other Soft Costs 25% of Construction Costs $60 $226,800 Total Soft Costs $72 $272,160
Other Project Costs
Developer Return on Investment 12% of Construction & Soft Costs $141,523 Residual Land Value Model Output/Supportable Land Cost $964,127 Total Other Costs $1,105,650
Total Project Cost (including land) $2,285,010
Residual Land Value $964,127
Per Acre $3,213,756
10% Affordable Housing Fee $20 psf $74,088
per acre $246,960
Willdan, 2024
Agenda Item #11.1.

City of St. Helena Development Impact Fee Feasibility Study 14 Multifamily

DEVELOPMENT PROGRAM ASSUMPTIONS ASSUMPTION/FACTOR TOTAL Development Site (Square Feet) 1 Acres 43,560
Dwelling Units 33 DU/Acre 33
Gross Building Area (Square Feet) 1,000 GBA/DU 33,000
Net Rentable Square Feet 85% 28,050

BUILDING INCOME AND VALUE ASSUMPTION/FACTOR PER GBA TOTAL Gross Potential Rent $2.60 per SF/Month $27 875,160
Gross Potential Parking Income 0 per Space/Month
Losses to Vacancy 5% of Gross Income ($1) (43,758)
Gross Residential Revenue 831,402
Basic Operating Expenses 25% of Gross Potential Rent ($7) (218,790) Total Operating Expenses (218,790)
Net Operating Income (NOI) $19 $612,612
Project Market Value 5.50% Cap Rate $0 $11,138,400
Project Leasing Cost (included in operating costs) 0.0% Value $0 $0.0 Net Project Value $0 $11,138,400

PROJECT DEVELOPMENT COSTS ASSUMPTION/FACTOR PER GBA TOTAL Construction Cost
Building Direct Cost (includes site development) $250 Cost/SF (leaseable area) $213 $7,012,500 Total Construction Cost $213 $7,012,500
Soft Costs
Financing 5% of Construction Costs $11 $350,625
Other Soft Costs 25% of Construction Costs $53 $1,753,125 Total Soft Costs $64 $2,103,750
Other Project Costs
Developer Return on Investment 12% of Construction & Soft Costs $1,093,950 Residual Land Value Model Output/Supportable Land Cost $928,200 Total Other Costs $2,022,150
Total Project Cost (including land) $11,138,400
Residual Land Value $928,200
per acre $928,200
10% affordable housing fee $20 $646,800
per acre $646,800
Willdan, 2024
Agenda Item #11.1.

City of St. Helena Development Impact Fee Feasibility Study 15 Retail

DEVELOPMENT PROGRAM ASSUMPTIONS ASSUMPTION/FACTOR TOTAL Development Site (Square Feet) 0.20 Acres 8,712
FAR 0.33
Gross Building Area (Square Feet) 14,235 GBA/Acre 2,847 Net Leaseable Square Feet 100% 2,847

BUILDING INCOME AND VALUE ASSUMPTION/FACTOR PER GBA TOTAL NNN Potential Rent $3.40 per SF/Month $41 $116,158
Losses to Vacancy 3% of Gross Income ($1) ($2,904)
NNN Commercial Revenue $113,254
Basic Operating Expenses 0% of Gross Potential Rent $0 $0 Additional Operating Expenses (TDM) 0 Per Year 0 0
Total Operating Expenses $0
Net Operating Income (NOI) $40 $113,254
Project Market Value 7.00% Cap Rate $0 $1,617,909
Project Leasing Cost 6.0% Value $0.0 $97,075
Net Project Value $0 $1,520,835

PROJECT DEVELOPMENT COSTS ASSUMPTION/FACTOR PER GBA TOTAL Construction Cost
Building Direct Cost (includes site development) $250 Cost/SF (leaseable) $250 $711,750 Tenant Improvements $50 cost/sf (leaseable sf) $50 $142,350 Total Construction Cost $300 $854,100
Soft Costs
Financing 5% of Construction Costs $15 $42,705
Other Soft Costs 25% of Construction Costs $75 $213,525 Total Soft Costs $90 $256,230
Other Project Costs
Developer Return on Investment 12% of Construction & Soft Costs $133,240 Residual Land Value Model Output/Supportable Land Cost $277,265 Total Other Costs 410,505
Total Project Cost (including land) 1,520,835
Residual Land Value 277,265
per acre $1,386,326
10% affordable housing fee $14 $40,143
per acre $200,714
Willdan, 2024
Agenda Item #11.1.

City of St. Helena Development Impact Fee Feasibility Study 16 Industrial

DEVELOPMENT PROGRAM ASSUMPTIONS ASSUMPTION/FACTOR TOTAL Development Site (Square Feet) 0.2 Acres 8,712
FAR 0.17
Gross Building Area (Square Feet) 7,500 GBA/Acre 1,500
Net Leaseable Square Feet 100% 1,500

BUILDING INCOME AND VALUE ASSUMPTION/FACTOR PER GBA TOTAL Gross Potential Rent $2.00 per SF/Month $24 $36,000
Losses to Vacancy 5% of Gross Income ($1) ($1,800)
Gross Residential Revenue $34,200
Basic Operating Expenses 15% of Gross Potential Rent -$4 -$5,400 Total Operating Expenses -$5,400
Net Operating Income (NOI) $19 $28,800
Project Market Value 7.00% Cap Rate $0 $411,429
Project Sale Cost 6.0% Value $0.0 $24,685.7
Net Project Value $0 $386,743

PROJECT DEVELOPMENT COSTS ASSUMPTION/FACTOR PER GBA TOTAL Construction Cost
Building Direct Cost (includes site development) $125 Cost/SF (leaseable area) $125 $187,500 Tenant Improvements $0 cost/sf (leaseable sf) $0 $0
Total Construction Cost $125 $187,500
Soft Costs
Financing 5% of Construction Costs (incl. site) $6 $9,375 Other Soft Costs 25% of Construction Costs (excl. site) $31 $46,875 Total Soft Costs $38 $56,250
Other Project Costs
Developer Return on Investment 12% of Construction & Soft Costs $29,250 Residual Land Value Model Output/Supportable Land Cost $113,743 Total Other Costs $142,993
Total Project Cost (including land) $386,743
Residual Land Value $113,743
per acre $568,714
10% Affordable Housing Fee $7 $10,050
per acre $50,250
Willdan, 2024
Agenda Item #11.1.

City of St. Helena Development Impact Fee Feasibility Study 17 Hotel

DEVELOPMENT PROGRAM ASSUMPTIONS ASSUMPTION/FACTOR TOTAL Development Site (Square Feet) 9.72 Acres 423,403
FAR 0.13
Rooms 65.00
Gross Building Area (Square Feet) 5,514 GBA/Acre 53,597 Net Leaseable Square Feet 100% 53,597

BUILDING INCOME AND VALUE ASSUMPTION/FACTOR REFERENCE TOTAL ADR $1,000 /night
Occupancy 80%
Gross Potential Room Revenue $18,980,000 annually $18,980,000 $18,980,000 Ancillary Income 80.00% % of Room Revenue 15,184,000
Gross Revenue $34,164,000
Overall Exp. 62.0% of Gross Revenue $21,181,680
Room Operations 18.0% of Room Revenue $3,416,400
Other Op Exp 27.5% of Ancillary Revenue $4,175,600
Total Operating Expenses $28,773,680
Net Operating Income (NOI) $5,390,320
Project Market Value 8.00% Cap Rate $0 $67,379,000
Net Project Value $0 $67,379,000

PROJECT DEVELOPMENT COSTS ASSUMPTION/FACTOR REFERENCE PER GBA TOTAL Construction Cost
Building Direct Cost (includes site development and improvments) $650 Cost/SF $650 $34,838,050 Total Construction Cost $650 $34,838,050
Soft Costs
Financing 5% of Construction Costs (incl. site) $33 $1,741,903 Other Soft Costs 25% of Construction Costs (excl. site) $163 $8,709,513 Total Soft Costs $195 $10,451,415
Other Project Costs
Developer Return on Investment 12% of Construction & Soft Costs $5,434,736 Residual Land Value Model Output/Supportable Land Cost $16,654,799 Total Other Costs $22,089,535
Total Project Cost (including land) $67,379,000
Residual Land Value $16,654,799
per acre $1,713,457
100% Affordable Housing Fee $41,797 $2,716,805
per acre $279,507
Willdan, 2024
Agenda Item #11.1.

May 9, 2024
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Willdan Financial Services Responses to Comments on the Affordable Housing and Commercial Linkage Fee Nexus Study
Comments From Jennifer La Liberte

1. When is this item scheduled to go to City Council, and when will the staff report be published? This item is scheduled for the City Council meeting on May 14, 2024.

2. Can the City provide a prototype comparison of the proposed Affordable Housing Impact Fee, which is in dollars per square foot, with the current fee, which is a percentage of construction costs? It seems that would be helpful for the decision makers as well as the public.

Willdan has prepared a fee comparison comparing the City’s current fees to the maximum justified fee schedule and other Napa County cities. Table 1 below shows the residential housing fee comparison, and Table 2 displays the commercial linkage fee comparison.

ATTACHMENT 3
Agenda Item #11.1.

May 9, 2024
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Tabe 1: Residential Affordable Housing Fee Comparison
American
Canyon Napa Cloverdale Cotati Healdsburg
Rohnert
Park
Santa Rosa
(Inside
Downtown)
Santa Rosa
(Outside
Downtown) Sebastopol1
St. Helena
Current
St. Helena -
Maximum
Justified
Fee Schedules
Per Square Foot
Single Family, Townhouse 3.43 4.75 - - - - - 22.24 -
Stacked Flats, Apartment 3.98 4.05 - - - - - 22.24 -
0 to 909 square feet - - - - - 4.00 2.00 22.24 -
910 square feet or above - - - - - 8.00 3.00 22.24 -
Rental Unit - - - 2.15 4.02 - - 22.24 135
For Sale Unit - - - 16.70 - - - 22.24 196
-
Per Unit
Studio $ 24,000
1 Bed $ 27,400
2 Bed $ 30,900
3 Bed $ 34,300
4 Bed $ 37,000
5 Bed $ 39,800
For Sale Unit $ 15,520
Fees for Prototype Units
Single Family, 2,761 square feet,
3 bedrooms $ 9,470 $13,115 $ 34,300 $ 33,400 $ 46,109 $ 15,520 $ 22,088 $ 8,283 $ 61,405 $ 22,500 $ 541,156 Single Family, 3,780 square feet,
5 bedrooms 12,965 17,955 39,800 41,400 63,126 15,520 30,240 11,340 84,067 27,500 740,880 Based on
sales price of
unit, calculated
as follows:
$2,400 first
$125,000 of
sales price
+$200 for each
$5,000
increment
thereafter
The housing
in-lieu fee
shall be
charged on a
percentage
basis of the
projected
construction
costs of
market rate
dwelling
units.
1 No in-lieu fee is required for less than 4 dw elling units. For 5 or more dw elling units, on-site inclusionary housing is required: https://sebastopol.municipal.codes/SMC/17.250 If there is a decimal fraction unit requirement, an in-lieu fee shall be provided equal to the applicable decimal fraction times the established in-lieu fee for one inclusionary unit (based on the average size of the units being built), or, at the developer’s discretion, an inclusionary unit may be provided.

Agenda Item #11.1.

May 9, 2024
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Table 2: Commercial Linkage Fee Comparison
Land Use
Category
American
Canyon Calistoga1 Napa Yountville Cotati2 Petaluma3
Rohnert
Park3
Santa
Rosa Sebastopol3 Sonoma
St. Helena -
Current
St. Helena
Maximum
Justified
Office $ 0.87 $ 2.63 $3.55 $ 11.60 $ 2.39 $ 3.36 $ 0.69 $ 3.00 $ 2.08 $ 4.00 $ 4.11 $ 176.08 Hotel 0.87 1,756.35 6.00 11.60 2.39 3.36 0.69 3.00 2.08 15.00 3.80 74.64 Retail 0.87 3.81 3.55 11.60 4.12 5.81 1.19 3.00 3.59 4.00 5.21 141.29 Industrial 0.57 1.93 3.50 11.60 2.47 3.46 0.71 3.00 2.15 n/a 1.26 66.66 All fees charged per square foot, except for Calistoga hotel fee, w hich is charged per room. 1 Calistoga hotel fee charged per room.
2 Hotel and office assumed charged at "commercial" rate. New construction less than 2,000 sf, and the first 2,000 sf of any commercial project is exempt. 3 Hotel and office assumed charged at "commercial" rate.

Agenda Item #11.1.

May 9, 2024
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3. Can the City provide an example of how much one or more of the current proposed hotel developments would generate in housing impact fees with the current fee and the proposed fee at the 10% and 15% levels, and compare that to what it would cost the developer to construct the number of affordable housing units that particular development will necessitate? Table 3 displays the potential commercial linkage fee revenue for a proposed hotel project, under the maximum justified fee schedule, the 15% and 10% scenarios. The current proposed hotel project is expected to be 75 rooms and 52,313 square feet.

For reference, the last hotel entitled included 62 rooms, and the City negotiated $3.4 M in payment towards affordable housing back in 2020 when housing costs were lower. It is the City’s policy to require a Development Agreement for all hotels to produce more housing production or larger funding than impact fees provide.

4. For the fee calculation on Table 1.11, how is the “Units Demanded” factor calculated? Or what is it based on?
Units demanded are identified in Tables 1.8 and 1.9. They are the number of units needed to house the employment generation needed to meet induced demand from the household spending of market rate households.

5. Has the City or consultant determined a maximum threshold a private development project can tolerate for the housing impact or in-lieu fee? If not, how did the consultant arrive at the 10% to 15% maximum for the proposed fee.

City staff recommended the 10% and 15% scenarios. A maximum threshold a private project can tolerate has not been determined, as it is subject to a wide variety of factors that vary from project to project and change according to market conditions. The 10% and 15% scenarios would make the fees more in line with the other Sonoma County cities in the fee comparison compared to the maximum justified fees.

Comments:

Table 3: Potential Hotel Fee Revenue
Square Feet 52,313
Maximum Justified Fee per Square Foot $ 75
Maximum Justified Fee $ 3,923,475
15% of Maximum Justified Fee 588,521
10% of Maximum Justified Fee 392,348
Agenda Item #11.1.

May 9, 2024
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1. It is a difficult balancing act to ensure the City can achieve a reasonable fee requirement while not discouraging private development. The City should identify and adopt incentives to encourage developers to include affordable housing in their developments that would be more attractive than writing a check to ensure affordable units actually get built.

The higher the fee, the greater the incentive for developer to incorporate affordable housing. A drawback of this approach is that some projects are limited in scale or other factors that make providing affordable housing problematic.

2. Toward the City’s goal to encourage housing, the City should consider adopting a policy that exempts affordable housing projects from paying impact and other fees, rather than requiring each project proponent to request a waiver, project by project. The City of Sacramento’s Zero-Dollar Rate Program For Affordable Dwelling Units is a good example to follow.

This is a common approach. Units that meet certain criteria (below market rate in perpetuity for a certain number of years) are frequently assessed reduced or exempt from paying impact fees. This is a policy decision, however, and therefore outside the scope of this fee study.

3. It would be helpful in the staff report to include a 10-year history of the Housing Impact Fee fund, how much has been paid, and how the funds have been utilized.

Table 4 displays the revenue and expenditure history of the housing impact fee fund.

Agenda Item #11.1.

May 9, 2024
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Table 4: Historical Affordable Housing Impact Fee Revenue and Expenses FY 13/14 FY 14/15 FY 15/16 FY 16/17 FY 17/18 FY 18/19 FY 19/20 FY 20/21 FY 21/22 FY 22/23 Totals Affordable Housing Impact Fees $884,027 $257,649 $427,649 $235,122 $ 80,340 $176,224 $317,631 $ 106,784 $ 2,226 $212,358 $2,700,009 Utilities - 684 McCorkle Ave $ 2,470 $ 2,314 $ 917 $ - $ - $ - $ - $ - $ (40) $ - $ 5,661 Maintenance - 684 McCorkle Avenue 2,488 750 - - - - - - - - 3,238 Property Taxes - 684 McCorkle Avenue 6,558 6,562 20 - - - - - - - 13,140 Title & Appraisal - 684 McCorkle Avenue - - 4,982 - - - - - - - 4,982 Napa Housing Authority - Housing Services 20,950 - - - - - - - - - 20,950 Affordable Housing Feasibility Study - 5,000 - - - - - - - - 5,000 Attorney Fees 4,424 5,388 21,848 91,550 19,754 20,472 - - (1,574) - 161,862 Brenkle Court Contributions - - 24,300 - 2,938 120,000 316,884 25,016 4,469 - 493,606 Turley Flats Contributions/Loan - - - 438 813,639 50,797 (50,336) 185,884 - 9,998 1,010,420 Our Town St. Helena | Non-Profit Grant - - - - - 10,000 25,000 - - - 35,000 Our Town St. Helena | 963 Pope Street - - - - - - 450,000 - 8,400 3,600 462,000 723 Hunt Avenue | CDBG Grant Reimbursement - - - - - - - 1,400,565 (1,400,565) - - Affordable Housing Fee Update - - - - - - - - 6,045 - 6,045 Housing Element Update - - - - - - - - 69,210 29,915 99,125 Total Expenses $ 36,890 $ 20,014 $ 52,066 $ 91,988 $836,331 $201,270 $741,548 $1,611,464 $ (1,314,054) $ 43,513 $2,321,029 Source: City of St. Helena.

Expenses
Revenues
Agenda Item #11.1.

May 9, 2024
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Comments from Mary Stephenson

1. What is the rationale for recommending 10% to 15% of maximum fees? This is a City staff recommendation. See response #5 above.

2. How many new housing starts (and renovation, if that is included in the fee structure) has the city had in the last 5-10 years? Projecting into the future with the recommended fee structure, what is the potential funding that new (and renovated if it applies) units could generate for the city? From 2015 to 2024 the City has added 29 net new residential dwelling units according to data from the California Department of Finance. Renovation is not included in the fee structure, unless the renovation is adding new square footage. Table 5 displays a projection of potential fee revenue, based on the growth projections from the City’s recently adopted development impact fee nexus study.

3. The current rents seem high to me. The rental rates include mostly single-family dwellings, which excludes a significant number of small multi-unit buildings that I think would illustrate a wider range of rentals.

The current rents were estimated based on all the available units that were advertised for rent at the time the study was completed. There were few multifamily units advertised for rent at that time. The only units that were excluded from the sample were luxury units with rents more than $10,000 per month. Further, many of the City’s existing multifamily units are rented at below market rate rents, so they do not accurately reflect current market rates.

4. Is the proposed fees for commercial development tied to past or projected development in each category? Is there an historical overview of commercial development by category that informs this? Table 5: Projected Affordable Housing and Commercial Linkage Fee Revenue Land Use
Projected
Increase (Sq.

Ft.)
Maximum
Justified Fee
per Square
Foot
Potential Fee
Revenue
(Maximum
Justified Fees)
Potential Fee
Revenue (15%
Fee Scenario)
Potential Fee
Revenue (10%
Fee Scenario)
Residential 685,152 $ 196 $ 134,289,792 $ 20,143,469 $ 13,428,979 Nonresidential
Commercial 325,943 $ 141 $ 45,958,019 $ 6,893,703 $ 4,595,802 Office 92,638 176 16,304,294 2,445,644 1,630,429
Industrial 640,517 67 42,914,655 6,437,198 4,291,466
Total 1,744,251 $ 239,466,761 $ 35,920,014 $ 23,946,676 Agenda Item #11.1.

May 9, 2024
8 | P a g e
The nonresidential fees are calculated based on the affordable housing demands of a hypothetical project, informed by the likely type of workers and current salary data.

5. Is it possible to see an analysis of what the current Housing Impact Fee structure has generated over the last 10 years divided between residential and commercial fees and how that money has been used? See Table 4 above for historical fee revenue and expenditures.

6. Has any scenario been flushed out regarding how any of the existing proposals for new hotels could contribute funding under this proposed fee structure and how that compares to the cost of housing incremental employees at various salary levels as documented in the study? This analysis has not evaluated any existing proposals for hotels.

7. How does this new Housing Impact Fee Study relate to the City’s plan to create the VL and L housing units in our RHNA requirements?
Affordable housing fee and commercial linkage fee revenue can be used to help fund the development of very low and low income units in the City.

Comments from Joe McGrath
General Comments/Questions:
*The report seems to lack effective context. It is not clear from the report what the current baseline policy is and/or fee structure. The comparison to other Napa County cities is useful, but there is not a comparison to St. Helena status quo.

