RPVCCA_SR_2010_12_21_07_Neighborhood_Parking_FeesDate:
PUBLIC HEARING
December 21,2010
Subject:NEIGHBORHOOD PARKING PERMIT FEES AND OTHER COST
BASED FEES
Subject Property:Citywide
1.Declare the Hearing Open:Mayor Long
2.Report of Notice Given:City Clerk Morreale
3.Staff Report &Recommendation:Kathryn Downs,Deputy Director of Finance
&Information Technology
4.Public Testimony:
Appellants:N/A
Applicant:N/A
5.Council Questions:
6.Rebuttal:
7.Declare Hearing Closed:Mayor Long
8.Council Deliberation:
9.Council Action:
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CITY OF
MEMORANDUM
RANCHO PALOS VERDES
TO:
FROM:
DATE:
SUBJECT:
REVIEWED:
HONORABLE MAYOR &CITY COUNCIL MEMBERS
DENNIS MCLEAN,DIRECTOR OF FINANCE AND ~
INFORMATION TECHNOLOGY ~
DECEMBER 21,2010
NEIGHBORHOOD PARKING PERMIT FEES AND
OTHER COST BASED FEES
CAROLYN LEHR,CITY MANAGER ~
Project Managers:Kathryn Downs,Deputy Director of Finance &Information
Technology
RECOMMENDATION
1.ADOPT RESOLUTION NO.2010-_A RESOLUTION OF THE CITY COUNCIL OF
THE CITY OF RANCHO PALOS VERDES ESTABLISHING FEES TO REIMBURSE
THE CITY FOR THE COSTS INCURRED IN CONNECTION WITH THE
ADMINISTRATION OF THE NEIGHBORHOOD PARKING PERMIT PROGRAM AND
REVOKING BUSINESS LICENSE PROCESSING FEES.
2.Select either Alternative 1 to charge full fees for neighborhood parking permits,or
Alternative 2 to charge only the City's costs for establishing a parking program in a
neighborhood and the costs of decals issued.
DISCUSSION
According to state law,City fees for services cannot exceed the estimated reasonable
costs of providing the service.Fees are based on the City's direct costs (Le.consultants,
materials,etc.)and/or staffs'Fully Burdened Hourly Rates (FBHR),and may be adjusted
annually to reflect increases to the City's costs.
The City Council is requested to conduct a public hearing.Noticing requirements have
been satisfied as required by law.
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December 21 ,2010
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NEIGHBORHOOD PARKING PERMIT FEES
On November 4,2010,the City Council directed Staff to proceed with preparation of a
resolution to establish Neighborhood Parking Permit Fees.In addition,Council directed
Staff to develop a proposal for a reduced or waived fee for those households in close
proximity to schools,parks,and trailheads.
Based on the estimated number of households that may participate in the program during
the first year (50-100),Staff has calculated that household permit fee revenue is unlikely to
exceed $4,000 during the next year.The additional administrative staff time necessary to
verify the proximity of households to schools,parks and trail heads would negate the
estimated fee revenue.Therefore,Staff proposes that the City Council choose to either
charge the full neighborhood parking permit fees to all participating households (including
those in proximity to schools and parks),or refrain from charging the per-household permit
fee.
Alternative 1 -Full Permit Fees
~Neighborhood establishes a trust deposit to pay for the City's actual costs of
establishing the parking program in the neighborhood (field investigation,sign
installation,etc.).Depending upon the neighborhood and circumstances,the trust
deposit could require one-time funding of between $1,000 and $2,000.
~Each household pays a fee of $34 for new issuance of a household parking permit
or $17 for renewal (required every 3 years).
~Participating households pay a fee of $2.50 for each decal purchased (estimated at
3 per household).
Alternative 2 -No Per-Household Permit Fees
~Neighborhood establishes a trust deposit to pay for the City's actual costs of
establishing the parking program in the neighborhood (field investigation,sign
installation,etc.).Depending upon the neighborhood and circumstances,the trust
deposit could require one-time funding of between $1,000 and $2,000.
~Participating households pay a fee of $2.50 for each decal purchased (estimated at
3 per household).
The Neighborhood Parking Permit Program Fee Schedule and the Neighborhood Parking
Permit Program Analysis of Fees,Charges and Rates (the fixed fee cost summary
worksheets)are attached as Resolution Exhibits 1 and 2 for each alternative.
