REPORT TO COUNCIL
SUBJECT
Title
Review and Approve Recommended Changes to the Community Event and Neighborhood Grant Program Eligibility Guidelines
Report
SUMMARY OF SUBCOMMITTEE ACTION
As part of its annual grant award deliberations on June 20, 2017, the City Council approved a recommendation from the Community Event and Neighborhood Grant Distribution Subcommittee (Subcommittee) to review the eligibility guidelines for both the Community Event Grant Program (CEGP) and the Neighborhood Grant Program (NGP). This recommendation was made primarily in response to four questions that had arisen during the Subcommittee’s FY 2017/18 grant review process:
1. Is the CEGP provision that requires a 500-person minimum level of attendance
so restrictive that it creates an artificial barrier for potential applicants? (CEGP)
2. Is award eligibility determined by the nature of the applicant organization, by the nature of the proposed project or both? (NGP)
3. Should neighborhood grant proposals that span multiple neighborhoods be eligible for funding? (NGP)
4. Should neighborhood grants that seek to build community by advocating for a policy position be eligible for funding? (NGP)
The Subcommittee was asked to convene a special meeting prior to the end of the calendar year so that the review could take place prior to any changes in the Subcommittee composition that might occur in January. As such, a special meeting of the Subcommittee was held on September 20, 2017. The Report to Subcommittee and draft minutes from that meeting are enclosed as Attachments 1 and 3 respectively.
In order to clarify the issue of program eligibility, staff requested written guidance from the City Attorney. A copy of the memorandum from the Office of the City Attorney (Memorandum) that was provided to the Subcommittee is also enclosed as Attachment 2. The central finding of the City Attorney was that it is within the discretion of the Subcommittee to establish any guidelines they deem appropriate, provided that all guidelines are legal and serve a public purpose.
Community Event Grant Program (CEGP)
The Subcommittee discussed three issues related to the CEGP eligibility guidelines including: 1) factors that may have contributed to the receipt of only one applicant for FY 2017/18; 2) whether the criteria of drawing a crowd of at least 500 people was too high a threshold; and 3) whether the criteria should be altered to accommodate grant proposals for smaller educational events. Ultimately, the Subcommittee decided to keep the current eligibility criteria the same in the hope of encouraging and incentivizing more groups to coordinate large community-wide events in the future.
As to the question of whether eligibility should be based on the nature of the applicant organization or the nature of the proposed project, the Subcommittee recommended adding language from the Memorandum related to public purpose to the “Who is Eligible to Apply” section. It is the opinion of the Subcommittee that this addition will clarify the goals of the program as well as encourage ideas for more large-scale events from different community groups throughout Sunnyvale thereby addressing the desire to increase the number of potential applications received.
This change to the CEGP Guidelines and Eligibility Criteria can be found in redline in Attachment 4.
Neighborhood Grant Program (NGP)
Public Purpose
The impetus for the discussion related to eligibility based on the nature of the applicant organization or the nature of the proposed project arose in the context of an application from a homeowner association. At issue was whether the fact that homeowners pay dues to their association for improvements should preclude them from receiving a City grant.
Based on the Memorandum, the Subcommittee recommends that the valid public purpose the organization proposes to advance should be the determining factor. The Subcommittee concluded that if homeowner associations propose to use grant funds for a valid public purpose (e.g., to build a sense of community in their neighborhood), they should not be excluded from applying to the program and therefore, recommended that homeowner associations be added to the list of groups that preference is given to in the “Who is Eligible to Apply” section of the guidelines.
Neighborhood Focus
The current guidelines limit projects to a single neighborhood, excluding the option for multiple neighborhood groups to come together and coordinate a project or event. It is the opinion of the Subcommittee that this provision does not align with the goal of fostering community spirit throughout the City. As such, it is the recommendation of the Subcommittee that the words “or groups” be added to the following sentence in the “Who is Eligible to Apply” section: “Applicants must be representatives of a neighborhood group or groups.”