Willdan has prepared a fee comparison comparing the City’s current fees to the maximum justified fee schedule and other Napa County cities. See Tables 1 and 2 above. * It is also not clear if this Impact Fee is meant to be in lieu of Inclusionary policy requirements for residential development or in addition to inclusionary requirements. (I attempted to look thru current zoning code but this is very time consuming as new code is not yet hyperlinked :/) Please refer to 17.30.030 E in the new zoning code. Please note that the City will be amending the zoning text to reflect that the calculation is based on the square footage of the proposed unit (no longer percentage of construction cost). The Housing In-Lieu fee in the ordinance is the same as the impact fee, not in addition to the impact fee.
* It is not clear as to whether this fee applies to renovated S.F. or just new S.F.? Only applies to net new square footage. Per 17.30.030 A.3 “Upon the remodeling or rebuilding of a residential dwelling to add additional square footage, the housing impact fee shall be paid on the additional square footage (except for a one-time exclusion of 850 square feet per residence)” Agenda Item #11.1.

May 9, 2024
9 | P a g e
* I believe the rental rates in the report are overstated and do not represent current market conditions.

The data biases itself by looking only at open listed units and appears to be mostly detached single family structures. I believe the construction cost per rental unit is also overstated and for some reason was based on a 5-unit complex whereas the work impact numbers were based on 100-units. Having said that, as both the rental rates are high and construction costs are high, the delta cost to deliver an affordable product to this sector is probably close.

The current rents were estimated based on all the available units that were up for rent at the time the study was completed. There were few multifamily units advertised for rent at that time. The only units that were excluded from the sample were luxury units with rents more than $10,000 per month. Were someone looking to rent a home, these would be the only available units to rent, so the data does reflect the current market.

The construction costs were based on data provided by the City. The City’s most recent experience came from 2020. Those costs were adjusted for inflation using the Engineering News Record’s Construction Cost index.

The hypothetical 100-unit market rate project is used to identify the affordable units demanded by income category. This is different from the cost to construct one affordable unit. The total affordability gap to meet the affordable housing demands of market rate units is then divided by 100 to identify the gap needed to meet the demands of a single unit, which drives the fee calculation. * It would be great to see a breakdown of Housing Impact Fee collections over the last ten years and a breakdown of where they were generated (ie Residential, Commercial, Industrial, Hospitality).

Please refer to Table 4 above. Unfortunately, the revenue data is not available by land use type paying the fee.
* It would also be great to see a Pareto/chart of where all of these funds collected have been allocated or spent.

Table 4 above also lists expenditures.

Inputs:
* For Residential Development. For projects >= 4 units the city should maintain an inclusionary policy (I believe it is 20%*,) and not create an in-lieu fee relief valve. It would fail logic to have both as you would be taxing the solution side of the ledger. Inclusionary Policies build affordable units, not just funds for future units. If you do create an in-lieu fee option it would seem that that fee should roughly represent a ~ 20 YR? Net Present Value of the delta income between market rents and affordable rents. [When I did this calculation in 2019 at 632 McCorkle, the 20YR NPV delta between market rents and affordable rents per inclusionary unit would have been approximately $200K/unit (I did not use a discount rate because I assumed both rents would rise proportionally). In comparing the $200K to 2019 costs per unit (~$550K) that represents about 36%. Against a 20% inclusionary policy that would represent 7.2% of ALL costs (20% * 36%). Instead I negotiated an "alternative equivalent" proposal which Agenda Item #11.1.

May 9, 2024
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deed-restricted existing units in my portfolio. The 20-YR NPV of that proposal was closer to $100k per unit which would be ~3.6% of all costs. That was palatable.] I believe the report is advocating between $14-20/SF. If we assume $500/SF construction costs, and $20/SF that would be 4% of CONSTRUCTION costs. An In-lieu fee at that rate would not be a great deal for the City and the developer would likely take the lower cost in-lieu fee (as much as I hate to say this as a developer). I believe the City would rather have the deed-restricted units than the funds so it should bias towards the built units. Having said that, there is of course a limit where the rates simply cause projects not to pencil.
* For Residential Projects <4 Units. It seems to me here there should be an option to either deed restrict an ADU for SF - Triplex developments or have an in-lieu option with a fee structure akin to what I recommend above.
* For Commercial, Industrial, Hospitality, Hotels. I will not comment greatly here. It seems that this fee structure should be "progressive" in nature. No Impact on renovation project (ie. no new SF). Negligible impact on small businesses/projects, and have rate progression based on the size of project. The comparison with other Napa County cities and Sonoma is very informative on Hotel rates and greatly suggests that impact fee on hotels is far too low in St. Helena.

The fees are calculated on net new square footage, so they wouldn’t apply to renovation projects, unless they are adding square footage.

Agenda Item #11.1.

WILLDAN
Financial Services
Agenda Item #11.1.

Sample Affordable Housing Impact/Commercial Linkage Fees Based on Prototypes Fee Type
Residential -
Rental Unit (1)
Residential - For
Sale Unit (2) Hotel Commercial Office Industrial
Square Footage/# of Rooms 2,761 3,780 65 2,847 5,000 1,500 Proposed Fee 14.00 per SF 20.00 per SF 41,797 per Room 14.00 per SF 18.00 per SF 7.00 per SF Current Total Fee 22,500 27,500 203,669 14,833 20,550 1,890 Proposed Total Fee 38,654 75,600 2,716,805 39,858 90,000 10,500 Variance 71.8% 174.9% 1233.9% 168.7% 338.0% 455.6%
Fee Type
Residential -
Rental Unit (1)
Residential - For
Sale Unit (2) Hotel Commercial Office Industrial
Square Footage/# of Rooms 2,761 3,780 65 2,847 5,000 1,500 Proposed Fee 20.00 per SF 29.00 per SF 41,797 per Room 21.00 per SF 26.00 per SF 10.00 per SF Current Total Fee 22,500 27,500 203,669 14,833 20,550 1,890 Proposed Total Fee 55,220 109,620 2,716,805 59,787 130,000 15,000 Variance 145.4% 298.6% 1233.9% 303.1% 532.6% 693.7%
(1) Single Family - 3 Bedrooms
(2) Single Family - 5 Bedrooms
Option A - All land uses with the exception of hotel be charged 10% of the Maximum Justified Fee per square foot Option B - All land uses with the exception of hotel be charged 15% of the Maximum Justified Fee per square foot Agenda Item #11.1.

Affo rd a b le Ho u s in g a n d Co m m e rc ia l Lin k a g e Fe e St u d y Cit y o f St . He le n a
October 8, 2024
Agenda Item #11.1.

Overview
Affordable housing impact fees
• Charged to new residential development
• Funds share of affordable housing induced by the household spending associated with new market rate residential
development
Commercial linkage fees
• Charged to new nonresidential development
• Funds share of affordable housing needed for employees of businesses located in retail, commercial and industrial development projects
Agenda Item #11.1.

Affordable Housing Impact Fee Approach
New residential
development
generates population
growth
Residents who can
afford to purchase
or rent this new
housing then
spend their
disposable income
in the city
Demand from
increased spending
generates
employment growth
at various wage and
salary levels
Low wage workers
cannot afford
market rate
housing within the
City of St. Helena
Funding gap exists
between what low
wage workers can
afford to pay and the
cost of providing
housing
Affordable housing
impact fee
calculated to
bridge the housing
funding gap
Agenda Item #11.1.

Commercial Linkage Impact Fee Approach
Identify “prototype”
projects representing
the types of
nonresidential
development that
could occur in St.

Helena
Estimate the
industries and
occupations that
could be located
in prototypes
Identify wages
associated with the
occupations
associated with each
prototype
Low wage workers
cannot afford
market rate
housing within the
City of St. Helena
Funding gap exists
between what low
wage workers can
afford to pay and the
cost of providing
housing
Commercial linkage
fee calculated to
bridge the housing
funding gap
Agenda Item #11.1.

2023 Napa County Income Limits
Persons per HH: 1 2 3 4 5 6 7 8
Extremely Low 28,050 32,050 36,050 40,050 43,300 46,500 49,700 52,900 Very Low Income 46,750 53,400 60,100 66,750 72,100 77,450 82,800 88,150 Low Income 74,700 85,400 96,050 106,700 115,250 123,800 132,350 140,850 Median Income 90,700 103,700 116,650 129,600 139,950 150,350 160,700 171,050 Moderate Income 108,850 124,400 139,950 155,500 167,950 180,400 192,800 205,250 Agenda Item #11.1.

 The analysis estimates the number of
affordable units demanded for each
land use
 Different land uses provide jobs for
different amounts of workers by
income category
 The number of units are multiplied by
the adorability gap to determine the
total financing gap
 The total financing gap for each
prototype is divided by 100,000 to
determine the fee per square foot
 Hotel fee assumes 560 square feet per
room
Factors Driving Differences In Nonresidential Fee Schedule Very Low
Income (31-50%
AMI)
Low Income
(51-80% AMI)
Moderate
Income (81-
120% AMI)
Total (per
Prototype)
Total per
Square
Foot or
Room
Financing Gap per
Affordable Unit 834,062 738,005 620,705
Commercial Prototype
Units Demanded 13.273 3.509 0.754 17.536
Total Financing Gap 11,070,844 2,589,522 468,154 14,128,520 141.29 Office Prototype
Units Demanded 7.807 8.312 7.995 24.114
Total Financing Gap 6,511,699 6,134,268 4,962,295 17,608,262 176.08 Industrial Prototype
Units Demanded 2.772 3.710 2.604 9.085
Total Financing Gap 2,311,978 2,737,705 1,616,097 6,665,780 66.66 Hotel Prototype (Assumes 560 Sq. Ft. per Room)
Units Demanded 6.836 1.804 0.694 9.334
Total Financing Gap 5,701,231 1,331,724 430,855 7,463,811 41,797.34 Agenda Item #11.1.

Maximum Justified Fee Schedules
Maximum Justified
Fee
Residential Affordable Housing Impact Fee
New Rental Unit – per Square Foot 135
New For Sale Unit – per Square Foot 196
Commercial Linkage Fee
Commercial – per Square Foot 141
Office – per Square Foot 176
Industrial – per Square Foot 67
Hotel – per Room 41,797
Agenda Item #11.1.

Residential Affordable Housing Fee Comparison per Prototype Unit St. Helena
Current
Single Family, 2,761
square feet, 3
bedrooms
22,500
Single Family, 3,780
square feet, 5
bedrooms
27,500
American
Canyon Napa Cloverdale Cotati Healdsburg
Rohnert
Park
Santa Rosa
(Inside
Downtown)
Santa Rosa
(Outside
Downtown) Sebastopol1
9,470 13,115 34,300 33,400 46,109 15,520 22,088 8,283 61,405 12,965 17,955 39,800 41,400 63,126 15,520 30,240 11,340 84,067 St. Helena -
Maximum
Justified
541,156
740,880
Agenda Item #11.1.

Commercial Linkage Fee Comparison
Calistoga1 Napa Yountville Cotati2 Petaluma3
Rohnert
Park3 Santa Rosa Sebastopol3 Sonoma

2.63 3.55 11.60 2.39 3.36 0.69 3.00 2.08 4.00

3.81 3.55 11.60 4.12 5.81 1.19 3.00 3.59 4.00

1.93 3.50 11.60 2.47 3.46 0.71 3.00 2.15 n/a
1,756.35 6.00 11.60 2.39 3.36 0.69 3.00 2.08 15.00
All fees charged per square foot, except for Calistoga hotel fee and maximum justified St. Helena hotel fee, which are charged per room. 1 Calistoga hotel fee charged per room.
2 Hotel and office assumed charged at "commercial" rate. New construction less than 2,000 sf, and the first 2,000 sf of any commercial project is exempt. 3 Hotel and office assumed charged at "commercial" rate. 4 Maximum justified hotel fee shown per room.

Land Use
Category
St. Helena -
Current
Office 4.11
Retail 5.21
Industrial 1.26
Hotel 3.80
St. Helena
Maximum
Justified4
176.08
141.29

66.66 41,797.34
Agenda Item #11.1.

Hotel Fee Comparison
Description Farmstead Castellucci Noble House
Number of Rooms 65 75 56
Square Footage 53,597 81,000 105,000
St. Helena Current Fee Per Square Foot - 3.80 203,669 307,800 399,000 St. Helena Max Justified Per Square Foot - 75.00 4,019,775 6,075,000 7,875,000 St. Helena Max Justified Per Room - 41,797.34 2,716,827 3,134,801 2,340,651 Calistoga - Per Room 114,163 131,726 98,356
San Francisco - Per Square Foot 1,435,328 2,169,180 2,811,900 Sonoma - Per Square Foot 803,955 1,215,000 1,575,000
Yountville - Per Room 767,075 885,086 660,864
Agenda Item #11.1.

Feasibility Analysis- Project Prototypes
SF
Residential
MF
Residential Office Retail
Industrial/
Warehouse Hotel
Density (FAR) 0.29 0.76 0.28 0.33 0.17 0.13
Density (Units/Acre) 33
Form Factor Single 3-5 Stories 1 Story 1 Story 1 Story Multi Residential Units/Rooms 1 33 65
Unit/Room Size 3,780 1,000 500
Residential SF 3,780 33,000 32,500
Commercial SF 3,597 2,847 1,500 21,097
Parcel size (acres) 0.3 1 0.30 0.2 0.2 9.72
Agenda Item #11.1.

Feasibility Analysis- Pro Forma Summary
Item
SF
Residential
MF
Residential Office Retail
Industrial/
Warehouse Hotel
Residual Land Value Per Acre 3,213,756 928,200 893,627 1,386,326 568,714 1,713,457 Residual Land Value Per Land SF 74 21 21 32 13 39
Potential Fees
10% Fee Per Acre 246,960 646,800 211,024 200,714 50,250 27,951 15% Fee Per Acre 370,440 970,200 316,536 301,070 75,375 41,926 100% Fee Per Acre 2,469,600 6,468,000 2,110,240 2,007,135 502,500 279,507 Max Fee at Threshold 2,113,756 NA NA 286,326 NA 613,457 Agenda Item #11.1.

Potential Revenue Scenarios
Development Impact Fee Study Planning Horizon of 2040
Land Use
Projected
Increase (Sq.

Ft. or Hotel
Rooms)
Maximum
Justified Fee per
Square Foot or
Room
Potential Fee
Revenue
(Maximum
Justified Fees)
Potential Fee
Revenue (15%
Fee Scenario)
Potential Fee
Revenue (10%
Fee Scenario)
Residential 685,152 196 134,289,792 20,143,469 13,428,979 Nonresidential
Commercial 325,943 141 45,958,019 6,893,703 4,595,802
Office 92,638 176 16,304,294 2,445,644 1,630,429
Industrial 640,517 67 42,914,655 6,437,198 4,291,466
Hotel 116 41,797 4,848,452 727,268 484,845
Total 244,315,213 36,647,282 24,431,521
Agenda Item #11.1.

Staff Recommended Fee Schedule
Land Use
Staff
Recommended Fee Factor
Estimated Fee
Revenue (1)
Residential
Rental Unit 14 per sq. ft. 10% Max Justified 13,428,979 For Sale Unit 20 per sq. ft. 10% Max Justified Non-Residential
Commercial 20 per sq. ft. Max Feasible 6,518,860
Office 18 per sq. ft. 10% Max Justified 1,630,429
Industrial 7 per sq. ft. 10% Max Justified 4,291,466
Hotel 41,797 per room Max Feasible 4,848,452
Total 30,718,186
(1) Based on Development Impact Fee Study planning horizon of 2040.

Agenda Item #11.1.

Questions
Agenda Item #11.1.

From: [email protected]
To: cityclerk; cityclerk
Subject: [External] Measure B housing impact fee
Date: Saturday, October 5, 2024 5:03:26 AM
Dear St Helena City Council and Staff,
In consideration of the great impact the Noble House hotel employees commuting to St Helena would have on the Napa Valley environment, I feel very strongly the in lieu of impact fee to the Affordable Housing Trust Fund should be raised to at least the maximum nexus study cost of $75 per square foot -in the area of $3,750,000- to make the building of the employee residences more sure to be built. The very low impact fees charged to developers are never enough encouragement for them to actually be built, or come close to providing St Helena enough money to assume the high costs of building the needed housing itself.

With this greater assurance of actually having the much needed housing built I would be much more likely to vote For Measure B rather than Against, mainly because of this objection. The inconsequential impact fee in this current contract is so low it seems likely to be another of the several hotels that have not built their needed staff housing, making staff have to commute long distances to work in St Helena, and also causing closure of fine restaurants and businesses due to lack of available staff.

Thank you for your consideration of this and all community opinion and dedication to keeping St Helena the great little city it's always been.

Holly Rogers
St Helena CA
Agenda Item #11.1.

From: Lyndsey Harrison
To: cityclerk
Subject: [External] Housing impact fee
Date: Friday, October 4, 2024 9:44:46 PM
Please approve the hotel impact fee to the maximum at next council meeting.

Lyndsey Harrison
1521 Allyn St. SH
Please excuse typos
Agenda Item #11.1.

October 7, 2024
To the City of St Helena City Council:

As you decide on the Development Impact Fees, please consider how your actions affect the potential development of workforce housing in St Helena. (All data from the Willdan Study and staff reports except where noted.)
Hotel
The recommendation is $41,787 per room
• Based on a 65 room hotel the total fee would be $2,716,155 • A luxury 65 room hotel will employ a minimum of 2.0 people per room or 130 people (source: Google)
Hotel Developers Options:

Recommended Fee Maximum Allowed Fee
$41,787 x 65 rooms = $2,716,155
*Estimated number of employees
housed: 5
$75 x 53,597 sq. ft. = $4,019,775
*Estimated number of employees
housed: 6
*At a cost of $750,000 per unit and 1.18 employees per unit Multi-Family
The recommendation is a 10% affordable housing fee
• Based on a 1 acre project with 33 units
• Total Project Development Cost of $11,138,400
• Per unit cost $338,000
Multi Family Developers Options:

Option 1 Option 2
Build the 20% inclusionary housing

6.6 units @ $338,000 per unit
Pay the in lieu fee of $20 per sq. ft
Developer Cost: $2,230,800 Developer Cost: $646,800
• City stated previously that the average cost to build one affordable unit is $750,000 • The develop would be paying 86% of one unit as opposed to actually building 6+ units • There are several multi-unit residential projects under consideration for St Helena. • WHY WOULD ANY DEVELOPER BUILD INCLUSIONARY HOUSING?
• The in lieu fee should provide an incentive for the developer to include affordable housing.

Maybe after this election, the City can reexamine its approach to local housing.

Mary Stephenson
[email protected]
Agenda Item #11.1.

Agenda Report to the City Council
Agenda Section: PUBLIC HEARINGS
Department: Finance
DATE: October 8, 2024
FROM: Martin Beltran, Senior Management Analyst
SUBJECT: Discussion of and Direction on the Potential Activities and Projects for Inclusion in the 2024 Community Development Block Grant (CDBG) Applications.

RECOMMENDED
ACTION:

Provide direction on the activities and projects to be
considered for funding under the 2024 Community
Development Block Grant program.

PREVIOUS COUNCIL
ACTION:

None.

STATEMENT OF THE
PURPOSE:

The purpose is to determine which activities and projects should be included in the application submittals for funding under the 2024 Community Development Block Grant
program.

FINANCIAL IMPACT: If each activity/project is awarded, the total financial impact is estimated to be $2.25 million in additional grant
revenues.

BACKGROUND:

The U.S. Department of Housing and Urban Development (HUD) Community Development Block Grant (CDBG) program authorizes the use of funds to assist lowand moderate-income families or aid in the prevention or elimination of slums or blight.

On August 30, 2024, the California Department of Housing and Community Development (Department) announces the availability of approximately $34 million in funding available through the federal Small Cities Community Development Block Grant Program (CDBG) for the 2024 funding year. The objectives of the CDBG program are to develop viable communities by the provision of decent affordable housing, a suitable living environment, and to expand economic opportunities, principally for the benefit of Low- and Moderate-Income (LMI) persons, families, households, and neighborhoods.

The City is required to conduct public outreach regarding potential CDBG projects/activities that could be considered for the current application period including holding a public hearing to discuss the potential application(s) and allow for public input.

Project/Activity Selection
In order to be considered eligible, a suggested project/activity must address one or more of the three national objectives:

1. Benefit to low- and moderate-income persons; or
Agenda Item #11.2.

2. Aid in the prevention or elimination of slums and blight; or

3. To meet an urgent need.

The benefit to low- and moderate-income persons is the most predominately used National Objective. In order to benefit low- or moderate-income persons, the project/activity must either benefit an area that is comprised of at least 51% low- or moderate-income households, or the program benefits individually qualified households (i.e., each participating household is income certified).

