Issue #1: Deceptive Budget
According
to the CFA, the revenue available to the future city is about $14 - $17
million (2007 - 2008 forecast). The revenue may be feasible to run a
city government, but the number is extremely low compared to other
cities. South Lake Tahoe for example, which has a similar population of
34,000, had an operation budget of $51 million in 2004.
South
Lake Tahoe is an atypical city. It has a very large itinerant
population of tourists, gamblers, boaters, skiers, people simply
passing through on US 50, and more. It operates an airport, it budgets
a million dollars per year for snow removal, and its police department
is unusually large, with 2.3 sworn officers per thousand people in the
permanent population. (click here to see City of South Lake Tahoe web site)
The cities of South Lake Tahoe and Placerville fund their own fire
departments from city budget. Our fire department will continue
to be separate from the city and had a 2004/2005 budget of almost $15
million. (click here to see EDH Fire Department 2004 Annual Report)
To compare EDH with South Lake Tahoe and Placerville we need to use the sum of EDH's city budget and its fire budget. That will conservatively be around $30 million to $35 million -- roughly triple the amount of Placerville's budget.
Such low
revenue in the EDH forecast will give an immediate excuse for the city
management to call for tax increase or commercial development once
incorporated. (click SLT city website and see the budget info).
The revenue is not low and the incorporation project's independent consultants, Economic & Planning Systems, found the city to be entirely viable under all analyzed projections of future conditions. (See Comprehensive Fiscal Analysis document) Even
if the new city wanted to increase taxes California law (mainly
Proposition 13 and Proposition 218) requires voter approval.
Among cities SLT is the fiscal oddball, not EDH.
When you check the South Lake Tahoe city website also check the SLT Police Department's
site. Its home page explains why they have "a few unique
characteristics when it comes to alcohol violations" -- such as 24-hour
partying and drink service at neighboring casinos. The web page
also shows a marine-patrol photo, they also operate on Lake Tahoe.
Add these to factors already cited and it's clear that comparing
SLT to any other city is a
classic case of apples versus oranges. For example, SLT's budget per
capita (permanent population) is double that of Placerville.
Issue #2: New Bureaucracy, Same Services
According
to the CFA, a municipal government generally requires 20% of the budget
for overhead. In the immediate term, that would cause a 20% shortfall
of funding for services. Someone has to pay for overhead. Using the
lower budget, the price tag for the new bureaucracy is $3 million
dollars. What the 20% overhead buys us is only to transfer 10 of the 18
services currently provided by the county to the new city plus a new
service, the cemetery.
The Comprehensive Fiscal Analysis does not say this, the claim is factually wrong. The Final EIR
even says explicitly in comment E-4 that "There is nothing in the Draft
EIR or CFA that suggests that new taxes or fees will be required to
operate."
The CFA
does
already include overhead, it is not omitted. It also focuses in on
finer levels of detail to identify overhead for major departments and
functions. For example, it analyzed existing operations, determined
that Sheriff's costs to EDH included an internal overhead of $571,466
(21% overhead). The CFA added a 2.5% overhead contingency allowance and
factored this projection of overhead into its forcast of
costs for the new city.
Issue #3: Forced Growth
According
to the CFA, the city has to grow 50% in the next 10 years just to pay
for the cost of running a city government. That is mainly due to the
fact that EDH's revenues are mainly coming from property tax.
El Dorado Hills' problems do not include not lack of growth.
Recent statistics show that about 1,300 building permits per year are
issued for single family homes in El Dorado Hills. At that rate EDH
would reach buildout under current land use planning before the end of
the next 10 years. Buildout potential is listed as 20,038 homes, 58,511 people [see Final EIR Table 1-2]. This level of growth is already
legally committed by development agreements entered into by the county.
The CFA's
projections for actual growth are conservative and include scenarios
for 25% less growth than even the conservative forcasts. The city is
fiscally viable under all of these scenarios.
Results could be better. For example, page 24 of the CFA describes why
sales tax receipts could actually grow between $136,000 and $860,000
per year more than its conservative estimate by 2014.
Issue #4: Low-income Housing
According
to the EIR, a part of the affordable housing allocation to the ED
county has to be re-assigned to EDH city. Due to EDH's high percentage
of the population of ED county (about 20%), a significant number of
affordable housing has to be allocation in the EDH area. It is very
important that the Community leaders develop the housing allocation
plan prior to the incorporation election. Delaying that allocation
would only transfer that issue to the city and create another
unforeseen cost to the city. That cost is not included in the CFA.