If City Council adopts the attached resolution,the new parking permit fees will become
effective February 19,2011.
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December 21 ,2010
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OTHER COST BASED FEES
As a housekeeping item,Staff proposes to remove the business license processing fee of
$20 for new licenses and $13 for renewing licenses from the Master Fee Schedule -
Finance.On November 3,2010,based on advice from the City Attorney's office,the City
discontinued charging these fees.Recently,there has been successful litigation
challenging this type of fee.In Weisblat v.San Diego (4 Dist.2009)176 Cal.App.4th
1022,the Court of Appeal held that a city's business tax processing fee was a general tax
requiring voter approval.The fee was adopted for the purpose of recovering the cost of
collecting and administering a rental unit business tax.Even though the fee did not exceed
the costs associated with processing applications,the court determined it was a tax
because the rental unit business tax was solely a taxing measure and provided no services
or regulation.Staff does not wish for the City to incur legal fees defending the City's
business license processing fee;and has therefore decided to discontinue charging the
fees and recommends the City Council revoke the fees.
2009 COST BASED FEE STUDY
The City engaged Revenue &Costs Specialists,LLC (RCS)to conduct a Cost-Based Fee
Study,which was completed in 2009.Similar to many cities in California,Rancho Palos
Verdes had gaps existing between the cost of services and the fees collected to pay for
those services.These studies are conducted to provide information to the City on what its
Personal Choice Public Services are costing.Personal Choice Public Services are defined
by RCS as services where the customer is identifiable and service is measurable and can
be withheld for non-payment.These differ from Community-Supported Public Services
which RCS defines as services that are 100 percent supported by taxes.The Council
decided on March 17,2009 (Resolution No.2009-19),to adjust most fees to achieve full
cost recovery with the exception of certain fees which were adjusted to less than 100
percent cost recovery to achieve certain policy objectives.
Fee levels are set according to the methodology described in the RCS report and are
based on staffs'FBHR.RCS uses a methodology that is modeled after the federal
government's method of calculating indirect support costs for grant reimbursement.This is
a widely accepted methodology which has been used in many cities across the state since
1975.RCS has used this methodology in more than 100 cities in California and other
various government agencies in seven other states.There are two main components of
the study which include the Fully Burdened Hourly Rate (FBHR)and the Total Cost
Allocation Plan (CAP).The methodology for each of these components of the study is
described below.
Fully Burdened Hourly Rate (FBHR)
To calculate direct costs for each f~e,departmental employees were asked to provide time
estimates for each fee and non-fee activity performed.The FBHR was determined based
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NEIGHBORHOOD PARKING PERMIT FEES AND OTHER COST BASED
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December 21 ,2010
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on salary,benefits and a proportionate share of the accounting activity's "general"costs for
indirect costs,operating expenses and overhead expenses.When all of these costs are
added together for a position,the result is the total cost of that position to the City.The
FBHR is then calculated by taking the total cost of the position and dividing it by the
number of available work hours.It is important to note that the FBHR methodology does
not account for staff overtime charges.The FBHR would be calculated as follows:
Direct Expenses
Direct Hourly Salary:Includes employee salary and benefits and is based on a
1,580 hour productive work year.
Services and Supplies:A proportionate share is based on total departmental
services and supplies divided by productive work hours multiplied by the ratio of the
employee's salary and benefits to all department employees'salary and benefits.
Indirect Expenses
Departmental Support:A proportionate share is based on the departmental
overhead cost (e.g.Department Director salary)divided by productive work hours
(1,580)multiplied by the ratio of the employee's salary and benefits to all
department employees'salaries and benefits.
Citywide Support:A proportionate share is based on the citywide support (e.g.
public liability insurance,property insurance,information technology,fleet
maintenance and building maintenance and annual replacement expenses)divided
by productive work hours (1 ,580)multiplied by the employee's salary and benefits to
all department employees'salaries and benefits.
FBHR=Direct Expenses +Indirect Expenses
The City Council recently adjusted FBHRs to compensate for increases in City employee
salaries and benefits (Resolution 2010-77).A trust deposit will be required to cover the
actual costs associated with the addition of a new street to the Neighborhood Parking
Permit Program,and will be based,in part,on the applicable FBHR as more fully detailed
on the worksheet.The Neighborhood Parking Permit household application fees have
been calculated based upon a reasonable estimate of staff time to process those
applications multiplied by the FBHR for the City employee who would perform the tasks
enumerated on the worksheets.The cost of the permit decal is based upon the cost
charged to the City by the vendor supplying the decals.