Application deadlines are as follows:

CDBG NOFA Releases August 30, 2024
Submission Portal for All Solicitation
Opens October 29, 2024
Application for Competitive Solicitation
Closes December 30, 2024
Application for OTC Solicitation Closes When funds are exhausted or December 30, 2024, whichever comes first
Eligible cities and counties may submit Community Development and Housing applications for CDBG funds under the 2024 NOFA for a maximum of $3.6 million for up to three activities.

The maximum number of applications a jurisdiction can apply for is three (3) applications in this 2024 NOFA and are as follows:
 1 Over-the-Counter (OTC) Project + 1 OTC Program + 1 Competitive -OR-  1 OTC Project + 2 Competitive -OR-
 1 OTC Program + 2 Competitive.
*Note: 2 OTC Project, 2 OTC Program, or 3 Competitive applications are not allowed
The funding limits for the 2024 NOFA are as follows:
 Total grant award for all activities combined per jurisdiction shall not exceed $3.6 million.
 Competitive Applications shall not exceed $300,000.
 OTC Project application limit shall not exceed $3.3 million.  OTC Program application limit shall not exceed $1.5 million.

Activity Limits
i) Competitive Applications
 Public Service – up to $300,000
 Planning – up to $300,000
ii) Over-the-Counter (OTC) Applications
Agenda Item #11.2.

 Projects – up to $3.3 million
 Housing Programs – up to $1.5 million
o A Housing Program can include the following activities.  13A – Housing Counseling
 13B – Single Family (1 - 4 units) Homeownership Assistance  14A – Single Family (1 - 4 units) Housing Rehabilitation  14F – Single Family (1 - 4 units) Energy Efficiency Improvements  15 – Code Enforcement
Economic Development Programs – up to $1.5 million
An Economic Development Program can include the following activities.  18A – Economic Development Direct Financial Assistance to For-Profit Business  18B – Economic Development Technical Assistance
 18C – Economic Development: Microenterprise Assistance A comprehensive list of eligible activities under this NOFA can be found in Attachment 2: CDBG Matrix Code Categories.

DISCUSSION:

Staff has identified two potential projects and is seeking City Council feedback on each project as well as provide direction on any other projects/activities to include in the 2024 application. Based on City Council direction, the final project list will be brought back to City Council at a later meeting for approval.

CDBG Projects Identified by Staff
Based on the 2024 NOFA eligibility criteria of CDBG funds the following is list of potential projects eligible for OTC applications.

Over the Counter Program: Economic Development $750,000 Rehabilitation: Energy Efficiency Improvements for multiple sites $1,500,000 Over the Counter Program: Economic Development
Funding will be used for a Business Assistance Program for the purpose of establishing a business assistance revolving loan fund, which will provide 1% interest loans to small and medium sized businesses in the City of St. Helena to assist with job creation and retention of low-moderate income jobs. In addition, the program will be structured that in specific cases where businesses show an extreme financial need, the loans may be forgiven.

The City was previously awarded $500,000 under the CDBG 2021 NOFA for Economic Development for Business Assistance. This program offered forgivable loans to businesses affected by the Covid-19 pandemic to help them retain or create jobs for Agenda Item #11.2.

low-to-moderate income individuals. The success of this program will enhance the appeal of the 2024 application.

Rehabilitation: Energy Efficiency Improvements for multiple sites The City is exploring opportunities to enhance energy efficiency at various affordable housing locations throughout the City, including Hunt's Grove. The City previously submitted an application for the Hunt's Grove parking lot improvements project as part of the 2021 CDBG NOFA.

The apartment complex was built on City property and has been in existence since 1991. The property is leased to Hunt's Grove (Bridge Housing Corporation) and is comprised of affordable housing units. There has been an on-going parking related issue at Hunt's Grove Apartments. The proposed project will expand and improve parking for Hunt's Grove Apartments.

Based on preliminary plans, it appears an additional six (6) tandem spots would fit in the proposed area, creating space for an additional twelve (12) parked cars. In addition, the project includes infrastructure and installation of six (6) EV chargers.

Other Considerations
Our Town St Helena (OTSH) initially approached the City to submit an application for the maximum award of $3.3 million per project. OTSH has been in discussions with the owner of two apartment buildings, each with 6 rental units, who would like to sell the properties to OTSH. The seller wants the properties to be long-term deed restricted at affordable rents, which may include a mix of low- and moderate-income units. The buildings are located at 1347 and 1357 Monte Vista Court.

A recent appraisal valued the properties at $4.7 million, therefore OTSH estimates it will need to secure $4.9 million to pay fair market value and cover City and OTSH administrative and closing costs. The NOFA outlines there will be a "Sources and Uses Chart", which will require documented evidence of commitment of all funds needed to complete the project. HCD will likely disqualify the application if they are not satisfied with the feasibility based on documented financial commitments. After conversations with OTSH, it was concluded that OTSH currently lacks committed funding to bridge the gap. As a result, the City will not be moving forward with the application at this time.

ENVIRONMENTAL REVIEW: None.

GOAL:

Goal 1: Strengthen Financial Sustainability
Goal 5: Enhance Quality of Life
DOCUMENTS ATTACHMENTS:

Agenda Item #11.2.

Attachment 1: 2024 CDBG Notice of Funding Availability
Attachment 2: Matrix Code Categories
Agenda Item #11.2.

STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF FEDERAL FINANCIAL ASSISTANCE
651 Bannon Street, 7th Floor
Sacramento, CA 95811
(916) 263-2771
www.hcd.ca.gov
California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 1
August 30, 2024
MEMORANDUM FOR: All Potential Applicants
FROM: Jenny Cho, Deputy Director
Division of Federal Financial Assistance
SUBJECT: 2024 Community Development Block Grant
Program Notice of Funding Availability
The California Department of Housing and Community Development (Department) is announcing the release the 2024 Notice of Funding Availability (NOFA) for approximately $34 million in federal funds for the Community Development Block Grant (CDBG) program.

Funding for this NOFA is available to the state from the United States Department of Housing and Urban Development (HUD), pursuant to the Housing and Community Development Act of 1974, as amended, and 24 Code of Federal Regulation (CFR) Part 570 Subpart I “State Community Development Block Grant Program.” These regulations require the state to make funds available to the state’s non-entitlement Units of General Local Government (UGLGs).

Units of General Local Government are defined by HUD as political subdivisions of the state, which in California are towns, cities, and counties. Only non-federally recognized Tribes can receive funding through applications submitted by non-entitlement Units of General Local Government. No direct funding from the Department can be provided to Tribes, TriballyDesignated Housing Entities, or nonprofits.

Applicants are encouraged to set-up profiles in the eCivis Portal at eCivis Portal | Login as early as possible. Profile set-up instructions and other technical assistance can be found in the eCivis Grants Network External User Manual found on the Department’s CDBG webpage under the “Resources” tab.

Applicants are encouraged to begin the application process early to ensure successful submission before the application deadline. If you have issues logging into the portal or have questions on how to complete the online application, please contact the Department at [email protected].

To receive CDBG program NOFA FAQs, emails, and other information and updates, please sign up for emails and check the “Federal Programs” box. If you have any questions, please submit them to [email protected].

All activities in this NOFA are subject to availability of funds and continuing HUD and legislative authority.

Attachments
Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 1
Community Development Block Grant Program
2024 Notice of Funding Availability
Gavin Newsom, Governor
State of California
Tomiquia Moss, Secretary
Business, Consumer Services and Housing Agency
Gustavo Velasquez, Director
California Department of Housing and Community Development Division of Financial Assistance, Federal Programs Branch, Community Development Block Grant Program
651 Bannon Street, 7th Floor, Sacramento, CA 95811
Email: [email protected]
August 30, 2024
Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 2
Table of Contents
Table of Contents.......................................................................................................................... 2 I. Overview................................................................................................................................ 4 A. Notice of Funding Availability.................................................................................. 4 B. Estimated Timeline ................................................................................................. 4 C. What is new in this NOFA ....................................................................................... 5 D. Authorizing Legislation............................................................................................ 7 II. Allocation and Funding .......................................................................................................... 8 A. Definitions ............................................................................................................... 9 III. Program Requirements ......................................................................................................... 9 A. Eligible Applicants................................................................................................... 9 B. Non-Entitlement Status ........................................................................................... 9 C. Housing Element Compliance...............................................................................10 D. Growth Control Limitations....................................................................................10 E. Limits for Administration and Planning..................................................................11 F. Insufficient Demand ..............................................................................................11 G. Eligible Activities ...................................................................................................11 H. Application Limits..................................................................................................12 I. Additional Requirements.......................................................................................14 IV. Application Requirements....................................................................................................15 A. National Objectives...............................................................................................15 B. Milestones.............................................................................................................15 C. Conditions.............................................................................................................16 V. Application Threshold and Initial Requirements ..................................................................16 A. Eligible Applicant...................................................................................................16 B. Single Audit...........................................................................................................17 C. Site Control ...........................................................................................................17 D. Statement of Assurances (Appendix D)................................................................18 E. Public Participation ...............................................................................................18 F. Resolution.............................................................................................................18 G. TIN ........................................................................................................................19 H. Budget...................................................................................................................19 I. Sources and Uses Chart.......................................................................................20 J. System for Award Management (SAM) ................................................................20 K. State Objectives....................................................................................................20 L. National Environmental Policy Act of 1969 (NEPA)..............................................20 M. Construction Projects............................................................................................21 Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 3
N. Economic Development (ED) Programs Only.......................................................21 VI. Application and Activity Requirements ................................................................................22 A. Federal Cross-Cutting Requirements ...................................................................22 B. Application Verification..........................................................................................22 C. Application Submission.........................................................................................23 D. Timely Submittal ...................................................................................................23 E. Gap Funding .........................................................................................................23 F. Good Standing......................................................................................................24 G. Racial Equity .........................................................................................................24 H. Homelessness Assistance....................................................................................25 I. Scoring ..................................................................................................................25 J. Readiness.............................................................................................................26 VII. Application Submission .......................................................................................................26 A. Workshops............................................................................................................26 B. Submission Process .............................................................................................27 C. Applicant Responsibility ........................................................................................28 D. Disclosure of Application.......................................................................................28 VIII. Application Review ..............................................................................................................28 A. Review Process ....................................................................................................29 IX. Award Recommendations ...................................................................................................29 X. Appeal Criteria and Process................................................................................................29 A. Competitive Application Appeals ..........................................................................30 B. OTC Application Appeals......................................................................................31 XI. Awards Announcement and Grant Implementation.............................................................32 A. Awards Announcements .......................................................................................32 B. Standard Agreements ...........................................................................................32 XII. Federal Program Requirements ..........................................................................................32 A. Federal Cross-Cutting Requirements ...................................................................33 B. Build America, Buy America Act (BABA) ..............................................................33 C. Relocation Plan Requirements .............................................................................34 D. Procurement Requirements ..................................................................................35 E. False, Fictitious or Fraudulent Claims...................................................................35 F. Whistleblower Protection Acts ..............................................................................36 G. The California Whistleblower Protection Act.........................................................37 XIII. LIST OF APPENDICES.......................................................................................................39 Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 4
I. Overview
A. Notice of Funding Availability
The California Department of Housing and Community Development (Department) announces the availability of approximately $34 million in funding available through the federal Small Cities Community Development Block Grant Program (CDBG) for the 2024 funding year.

The objectives of the CDBG program are to develop viable communities by the provision of decent affordable housing, a suitable living environment, and to expand economic opportunities, principally for the benefit of Low- and Moderate-Income (LMI) persons, families, households, and neighborhoods.

Applicants are expected to plan activities that will reduce disparities and increase racial and socioeconomical equity in their communities. Applicants are to ensure all eligible persons receive equitable access to services, and are served with dignity, respect, and compassion regardless of circumstance, ability, or identity, which includes marginalized populations, including but not limited to, Black, Native and Indigenous, Latinx, Asian, Pacific Islanders and other people of color, immigrants, people with criminal records, people with disabilities, people with mental health and substance abuse vulnerabilities, people with limited English proficiency, people who identify as LGBTQ+, and other individuals that may not traditionally access mainstream support.

All applications will be reviewed for completeness and compliance with state and federal requirements. Only complete and compliant applications will be eligible for application review, approval, and potential funding per 42 U.S.C. §5302(a), 24 CFR Part 570 and the State CDBG Guidelines.

B. Estimated Timeline
CDBG NOFA Releases August 30, 2024
Submission Portal for All
Applications Opens October 29, 2024, at 9AM P.D.T.

Application for Competitive
Solicitation Closes December 30, 2024, at 3PM P.D.T.

Application for OTC
Solicitation Deadline
When funds are exhausted or December
30, 2024, at 3PM P.D.T., whichever
comes first
Contract Execution for
Competitive Applications May 2025
Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 5
Contract Execution for OTC
Applications Rolling basis starting May 2025
Expenditure Deadline 2 years, 9 months from contract
execution
Applications submitted before the application open date or after the respective closing date or deadline will not be accepted. There will be no exceptions. The Department recommends Applicants plan to submit their application(s) well before the application deadline to provide opportunity for troubleshooting if needed.

Each application will be digitally time-stamped upon submittal.

If this NOFA is undersubscribed, unawarded funds may be made available under a subsequent NOFA. If funds become disencumbered between this NOFA release and the application deadline, the disencumbered funds may be made available under this NOFA or any subsequent NOFA’s, at the department’s discretion. If disencumbered funds exceed applications, the disencumbered funds will be made available under a subsequent NOFA.

C. What is new in this NOFA

1. A comprehensive list of eligible activities under this NOFA can be found here:

IDIS CDBG Matrix Code/National Objective Table.

2. Public Service and Planning activities are eligible under a Competitive Application process.

3. Housing Program and Economic Development Program activities are eligible under an Over-The-Counter application process.

4. Economic Development Programs and Housing Programs with multiple activity types (e.g., ED Assistance to For-Profits and Micro-Enterprise Assistance or Homeownership Assistance and Housing Rehabilitation) will be considered as a single application and, if awarded, will be funded under a single Standard Agreement.

5. Maximum number of applications a jurisdiction can apply for has increased from one (1) application in the 2023 NOFA Amendment #1 to three (3) applications in this 2024 NOFA and are as follows:
• 1 OTC Project + 1 OTC Program + 1 Competitive -OR-
• 1 OTC Project + 2 Competitive -OR-
• 1 OTC Program + 2 Competitive.
**Note: 2 OTC Project, 2 OTC Program, or 3 Competitive
applications are NOT allowed.

Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 6

6. Funding limits have been updated as follows:
i) Total grant award for all activities combined per jurisdiction shall not exceed $3.6 million.
ii) Competitive Applications shall not exceed $300,000. iii) OTC Project application limit shall not exceed $3.3 million. iv) OTC Program application limit shall not exceed $1.5 million.

7. Application Process
i) A complete application consists of:
a.One Main Application -ANDb.One Sub Application PER Matrix Code *For a complete Housing or Economic Development Program application, a Sub Application is required for each activity (matrix code) for the program.
ii) All applications must be submitted through the eCivis Grants Network Portal before the applicable closing date and/or deadline.

8. Applications must demonstrate Build America, Buy America (BABA) compliance, as applicable.

9. In accordance with CDBG Program Guidelines Section 202(a)(2), 50 Percent Rule, Grantees shall be ineligible to apply for any additional CDBG funds for Public Services or Planning activities unless, at the time of application submission, the grantee has expended at least 50 percent of CDBG funds previously awarded for such an activity. To encourage timely expenditure, this will mean ANY Planning grant or Public Service grant, regardless of matrix code.

10. For all CDBG-funded programs including Public Services and Housing or Economic Development programs, threshold documentation of site control can be satisfied with a current lease for the location from which the program will operate and a signed statement from the authorizing official that the grantee intends to extend the lease upon expiration. A new or renewed lease must be submitted at expiration of the current lease.

11. Membership in local Continuum of Care (CoC) is now a requirement for activities involving homelessness assistance.

12. Permit requirements have been added to competitive projects.

13. Authorized Signatory for cities must be the Mayor or Mayor pro tempore unless there is an ordinance or municipal code designating another position.

Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 7

14. Completed Law and Authority topic worksheets must be included with all Environmental Review Records.

15. All OTC applications must demonstrate readiness to the satisfaction of the Department.

D. Authorizing Legislation
Funding under this NOFA is made available pursuant to the Housing and Community Development Act of 1974. This NOFA should be read in conjunction with the following statutes, regulations, and guidelines that establish state and federal CDBG requirements. Relevant legal authorities include, but are not limited to, the following:
• 24 Code of Federal Regulations (CFR) §570.480, et. Seq, Federal CDBG Regulations
• 24 CFR Part 58, Environmental Review Procedures
• 2 CFR Part 200, Uniform Grant Administration Requirements • Health & Safety Code (HSC) §§50825-50834, State of California CDBG program
• CDBG Final Program Guidelines
• 2020-2024 State of California Consolidated Plan
• 2024-2025 State of California Annual Action Plan
If there are changes to federal or state statutes, regulations, guidelines, or other laws governing the CDBG program, or if funding is modified by Congress, HUD, the Department, or the state Legislature, these changes may become effective immediately and apply to activities under this NOFA.

Note: The Housing and Community Development Act of 1974 (HCDA) is codified as Title 42 U.S.C. §5301, et. seq.: thus, those citations are interchangeable and cite the same statute language. For example, the citation of HCDA 105(a)(22) and 42 U.S.C. §5305(a)(22) are references to the same statute language. For the purposes of this NOFA, we will use the 42 U.S.C. §5301 citations for references to the federal statutes.

In administering this NOFA, if there is a conflict between the federal statutes or regulations and state statutes or guidelines, the federal statutes and regulations shall prevail. All activities in this NOFA are subject to availability of funds and continuing HUD and California legislative authority. The Department reserves the right, at its sole discretion and at any time, to rescind, suspend or amend this NOFA and any or all its provisions.

The Department will notify interested parties through listserv emails and by posting notification on the Department website if the Department rescinds, suspends, or Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 8
amends this NOFA. This NOFA is not a commitment of funds to any Activity or Applicant.

II. Allocation and Funding
Funds will be allocated in accordance with federal regulations found in 24 CFR §570 and state statute, as found in HSC §50827, et seq. For more information, please reference the CDBG Guidelines, Section 200.

The table below include the estimated percentage of Funding Allocations for the 2024 NOFA:

Funding Allocation Percentage Estimated Dollar Amount
Local Administration 7% $2,500,000.00
Competitive Awards (Public Service)
(24 CFR 570.201(e)(1))
Competitive Awards (Planning) (24
CFR 570.483(b)(5))
≤15%
≤10%
$5,400,000.00
$3,600,000.00
Over-the-Counter Awards (Housing
59% $20,500,000.00
Colonias Set-Aside (Section 916 of
the National Affordable Housing Act)
Set-aside of
5% $1,800,000.00
Non-federally recognized Tribes
Set-Aside (HSC §50831)
Set-aside of

1.25% $455,000.00
*Note: The amount of total funding available and the allocations of those funds are only estimates and are subject to change without notice.

Projects, Economic Development
Projects, Housing Programs,
Economic Development Programs)
Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 9
A. Definitions
Except as otherwise defined herein, all defined terms have the meaning set forth in 42 U.S.C. §5302(a), 24 CFR Part 570, and the State CDBG Guidelines.

III.Program Requirements
All Program Requirements, Application Requirements, Application Threshold and Initial Requirements, and Application and Activity Requirements set forth in Sections III-VI must be met. Failure to timely satisfy all of the requirements will result in disqualification.

A. Eligible Applicants

1. Only non-entitlement Units of General Local Government such as cities, counties and municipalities are eligible to apply. Federally recognized Tribes, non-federally recognized Tribes, and nonprofits may receive assistance only by entering into a subrecipient agreement*, a Memorandum of Understanding, or a contract with an eligible Applicant.
*A subrecipient agreement is a written agreement in effect for each subrecipient before giving out any CDBG funds and remaining in effect for the period during which a subrecipient has control over any CDBG funds, including Program Income. At a minimum, a subrecipient agreement must contain content required by the federal CDBG regulations at 24 CFR §570.503.

2. Applicants must meet one or more of the following requirements when the application is submitted to be eligible to apply for funding under this NOFA:
i) An eligible Applicant may apply on its own behalf.
ii) An eligible Applicant may apply on behalf of one or more other eligible Applicants.
iii) Two or more eligible Applicants, which share an activity, may submit a joint application.
iv) An eligible Applicant may apply on behalf of an eligible subrecipient including a non-federally recognized Tribe or nonprofit.
v) In addition to Activity and application limits identified in this NOFA, an eligible Applicant may apply for activities in service areas within or outside of the Applicant’s Jurisdiction when the Applicant is applying for funds set aside by the California State Legislative for non-federally recognized Tribes (HSC §50831) and/or Colonias.