Advocacy
It is the consensus of the Subcommittee that programs or events that take a position on a policy issue, either in support of or in opposition to, do not meet the program mission of strengthening neighborhoods and should not be eligible to receive funding. Therefore, the Subcommittee recommends the current guideline that lists potential ineligible activities that are political in nature be amended to include those that are in support of a “policy position.” It is also recommended the words “or opposition” be added when listing the activities. With the recommended changes, the statement would read: Activities that are political in nature, including but not limited to, the support or opposition of a proposed initiative, ballot measure, policy position or candidate.
To clarify project eligibility, the Subcommittee also recommended the creation of a sub-section under “Projects and/or Event Eligibility” to give specific examples of projects or events that are not eligible. This new section would include the statement about activities that are political in nature (described in the paragraph above), as well as additional examples from the Memorandum.
A final recommended revision relates to the reference to “projects that have worked well in other cities” statement included in the “Project and/or Event Eligibility” section. The Subcommittee recommends that references to successes in other cities be removed as they are not relevant to the City’s processes.
The Subcommittee’s recommended changes to the NGP eligibility guidelines are shown in redline in Attachment 5.
Appropriation Recommendation
Not specifically related to program eligibility, the Subcommittee also requested that the future NGP recommended budget be allocated in increments of $250. While the CEGP budget is currently divisible by $250, the Subcommittee would like to ensure that future allocations continue to be divisible by $250. The current level of appropriation results in an awkward distribution of funds (For FY 2017/18, the appropriated amounts were $10,250 for the Community Event Grants and $6,278 for the Neighborhood Grants).
Conclusion
Based on its review, the Subcommittee recommends the following changes be made to the FY 2018/19 CEGP and NGP guidelines:
1. Add the definition of public purpose from the Memorandum to the “Who is Eligible to Apply” section of the CEGP guidelines;
2. Add homeowner associations to the list of groups that preference is given to in the “Who is Eligible to Apply” section of the NGP guidelines;
3. Add the words “or groups” to the following sentence in the “Who is Eligible to Apply” section of the NGP guidelines: “Applicants must be representatives of a neighborhood group or groups.”;
4. Amend the provision related to ineligible political activities for the NGP to read, “Activities that are political in nature, including but not limited to, the support or opposition of a proposed initiative, ballot measure, policy position or candidate;
5. Add a new sub-section under “Projects and/or Event Eligibility” that includes specific examples of projects or events that are not eligible to the NGP guidelines;
6. Delete the reference to “projects that have worked well in other cities” in the “Project and/or Event Eligibility” section of the NGP guidelines; and
7. That the recommendation that future appropriations for both grant programs be made in increments of $250 be considered as part of the FY18/19 budget process.
ENVIRONMENTAL REVIEW
The action being considered does not constitute a “project” with the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines sections15378(b)(5) and 15378(b)(4) in that it is a governmental organizational or administrative and fiscal activity that does not involve any commitment to any specific project which may result in a potential significant impact on the environment.
FISCAL IMPACT
The subcommittee's recommendation to allocate funds in increments of $250 should be referred to the annual budget process for consideration; however, adjusting the current NGP appropriation to allow for $250 increments is not material and won’t be a significant impact.
PUBLIC CONTACT
Public contact was made through posting of the Council agenda on the City’s official-notice bulletin board, on the City’s website, and the availability of the agenda and report in the Office of the City Clerk.
ALTERNATIVES
1. Approve Subcommittee recommendations as outlined in this Report to Council and as shown in the redline documents attached.
2. Take other action as determined by the City Council.
RECOMMENDATION
Recommendation
Staff makes no recommendation.
Staff
Prepared by: Alisha Rodrigues, Community Services Coordinator II
Reviewed by: Daniel Wax, Superintendent of Community Services
Reviewed by: Cynthia E. Bojorquez, Director of Library and Community Services
Approved by: Teri Silva, Interim Assistant City Manager
Approved by: Kent Steffens, Interim City Manager
ATTACHMENTS
1. Report to Subcommittee - September 20, 2017 Subcommittee Meeting
2. Memorandum from the Office of the City Attorney
Additional Attachments for Report to Council
3. Draft Minutes of September 20, 2017 Subcommittee Meeting
4. Redline Document - CEGP Guidelines and Eligibility Criteria
5. Redline Document - NGP Guidelines and Eligibility Criteria