Total Cost Allocation Plan (CAP)
The CAP is the plan which was used to calculate the overhead expenses.Costs in this
category are for general administration (e.g.City Council,City Manager,City Clerk,City
Attorney,Personnel,and Finance)and support services (e.g.public liability insurance,
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NEIGHBORHOOD PARKING PERMIT FEES AND OTHER COST BASED
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property insurance,information technology,fleet maintenance and building maintenance
and annual replacement expenses).RCS took the following steps when allocating these
internal services:
1.Created cost "pools"called "subpools"for each of the above internal services.
2.Calculated the costs for each subpool.
3.Identified departments receiving support from each internal service subpool.
4.Selected a method for allocating the costs to other departments.
5.Reviewed the allocations for Reasonableness with City staff.
This methodology allocates all general administrative time that was not specifically charged
to a service to the rest of the organization.As such,fee services only have a share of
general administration proportionate to those costs compared to all City non-administrative
costs.It is important to note that this methodology does not result in full absorption
because employees quantified work time for non-fee activities and some administrative
items were excluded from being allocated (e.g.City Attorney's and City Clerk's time
supporting the Council).
FISCAL IMPACT
The Trust Deposit to establish a neighborhood parking program will not generate any fee
revenue for the City,but would provide cost recovery of about $1,000 to $2,000 per
neighborhood.If City Council chooses Alternative 1,household permit fee revenue may be
as much as $4,000 during FY1 0-11 (based upon 50-100 participating households).At the
same assumed level of participation, decal fee revenue could reach up to $1 ,000.Due to
the potentially immaterial amounts of cost recovery,Staff does not propose any budget
adjustments to fee revenue at this time.
By adopting either Alternative 1 or Alternative 2,the fees collected will not exceed the cost
of providing service.
Eliminating the Business License Processing Fees will likely reduce General Fund revenue
by about $24,000 annually.Staff believes that other favorable General Fund revenue
variances may offset this potential loss.Staff recommends waiting until General Fund
revenue is analyzed as part of the Midyear Financial Review in February 2011 before
proposing any revenue budget adjustment to account for the potential loss.
ATTACHMENTS
RESOLUTION NO.2010-A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
RANCHO PALOS VERDES ESTABLISHING FEES TO REIMBURSE THE CITY FOR THE
COSTS INCURRED IN CONNECTION WITH THE ADMINISTRATION OF THE
NEIGHBORHOOD PARKING PERMIT PROGRAM AND REVOKING BUSINESS
LICENSE PROCESSING FEES.
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FEES
December 21,2010
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Resolution Exhibit 1:
Neighborhood Parking Permit Program Fee Schedule
Resolution Exhibit 2:
Neighborhood Parking Permit Program Analysis of Fees,Charges and Rates (Fixed Fee
Cost Summary Worksheets)
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RESOLUTION NO.2010-_
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
RANCHO PALOS VERDES ESTABLISHING FEES TO
REIMBURSE THE CITY FOR THE COSTS INCURRED IN
CONNECTION WITH THE ADMINISTRATION OF THE
NEIGHBORHOOD PARKING PERMIT PROGRAM AND
REVOKING BUSINESS LICENSE PROCESSING FEES.