B. Non-Entitlement Status
Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 10
CDBG program funds are provided as grants to Non-Entitlement Units of General Local Government (UGLGs). These UGLGs are encouraged to partner with federally- and non-federally recognized Tribes, districts, agencies, nonprofit service providers, and other community organizations, whenever appropriate, to prepare and submit applications for CDBG funding, and to administer and complete CDBGfunded programs and projects.

Incorporated cities located in an urban county as defined by 42 U.S.C. §5302 (a)(6) must formally elect to be excluded from participation in the urban county entitlement status. HUD and the Department must be notified that the city has elected to be excluded from the urban county participation as per 24 CFR 570.307(g) for it to be eligible for the state CDBG program. Only eligible activities from eligible Applicants will be considered for an award.

Applications for eligible activities outside the Applicant's Jurisdiction must include a legally binding agreement, acceptable to the Department, with the city or county in which the eligible Activity is located. Applicants may not apply to both the State CDBG program and to a CDBG program administered by an Urban County or other entitlement entity during the same program year.

C. Housing Element Compliance
As per HSC §50829, the Applicant must, at a minimum, submit a draft or adopted housing element to the Department in accordance with the requirements listed in Government Code (GC) §65580, et seq., and GC §65585 (see Appendix B) prior to an application submission. Jurisdictions who fail to complete the Housing Element compliance process in a timely manner will be ineligible for funding until the Housing Element meets requirements pursuant to H.S.C. 50829 and 50830. Per CDBG Guidelines, Section 202(a)(4), by the time of award funding, the Applicant must have complied with all the Housing Element requirements listed in H.S.C. 50829 and 50830.

D. Growth Control Limitations
Applicants that have adopted growth controls, including, but not limited to, restrictions on residential building permits and residential buildable lots, that do not meet the exception criteria in HSC §50830 (b) and (c) are ineligible for funding as per HSC §50830. Applicants intending to apply for CDBG funds are required to submit a signed 2024 CDBG Application Certifications and Statement of Assurances form that certifies the Applicant has not adopted any residential growth controls or adopted residential growth controls meet the applicable exception criteria. Failure to submit an executed Application Certifications and Statement of Assurances at the time of application will result in Applicant ineligibility.

Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 11
E. Limits for Administration and Planning

1. Program Administration
The Department can use 3 percent of the total funding +$100,000 for administration costs.

2. General Administration (GA)
i) Applicants may request up to 7 percent of the total CDBG grant funding requested by that Applicant for General Administration (GA). For detailed information regarding General Administration costs, see Chapter 6: Financial Management of the current posted version of the CDBG Grants Management Manual (GMM), as may be amended, which is found on the CDBG page of the Department’s website.
ii) The calculation to determine the maximum allowable General Administration amount is the amount of Activity expenses plus Activity Delivery expenses, multiplied by 7 percent. Appendix G has been provided for ease of calculation. iii) In general, there should be minimal GA. Staff time and/or work completed directly on a specific Activity should be reported as Activity Delivery Cost (ADC) whereas the overall management of the CDBG Program, such as NOFA webinars and Office Hours, should be reported as GA.
iv) For detailed information regarding ADC, see Chapter 6: Financial Management of the current posted version of the CDBG GMM, as may be amended, which is found on the CDBG page of the Department’s website. v) GA should be requested in the Main Application for the aggregate amount of all Sub Applications.

3. GA for Program Income (PI) funds is 17 percent of the annual PI receipts for the most recently completed Department Program Year (e.g., for PY 2023, receipts PY 2022 (July 1, 2022 – June 30, 2023).

4. Applicants may elect to assign more funds to Activity costs and take less than the 7 percent (17 percent for Program Income) as their GA allocation.

5. For project budgets with both grant award and PI as funding sources, applications must identify how much GA will be from each source to ensure that GA stays within the appropriate program caps.

F. Insufficient Demand
If there is insufficient demand under this NOFA, the Department will make the unused funding available under subsequent CDBG NOFA(s).

G. Eligible Activities
Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 12
For a complete list of eligible activities allowed under the HCDA, go to 42 U.S.C. §5305 and Chapter 2 of the current version of the CDBG Grants Management Manual which is found on the CDBG page of the Department’s website. For a list of eligible activities allowed under this NOFA, go to: IDIS CDBG Matrix Code/National Objective Table (ca.gov).

Pursuant to both federal and state laws all CDBG costs must:

1. be eligible;

2. be necessary;

3. be reasonable;

4. not be used to supplant local or state resources; and

5. be guarded against fraud.

H. Application Limits

1. Each Jurisdiction can submit up to three (3) applications during this NOFA cycle.
i) 1 OTC Project + 1 OTC Program + 1 Competitive -ORii) 1 OTC Project + 2 Competitive -ORiii) 1 OTC Program + 2 Competitive. **Note: 2 OTC Project, 2 OTC Program, or 3 Competitive applications are NOT allowed.

2. The two (2) Competitive Applications can be 2 Public Service, 2 Planning, or 1 Public Service and 1 Planning Application.

3. The maximum combined award amount per jurisdiction is $3.6 million. Each activity must have a unique Sub Application with a complete budget, National Objective, scope of work, and milestone timeline.

4. For Housing and Economic Development Programs with multiple matrix codes, the Main Application’s Budget will need to breakdown the total amount requested by each matrix code activity.

5. Applicants are encouraged to review the sample draft Standard Agreement in Appendix K as a sample of the applicable terms and conditions required for CDBG funded activities.

6. The $3.6 million per jurisdiction limits do not apply to Colonias and Native American set-asides. The maximum activity limits are listed below. Program Income (PI) included in an activity budget does not count against the Jurisdiction’s maximum award limit.

7. Activity Limits
i) Competitive Applications
Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 13
• Public Service – up to $300,000
• Planning – up to $300,000
ii) Over-the-Counter (OTC) Applications
• Projects – up to $3.3 million
• Housing Programs – up to $1.5 million
• A Housing Program can include the following activities. Each activity must have its own Sub Application.
 13A – Housing Counseling
 13B – Single Family (1 - 4 units) Homeownership
Assistance
 14A – Single Family (1 - 4 units) Housing
Rehabilitation
 14F – Single Family (1 - 4 units) Energy Efficiency
Improvements
 15 – Code Enforcement
• Economic Development Programs – up to $1.5 million
• An Economic Development Program can include the following activities. Each activity must have its own Sub Application.  18A – Economic Development Direct Financial
Assistance to For-Profit Business
 18B – Economic Development Technical Assistance
 18C – Economic Development: Microenterprise
Assistance

8. Code Enforcement – Changes. Different from previous years, to align with HUD’s directive regarding code enforcement programs, the Code Enforcement activity will only be eligible under the Housing Program application. Per HUD, code enforcement is defined as a process whereby local governments gain compliance with ordinances and regulations regarding health and housing codes, land use and zoning ordinances, sign standards, and uniform building and fire codes. The CDBG program expects the focus of code enforcement to be on health and safety issues in buildings and structures. • To gain compliance with HUD’s intent for the program, applicants are required to demonstrate a $1:$2.50 ratio of code enforcement to housing rehabilitation availability. That is to say, for every $1 of code enforcement funds requested, Applicants must have $2.50 in demonstrated or applied for funds for a Housing Rehabilitation Program.

Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 14
a. “Demonstrated” refers to housing rehabilitation program(s) already in existence within the Applicant’s jurisdiction.
b. “Applied for” funds refers to a housing rehabilitation program through this Application.

I. Additional Requirements

1. Americans with Disabilities Act and Physical Accessibility Requirements i) The Grantee shall ensure compliance with all applicable state and federal building codes and accessibility laws and standards. All developments shall adhere to the accessibility requirements set forth in: (i) California Building Code Chapters 11A and 11B; (ii) the federal Fair Housing Act (42 U.S.C. § 3601 et seq.) and its regulations at 24 CFR part 100 (particularly 24 CFR 100.205), and its design and construction requirements, including ANSI A117.1-1986, and the Fair Housing Accessibility Guidelines, March 6, 1991, in conjunction with the Supplement to Notice of Fair Housing Accessibility Guidelines: Questions and Answers About the Guidelines, June 28, 1994; and (iii) the Americans with Disabilities Act of 1990 (42 U.S.C. § 12101 et seq.) and its Title II and Title III regulations at 28 CFR parts 35 and 36; and Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. § 794) and the implementing HUD regulations at 24 CFR Part 8.

2. Construction Standards/Requirements
i) All residential construction Projects, where applicable, must comply with the housing construction codes of the State of California. All units must meet these codes as well as any locally adopted codes and ordinances. Housing construction codes for building in California follow federal and state laws, regulations, and adaptions for construction of single family and multifamily units.

The State Housing Law Program within the Department continuously refines the building standards to ensure they comply with new or changing laws and regulations and develops statewide building standards for new construction of all building types and accessories. The State Housing Law Program also develops the building standards necessary to provide accessibility in the design and construction of all housing other than publicly funded housing. The building standards are published as the California Building Standards Code under the California Code of Regulations, Title 24, and construction standards in the Standard Agreement must meet or exceed all applicable requirements for housing or building construction. Tribal Entities with Projects on Native American Lands are required to follow their own tribal building codes or the International Building Code.

Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 15
IV. Application Requirements
A. National Objectives
CDBG-funded activities must meet the following National Objective:
• Benefit LMI persons
At least 70 percent of the funds awarded must benefit LMI individuals or households.

No activity or portion of a program assisted by these funds may exclude from its benefits the lowest income-eligible group. Individual activities must meet the Low- to Moderate-Income National Objective as defined and described in detail in Chapter 2 of the CDBG GMM:

B. Milestones
All CDBG program-funded activities must be timely implemented in accordance with the milestones defined in the Standard Agreement. Milestones should be project/program specific and a reflection of significant progress. Applicants must include at least five (5) milestones per Activity application. The first and last milestone will be prepopulated and cannot be edited by Applicants. Failure to meet the first milestone identified, is a material breach of the Standard Agreement and will result in a for-cause termination of this Agreement.
• First Milestone: Activity Initiation. Must be completed no later than 60 days from the Effective Date of the Standard Agreement.
• Milestone Two: [populated by Applicant] – examples below • Milestone Three: [populated by Applicant] – examples below • Milestone Four: [populated by Applicant] – examples below • Final Milestone: Activity closeout (must be completed no later than 90 days after the Expenditure Deadline).

TIP: The Department recognizes that Applicants’ proposed milestone dates are estimates.

Instead of using an actual date for all optional milestones, please utilize time frames.

For example:

Milestone One (required): Activity Initiation. Must be completed no later than 60 days from the Effective Date of the Standard Agreement.

Milestone Two: Release Invitation for Bid (IFB) within 90 days of Standard Agreement execution by HCD.

Milestone Three: Execute contract with a General Contractor within 120 days of Standard Agreement execution by HCD.

Milestone Four (optional): Begin construction within 9 months of Standard Agreement execution by HCD.

Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 16
Milestone Five: Record Notice of Completion within 2 months of project completion.

Milestone Six (required): Activity closeout (must be completed no later than 90 days after the Expenditure Deadline).

If necessary, prior to Standard Agreement execution, your CDBG representative may update milestones if changes need to be made.

Additional milestones are optional, though encouraged for best practice of Activity implementation. Applicants are encouraged to evaluate feasibility of meeting milestones and build time for unexpected delays into the milestone schedules.

Milestones may not extend beyond the term of the Standard Agreement. All milestones proposed by Applicants are subject to the review and approval of the Department in its discretion.

C. Conditions
Applicants and awardees acknowledge that the funding opportunities referenced in this NOFA, and all obligations of the Department herein, are expressly subject to and conditioned upon the ongoing availability of funds, as well as the continued federal and state authority of the Department to operate the CDBG program. In the event that funds are not available, the CDBG Program or Act under this NOFA is eliminated, or in any way restricted, the Department shall have the option, at its sole discretion, to amend, rescind, suspend, or terminate this NOFA and any associated funding pursuant to the provision set forth immediately above.

This NOFA is not a commitment of funds to any Activity or Applicant and the submission of an application does not guarantee an award to an Applicant.

V. Application Threshold and Initial Requirements
All applications are required to meet and pass threshold requirements at the time of application submission, as determined by the Department. Over-the-Counter applications that do not meet threshold will not be reviewed for award and may be immediately disqualified or reverted to draft. Competitive Applications that do not meet threshold will not move on to scoring and may be immediately disqualified.

The Department strongly recommends a careful review of the application and application instructions PRIOR to beginning the application.

A. Eligible Applicant

1. Applicant must be an Eligible Applicant as defined under Section III. Program Requirements of this NOFA.

Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 17

2. Applicant must demonstrate to the satisfaction of the Department that it is compliant with the financial management requirements of 2 CFR §200.

B. Single Audit
Applicant must provide the Department with its most recent single audit (as submitted to the State Controller’s Office), if applicable. If the Applicant had or has single audit findings identified in the audit, the Applicant must include the remediation plan/agreement; the Applicant will be deemed ineligible for funding through the CDBG program until the findings are resolved or a remediation plan or agreement is established. Any and all single audit findings are included in this evaluation.

This requirement is not limited to federal funds administered by the Department. If an Applicant is not subject to single audit requirements, the Applicant is not required to submit an audit.

If an Applicant is not required to submit an annual single audit, they must provide documentation directly from the State Controller’s Office (SCO) to such effect.

C. Site Control

1. If securing federal funding is contemplated for any stage of a project at the time a project site is acquired, grantee must complete a NEPA environmental review record prior to completing the acquisition. Failure to do this will result in a choice-limiting action, which prohibits the project from receiving any federal funds in the future. If a site is to be acquired for a CDBG-funded project, regardless of whether CDBG funds are used for acquisition or development and construction, evidence of site control must be provided.

Acceptable evidence of site control may be conveyance documentation with substantiation that the transfer is contingent on completion of a NEPA environmental review record and securing federal funds.

Applicant must submit evidence of site control.

2. Construction-related activities must have documented site control for the year in which the application is submitted and for the duration of the Standard Agreement. Public facilities are subject to a five-year no change in use restriction. This restriction will be recorded against the property, will run with the land, and remain in effect regardless of the ownership of the property.

3. If project/activity is in a public right of way or easement, the grantee must submit an opinion of counsel that all necessary rights, easements, and permits have been obtained.

4. If site control is expected to expire during the open activity period, the Applicant must document that either an alternative site will be made available or that the Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 18
activity operators intend to extend or renew the site control on the existing site.

All activities will need to provide proof of intent to extend site control and submit documentation upon site control extension. Site control must be maintained through the operation period of the activity.

5. Acceptable evidence of site control include: a conditional purchase agreement or enforceable option for projects involving acquisition, a deed or lease, or a title report showing ownership of the property vested in the applicable entity. The determination as to what constitutes acceptable evidence of site control shall be made by the Department in its sole discretion.

D. Statement of Assurances (Appendix D)
Applicant must submit the fully executed Certifications and Statement of Assurances (see Appendix D), including the Jurisdiction’s name, initialing all pages [where applicable], and completing the last page. Please review the Statement and confirm compliance with each requirement. Failure to comply with the certifications and assurances may result in disqualification, recapture of federal funds, and/or debarment.

E. Public Participation
Pursuant to 24 CFR §570.486, Applicants must follow CDBG Public Participation regulations. Applicants must provide documentation that the Department’s Citizen Participation Plan requirements have been met. Documentation must include proof of public noticing, information provided during the public meeting, and public comments received during the public participation, including Jurisdiction responses to comments. Additional information about public participation requirements can be found in CDBG Grants Management Manual Chapter 4.

F. Resolution

1. Applicant must submit a completed Authorizing Resolution using the required Department-approved Authorizing Resolution form, which has been duly approved by the Applicant’s governing board. The Authorizing Resolution designates a person or persons responsible for, and authorized to, execute and deliver all documents related to the application of CDBG funds and, if awarded, the execution of a Standard Agreement with the Department.

2. See Appendix C for the Department-approved Authorizing Resolution form as well as instructions on how to complete it.

3. If a governing body must prepare a separate resolution concurrently that conforms to its local standard, it may do so in addition to preparing the Authorizing Resolution form provided by the Department. Applicants must submit their approved resolutions on the form provided by the Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 19
Department by the application due date. Failure to provide an acceptable resolution at the time of application will result in a delay executing the Standard Agreement.

4. Authorized Signatory for Contracts involving a City Jurisdiction Recipient:

Pursuant to California Government Code sections 40601 and 40602, the mayor or mayor pro tempore must sign any written contracts and conveyances made or entered into by the city, unless the city has an ordinance or municipal code provision in effect that specifically allows or designates contracts to be signed by an officer other than the mayor or mayor pro tempore. Accordingly, if the city does not have a city ordinance or municipal code provision described above, then the Department requires that the mayor or mayor pro tempore sign the Standard Agreement as the authorized signer for the city and provide to the Department the Resolution from the City Council authorizing the mayor to sign the Standard Agreement and related documents on behalf of the city. The mayor or mayor pro tempore may not delegate to a third party his or her authority to sign documents unless there is a city ordinance or municipal code provision in effect that expressly authorizes such delegation and a duly authorized resolution reflecting such delegation is provided to the Department.

If the city does have an ordinance or municipal code provision as described above, the Department requires the city to provide a copy of such ordinance or municipal code, as well as the Resolution that indicates the name and title of the city official authorized to sign the Standard Agreement and related documents. The Resolution required by this section must be in form and content acceptable to the Department.

G. TIN
Applicant must submit the required Government Agency Taxpayer ID (TIN) Form found in the Files tab of each program solicitation. The submitted TIN form must include FEIN, accurate payment information to be complete, and must not have been signed more than one (1) year before submission.

H. Budget
Applicant must complete CDBG budget found in the Grants Network portal.

Required budget information includes direct costs only. Direct costs for Activity, GA, and Program Income, if applicable, must be completed and clearly identified. Do not include any information on indirect cost, match, or cost share.

A Budget must be completed for the Main and every Sub Application. Failure to complete the Budget for the Main and every Sub Application may result in an immediate disqualification.

Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 20
I. Sources and Uses Chart
Applicants must submit a Sources and Uses Chart which evidences the commitment of all funds required to complete the applied for CDBG project or program. The application will guide Applicants that are using multiple funding sources to upload a comprehensive Activity Sources and Uses Chart. Grantees may use their own form, or the template Sources and Uses Chart found in the Files tab of the application.

Evidence of commitment of any funding sources other than CDBG needed for a project to be feasible must be uploaded at application.

J. System for Award Management (SAM)
Pursuant to 24 CFR Part 5, all CDBG Applicants are required to verify they and their principals, or any/all persons, contractors, consultants, businesses, subrecipients, etc., that are conducting business with the Applicant are not presently debarred, proposed for debarment, suspended, declared ineligible, or voluntarily excluded from participation in the covered transaction or in any proposal submitted in connection with the covered transaction. Applicants and their partners, contractors, consultants, and subrecipients must register with the System for Award Management (SAM) to do business with the U.S. government and have debarment checks that return a registration status of “Active” and “No Active Exclusion Records” under the Exclusion Summary. See Chapter 5 of the CDBG GMM for additional guidance.

The Department will not award or distribute any CDBG program funds to Applicants and Applicant partners, including contractors, subrecipients, and consultants that are debarred, suspended, proposed for debarment, declared ineligible, voluntarily excluded from participation, and/or unregistered in SAM from federally assisted programs. Applicants are not required to perform debarment checks on individual Applicant or partner employees or individual persons unless that person is acting as a contractor, consultant, subrecipient, or program partner and will be receiving payment directly from CDBG funds. Debarment checks for Applicant and all applicant partners must be completed before award of funds.

K. State Objectives
The Applicant must answer the questions regarding Affirmatively Furthering Fair Housing and Disaster Resiliency in the application form.

L. National Environmental Policy Act of 1969 (NEPA)
Pursuant to 24 CFR 570.604 Environmental Standards, the regulations in 24 CFR Part 58 specify how the National Environmental Policy Act of 1969 (NEPA), must be met. Applicants must demonstrate compliance by submission of a complete, current, and applicable Environmental Review Record with the appropriate level of review form, completed Related Federal Laws and Authority topic worksheets, and all Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 21
supporting documentation. For more information regarding the Related Federal Laws and Authority, please visit the HUD Exchange website.

Required NEPA process, training, and current forms are available on the HUD Exchange website. Additional HUD guidance can be found on the Orientation to Environmental Reviews page and in Chapter 3 of the CDBG Grants Management Manual.