Affordable
housing quotas for a "fair share" of regional affordable housing are
assigned to city and county governments by SACOG, the Sacramento Area
Council Of Governments. No quota has yet been assigned to El
Dorado County, including El Dorado Hills.
The new city inherits affordable housing policies from the county's
General Plan, which states that "To the extent feasible, very low, low,
and moderate income housing produced through government subsidies,
incentives, and/or regulatory programs shall be shall be distributed
throughout the county and shall not be concentrated in a particular
area or community."
In El Dorado Hills, feasibility is limited by existing development
agreements already entered into by the county. These are legally
binding and dedicate almost all undeveloped land within the new city to
other residential uses (not low-cost housing).
The combination of these factors would appear to constrain legal
ability of SACOG to assign substantial amounts of affordable housing to
El Dorado Hills. Reference to the county policy in Final EIR
Response
L-5 adds: "Because it involves a smaller, more manageable and
homogeneous area, the new City is more likely than the larger County to
comply with its affordable housing allocation."
Issue #5: Property Valuation
Affordable
housing would also have an impact on the property values due to the
high number of units would be allocated to the area. The CFA only
calculates the forecast based on the current General Plan; which
treated EDH as an unincorporated area. The housing plan will no longer
be valid once EDH becomes incorporated. Also the EIR did not consider
this issue and needs to be revised.
No units have been allocated to the area yet, and a search of the Final EIR document finds 55 occurrences of the phrase "affordable housing".
An
equally viable conjecture to this one about risk of dropping property
values is that high values in a desirable area bring up low values
in or near it. There
may be an example in the Bay Area: For many years homes in Palo Alto
have been expensive while those in East Palo Alto have been low-valued
and would be considered low-income housing. A recent news
report indicated that values were rising in East Palo Alto.
Issue #6: Incorporation can delay current road projects
The
county currently has 12 major road projects being done in El Dorado
Hills. Incorporation would cause these projects to be transferred to
the city.
Only
projects not yet started are to be transferred to the city. Projects
which are partially complete will be finished by the county.
There are no provisions in the city budget for a project
engineer to administer these projects.
New cities, and sometimes even mature cities, contract out for project engineering work instead of maintaining in-house staff.
The first year budget for the
city is already showing a $500,000 deficit.
The first-year deficit is due to the transition from county to city
government. During this time the county continues to supply services
while the city starts up its own government. A first-year deficit
is normal for all new cities; The EDH CFA shows the city to be in the black as soon as the transition year is complete.
Thus these projects would,
at best, have to be delayed because of lack of funds to administer
them. Another example of how incorporation will give us less government
service.
The
funds are there, there is no delay due to incorporating. Road projects
can be delayed for other reasons, but not for this one. For example,
the US 50/Silva Valley interchange design was ready in 1991;
now the never-built design must be redone to handle a higher level
of traffic. Whether or not the county deserves responsibility for this
delay, it happened on their watch.
Overall, the CFA and EIR have once again shown that
incorporation will result in service cuts, traffic increase, high
density affordable housing, unplanned commercial expansion, and tax
(fee) hikes.
This is simply incorrect.
The CFA says that the city will be able to increase service.
The EIR
says that traffic will increase, but that's because of the county's
planning decisions. It says explicitly that this is an impact that's
inherited by the city, it's not caused by becoming a city.
EDH will have very little land available for affordable housing within
its boundaries. This is constrained by existing (completed) development
and by legally binding development agreements for remaining undeveloped
land under the county's land use policies, which EDH will inherit.
Affordable housing will always be an issue, but the constraints of law
mean that SACOG will have no substantial alternative except to require
affordable housing to be built mainly in areas outside EDH's city
limits.
All expansion, commercial or otherwise, requires approval of the
regulating agency. Incorporation moves that agency from the county to
the city, providing a higher degree of local control.
Tax hikes are virtually out of the question due to state law
(propositions 13 and 218). Fee hikes -- or even fee cuts -- are always
possible, regardless of whether the agency receiving the fees is the
county or the city. Given that the CFAsays
that the city will have a fiscal advantage over the county, fee
hikes should be more likely with county government than with city
government. A comparison of building fees for a new house showed that
they were only about 2/3 as much in the City of Folsom as in El
Dorado County.
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