THE CITY COUNCil OF THE CITY OF RANCHO PALOS VERDES DOES
RESOLVE AS FOllOWS:
WHEREAS,the City of Rancho Palos Verdes ("City")currently has a neighborhood
parking permit program as set forth in Chapter 10.20 of the Rancho Palos Verdes
Municipal Code that regulates parking in certain areas of the City,which areas are defined
by City Council resolution ("Neighborhood Parking Permit Program");and
WHEREAS,Section 10.20.11 OA authorizes the City Council,by resolution,to set
parking permit fees for the Neighborhood Parking Permit Program;and
WHEREAS,the City conducted an analysis of the costs incurred by the City in
providing regulatory services relating to the administration of the Neighborhood Parking
Permit Program and has based the proposed fees,charges and rates for the
Neighborhood Parking Permit Program on that analysis;and
WHEREAS,the City desires to eliminate business license processing fees from the
Finance Schedule of the City's previously-adopted Master Fee Schedule;and
WHEREAS,California Government Code Section 66000,et.seq.authorizes the
City to adopt fees for municipal services,provided such fees do not exceed the estimated
reasonable cost to the City of providing the service;and
WHEREAS,on December 21,2010,the City Council conducted a duly noticed
public hearing concerning the fees,charges and rates proposed to be adopted;and
WHEREAS,the adoption of this Resolution approves and sets forth fees,charges
and rates for the purpose of meeting the operating expenses of City departments and is,
therefore,exempt from the California Environmental Quality Act (Public Resources Code
Sections 21080 et seq.)pursuant to Public Resources Code Section 21 080(b )(8)(A);and
WHEREAS,all requirements of California Government Code Sections 66016 and
66018 are hereby found to have been satisfied.
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NOW,THEREFORE,the City Council of the City of Rancho Palos Verdes does
hereby resolve as follows:
Section 1.The facts set forth in the Recitals of this Resolution are true and
correct and are hereby incorporated by reference as though set forth in full.
Section 2.The City Council hereby finds that none of the fees,charges and
rates set forth in the Neighborhood Parking Permit Program Fee Schedule ("Parking
Permit Fee Schedule")attached hereto as Exhibit 1 and incorporated by this reference,
exceeds the cost to the City of providing the permit or service to which such fee,charge or
rate applies.The basis for the fees,charges and rates is set forth in the Neighborhood
Parking Permit Program Analysis of Fees,Charges and Rates,which is attached hereto as
Exhibit 2 and incorporated herein by this reference.
Section 3.The City Council hereby approves and adopts the Parking Permit Fee
Schedule as the schedule of fees,charges and rates applicable to the City's Neighborhood
Parking Permit Program.
Section 4.The fees,charges and rates specified in the Parking Permit Fee
Schedule shall become effective on February 19,2011;provided,however,that those
fees,charges and rates for processing an application shall not be applicable to any
"deemed complete"application received by the City prior to February 19,2011,and such
applications shall continue to be subject to the fee schedule,if any,in effect when the
application was deemed complete.
Section 5.Any person paying a fee set forth on the Parking Permit Fee Schedule
who feels that any fee,charge or rate determined and set is in excess of the percentage of
costs reasonably borne by the City and to be recovered as set out in this Resolution,or
has not been reviewed and approved by the City Council,may appeal in writing to the City
Council.
Section 6.The City Council hereby revokes,effective immediately,the "Business
License Processing Fee -New"and the "Business License Processing Fee -Renewal"as
set forth on the City's Master Fee Schedule adopted by Resolution No.2010-77.All other
existing rates,charges and amounts on the Master Fee Schedule for previously imposed
fees shall continue unmodified by this Resolution and this Resolution is not intended,and
shall not be construed,as the imposition,extension,or increase of any such fees.
Section 7.The City Clerk shall certify to the passage,approval,and adoption of
this Resolution,and shall cause this Resolution and her certification to be entered in the
Book of Resolutions of the City Council of the City.
PASSED,APPROVED and ADOPTED this 21 st day of December 2010.
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Mayor
ATTEST:
City Clerk
State of California )
County of Los Angeles )ss
City of Rancho Palos Verdes )
I,Carla Morreale,City Clerk of the City of Rancho Palos Verdes,hereby
certify that the above Resolution No.__,was duly and regularly passed and adopted by
the said City Council at a regular meeting thereof held on December 21,2010.
City Clerk
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EXHIBIT 1
Neighborhood Parking Permit Program Fee Schedule
Alternative 1
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Alternative 1
RESOLUTION NO.2010-XX EXHIBIT 1
NEIGHBORHOOD PARKING PERMIT PROGRAM FEE SCHEDULE
PROPOSED
FEE
EFFECTIVE
2/19/2011
NEIGHBORHOOD PARKING PERMIT
NEIGHBORHOOD PROGRAM ESTABLISHMENT TRUSTDEP.
TRUST DEPOSIT FOR ACTUAL STAFF TIME AT THE FULLY BURDENED HOURLY RATE AND DIRECT
COSTS (SUCH AS PURCHASE OF SIGNS)TO PROCESS AN APPLICATION TO ESTABLISH A
NEIGHBORHOOD PARKING PERMIT PROGRAM.