If CDBG funds will be used for GA Activities, a GA NEPA Environmental Review Record must be submitted specifying the applicable exemption in 24 CFR §58.34(a).

For Business Assistance and Housing Assistance activities that operate as a program but, as per HUD, require a Tiered Review process with site specific environmental reviews for NEPA clearance, both a GA NEPA review and Tier 1 NEPA review are required at time of application.

M. Construction Projects
All construction projects applying for funding under this NOFA must demonstrate readiness at the time of application, including but not limited to, the submission of the following items:
• Independent Cost Estimate
• Completed NEPA Environmental Review Record for the project. • Bid-ready Plans and Specs
• Certification from Engineer that Plans and Specs are bid-ready. • Certification from City that bid docs are ready.
• Construction timeline (Gantt Chart preferred)
• Demonstration and Certification that jurisdiction has the capacity and knowledge to manage the project.
• Demonstration and Certification that developer is experienced. • List of required permits including anticipated date of obtaining the permit and any prerequisites needed to obtain the permit. Specifics regarding permit acquisition should be detailed in the application Narrative and Milestones.
• Written commitments for any and all third-party funding that is needed to complete the project.

N. Economic Development (ED) Programs Only
The Applicant must demonstrate capacity and experience to operate an ED Program. Capacity and experience may be documented through one of the following options:

Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 22

1. The Applicant has hired staff that are able to dedicate capacity to the operation of a CDBG-funded ED Program. These staff must have at least:
i) Three years of CDBG ED experience; or
ii) Five years of commercial underwriting experience plus two years of general CDBG experience; -OR2. The Applicant has prepared a draft request for proposals (RFP) or subrecipient selection process for a qualified consultant or nonprofit ED group with direct experience in implementation of the ED activities proposed in the ED Program application.
i) A request for proposals or a subrecipient selection process must be completed within 60 days of applicant’s receipt of the Standard Agreement. A copy of the executed agreement with the selected subrecipient or contractor must be provided to the Department within 120 days of execution of the Standard Agreement. These must be listed as milestones in the application. -OR3. The applicant has identified at least three (3) qualified consultants or nonprofit ED groups with direct experience in implementation of the ED activities proposed in the ED Program application.

4. The Applicant commits to partnering with the Small Business Development Centers or a similar organization that has direct experience in CDBG ED program design, implementation, and commercial underwriting. This commitment will be a resolution, memorandum of understanding, or similar formal statement and will be required at application.

VI. Application and Activity Requirements
A. Federal Cross-Cutting Requirements
At time of application submission, all applications must comply with and provide documentation of HUD’s federal cross-cutting requirements found at 24 CFR §570.600, et seq, and summarized in XII: Federal Program Requirements of this NOFA.

B. Application Verification
Applicants must certify upon submission that their application is true and correct to the best of their knowledge. Selecting an input field or uploading a blank document to circumvent the application requirements invalidates the application certification and will result in immediate disqualification. Applicants that intentionally input false information or that intentionally upload blank documents will have their good standing with the Department revoked and may be determined to be ineligible for other Department funding. Applicants are warned that intentionally Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 23
providing false information to the Department may constitute fraud.

C. Application Submission

1. Applicants are ultimately responsible for what is submitted in an application, even if the application was prepared by a consultant. Applicants that rely on consultants or grant writers to prepare the CDBG application must carefully and thoroughly review the application for completeness and correctness prior to submittal.

2. Applications submitted through the eCivis Grants Network Portal must be submitted by a jurisdiction’s Profile account.

3. All documents requiring signature must be executed by the Authorized Representative identified in the applicant’s Authorizing Resolution.

4. All application certifications must be certified by a staff member of the applying jurisdiction.

5. A complete application consists of one Main Application and at least one Sub Application. Failure to submit a Main or a Sub Application will be considered an incomplete application. Incomplete applications WILL NOT be reviewed. We recommend reaching out to your CDBG representative for confirmation of receipt.

D. Timely Submittal
Applicants are strongly encouraged to give plenty of time for submitting prior to the application cutoff date and at least several hours prior to the cutoff time.

If an input field, upload requirement, or application component is not functioning correctly, or if there are system outages or other system failures prior to submittal, please contact [email protected] as soon as possible prior to the cutoff time to document the issue so that applications are not disqualified due to technical difficulties. Failure to contact the Department with system issues will not exempt Applicants from application verification requirements.

E. Gap Funding
CDBG is intended to provide stop-gap funding for crucial infrastructure, public safety, housing, and social service projects. CDBG funds may not be obligated to Activities that are documented to already have sufficient funding for the Activity as described, or that have identified multiple funding sources for the same costs, resulting in overfunding of the Activity. CDBG funds must be “but-for” funding for every Activity and may not be used to supplant local or state resources. CDBG grant funds cannot be used to replace funds that have been budgeted and/or Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 24
expended from another funding source for the same Activity (i.e., there cannot be any Duplication of Benefit.) Pre-agreement costs are generally eligible provided that the initial funding for those costs is identified as a temporary funding source (such as a loan from a local fund wherein the loan is float-funding the CDBG Activity preagreement costs, but such costs must be repaid so that the temporary loaned funds may be used as originally intended) and that the costs are budgeted to be part of the CDBG Activity.

F. Good Standing
The Applicant, and any co-Applicant, together with all respective affiliates, must be in good standing with the Department (i.e., are current on all loan and/or grant obligations, have a satisfactory past performance history in all their prior dealings with the Department, and are in full compliance with all Department contracts and reporting requirements). Applicants not meeting the foregoing requirements shall be ineligible to apply for or receive funding under this NOFA.

G. Racial Equity
Applicants should prioritize the advancement of racial equity in all CDBG programs and across systems and units of government in the Jurisdiction. The Department asks Applicants to be leaders in the community, facilitating partnerships among service organizations, housing providers, units of government, businesses, the homelessness response system, and other partners to promote racial equity practices.

All Applicants must identify the work performed to ensure racial equity in access to programs, projects, and activities funded with CDBG resources. Applicants must commit to analyzing disproportionality in access to housing, access to services, quality of service provision, and desired outcomes in Programs and Projects and affirmatively further equitable access, quality of service provision and outcomes for protected classes, including but not limited to Black, Native and Indigenous, Latino/Latina/ Latinx, Asian, Pacific Islanders, and other people of color who have been historically marginalized and are disproportionately impacted by housing segregation, poverty, and homelessness.

Applicants cannot simply rely on delivering a standardization of services to address equity. Applicants must commit to reviewing their current policies and procedures and examining available data to ensure all eligible persons receive equitable services, and support, and are served with dignity, respect, and compassion regardless of circumstances, ability, or identity.

When applying for 2024 CDBG funds, Applicants should consider:

Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 25

1. What are the community’s racial demographics and the demographics of those experiencing homelessness, housing, and economic insecurity?

2. What are the outcomes of the CDBG programs based on race? What are the requirements for all sub-grantees to look at data to determine racial disparities and then put a plan in place to address them?

3. How do underserved and marginalized communities learn about and access the CDBG program? What marketing and communication strategies are used to increase equitable access to CDBG programming?

4. How does the grant-making process include prioritization for programs that are addressing the disproportionate impacts that housing insecurity, homelessness, economic insecurity, lack of access to equitable health care, and COVID-19 has on communities of color, particularly Black, Latinx, Asian, Pacific Islander, and Native and Indigenous communities?

5. How are the voices of Black, Latinx, Asian, Pacific Islander, and Native and Indigenous communities and those having lived with the experience of housing insecurity, homelessness and economic insecurity being centered in a meaningful, sustained way in creating effective approaches to addressing these challenges? How are they involved in the funding decision-making process?

6. How are these funds accessible to smaller and non-traditional organizations that have historically been serving communities of color but may not have previously participated formally in government grant programs? How would these funds address the capacity of organizations that are led by Black, Latinx, Asian, Pacific Islander, and Native and Indigenous people?

7. At application, applicants should provide a list of organizations with which the jurisdiction has partnerships that are addressing racial equity in the housing and homelessness response system, the Economic Development sector, and the health care sector and describe how you partner with them.

The Department may require successful Applicants to submit related racial and ethnic data metrics of their CDBG programming on a quarterly reporting basis.

H. Homelessness Assistance
If you are seeking funding for homelessness assistance, generally defined as activities falling under matrix codes 03C or 03T, you must be a participating member of your local homelessness Continuum of Care (CoC). To demonstrate this, please submit a letter on CoC letterhead signed by the CoC coordinator that states that your jurisdiction is a participating member of the Continuum of Care.

I. Scoring
Qualifying Competitive Applications will be scored according to the evaluation Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 26
criteria outlined in Appendix F. Applications requiring the least number of corrections will score higher than applications needing corrections.

1. Community Need Score (Formerly known as Needs Score) Community Need Score use publicly available data from the U.S. Census Bureau's American Community Survey to measure poverty, housing, and ED needs. These statistics are used to rank all eligible Non-Entitlement Jurisdictions and the rankings are translated into numeric scores. The score summarizes the severity of a community's need for a specific Activity relative to other communities. The Department will prepare the Community Need Score and provides the scores as Appendix A to this NOFA.

2. Scoring (Formerly known as Activity Readiness Score) Activity readiness is an indicator of Applicant preparedness for Activity implementation. The Scoring Matrix is provided as Appendix F to this NOFA. i) Applicants are expected to have necessary contracts and subrecipient agreements in place at the time of application submittal. Fully executed contracts and agreements will score higher than draft contracts and agreements. Applicants that will not be using contracts or subrecipient providers to carry out the Activity and will instead use Applicant staff must clearly document that staff have the experience and capacity necessary to successfully complete the Activity. Documentation may include position description(s) for the identified staff, resumes, or Curriculum Vitae for each staff person involved in the implementation of the Activity, organizational chart, and estimated workload.

Qualifying Competitive Applications will be ranked based on highest score.

Applicants will be notified of their point score and the Final Award List will be posted to the CDBG webpage.

J. Readiness
Housing and Economic Development Program applications must demonstrate readiness to be considered for funding. To be considered “ready,” a program will need to provide the following at application submission:

1. Draft or final program guidelines,

2. An underwriter either secured or a draft RFP/RFQ to be released within 60 days of Standard Agreement execution by the Department, and

3. A marketing plan/strategy.

VII. Application Submission
A. Workshops
The Department is conducting a series of both live and pre-recorded application Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 27
workshops. These workshops will include training on:
i) Resolutions: What is required and why
ii) Public Participation
iii) How to complete the correct level of Environmental Review iv) How to pull a debarment check
v) How to pick the correct National Objective
vi) How to pick the correct Matrix Code
vii) How to write a narrative and milestones
viii) Single Audit
ix) How to address racial equity in your CDBG funded projects and programs x) Completing the 2024 NOFA Application and Budget
xi) CDBG 2024 NOFA Review
Applicants are required to attend these workshop sessions. It is important to attend and engage in the live webinars to ensure a complete and accurate application is submitted. If they are unable to attend the live virtual workshop, Applicants must certify that they have reviewed these workshops on the CDBG website. The website also provides Training and Technical Assistance materials on the CDBG program, the CDBG Program Redesign, using Grants Network, and preparing a CDBG program application in Grants Network.

Excessive corrections may result in disqualification, or an application being reverted to draft to reapply. Please visit the Department’s website for upcoming information.

B. Submission Process
Applicants must follow instructions in this NOFA, the online application, and the CDBG program Guidelines. The Department strongly encourages Applicants to have all required documents on hand when completing the application. Failure to follow instructions and timely submit all required documentation will result in disqualification. Once submitted, applications must stand on their own. It is the Applicant’s responsibility to ensure that the submitted application is clear, complete, and accurate. Department staff may request clarifying information but are unable to accept any new documentation that would provide an unfair advantage over other applications. It is strongly recommended that all documents be reviewed and saved to their own electronic files PRIOR to submission.

The CDBG Application and all required attachments must be submitted to the Department through the eCivis Portal. Applicants must certify that all information is Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 28
true and complete to the best of their knowledge, under penalty of perjury. Per 83 FR 5848 “Any person who knowingly makes a false claim or statement to HUD may be subject to civil or criminal penalties under 18 U.S.C. §287, 1001 and 31 U.S.C. §3729.’’
Applicants that do not have an account with the eCivis Portal should create an account through the eCivis website. Use the “Create an account” option to initiate a profile. See the available training on the CDBG webpage to learn how to open an account. There is no cost associated with an eCivis Portal account.

A complete application consists of one Main Application and at least one Sub Application. Failure to submit a Main or a Sub Application will be considered an incomplete application. Incomplete applications WILL NOT be reviewed. We recommend reaching out to your CDBG representative or [email protected] for confirmation of receipt.

C. Applicant Responsibility
It is the duty and responsibility of each Applicant to review the provisions, requirements, and limitations of all funding sources applied for and obtained for a particular project, program, or activity to ensure that each and every requirement of those funding sources is compatible with all Department program requirements and restrictions. Incompatibility of funding sources may result in the denial or cancellation of an award or may result in the placement of conditions or limitations on an award, all as determined by Department in its sole and absolute discretion.

D. Disclosure of Application
Information provided in the Application will become public record available for review by the public pursuant to the California Public Records Act (GC §7920, et. seq). As such, the Department may disclose any materials provided by the Applicant to any person making a request under this Act, without prior notice to the Applicant. The Department cautions Applicants to use discretion in providing information not specifically requested, including, but not limited to, bank account numbers, personal phone numbers, home addresses, or other personally identifying information (PII).

By providing this information to the Department, the Applicant is waiving any claims of confidentiality, and consents to the Department’s disclosure of the Applicant’s material upon receipt of a Public Records Act request and without advance notice to the Applicant.

VIII. Application Review
All applications submitted by the application deadline (Competitive Applications) or Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 29
until funds are exhausted (OTC Applications) that pass the Threshold evaluation phase will be reviewed for Activity eligibility. Activities that do not meet program eligibility requirements will be disqualified for funding.

The Department reserves the right, at its sole discretion, to suspend, amend, or modify the provisions of this NOFA at any time, including, without limitation, the amount of funds available hereunder. This includes, but is not limited to, authorizing an eligible increase in funding to any Applicant after the Department makes an award under this NOFA.

A. Review Process

1. OTC Applications
i) Applications will be reviewed in the order received for minimum Threshold Requirements.
ii) If an application meets the minimum Threshold Requirements, funds may be allocated for an award.
iii) Once all funds are allocated and the Department has announced that all funds have been exhausted, additional OTC Applications may not be reviewed.

2. Competitive Applications
i) All applications will be reviewed for minimum Threshold Requirements as outlined in this NOFA.
ii) Applications that meet minimum Threshold Requirements will be scored as outlined in Appendix F - CDBG Scoring Matrix.

IX. Award Recommendations
Applications that are eligible, complete, timely submitted, and that satisfy all threshold requirements may be recommended for funding, subject to the availability of funds for the activity(ies) applied for. Applicants recommended for award will officially be notified of awards via an award letter sent via email. Subsequently, the grantee will receive award notification through the eCivis Grants Network. The award notification will include instructions for accepting or declining the award, as well as an executable Standard Agreement. Applicants that are not recommended for awards or that fail threshold will be officially notified via email that their application was not awarded or failed to pass threshold. The Final Award List will be posted on the Department’s CDBG webpage. Applicants may request a copy of their application reviews after the review has been completed and the Applicant has been notified of the results.

X. Appeal Criteria and Process
Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 30
Any request to appeal the Department’s decision regarding an application shall be reviewed for compliance with the Guidelines and the NOFA. All decisions rendered shall be final, binding, and conclusive, and shall constitute the final action of the Department.

The Department will provide opportunity to appeal any disagreed points assessment, pursuant to the appeals process as set forth in the NOFA. Disqualifying threshold determinations shall also follow a similar process, which shall be set forth in greater detail in the NOFA. For reference, all such appeals must be received by the Department no later than five (5) business days from the date of the Department’s threshold review, and/or initial score letter, as applicable, representing the Department’s decision made in response to the application.

A. Competitive Application Appeals

1. Basis of Appeals
i) Applicants may appeal HCD’s written determination that an application is incomplete, has failed threshold review, or has otherwise been determined to provide an insufficient basis for an award (including point scoring and tie breaker).
ii) At the sole discretion of the Department, the Department’s written determination may include a request for clarifying and/or corrective information. For purposes of this section, “clarifying information” includes information and/or documentation that resolves ambiguities in any application materials that will inform the Department’s threshold, scoring, and feasibility determinations. iii) No Applicant shall have the right to appeal a decision of HCD relating to another Applicant’s application (e.g., eligibility, award).
iv) Any request to appeal HCD’s decision regarding an application shall be reviewed for compliance with the Guidelines and this NOFA. All decisions rendered shall be made by the Program Manager or his/her designee. The decision shall be final, binding, and conclusive, and shall constitute the final action of HCD.
v) The appeal process provided herein applies solely to decisions of HCD made pursuant to this NOFA.

2. Process
i) To file an appeal, Applicants must submit to HCD, by the deadline set forth below, a written appeal which states all relevant facts, arguments, and evidence upon which the appeal is based. Furthermore, the Applicant must provide a detailed reference to the area or areas of the application that provide clarification and substantiation for the basis of the appeal. No new or additional Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 31
information will be considered if this information would result in a Competitive advantage to an Applicant. Once the written appeal is submitted to HCD, no further information or materials will be accepted or considered thereafter.

Appeals are to be submitted to HCD at [email protected] according to the deadline set forth in HCD review letters.

3. Filing Deadline
i) Appeals must be received by HCD no later than five (5) business days from the date of HCD’s threshold review, or initial score letters, as applicable, representing HCD’s decision made in response to the application.

B. OTC Application Appeals

1. Basis of Appeals
i) Applicants may appeal HCD’s written determination that an application is incomplete, has failed threshold review, or has otherwise been determined to provide an insufficient basis for an award.
ii) At the sole discretion of HCD, the HCD’s written determination may include a request for clarifying and/or corrective information. For purposes of this section, “clarifying information” includes information and/or documentation that resolves ambiguities in any application materials that will inform HCD’s determinations. iii) No Applicant shall have the right to appeal a decision of HCD relating to another Applicant’s application (e.g., eligibility, award, etc.) iv) Any request to appeal HCD’s decision regarding an application shall be reviewed for compliance with the Policies and Procedures and this NOFA. All decisions rendered shall be made by the Program Manager or his/her designee. The decision shall be final, binding, and conclusive, and shall constitute the final action of HCD.
v) The appeal process provided herein applies solely to decisions of HCD made pursuant to this NOFA.

2. Process
i) To file an appeal, Applicants must submit to HCD, by the deadline set forth below, a written appeal which states all relevant facts, arguments, and evidence upon which the appeal is based. Furthermore, the Applicant must provide a detailed reference to the area or areas of the application that provide clarification and substantiation for the basis of the appeal. No new or additional information will be considered if this information would result in a Competitive Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 32
advantage to an Applicant. Once the written appeal is submitted to HCD, no further information or materials will be accepted or considered thereafter.

Appeals are to be submitted to HCD at [email protected] according to the deadline set forth in HCD’s written determination letters.

3. Filing Deadline
i) Appeals must be received by HCD no later than five (5) business days from the date of HCD’s written determination letter made in response to the application.

XI. Awards Announcement and Grant Implementation
A. Awards Announcements
The Department anticipates awards will be announced no later than May 2025. OTC awards will be announced on a rolling basis as applications are recommended for funding until funds are exhausted. All awards are subject to availability of funds and compliance with all applicable legal requirements of the Program. Until all awards are announced, the CDBG staff will not be able to discuss applications or the status of applications.

B. Standard Agreements
Successful Applicants (awardees) will enter into a Standard Agreement with the Department. A draft, sample Standard Agreement is included as Appendix E to this NOFA. The Standard Agreement contains all the relevant state and federal requirements, Activity performance and management requirements, and disbursement requirements. The form and content of the sample draft Standard Agreement is subject to revision without prior notice. A condition of award will be that a Standard Agreement must be executed by the awardee within 30 days (contracting period) of the awardee’s receipt of the Standard Agreement(s). Failure to execute and return the Standard Agreement(s) to the Department within the contracting period may result in award cancellation. Award cancellations are final.

Funding awarded through this NOFA will have a 33-month (two (2) years and nine (9) months) expenditure and liquidation period.

To ensure that the Standard Agreement(s) are being sent to the correct individual, Applicants MUST complete ALL required sections of the profile section of the application and must let the Department know in writing if the contact information has changed since the time of application submittal by emailing [email protected]. Standard Agreements and communication during this process will be with the email address designated in the profile section of the Application.

XII. Federal Program Requirements
Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 33
A. Federal Cross-Cutting Requirements
The CDBG program is administered under the rules and regulations promulgated primarily in 24 CFR §570.600, et seq. These primary regulations are known as the federal cross-cutting requirements and form the basis of the programmatic requirements. The Department incorporates all federal cross-cutting requirements into the state CDBG program, and the regulations in Part 570 are translated into required actions on the part of all Grantees of the state CDBG program.

The following is a list of some of the most commonly applicable federal cross-cutting requirements. This is not an exhaustive list.
i) Environmental Standards (based on National Environmental Policy Act of 1969 [NEPA])
ii) Labor Standards (Davis-Bacon and related laws)
iii) Achieving a HUD National Objective
iv) Public participation requirements
v) Fair Housing and Affirmatively Furthering Fair Housing vi) Equal Opportunity and Non-Discrimination in federal Grant Programs vii) Federal Procurement Guidelines
viii) National Flood Insurance Program compliance
ix) Relocation and displacement requirements
x) Employment and Contracting Opportunities Section 3 Compliance xi) Lead-based paint requirements
xii) No use of debarred, ineligible, or suspended contractors or sub-recipients xiii) Uniform Administrative Requirements and Cost Principles xiv) Conflict of interest prohibitions
xv) Compliance with the Architectural Barriers Act and the Americans with Disabilities Act
xvi) Compliance with Eligibility Restrictions for certain resident aliens xvii) Federal reporting requirements
xviii) Grant and subrecipient monitoring requirements
xix) Build America, Buy America Act (BABA) requirements B. Build America, Buy America Act (BABA)
Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 34
On November 15, 2021, the Build America, Buy America Act (the Act) was enacted as part of the Infrastructure Investment and Jobs Act (IIJA). Pub. L. 117-58. The Act establishes a domestic content procurement preference, the BAP, for federal programs that permit federal financial assistance to be used for infrastructure projects. In Section 70912, the Act further defines a project to include “the construction, alteration, maintenance, or repair of infrastructure in the United States” and includes within the definition of infrastructure those items traditionally included along with buildings and real property.

Starting May 14, 2022, new awards of Federal financial assistance from a program for infrastructure, as defined below, and any of those funds obligated by the grantee, are covered under the Build America, Buy America (BABA) provisions of the Act, 41 U.S.C. 8301. Note, while HUD has issued a waiver of the application of the BAP through HUD’s Notice, “General Applicability Waiver of Build America, Buy America Provisions as Applied to Recipients of HUD Federal Financial Assistance” (87 FR 26219), HUD will begin requiring compliance with BAP for all new funds obligated on or after November 14, 2022, unless covered by a subsequent waiver. Additional details on fulfilling the BABA requirements can be found on HUD’s website Build America, Buy America (BABA).

The following should be included in all contracts and agreements with Subrecipients, contractors, developers and subgrantees, and in any procurement bid/contract documents to ensure BABA compliance by subgrantees, developers and/or contractors:

The parties to this contract must comply with the requirements of the Build America, Buy America (BABA) Act, 41 U.S.C. 8301 note, and all applicable rules and notices, as may be amended, if applicable to the Grantee’s infrastructure project.* Pursuant to HUD’s Notice, “Public Interest Phased Implementation Waiver for FY 2022 and 2023 of Build America, Buy America Provisions as Applied to Recipients of HUD Federal Financial Assistance” (88 Financial Report 17001), any funds obligated by HUD on or after the applicable listed effective dates, are subject to BABA requirements, unless excepted by a waiver.
*The term “infrastructure project,” in this context, is defined in 2 CFR 184.3 and means any activity related to the construction, alteration, maintenance, or repair of infrastructure in the United States regardless of whether infrastructure is the primary purpose of the project.

C. Relocation Plan Requirements
Applicants engaging in project-specific activities that may or will cause the temporary or permanent relocation and displacement of persons, property, or businesses must Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 35
provide a project-specific relocation plan as part of the application. The plan must meet the standards established in the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (URA) and any applicable State relocation requirements. Applicants must successfully demonstrate that they have met URA requirements prior to the start of the project or displacement Activity.

Applicants must include relocation costs in project budgets.

Applicants must provide relocation assistance to persons who may be displaced if the Activity in the grant application is funded. This plan must outline how the Grantee will enforce and manage the project’s relocation and displacement activities and estimate what relocation benefits will be required so those costs can be included in the project’s development budget.

D. Procurement Requirements
Pursuant to 24 CFR §570.489(g), all Grantees must comply with federal procurement requirements. The Department will review the Grantee’s procurement documents for services (i.e., administrative sub-contractor, Davis-Bacon consultant, etc.) at time of monitoring or upon the Grantee’s request.

Requirements for federal procurement can be found at 2 CFR §200.317-327.

Applicants are responsible for meeting all federal procurement standards for goods and services funded through federal programs. Failure to meet procurement requirements may result in disqualification, recapture of federal funds, and debarment.

E. False, Fictitious or Fraudulent Claims
Warning: Any person who knowingly makes a false claim or statement to HUD or the Department may be subject to civil or criminal penalties under 18 U.S.C. §287, 1001 and 31 U.S.C. §3729.

1. Detecting, Preventing, and Reporting Fraud
Fraud is a white-collar crime that has a devastating effect on the CDBG program because the CDBG program beneficiaries are victims of this crime when the CDBG program is abused. The Department wants to stop any criminal assault on the CDBG program it administers, and in doing so all CDBG funds go to people it was designed to help and improve their living conditions.

2. Combatting Fraud
The HUD Office of Inspector General (OIG) is committed to protecting HUD’s programs, operations, and beneficiaries from dishonest individuals and organizations.

HUD cannot combat fraud alone; they rely on Department and CDBG NOFA Applicants to combat CDBG program fraud. HUD also relies on Applicants for, Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 36
and people receiving, HUD benefits, such as: tenants receiving rental assistance, borrowers with HUD insured loans, or citizens having their communities restored using HUD grants.

The HUD OIG Hotline number is 1-800-347-3735. This is the primary means to submit allegations of fraud, waste, abuse, mismanagement, or Whistleblower related matters for the CDBG program to the OIG.

HUD OIG accepts reports of fraud, waste, abuse, or mismanagement in the CDBG program from HUD employees, anyone administering the CDGB program, anyone working in the CDBG program, contractors, and the public.

You can report mismanagement or violations of law, rules, or regulations by HUD employees or program participants.

Fraud, Waste and Abuse in the CDBG program and its operation may be reported in one of the following four (4) ways:
i) By email:
[email protected]
ii) By phone:

Call toll free: 1-800-347-3735
iii) By fax:
202-708-4829
iv) By mail: Department of Housing & Urban Development
HUD OIG, Office of Investigation, Room 1200
Field Office
One Sansome Street
San Francisco, CA 94104
(213) 534-2518
HUD OIG, Office of Investigation
Suite 4070
Regional Office
300 North Los Angeles Street
Los Angeles, CA 90012
(213) 534-2518
F. Whistleblower Protection Acts
(Federal Whistleblower Protection Act (5 U.S.C Section 2302(b)(8)) The Federal Whistleblower Protection Act (WPA) protects employees from retaliation for making protected disclosures. The WPA also provides penalties for supervisors who retaliate against Whistleblowers.

Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 37

1. A disclosure is protected under the WPA if the employee discloses information the employee reasonably believes to be evidence of:
i) a violation of any law, rule, or regulation,
ii) gross mismanagement,
iii) a gross waste of funds,
iv) an abuse of authority, or
v) a substantial and specific danger to public health or safety.

2. In general, an employee or Applicant may make a protected disclosure to anyone, including non-governmental audiences, unless the information is classified or specifically prohibited by law from release. Options for making a protected disclosure include:
i) Informing a supervisor or someone higher up in management, ii) Submitting a complaint to the OIG by emailing the OIG at [email protected], iii) Filing a complaint with the Office of Special Counsel (OSC) http://www.osc.gov/
G. The California Whistleblower Protection Act
The California Whistleblower Protection Act (Title 2, Division 1, Chapter 6.5, Article 3.5, Gov. Code §§ 8548-8548.5) authorizes the California State Auditor to receive complaints from state employees and members of the public who wish to report an improper governmental activity. An "improper governmental activity" is any action by a state agency or any action by a state employee directly related to state government that:
i) Violates any state or federal law or regulation,
ii) Violates an Executive Order of the Governor, a California Rule of Court, or any policy or procedure required by the State Administrative Manual or State Contracting Manual, or
iii) Is economically wasteful or involves gross misconduct, incompetency, or inefficiency. Complaints received by the State Auditor are confidential, and the identity of the complainant may not be revealed without the complainant's permission, aside from to an appropriate law enforcement agency conducting a criminal investigation.

There are many ways to file a complaint:
i) By Telephone:

You may call the Whistleblower Hotline at (800) 952-5665 to file a complaint by talking to one of the State Auditor's employees. The hotline generally is staffed Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 38
Monday through Friday from 8:00 a.m. to 5:00 p.m. If you call when the hotline is not being staffed, or staff is occupied with other calls, you may leave a voicemail message requesting a return call.
ii) By Mail or Facsimile:

You may file a complaint in the form of a letter to the State Auditor addressed as follows:

Investigations
California State Auditor
P.O. Box 1019
Sacramento, CA 95812
Or you may fax the letter to the State Auditor at (916) 322-2603. iii) As an alternative, you may complete the electronic version of the complaint form (which is available on the State Auditor website at auditor.ca.gov), print it out, and return it by mail or facsimile as stated above. iv) Online:

Although the State Auditor does not accept complaints by e-mail, you may file a complaint online at
https://app.scoutcms.com/CaStateAuditorWhistleblowerComplaint v) The State Auditor will not undertake an investigation unless there is a basis for believing that your complaint has sufficient merit to warrant spending resources on an investigation. Your complaint should therefore include:
a.A clear and concise statement of what you Compare alleging to be improper activity and why you believe it is improper.
b.The name or other information that clearly identifies the person you are alleging has acted improperly and the department where that person works.
c. The names and contact information for any witnesses who can confirm the truth of what you are saying.
d.Copies of any documents that will support what you are saying. (You should not submit original documents, as they cannot be returned.)
Agenda Item #11.2.

California Department of Housing and Community Development 2024 Community Development Block Grant Program NOFA 39
XIII. LIST OF APPENDICES
Appendices are located in the eCivis Grants Network under the ‘Files’ tab on within each specific program solicitation.

Appendix A: Community Need Score
Appendix B: Housing Element and Growth Control Requirements Appendix C: Resolution Template of the Governing Body
Appendix D: 2024 CDBG Application Certifications and Statement of Assurances Appendix E: Sample DRAFT Standard Agreement
Appendix F: 2024 CDBG Scoring Matrix
Appendix G: General Admin Calculator
Agenda Item #11.2.

Agenda Item #11.2.

Agenda Item #11.2.

Agenda Item #11.2.

Agenda Report to the City Council
Agenda Section: NEW BUSINESS
Department: Human Resources
DATE: October 8, 2024
FROM: Mandy Kellogg, Administrative Services Director
SUBJECT: Discussion Regarding Existing and Potential Shared Services with Napa County Agencies, and Presentation
from Center for Public Safety Management (CPSM) of the
Analysis of Fire and Emergency Medical Services (EMS).

RECOMMENDED
ACTION:

Receive and file.

PREVIOUS COUNCIL
ACTION:

Resolution 2023-59: Execution of a Professional Services Agreement with CPSM to perform and analysis of fire and emergency medical services for the City.

STATEMENT OF THE
PURPOSE:

To provide an update of exploration of shared services
with Napa County governmental agencies and receive a
report from CPSM regarding Fire services.

FINANCIAL IMPACT: There is no financial impact associated with this report.

BACKGROUND:

Shared services between government agencies involves the consolidation and centralization of functions, resources, and operations to improve efficiency, reduce costs, and enhance service delivery. Shared services can enable agencies to access specialized expertise that they may not have in-house. By leveraging the skills and knowledge available in a shared service model, agencies can offer services that would otherwise be beyond their capabilities. This not only broadens the range of services that can be provided but also enhances the quality and effectiveness of operations.

The size of the city limits the range of skills and expertise that can be obtained internally and therefore, in addition to the above, the city routinely uses a variety of private firms to provide services or augment City staff. For example, all road paving is performed by private firms, sports games are refereed by contractors, and several firms provide Planning and Community Engagement services, etc.

Challenges can arise with shared services. Transitioning to shared services model can be complex, require significant planning and coordination, and require effective change management strategies to assist with adapting to new systems, processes, and organization structures. Therefore, before implementing a shared service model, it is crucial to conduct a thorough evaluation to ensure that it meets the needs of the organization and is viable in practice. Thoroughly evaluating the shared service model ensures that the organization is making a well-informed decision that will bring tangible benefits without compromising service quality.

Agenda Item #13.1.

The table below provides a summary of the City's existing shared services.

Function Agency Description
Dispatch - Fire Cal-Fire Fire and emergency dispatch
services.

Dispatch -
Police City of Calistoga
St. Helena Dispatch services are
currently co-located at the City of
Calistoga on a temporary basis.

Fire Protection Napa County
St. Helena provides services to the
County for areas adjacent to the city
limits.

Housing City of Napa Housing
Authority Affordable housing services.

Stormwater
Napa County Flood
Control & Water
Conservation District
Controls flood and storm waters in
Napa County.

Benefits and
Risk
Management
California
Intergovernmental Risk
Authority (CIRA)
Risk management, workers
compensation, and benefits programs.

At the direction of the City Council and consistent with the Council Goals #5 - Enhance Quality of Life for residents and Goal 7 Optimize Organizational Effectiveness, staff has been exploring shared service models for several departments, including Police, Fire, Administrative Services (Human Resources), Community Services (Library and Parks & Recreation), and Public Works (Water-Wastewater). The goal in doing so is to improve the quality of services, create efficiencies, and potentially even reduce the cost of services to the community. Likewise, staff continually seeks ways to break down departmental silos to increase collaboration, innovation, and staff morale.

Fire services are very important to all communities and especially ours since we are in a region that is prone to fires with several portions that are considered Wildland Urban Interface (WUI). The county has several fire agencies, and a Cal-Fire station located approximately 4 miles to the north of the City, provides fire services to the County. The Cal-Fire station has a robust staffing component and considerable fire suppression assets. The City of St. Helena has had a very active and beloved volunteer firefighting force and since 2016 has steadily transitioned to a full-time fire department. Therefore, the cost of providing fire services to the community from the City's General Fund has gone from approximately $582,000 in FY 2015-16 to approximately $2.9 million annually, when the City brought on board 6 full-time firefighters and 6 full-time equivalent part-time firefighters from 2018 to 2021 to staff shifts and provide round-theclock fire protection services. This change was driven by the post-fires-realization that the community needed more consistent and stable staffing for fire protection. Staffing and therefore services had to be cut in several other departments to accommodate the cost increase.

Agenda Item #13.1.

In 2023, the City entered into its first labor agreement with its professional firefighters. It was therefore prudent to evaluate the City's fire service delivery model along with other city services.

DISCUSSION:

In 2023, at the direction of the City Council, staff began to undertake an evaluation of various City services to determine if a different delivery model would enable the City to provide better services to the community - and potentially at a lower cost. The following is a summary of the outcome of the evaluation process:

Library Services
Given the public comments of some residents, the idea of contracting with the county for library services was appraised for its viability and quickly dismissed in favor of exploring more localized consolidation to enhance service quality. Staff arrived at that conclusion because contracting with the county would not eliminate or reduce staffing costs for the St. Helena library. While the City would benefit from the county's broad as well as specialized expertise, the City already has access to similar resources through consortium memberships. Even if the City chose to contract with the county, it would still need to reimburse the county for staffing and managing the library. Additionally, the City would remain responsible for maintaining the physical building, equipment, online services, and materials.

Instead of contracting out library services to the county, when the opportunity presented itself, staff began exploring an internal consolidation. In many communities, library operations have been merged with that of other functions and the City Manager had personally been involved in different stages of consolidations in other cities (Beverly Hills, San Rafael, and Richmond). Since it had been effective for these agencies and many others, it would seem to be even more logical and pragmatic for a significantly smaller city. Over many months staff participated in an engagement process and sought input from various stakeholders including the Library Board, the Friends and Foundation, the Parks and Rec Commission, City staff, and other resident groups.

Staff’s initial analysis showed that while the consolidation would not save the City money, the potential for improvements in the delivery of services was high. On March 26, 2024, the City Council gave its approval for the formation of a new department initially to be called the Department of Community Services as an umbrella for several functions including library, parks and recreation, grants, and communications. With the hire of a Deputy Director of Community Services – Library, it is estimated that the consolidation will save approximately $11,000 for the current Fiscal Year.

Human Resources
The City has not had sufficient monies to fund the HR Manager position and therefore that position has been frozen. So, currently the role of an HR Manager is primarily performed by the Director of Administrative Services. Since she has other responsibilities, she does not have the capacity to perform all the duties encompassed Agenda Item #13.1.

by the HR Manager role. Therefore, staff began to procure specialized services from Regional Government Services (RGS) including recruitment assistance and disability and leaves management. Additionally, the City explored the cooperating with neighboring cities for the services of a HR Director. Unfortunately, the cost of even partially funding a HR Director position at another city was too high and it was deemed to be unaffordable relative to other needs. At this time the City has agreed to collaborate with the City of Napa, Napa County, and other cities in the county on contributing to a county-led comprehensive training and staff development program.

Water Treatment Plant Management and Staffing
For several years, the City has had difficulty in filling positions to support the water treatment operations; this along with general underinvestment are the root causes of many problems experienced by the water enterprise. The classifications are specialized with strict state-mandated certification requirements. This means that there are very few individuals who qualify for these critical positions. This is compounded by the City’s geographic location, cost of living, and comparatively low compensation scales. As a result, the City has been using the services of Operational Technical Services (OTS) professionals to serve at the City’s water treatment plant. While obtaining qualified personnel from external sources was necessary, it is not sustainable because of the significantly higher cost. The City therefore explored contracting with neighboring cities for the management and staffing of the water treatment function to no avail. Therefore, the City increased the compensation by 14.2% for the Plant Operators and 20.4% for the Chief Plant Operator classifications and conducted more aggressive marketing efforts, including a direct mail campaign that targeted certified individuals throughout the state. As a result of these efforts, the Water Treatment Division is finally fully staffed.

The City also increased the compensation by approximately 9.0% for the Underground Utility classifications. The position of the Underground Utilities Superintendent remains vacant despite conducting several rounds of recruitment. Consequently, staff will be pursuing filling the vacancy temporarily with an OTS professional.

Wastewater Treatment Plant Management and Staffing
Similar to the experience in the water treatment operations, the City, because of various constraints listed above including low compensation rates, has been unable to fully staff the wastewater treatment function. Over the last few years, the City has augmented its staff with professionals from OTS especially for the provision of Chief Plant Operator (CPO) services. As mentioned earlier, this is fiscally unsustainable, and staff has explored alternate models including seeking the assistance of neighboring agencies.

The City is open to exploratory discussions with a nearby agency for contract services.

Police Services
Similar to library services, some community members believe that the Sheriff’s Department could provide better and much cheaper alternative to having an independent police department. That is incorrect. Staff communicated with the Sheriff's Department and reviewed a report prepared for the City of Calistoga by the Matrix Consulting Group, as part of the police services evaluation process. Staff concluded that, while contracting with the Sherriff's Department for police services is viable, it Agenda Item #13.1.

would not have saved the City any money. Further the City's residents, businesses, and visitors would in effect have a lower level of service since the law enforcement personnel assigned to the City would also be responsible for coverage outside the City and may not be able to respond as quickly to developing events within the City as they do now. So, even though the City could be an integral part of a larger police agency, the fact that the City can already tap those resources when needed negated any need to have the Sheriff's Department take over police services in St. Helena.

While staff continues to believe the current model serves the City well, we also believe that at some point, the cities of Calistoga and St. Helena may want to explore a comprehensive consolidation of police functions. This is because the police departments of the two cities have a long tradition of supporting each other and cooperating on public safety matters and there are practical considerations as well.

Having a larger Upvalley police force under a unified command will provide for greater specialization, enhanced training, and better growth opportunities (and therefore greater retention of high performers). A larger and well-rounded Upvalley police force will enhance the ability of police to respond to the wider scope of issues that police departments face today compared to say 50 years ago. A consolidation has the potential of benefiting and improving the quality of life for residents in both communities.