HOUSEHOLD-NEWISSUANCE $34
HOUSEHOLD-RENEWAL $17
DECAL $2.50
NOTE:MINIMUM INITIAL DEPOSIT TO BE DETERMINED BY STAFF FOR ALL TRUST DEPOSITS.TRUST DEPOSITS MAY
BE USED TO PAY FOR SERVICES FROM THE CITY ATTORNEY,TRAFFIC COMMITTEE,NPDES CONSULTANT,OR OTHER
CONSULTANTS,AS SET FORTH IN RESOLUTION 2009-19.
OTHER:
ADDITIONAL SERVICES FOR WHICH A FEE HAS NOT BEEN ESTABLISHED SHALL BE CHARGED AT THE CITY'S FULLY
BURDENED HOURLY RATE.
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Alternative 1
EXHIBIT 2
Neighborhood Parking Permit Program Analysis of Fees,Charges and Rates
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Alternative 1
FIXED FEE COST SUMMARY WORKSHEET
FISCAL YEAR 2010-2011
SERVICE
NEIGHBORHOOD PARKING
PERMIT -NEIGHBORHOOD
PROGRAM ESTABLISHMENT
REFERENCE #S-290
PRIMARY DEPARTMENT PW-ADMINISTRATION
UNIT OF SERVICE APPLICATION
DESCRIPTION OF SERVICE
Evaluate a neighborhood
petition to establish a
neighborhood parking permit
program.Attend neighborhood
meeting(s),investigate the site,
evaluate signage needs,
purchase and install new signs.
SUBORG ID#POSITION DIRECT COST HOURS 2010 FBR COST
For actual staff time at the fUlly
burdened hourly rate and direct
costs (such as purchase of
signs)to process an
application to establish a
neighborhood parking permit
TRUST DEPOSIT Iprogram.Variable Variable Variable Actual
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Alternative 1
FIXED FEE COST SUMMARY WORKSHEET
FISCAL YEAR 2010·2011
SERVICE NEIGHBORHOOD PARKING
PERMIT -HOUSEHOLD -
NEW ISSUANCE
REFERENCE #S-291
PRIMARY DEPARTMENT PW-ADMINISTRATION
UNIT OF SERVICE APPLICATION
DESCRIPTION OF SERVICE Process a new permit
application for a household,
verify proof of residency,log
permit in database and issuing
decals.
SUBORG ID#POSITION DIRECT COST HOURS 2010 FBR COST
101-D-3006 1178 PERMIT CLERK 0.33 $102.69 $34
TOTAL $34
RECOMMENDED NEW FEE $34
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Alternative 1
FIXED FEE COST SUMMARY WORKSHEET
FISCAL YEAR 2010·2011
SERVICE NEIGHBORHOOD PARKING
PERMIT-HOUSEHOLD-
RENEWAL
REFERENCE #S-292
PRIMARY DEPARTMENT PW-ADMINISTRATION
UNIT OF SERVICE APPLICATION
DESCRIPTION OF SERVICE Process permit renewal
application for a household,
verify residency information
and issue decal(s).
SUBORG ID#POSITION DIRECT COST HOURS 2010 FBR COST
101-D-3006 1178 PERMIT CLERK 0.17 $102.69 $17
TOTAL $17
RECOMMENDED NEW FEE $17
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Alternative 1
FIXED FEE COST SUMMARY WORKSHEET
FISCAL YEAR 2010·2011
SERVICE NEIGHBORHOOD PARKING
PERMIT -DECAL
REFERENCE #8-293
PRIMARY DEPARTMENT PW-ADMINI8TRATION
UNIT OF SERVICE DECAL
DESCRIPTION OF SERVICE Purchase one neighborhood
parking permit decal
SUBORG ID#POSITION DIRECT COST HOURS 2010 FBR COST
$2.64 $2.64
TOTAL $2.64
RECOMMENDED NEW FEE $2.50
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EXHIBIT 1
Neighborhood Parking Permit Program Fee Schedule
Alternative 2
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Alternative 2
RESOLUTION NO.2010-XX EXHIBIT 1
NEIGHBORHOOD PARKING PERMIT PROGRAM FEE SCHEDULE
PROPOSED
FEE
EFFECTIVE
2/19/2011
NEIGHBORHOOD PARKING PERMIT
NEIGHBORHOOD PROGRAM ESTABLISHMENT TRUST DEP.