That said, the challenges of any such consolidation should not be underestimated. It will require open dialogue with residents in both communities on the merits of even exploring such a major change (we have learnt lessons from the experience of consolidating the library under the Community Services umbrella). There would need to be a clear understanding of the goals, benefits, as well as downsides of any such consolidation. Stakeholders would need to be brought into the process right from the start, especially the unions representing employees in both cities, and a cost analysis and feasibility study would need to be undertaken. Most importantly, the members of City Council for Calistoga and St. Helena along with the City's managers will need to be open to the value of such a merger. Given the complexities and challenges of such an endeavor, staff is not recommending that the city explore a consolidation at this time.

Police Dispatch
When the City moved its City Hall and Police Department to the current location at the Napa Valley College site in early 2023, dispatch staff had to also be moved from the old city hall site on Main Street. However, it was deemed prudent to not locate them to the new city hall because the site lacked a backup generator which is considered important and previously was required by state rules. The City of Calistoga graciously agreed to host the dispatch staff. The City of Calistoga Police Chief and City Manager worked hard and expended great effort to ensure that our dispatch staff were welcomed, comfortable, and integrated into their operations. The temporary measure was subsequently deemed successful enough to warrant the leadership in the two cities to consider a longer-term agreement and even full consolidation of the dispatch services.

In a cautionary example, despite the best efforts of executives in both cities, and despite transparent negotiations with the respective unions, the parties were not able to Agenda Item #13.1.

construct an agreement that would derive savings and a guarantee of enhanced services. So, the parties chose to abandon the effort and stay with the current temporary mode. It should be noted that this does not preclude some other form of collaboration and/or consolidations with Calistoga or another public agency in the future.

Fire Services
On June 13, 2023, City Council approved a Professional Services Agreement with CPSM to perform an analysis of the City's Fire and EMS. The CPSM team conducted an extensive analysis of the Fire and EMS operational functions, which included the following:
 Examination and analysis of the factors that enhance/impact the department’s current service delivery model.
 Examination and analysis of operational guidelines and their connection to the current service delivery model.
 Discussion of the organization’s strengths, weaknesses, opportunities, and threats as it relates to deployment of resources and response times.  Analysis of Fire Management Zones.
 Analysis all-hazards that will lead to the completion of a Community Risk Assessment.
 Analysis of Standard of Cover Concepts.
 Exploration and analysis of various mission driven specialty fire protection and other response duties such as EMS ground transport, emergency management operations, and technical rescue.

In addition, CPSM was tasked with providing recommendations that the City may consider in changing its current independent Fire and EMS delivery system to an alternative model, either through contracting with an outside agency for these services or considering a public safety model, which utilizes a combined service force in which personnel are trained in providing both fire and law enforcement services through a single agency.

CPSM analyzed performance data provided by the St. Helena Fire Department (SHFD) and also conducted examinations of the department’s operations, while comparing to benchmarks that have been developed by organizations such as the National Fire Protection Association (NFPA), Center for Public Safety Excellence, Inc. (CPSE), the ICMA Center for Performance Measurement, as well as others.

The SHFD operates from a single station and the department is composed of both career personnel and part-time employees. The results of the study showed that while the Fire Department is a relatively small organization with limited resources, it is highly proficient in managing its workload. The Fire Department relies heavily on the recall of off-duty personnel, its part-time workforce, and its mutual aid partners (primarily from neighboring agencies) in meeting service demands. The Fire Department works closely Agenda Item #13.1.

with AMR, a county-contracted private EMS agency, which provides advanced life support (ALS) services and ambulance transports throughout the county. However, as a small agency with limited resources, the Fire Department must interact seamlessly with a multitude of neighboring agencies to provide the appropriate protections to the community, area businesses, and the many tourists who visit the area.

In order to determine the effectiveness of the City's existing fire services model, CPSM reviewed alternative services models that included the following:

1. Contract Services with CAL-Fire

2. Contract Services with County of Napa

3. Public Safety Model (joint police and fire department) The following table provides a cost summary to provide Public Safety services (Fire and Police) under the different models evaluated. It should be noted that the numbers below are now dated since they were originally collected in early 2023 and since then there have been leadership changes at Napa County and at Cal-Fire. Additionally, new labor Memorandums of Understanding (MOUs) have gone into effect, which will necessarily affect the cost. However, the general magnitude of the costs continues to be relevant for evaluation purposes at this point on time.

Description Fire Cost Police Cost Total Cost
Existing Fire & Police
Model $2.69 M $4.49 M $7.18 M
Projected CAL-Fire
Contract $2.48 M $4.49 M $6.97 M
Projected Napa County
Contract $2.44 M $4.49 M $6.93 M
Projected Public Safety
Model $6.29 M $6.29 M
As the above summary shows, the current model is slightly more expensive than contracting with the County of Napa or directly with Cal-Fire. Even though the above analysis indicates that there is potential for saving approximately $1 million per year on fire services by creating a Public Safety (cross-trained police and fire personnel), doing so would be a multiyear and highly complicated endeavor and will likely generate significant community concern. For those reasons, staff is recommending that the City stay with its current model of delivery for fire services. It should be noted that the current model and staff's recommendation to stay with the current model is predicated upon the use of part-time employees who staff one-third and sometimes two-thirds of some shifts. In other words, if the City were to explore adding a third full-time employee to the three-person fire shift, staff would recommend a reevaluation of the City’s options with the goal of delivering better and more efficient services to the community. This was underscored by CPSM as noted below.

Agenda Item #13.1.

After evaluating the City's existing fire services model compared to other service models, CPSM determined that the City's existing fire services model was effective through the use of career and part-time firefighters. In addition, CPSM provided a list of recommendations to help support the City in fulfilling its mission in providing both emergency and nonemergency response.

ENVIRONMENTAL REVIEW: None.

GOAL:

Goal 5: Enhance Quality of Life
Goal 7: Enhance Organizational Effectiveness
Agenda Item #13.1.

CITY OF ST. HELENA

SHARED SERVICES DISCUSSION
October 8, 2024
Agenda Item #13.1.

UNDERSTANDING SHARED SERVICES
Access to
Specialized
Services
Broader Range of
Services
Enhanced Quality
of Operations
Cost Efficiency Improved Focus
on Organization
1 2 3 4 5
Agenda Item #13.1.

Complexity of Transition
Resistance to Change
Need for Thorough Evaluation
Agenda Item #13.1.

EXISTING SHARED SERVICES
Function Agency Description
Dispatch - Fire Cal-Fire Fire and emergency dispatch services Dispatch - Police City of Calistoga St. Helena Dispatch services colocated at City of Calistoga temporarily Fire Protection Napa County St. Helena provides services to the County for areas adjacent to city limits
Housing City of Napa Housing Authority Affordable housing services Stormwater Napa County Flood Control &
Water Conservation District
Controls flood and storm waters in
Napa County
Benefits & Risk
Management
California Intergovernmental
Risk Authority (CIRA)
Risk management, workers
compensation, & benefit programs
Agenda Item #13.1.

EVALUATION

OF CITY

SERVICES
Agenda Item #13.1.

LIBRARY SERVICES
Internal
Consolidation
Contracting
Challenges
Improved
Service Delivery
Agenda Item #13.1.

HUMAN

RESOURCES
Budget
Constraints
Collaboration
Solutions
Countywide
Training Program
Agenda Item #13.1.

WATER & WASTEWATER TREATMENT
Staffing Challenges
Compensation
Adjustments
Regional
Collaboration
Agenda Item #13.1.

POLICE SERVICES
Contracting with
Sheriff’s
Department
Stakeholder
Engagement
Cost Analysis &
Feasibility Study
Consolidating
with Calistoga
Police
Department
Agenda Item #13.1.

POLICE DISPATCH
• Temporary Relocation at City of Calistoga
• Explored Permanent Consolidation
• Lacked Cost Effectiveness
Agenda Item #13.1.

FIRE SERVICES
Contracted with Center for Public Safety Management (CPSM) Evaluated the following:

1. Contract Services with CAL-Fire

2. Contract Services with County of Napa

3. Public Safety Model (joint police and fire department) Agenda Item #13.1.

12 // EXCLUSIVE PROVIDER OF TECHNICAL ASSISTANCE TO ICMA St. Helena Fire Department
October 8, 2024
Tom Wieczorek, Director
Mike Iacona, Manager Fire & EMS
Agenda Item #13.1.

13 // EXCLUSIVE PROVIDER OF TECHNICAL ASSISTANCE TO ICMA Project Objectives:

Review the Existing Service Demand & Deployment Practices.

Evaluate the Organizational Structure & Managerial Oversight.

Determine the effectiveness of Part-time Employees.

Assess the quality of Inter-Agency Joint-Response.

Identify Options for Service Alternatives & Cost Comparisons.

Provide System Analysis and Recommendations.

Agenda Item #13.1.

14 // EXCLUSIVE PROVIDER OF TECHNICAL ASSISTANCE TO ICMA

Limited Workload-mostly EMS and Service Calls (2-3/calls daily).

Transition from Volunteer to Career Department: Very Effective.

Excellent resources: station facility, vehicles & equipment.

Quality leadership, field supervision & organizational culture.

Comprehensive Fire Prevention/Code Review Effort (In-house).

Exceptional cooperation: joint response & mutual aid partners.

Expanded focus on Training & Career Development is needed.

Department Profile and Workload:

Agenda Item #13.1.

15 // EXCLUSIVE PROVIDER OF TECHNICAL ASSISTANCE TO ICMA

Current structure & deployment very effective.

Integration of Career and Part-time personnel - Excellent.

Utilization of Volunteer Association – Very Positive.

Strong Integration with Field Personnel and prevention efforts.

Greater focus needed on performance measures and reporting.

Dispatching is fragmented-Difficult to monitor performance.

Organization & Management:

Agenda Item #13.1.

16 // EXCLUSIVE PROVIDER OF TECHNICAL ASSISTANCE TO ICMA

Career/Part-time model is critical to overall efficiency.

Extensive utilization - approximately 45% of on-duty hours.

Excellent workforce integration - opportunities for expansion.

Realized cost savings – approximately $250,000 annually.

Reduces overtime expenditures (additional savings).

Part-Time Employees:

Agenda Item #13.1.

17 // EXCLUSIVE PROVIDER OF TECHNICAL ASSISTANCE TO ICMA Exceptional joint response arrangements w/AMR & CAL-FIRE.

Frequent mutual aid responses with Calistoga and others.

Approximately 20% of SHFD responses outside city - $82,900.

Effective arrangements for specialized services. (Haz-Mat, etc.) Wildland joint response and resource access is essential.

Strong cooperation with County Emergency Management

Inter-Agency Cooperation:

Agenda Item #13.1.

18 // EXCLUSIVE PROVIDER OF TECHNICAL ASSISTANCE TO ICMA

1. Cooperative Fire Service Agreement with CAL-FIRE.

2. Contract for services through Napa County.

3. Establish a Public Safety Model (Combined Police & Fire).

4. Engage a Private Company to provide fire protection services.

5. Establish a regional Fire/EMS service agency (multi-city).

Alternative Service Options:

Agenda Item #13.1.

19 // EXCLUSIVE PROVIDER OF TECHNICAL ASSISTANCE TO ICMA

Pricing based on personnel & shared costs – Billed Quarterly.

Requires approval by CAL-FIRE Labor Union.

Short-term agreement (2-3 years).

Uncertain impact on Association’s continued affiliation.

1. Agreement with CAL-FIRE:

Agenda Item #13.1.

20 // EXCLUSIVE PROVIDER OF TECHNICAL ASSISTANCE TO ICMA

1. Agreement with CAL-FIRE:

Projected Cost
Current Police Budget (including dispatch) $4,489,352
Fire Personnel Costs (1 Engine/3 Personnel) $2,400,000
Fire Dispatching Services 80,000
TOTAL $6,969,352
Not Included:

Overtime & Supervision
Fire Prevention Services
Payment for Part-time personnel
Capital Replacement
Insurance & Maintenance (Vehicles & Building)
Utilities
Agenda Item #13.1.

21 // EXCLUSIVE PROVIDER OF TECHNICAL ASSISTANCE TO ICMA

CAL-FIRE continues provide services.

Requires approval by County Executive & Bd. of Supervisors.

Pricing varies on the basis of shared costs – negotiable.

Long-term agreement possible.

Limited control of Service Levels & Future Costs.

2. Contract with Napa County:

Agenda Item #13.1.

22 // EXCLUSIVE PROVIDER OF TECHNICAL ASSISTANCE TO ICMA

2. Contract with Napa County:

Projected Cost
Current Police Budget (including dispatch) $4,489,352
Fire Personnel Costs (1 Engine/3 Personnel) $2,400,000
Fire Dispatching Services (50%) 40,000
TOTAL $6,929,352
Not Included:

Overtime & Supervision
Fire Prevention Services
Payment for Part-time personnel
Capital Replacement
Insurance & Maintenance (Vehicles & Building)
Utilities
Agenda Item #13.1.

23 // EXCLUSIVE PROVIDER OF TECHNICAL ASSISTANCE TO ICMA

Multi-year implementation process (3-5 years).

Complex recruitment and training requirements (3-Type’s).

Projected 16 PSO’s to provide combined services (Excludes Dispatch).

Many existing employees will not obtain all certifications.

Joint response & mutual aid may be problematic.

Uncertain impact on Association’s continued affiliation.

3. Public Safety Model:

Agenda Item #13.1.

24 // EXCLUSIVE PROVIDER OF TECHNICAL ASSISTANCE TO ICMA

3. Public Safety Model:

Projected Cost
Current Police Budget (including dispatch) $4,489,352
Additional Public Safety Officers (5 @ $200K) 1,000,000 Public Safety Officer Incentive (11 @ 15%) 350,000
Training for PSO 75,000
Overtime 200,000
Part-time Employees 100,000
911 Dispatch (CAL-FIRE) 80,000
TOTAL $6,294,352
Not Included:

Fire Prevention Services
Capital Replacement
Utilities & Maintenance (Vehicles & Building)
Agenda Item #13.1.

25 // EXCLUSIVE PROVIDER OF TECHNICAL ASSISTANCE TO ICMA Cost Comparisons (FY24-25):

Description Fire Cost Police
Cost Total Cost

1. Existing Fire & Police Model $2.69 M $4.49 M $7.18 M

2. Projected CAL-Fire Contract $2.48 M $4.49 M $6.97 M

3. Projected Napa County
Contract $2.44 M $4.49 M $6.93 M

4. Projected Public Safety Model $6.29 M $6.29 M
Agenda Item #13.1.

26 // EXCLUSIVE PROVIDER OF TECHNICAL ASSISTANCE TO ICMA SHFD is an excellent organization providing quality services.

SHFD is still transitioning with several areas requiring improvement.

Career/Part-time model is critical to overall efficiency.

Joint Response and Mutual Aid agreements are very viable.

Contracted models can jeopardize local control (Service/Future Costs).

Volunteer Association contributes positively to the organization.

Conclusions:

Agenda Item #13.1.

FY25 EXPENSES
BY

DEPARTMENT
$21.5M
Agenda Item #13.1.

OPPORTUNITIES
Police Dispatch
Services
Wastewater
Treatment Plant
Agenda Item #13.1.

QUESTIONS
Agenda Item #13.1.

COMPREHENSIVE FIRE

DEPARTMENT STUDY
ST. HELENA FIRE DEPARTMENT,
ST. HELENA, CALIFORNIA
Final Report-October 2024

CENTER FOR PUBLIC SAFETY MANAGEMENT, LLC
475 K STREET NW, STE 702 • WASHINGTON, DC 20001
WWW.CPSM.US • 716-969-1360
Exclusive Provider of Public Safety Technical Services for International City/County Management Association

CENTER FOR PUBLIC SAFETY MANAGEMENT, LLC
Agenda Item #13.1.

i

THE ASSOCIATION & THE COMPANY

INTERNATIONAL CITY/COUNTY MANAGEMENT ASSOCIATION (ICMA) The International City/County Management Association (ICMA) is a 109-year-old, non-profit professional association of local government administrators and managers, with approximately 13,000 members located in 32 countries.

Since its inception in 1914, ICMA has been dedicated to assisting local governments and their managers in providing services to their citizens in an efficient and effective manner.

ICMA advances the knowledge of local government best practices with its website, www.icma.org, publications, research, professional development, and membership.

CENTER FOR PUBLIC SAFETY MANAGEMENT (CPSM)
The ICMA Center for Public Safety Management (ICMA/CPSM was launched by ICMA to provide support to local governments in the areas of police, fire, and Emergency Medical Services.

The Center also represents local governments at the federal level and has been involved in numerous projects with the Department of Justice and the Department of Homeland Security.

In 2014, as part of a restructuring at ICMA, the Center for Public Safety Management (CPSM) spun out as a separate company and is now the exclusive provider of public safety technical assistance for ICMA. CPSM provides training and research for the Association’s members and represents ICMA in its dealings with the federal government and other public safety professional associations such as CALEA, PERF, IACP, IFCA, IPMA-HR, DOJ, BJA, COPS, NFPA, etc.

The Center for Public Safety Management, LLC, maintains the same team of individuals performing the same level of service that it had for ICMA. CPSM’s local government technical assistance experience includes workload and deployment analysis using our unique methodology and subject matter experts to examine department organizational structure and culture, identify workload and staffing needs, and identify industry best practices.

We have conducted more than 400 such studies in 46 states and provinces and more than 275 communities ranging in population size 3,300 (Lewes, DE) to 800,000 (Indianapolis, IN).

Thomas Wieczorek is the Director of the Center for Public Safety Management.

Leonard Matarese serves as the Managing Partner for Research and Project Development.

Dr. Dov Chelst is the Director of Quantitative Analysis.

Agenda Item #13.1.

ii

CENTER FOR PUBLIC SAFETY MANAGEMENT

PROJECT CONTRIBUTORS
Thomas J. Wieczorek, Director
Leonard A. Matarese, Director, Research & Project Development Dov Chelst, Ph.D. Director of Quantitative Analysis
Michael Iacona, Senior Manager Fire and EMS
Monicque Lee, Senior Data Analyst
Xianfeng Li, Data Analyst
Dennis Kouba, Senior Editor
Agenda Item #13.1.

iii

CONTENTS
Tables ............................................................................................................................ vi Figures ......................................................................................................................... viii Section 1. Executive Summary .................................................................................... 1 Recommendations ..................................................................................................................................... 2 Section 2. Scope of Project .......................................................................................... 5 Section 3. Organization and Management ................................................................ 6 Governance and Administration .............................................................................................................. 6 St. Helena Fire Department Overview ...................................................................................................... 8 Workweek and Definition of Time Worked......................................................................................... 10 Two-In/Two-Out Provision ..................................................................................................................... 10 Alternative Response Vehicles ............................................................................................................ 11 Staffing and work schedule ..................................................................................................................... 13 Work Schedule ...................................................................................................................................... 14 Program Management Responsibilities .............................................................................................. 17 Internal Communication ...................................................................................................................... 19 Promotional Testing Processes ............................................................................................................. 19 Performance Reviews .......................................................................................................................... 23 Fire Incident Reporting Review ........................................................................................................... 23 Fire Station Facilities .................................................................................................................................. 24 Fire Station Location and Service Area .............................................................................................. 25 Apparatus and Fleet Management ....................................................................................................... 26 Capital Equipment ............................................................................................................................... 30 Radio Interoperability and Coverage .................................................................................................... 31 911 Calls / Dispatch .................................................................................................................................. 31 Section 4. Analysis of Planning Approaches ............................................................ 33 Fire Risk Analysis ......................................................................................................................................... 33 Hazard Analysis and Community Risk Assessment ............................................................................ 34 Hazardous Materials Response ............................................................................................................... 37 Target Hazards and Fire Preplanning ..................................................................................................... 39 Accreditation ............................................................................................................................................ 40 Section 5. Operational Response Approaches ........................................................ 42 Fire Response Protocols ............................................................................................................................ 44 Call Activities ......................................................................................................................................... 44 EMS Response and Transport ................................................................................................................... 50 Evaluating BLS First Response Capabilities ......................................................................................... 50 EMS Response Mode ............................................................................................................................ 51 Agenda Item #13.1.