TRUST DEPOSIT FOR ACTUAL STAFF TIME AT THE FULLY BURDENED HOURLY RATE AND DIRECT
COSTS (SUCH AS PURCHASE OF SIGNS)TO PROCESS AN APPLICATION TO ESTABLISH A
NEIGHBORHOOD PARKING PERMIT PROGRAM.
DECAL $2.50
NOTE:MINIMUM INITIAL DEPOSIT TO BE DETERMINED BY STAFF FOR ALL TRUST DEPOSITS.TRUST DEPOSITS MAY
BE USED TO PAY FOR SERVICES FROM THE CITY ATTORNEY,TRAFFIC COMMITTEE,NPDES CONSULTANT,OR OTHER
CONSULTANTS,AS SET FORTH IN RESOLUTION 2009-19.
OTHER:
ADDITIONAL SERVICES FOR WHICH A FEE HAS NOT BEEN ESTABLISHED SHALL BE CHARGED AT THE CITY'S FULLY
BURDENED HOURLY RATE.
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Alternative 2
EXHIBIT 2
Neighborhood Parking Permit Program Analysis of Fees,Charges and Rates
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Alternative 2
FIXED FEE COST SUMMARY WORKSHEET
FISCAL YEAR 2010·2011
SERVICE
NEIGHBORHOOD PARKING
PERMIT -NEIGHBORHOOD
PROGRAM ESTABLISHMENT
REFERENCE #S-290
PRIMARY DEPARTMENT PW-ADMINISTRATION
UNIT OF SERVICE APPLICATION
DESCRIPTION OF SERVICE
Evaluate a neighborhood
petition to establish a
neighborhood parking permit
program.Attend neighborhood
meeting(s),investigate the site,
evaluate signage needs,
purchase and install new signs.
SUBORG ID#POSITION DIRECT COST HOURS 2010 FBR COST
For actual staff time at the fUlly
burdened hourly rate and direct
costs (such as purchase of
signs)to process an
application to establish a
neighborhood parking permit
TRUST DEPOSIT program.Variable Variable Variable Actual
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Alternative 2
FIXED FEE COST SUMMARY WORKSHEET
FISCAL YEAR 2010·2011
SERVICE NEIGHBORHOOD PARKING
PERMIT -HOUSEHOLD -
NEW ISSUANCE
REFERENCE #S-291
PRIMARY DEPARTMENT PW-ADMINISTRATION
UNIT OF SERVICE APPLICATION
DESCRIPTION OF SERVICE Process a new permit
application for a household,
verify proof of residency,log
permit in database and issuing
decals.
SUBORG ID#POSITION DIRECT COST HOURS 2010 FBR COST
101-D-3006 1178 PERMIT CLERK 0.33 $102.69 $34
TOTAL $34
RECOMMENDED NEW FEE None
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Alternative 2
FIXED FEE COST SUMMARY WORKSHEET
FISCAL YEAR 2010-2011
SERVICE NEIGHBORHOOD PARKING
PERMIT -HOUSEHOLD -
RENEWAL
REFERENCE #S-292
PRIMARY DEPARTMENT PW-ADMINISTRATION
UNIT OF SERVICE APPLICATION
DESCRIPTION OF SERVICE Process permit renewal
application for a household,
verify residency information
and issue decal(s).
SUBORG 10#POSITION DIRECT COST HOURS 2010 FBR COST
101-D-3006 1178 PERMIT CLERK 0.17 $102.69 $17
TOTAL $17
RECOMMENDED NEW FEE None
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Alternative 2
FIXED FEE COST SUMMARY WORKSHEET
FISCAL YEAR 2010·2011
SERVICE NEIGHBORHOOD PARKING
PERMIT -DECAL
REFERENCE #8-293
PRIMARY DEPARTMENT PW-ADMINI8TRATION
UNIT OF SERVICE DECAL
DESCRIPTION OF SERVICE Purchase one neighborhood
parking permit decal
SUBORG ID#POSITION DIRECT COST HOURS 2010 FBR COST
$2.64 $2.64
TOTAL $2.64
RECOMMENDED NEW FEE $2.50
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