iv
Mutual Aid/Automatic Response ........................................................................................................... 53 Workload Analysis ..................................................................................................................................... 55 Frequency of Overlapping Calls ......................................................................................................... 56 Alternative Service Delivery Options ...................................................................................................... 58 Entering into a Cooperative Services Agreement with CAL FIRE.................................................... 58 Entering into a Services Agreement with Napa County .................................................................. 60 Establishing a Public Safety Model (Combined Police and Fire/EMS Department) ..................... 61 Summary of Alternative Service Options ........................................................................................... 62 Section 6. Response Time Analysis ............................................................................ 64 Measuring Response Times ...................................................................................................................... 65 St. Helena Response Times ....................................................................................................................... 66 Section 7. Performance Measurement ..................................................................... 76 Section 8. Essential Resources ................................................................................... 80 Fire Prevention and Code Enforcement ................................................................................................ 80 Fire Investigations .................................................................................................................................. 81 ISO Rating .................................................................................................................................................. 81 Education and Training Programs .......................................................................................................... 83 In-Service Fire & EMS Training .............................................................................................................. 83 Firefighter Recruit Training .................................................................................................................... 85 EMS Training ........................................................................................................................................... 85 Physical Fitness Evaluation ................................................................................................................... 86 Emergency Management ....................................................................................................................... 87 Emergency Communications Center (911) .......................................................................................... 89 Section 9. Data Analysis ............................................................................................. 92 Part 1: Fire Protection and Rescue ............................................................................. 93 SHFD Responding Call Totals ................................................................................................................... 94 SHFD Responding Calls by Type .......................................................................................................... 94 SHFD Responding Calls by Type and Duration .................................................................................. 97 SHFD Responding Calls by Month and Hour of Day ......................................................................... 98 SHFD Units Arriving at Calls ................................................................................................................. 100 SHFD Workload: Runs and Total Time Spent ........................................................................................ 103 Runs and Deployed Time ................................................................................................................... 103 SHFD Workload by Unit ....................................................................................................................... 107 SHFD Workload by Location .............................................................................................................. 109 Analysis of Busiest Hours ......................................................................................................................... 111 SHFD Response Time ............................................................................................................................... 113 SHFD Response Time by Type of Call ................................................................................................ 113 SHFD Response Time Distribution ....................................................................................................... 118 Part 2. Emergency Medical Service ........................................................................ 120 Agenda Item #13.1.

v
AMR Responding Calls by Type ............................................................................................................ 121 AMR Responding Calls by Type ........................................................................................................ 121 AMR Responding Calls by Type and Duration ................................................................................ 123 Average AMR Responding Calls by Month and Hour of Day ....................................................... 124 AMR Workload: Runs and Total Time Spent ......................................................................................... 126 AMR Unit Runs and Deployed Time .................................................................................................. 126 AMR Response Time ............................................................................................................................... 128 AMR Response Time by Hour of Day ................................................................................................ 129 AMR Response Time Distribution ....................................................................................................... 131 AMR Ambulance Transport ................................................................................................................... 133 Transport Runs by Type ....................................................................................................................... 133 Average Transport Calls per Hour ..................................................................................................... 134 Transport Calls by Type and Duration .............................................................................................. 136 Transport Time Components .............................................................................................................. 137 Attachment I: Actions Taken ................................................................................................................. 138 Attachment II: Fire Loss ........................................................................................................................... 139 Attachment III: Aid Received ................................................................................................................ 140 Attachment IV: SHFD Responding Call Type Identification ............................................................... 141 Attachment V: AMR Responding Call Type Identification ................................................................ 143 Agenda Item #13.1.

vi
TABLES
TABLE 3-1: SHFD Fire Station, Response Units, and Assigned Personnel .............................................. 14 TABLE 3-2: Program Assignment Duties ................................................................................................... 18 TABLE 3-3: Recommended Educational Prerequisites for Promotions ................................................ 22 TABLE 3-4: Station Location, Year Built, and Size ................................................................................... 24 TABLE 3-5: SHFD Inventory of Frontline Apparatus ................................................................................. 28 TABLE 3-6: Fire Pumper Life Expectancy by Type of Jurisdiction ......................................................... 29 TABLE 5-1: Calls by Call Type and Number of Arriving SHFD Units ....................................................... 46 TABLE 5-2: Calls by Type ........................................................................................................................... 47 TABLE 5-3: Content and Property Loss, Structure and Outside Fires ................................................... 49 TABLE 5-4: Total Fire Loss Above and Below $25,000 ............................................................................ 50 TABLE 5-5: Annual Workload by Location .............................................................................................. 54 TABLE 5-6: Annual Workload by Unit ....................................................................................................... 56 TABLE 5-7: Annual Runs by Unit and Type .............................................................................................. 56 TABLE 5-8: Frequency of Overlapping Calls ........................................................................................... 57 TABLE 5-9: Top 10 Hours with the Most Calls Received ......................................................................... 57 TABLE 5-10: Projected Costs: CAL-FIRE Cooperative Fire Service Agreement .................................. 59 TABLE 5-11: Projected Costs: Napa County Professional Services Agreement ................................. 60 TABLE 5-12: Projected Costs: St. Helena Department of Public Safety ............................................... 62 TABLE 6-1: Average and 90th Percentile Response Time of First Arriving Unit, by Call Type ............ 67 TABLE 7-1: The Five GASB Performance Indicators ............................................................................... 77 TABLE 8-1: SHFD Fire Prevention Activities, 2022–2023* ......................................................................... 80 TABLE 9-1: SHFD Calls by Type .................................................................................................................. 94 TABLE 9-2: Calls by Type and Duration ................................................................................................... 97 TABLE 9-3: Calls by Type and Number of Arriving SHFD Units ............................................................. 100 TABLE 9-4: SHFD Annual Runs and Deployed Time by Type ............................................................... 103 TABLE 9-5: SHFD Deployed Minutes by Hour of Day ........................................................................... 105 TABLE 9-6: SHFD Workload by Unit ......................................................................................................... 107 TABLE 9-7: Total Runs by Type and SHFD Unit ....................................................................................... 108 TABLE 9-8: Deployed Minutes per Day by Type and SHFD Unit ......................................................... 108 TABLE 9-9: Annual Workload by Location ............................................................................................ 109 TABLE 9-10: SHFD Runs for Structure and Outside Fires by Municipality ............................................ 109 TABLE 9-11: Frequency Distribution of the Number of Calls ............................................................... 111 TABLE 9-12: Top Ten Hours with the Most Calls Received ................................................................... 111 TABLE 9-13: Frequency of Overlapping Calls ....................................................................................... 111 TABLE 9-14: Average and 90th Percentile Response Time of First Arriving SHFD Unit, by Call Type .................................................................................................................................................................. 114 TABLE 9-15: Average and 90th Percentile Response Times of First Arriving SHFD Unit, by Hour of Day ........................................................................................................................................................... 116 TABLE 9-16: Cumulative Distribution of Response Time for First Arriving SHFD Unit ........................... 119 TABLE 9-17: AMR Responding Calls by Type ........................................................................................ 120 Agenda Item #13.1.

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TABLE 9-18: AMR Responding Calls by Type ........................................................................................ 121 TABLE 9-19: AMR Responding Calls by Type and Duration ................................................................ 123 TABLE 9-20: AMR Workload by Unit ....................................................................................................... 126 TABLE 9-21: Average and 90th Percentile AMR Response Times ...................................................... 128 TABLE 9-22: Average and 90th Percentile AMR Response Time, by Hour of Day ............................ 129 TABLE 9-23: Cumulative Distribution of AMR Response Time ............................................................. 132 TABLE 9-24: AMR Transport Calls by Call Type ..................................................................................... 133 TABLE 9-25: AMR Transport Calls per Hour, by Time of Day ................................................................ 134 TABLE 9-26: Transport Call Duration....................................................................................................... 136 TABLE 9-27: Time Component of AMR Unit Transport Runs by Destination ...................................... 137 TABLE 9-28: Actions Taken Analysis for Structure and Outside Fire Calls .......................................... 138 TABLE 9-29: Total Fire Loss Above and Below $25,000 ........................................................................ 139 TABLE 9-30: Content and Property Loss, Structure and Outside Fires ............................................... 139 TABLE 9-31: Aid Received Calls by Type ............................................................................................... 140 TABLE 9-32: Aid Received Workload by Agency ................................................................................ 140 TABLE 9-33: Call Types by NFIRS Incident Type Code and Description ............................................ 141 TABLE 9-34: Call Type by CAD Type Description ................................................................................. 142 TABLE 9-35: Call Type by Primary Impression ........................................................................................ 143 Agenda Item #13.1.

viii

FIGURES
FIGURE 3-1: City of St. Helena Table of Organization ............................................................................. 7 FIGURE 3-2: St. Helena Fire Department Table of Organization ............................................................ 9 FIGURE 3-3: Alternative Response Vehicle ............................................................................................. 12 FIGURE 3-4: 24/48 Work Schedule (56-Hour Workweek) ....................................................................... 15 FIGURE 3-5: 48/96 Work Schedule (56-Hour Workweek) ....................................................................... 15 FIGURE 3-6: 24/72 Work Schedule (42-Hour Workweek) ....................................................................... 16 FIGURE 3-7: 12/12, 10/14, or 9/14 Work Schedule (42-Hour Workweek) ............................................. 17 FIGURE 3-8: City of St. Helena Fire Station Location .............................................................................. 25 FIGURE 4-1: Community Risk Matrix ......................................................................................................... 34 FIGURE 5-1: Low-Risk Response, Exterior Fire Attack ............................................................................. 42 FIGURE 5-2: Moderate-Risk Response, Interior Fire Attack .................................................................... 43 FIGURE 5-3: Full-Force Response, Utilizing an Aerial Device ................................................................. 43 FIGURE 5-4: Number of Arriving SHFD Units for EMS Calls ...................................................................... 45 FIGURE 5-5: Number of Arriving SHFD Units for Fire Calls ....................................................................... 45 FIGURE 5-6: Location of Structure Fires ................................................................................................... 48 FIGURE 5-7: Location of Structure Fire with Fire Loss Greater Than $25,000 ....................................... 49 FIGURE 5-8: MDPS Response Matrix ......................................................................................................... 53 FIGURE 5-9: Annual Workload Outside City Limits ................................................................................. 55 FIGURE 6-1: Times to Flashover: Modern vs. Legacy Construction Methods ..................................... 65 FIGURE 6-2: St. Helena Station Location with Travel Projection of 240 Seconds ............................... 68 FIGURE 6-3: St. Helena Station Location with Travel Projection of 360 Seconds ............................... 69 FIGURE 6-4: St. Helena Station Location with Travel Projection of 480 Seconds ............................... 70 FIGURE 6-5: St. Helena Station Location with Composite Travel Projections ..................................... 71 FIGURE 6-6: SHFD Fire Runs ....................................................................................................................... 72 FIGURE 6-7: SHFD EMS Runs ...................................................................................................................... 73 FIGURE 6-8: SHFD Other Runs ................................................................................................................... 74 FIGURE 6-9: SHFD Responses with Total Response Times of 10 Minutes or Greater ........................... 75 FIGURE 9-1: SHFD Responding Calls by Grand Type ............................................................................. 95 FIGURE 9-2: SHFD Responding EMS Calls by Type ................................................................................. 95 FIGURE 9-3: SHFD Responding Fire Calls by Type .................................................................................. 96 FIGURE 9-4: SHFD Responding Calls per Day by Month ....................................................................... 98 FIGURE 9-5: Average SHFD Responding Calls by Hour of Day ............................................................ 99 FIGURE 9-6: Number of Arriving SHFD Units for EMS Calls .................................................................... 101 FIGURE 9-7: Number of Arriving SHFD Units for Fire Calls ..................................................................... 101 FIGURE 9-8: Average SHFD Deployed Minutes by Hour of Day ......................................................... 106 FIGURE 9-9: Average Response Time of First Arriving SHFD Unit, by Call Type ................................. 114 FIGURE 9-10: Average Response Time of First Arriving SHFD Unit, by Hour of Day ........................... 117 FIGURE 9-11: Cumulative Distribution of Response Time for First Arriving SHFD Unit, EMS ............... 118 Agenda Item #13.1.

ix
FIGURE 9-12: Cumulative Distribution of Response Time for First Arriving SHFD Unit, Outside and Structure Fires ........................................................................................................................................... 119 FIGURE 9-13: AMR Responding EMS Calls by Type .............................................................................. 122 FIGURE 9-14: Average AMR Responding Calls by Month .................................................................. 124 FIGURE 9-15: Average AMR Responding Calls by Hour of Day ......................................................... 125 FIGURE 9-16: Average Deployed Minutes by Hour of Day ................................................................ 127 FIGURE 9-17: Average AMR Response Time, by Hour of Day ............................................................ 130 FIGURE 9-18: Cumulative Distribution of AMR Response Time ........................................................... 131 FIGURE 9-19: Average Transport Calls by Hour .................................................................................... 135 Agenda Item #13.1.

1 SECTION 1. EXECUTIVE SUMMARY
The Center for Public Safety Management, LLC (CPSM) was retained by the City of St. Helena to conduct an Operational and Administrative Analysis for its fire department, including a detailed review of department operations, its organization structure, work schedule, training, performance measures, prevention activities and its interaction with AMR and neighboring agencies. This analysis also includes a review of those primary options the city may consider as an alternative service delivery model. Specifically, CPSM was tasked with providing recommendations that the city may consider in changing its current independent Fire and EMS delivery system to an alternative model, either through contracting with an outside agency for these services or considering a public safety model, which utilizes a combined service force in which personnel are trained in providing both fire and law enforcement services through a single agency.

CPSM analyzed performance data provided by the St. Helena Fire Department (SHFD) and also conducted a firsthand examination of the department’s operations. Fire departments tend to deploy resources utilizing traditional approaches, which are rarely reviewed. To begin the review, project staff asked for certain documents, data, and information. The project staff used this information/data to familiarize themselves with the department’s structure, assets, and operations. The provided information was supplemented with information collected during an on-site visit to observe the performance of the department and to compare that performance to national benchmarks. CPSM will typically utilize benchmarks that have been developed by organizations such as the National Fire Protection Association (NFPA), Center for Public Safety Excellence, Inc. (CPSE), the ICMA Center for Performance Measurement, as well as others.

Project staff conducted a site visit on November 8-10, 2023, for the purpose of observing fire department and agency-connected support operations, interviewing key department staff, and reviewing preliminary data and information. We also evaluated the community, identifying the potential fire risk in the area, both structural and wildland, in order to determine the alignment of workload with the potential service demands. Telephone and video conference calls as well as email exchanges were conducted between CPSM project management staff, the city, and the fire department so that CPSM staff could affirm the project scope, and elicit further discussion regarding this analysis.

The St. Helena Fire Department (SHFD) operates from a single station; the department is composed of both career personnel and part-time employees. Though SHFD is a relatively small organization with limited resources, it is highly proficient in managing its workload. SHFD relies heavily on the recall of off-duty personnel, its part-time workforce, and its mutual aid partners (primarily from neighboring agencies), in meeting service demands. SHFD works closely with AMR, a county-contracted private EMS agency, which provides advanced life support (ALS) services and ambulance transports throughout the county.

The SHFD personnel with whom CPSM interacted demonstrated a profound work ethic, professionalism, and a commitment to customer service and protecting the community.

However, as a small agency with limited resources, SHFD must interact seamlessly with a multitude of neighboring agencies to provide the appropriate protections to the community, area businesses, and the many tourists who visit the area. The challenges in St. Helena, however, are not unique nor are they insurmountable. CPSM will provide a series of observations and recommendations that we believe will support SHFD in fulfilling its mission in providing both emergency and nonemergency response.

Agenda Item #13.1.

2 RECOMMENDATIONS
The St. Helena Fire Department is currently providing a wide range of services to its citizens, local businesses, and visitors who frequent the area. The department is well-respected in the community it serves and by city leadership. In the evaluations we conduct, we will recognize those departments when we observe exceptional services or a level of proficiency that stands out. In these situations, we recognize these efforts as a Best Practice. In those areas that we find deficiencies or areas in need of improvement, we provide Recommendations that could be considered. Though the St. Helena Fire Department and its command structures are very limited in terms of number of personnel, and the agency relies heavily on the use of part-time employees along with the support from the St. Helena Volunteer Fire Dept. Association. We discovered an agency that is vibrant and operates in a cost-effective manner to provide a very high level of service to the community. Every agency has its shortfalls and struggles to find the right approach in meeting the ever-changing service demands of our time. However, we found the SHFD to be very adept and nimble in meeting these challenges; it demonstrates a vital capacity to address its challenges and shows a willingness to make changes in order to meet the challenges that lie ahead.

Twenty-six recommendations are listed below and are also found in applicable sections within this report. The recommendations are based on best practices derived from the NFPA, CPSM, ICMA, the U.S. Fire Administration, the International Association of Emergency Managers (IAEM), and the Federal Emergency Management Agency (FEMA).

These recommendations are listed in the order in which they appear in the report.

Section 3
(See pp. 6-32.)
Alternative Response Vehicles

1. The St. Helena Fire Department should consider the use of EMS squad units to handle EMS and non-fire related service calls in the city’s service area.

Promotional testing Processes

2. SHFD should revise its promotional requirements for Engineer, Captain, and Battalion Chief and include specific prerequisites regarding time-in-grade, certifications, and college coursework.

3. SHFD should move to a regular testing process for all promoted positions (Engineer and Fire Captain). These testing processes should be specified in written policy, clearly identifying the components and weighting of the elements involved in the testing processes.

4. SHFD should formalize the step-up process for all promoted positions and use the existing promotional eligibility lists to determine who is qualified for step-up assignments.

Fire Incident Reporting Review

5. The St. Helena Fire Department should institute a Quality Assurance/Quality Improvement (QA/QI) review process for its fire incident reporting.

Apparatus and Fleet Management

6. The city should institute a work-order tracking system and vehicle repair log for the fire department fleet which provides a comprehensive chronology and the cost accounting associated with the SHFD fleet repairs and maintenance.

Agenda Item #13.1.

3 Radio Interoperability and Coverage

7. St. Helena should take immediate steps in instituting a common radio link that will enable direct radio communications between the Calistoga/St. Helena Dispatch Center and the CAL-FIRE Center.
911/Dispatch

8. St. Helena should initiate an effort to evaluate the effectiveness and efficiency of the 911 dispatching services currently being utilized for law enforcement, fire, and EMS services.

Section 4
(See pp. 33-41.)
Fire Risk Analysis

9. The St. Helena Fire Department should conduct a formal structure fire risk assessment that concentrates on the city’s downtown, commercial establishments, wineries, and institutional properties.

Target Hazards and Fire Pre-Planning

10. The St. Helena Fire Department should continue in its efforts to develop a comprehensive Pre-Incident Planning program for its target hazards and high-risk occupancies.

Accreditation

11. St. Helena should consider working toward CPSE Fire Accreditation in the future.

Section 5
(See pp. 42.63.)
EMS Response

12. SHFD should work with the CAL-FIRE Emergency Communications Center to implement response protocols that alter the SHFD response mode when calls are determined to be minor or non-emergency.

Alternative Service Delivery Options

13. St. Helena should maintain its current service delivery model, which utilizes a municipal fire department that combines both career and part-time employees along with cooperative response agreements with neighboring agencies.

Section 7
(See pp. 76-79.)
Performance Measurement

14. SHFD should implement a series of performance measures that enable ongoing review of service outcomes. The process of developing these measures should utilize input from SHFD members, the community, the City Council, and City Administration.

Section 8
(See pp. 80-90.)
Fire Prevention and Code Enforcement

15. The City of St. Helena should implement fire inspection, weed abatement and permitting fees in order to recover the full cost of providing these services in the community.

Education and Training

16. The St. Helena Fire Department should establish a minimum shift training requirement (in number of hours) for each employee and implement this requirement in the department’s Standard Operating Guidelines.

Agenda Item #13.1.

4 17. The St. Helena Fire Department should implement an electronic training calendar and utilize this recordkeeping to document training activities throughout the year.

18. The St. Helena Fire Department should assign a Fire Captain to assume the role of the fire department Training Officer, with responsibility to coordinate training activities for the department.

19. The St. Helena Fire Department should establish a Training Steering committee to assist the department Training Officer in developing the training curriculum, identifying source materials, and implementing the training calendar.

20. The St. Helena Fire Department should pursue joint training opportunities with AMR to enhance improved working relationships and to provide the needed EMS continuing education credits (CEs) for EMT recertification.

Physical Fitness, Medical Evaluations

21. The St. Helena Fire Department should modify its annual medical physicals for firefighters and utilize the screening criteria specified in NFPA 1572, Standard on Comprehensive Occupational Medical Program for Fire Departments.

22. The City of St. Helena should implement a drug testing policy that requires employees to undergo testing when there is reasonable suspicion or when the employee is involved in a vehicle accident while driving a fire department vehicle.

Emergency Management

23. The City of St. Helena should initiate an effort with Napa County Emergency Management that simulates the full activation of the city’s EOC and the exercise of the Emergency Operations Plan (EOP) on an annual basis.

24. The City of St. Helena should initiate an effort in which every city department develops and exercises a Continuity of Operations Plan (COOP).

Emergency Communications Centers

25. The City of St. Helena should initiate an effort to fully evaluate its dispatching operations and obtain the necessary reporting to understand the level of effectiveness of these operations. § § §
Agenda Item #13.1.