CC 2021-10-12_10a Allocations of Anticipated American Rescue Plan Act FundingMEMORANDUM
TO: CITY COUNCIL
FROM: WHITNEY MCDONALD, CITY MANAGER
BILL ROBESON, ASSISTANT CITY MANAGER/PUBLIC WORKS
DIRECTOR
NICOLE VALENTINE, ADMINISTRATIVE SERVICES DIRECTOR
BRIAN PEDROTTI, COMMUNITY DEVELOPMENT DIRECTOR
SUBJECT: DISCUSS AND CONSIDER ALLOCATIONS OF ANTICIPATED
AMERICAN RESCUE PLAN ACT FUNDING NOT PREVIOUSLY
ALLOCATED BY COUNCIL
DAT E: OCTOBER 12, 2021
SUMMARY OF ACTION:
Review and provide direction regarding the allocation of the City’s anticipated American
Rescue Plan Act (ARPA) Funding that was not previously allocated on July 27, 2021, and
appropriate ARPA funds according to Council direction.
IMPACT ON FINANCIAL AND PERSONNEL RESOURCES:
ARPA funds in the amount of $4,300,241 are expected to be received during Fiscal Years
2021-22 and 2022-23. One-half of this amount was received on July 13, 2021, and the
other half is expected 12 months later. On July 27, 2021, Council appropriated $2,493,950
of ARPA funds for identified water, sewer, and stormwater projects. It is recommended
that Council provide direction to allocate the $1,806,291 remaining anticipated ARPA
funds.
RECOMMENDATION:
It is recommended the City Council: (1) Appropriate $1,254,275 of ARPA Funds
to additional Water, Sewer, and Stormwater Infrastructure projects and qualified
anticipated City expenditures related to the COVID-19 pandemic as recommended by
the ad hoc committee; and (2) Consider and provide direction regarding allocation of
the remaining $552,016 of anticipated ARPA Funds to other qualified uses
consistent with US Treasury guidance.
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BACKGROUND:
On March 11, 2021, President Biden signed the American Rescue Plan Act (ARPA) of
2021 into law. The $1.9 trillion economic recovery package, based on President Biden’s
American Rescue Plan, is intended to provide financial aid to families, governments,
businesses, schools, non-profits and others impacted by the COVID-19 public health
crisis. To support the immediate pandemic response, bring back jobs, and lay the
groundwork for a strong and equitable recovery, ARPA established the Coronavirus State
and Local Recovery Fund, designed to deliver $350 billion to state, local, territorial, and
Tribal governments to bolster their response to the COVID-19 emergency and recover
from the economic impacts caused by the public health crisis. This legislation provided
$27 billion in federal money to the State of California. The State will allocate $1.2 billion
to non-entitlement units of local government (NEUs). As an NEU, Arroyo Grande is
eligible to receive $4,300,241. The City received the first tranche of funding on July 13,
2021, totaling $2,150,121, and the balance will be delivered 12 months later.
Recipients may use ARPA funds to:
• Support public health expenditures, by funding COVID-19 mitigation efforts,
medical expenses, behavioral healthcare, and certain public health and safety staff
• Address negative economic impacts caused by the public health emergency,
including economic harms to workers, households, small businesses, impacted
industries, and the public sector
• Replace lost public sector revenues, using this funding to provide government
services to the extent of the reduction in revenue experienced during the pandemic
• Provide premium pay for essential workers, offering additional support to those
who have borne and will bear the greatest health risks because of their service in
critical infrastructure sectors
• Invest in water, sewer, and broadband infrastructure, making necessary
investments to improve access to clean drinking water, support vital wastewater
and stormwater infrastructure, and to expand access to broadband internet
The U.S. Treasury issued an Interim Final Rule with guidance on the funding allocation
methodology, distribution process, and reporting requirements as well as Frequently
Asked Questions to assist jurisdictions in interpreting the policy language. The Treasury
accepted comments on the Interim Final Rule through July 16, 2021, and thereafter will
issue the Final Rule that will govern the program.
Ineligible Uses
The following is a list of examples of costs that would not be eligible expenditures of
payments from the Fund:
• Offset tax cuts implemented during the public health crisis
• Deposits into pension funds or rainy day funds
• Funding debt services and legal services
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Timeline
Arroyo Grande has until December 31, 2024, to commit ARPA funds by way of
contract/PO. Interim US Treasury rules currently list December 31, 2026, as the deadline
to spend these monies.
Reporting Requirements
The City’s ARPA funds are subject to annual project and expenditure reports, which
include financial data, information on contracts and subawards over $50,000, and other
information regarding utilization of funds. These reports will be similar to what was
required for the CARES Act Coronavirus Relief Fund. The first report, which is now due
April 30, 2022 (extended from October 31, 2021), will cover spending from the date the
City received its first tranche of ARPA funds through March 31,2022.
On July 27, 2021, the City Council provided direction regarding the allocation of the City’s
anticipated ARPA funds. At that time, Council approved staff’s recommendation to
appropriate a total of $2,493,950 in APRA funds toward specific water, sewer, and
stormwater projects as follows:
Water Infrastructure Projects
Reservoir No. 4 Exterior Coating 147,500
Phased Main Replacement Fair Oaks - Elm to Alder 232,750
Andre Drive/Los Ciervos Ct. Interconnect 100,000
480,250
Sewer Infrastructure Projects
Trenchless Sewer Rehabilitation
S. Alpine, S. Halcyon Rd., Wood Pl., Vernon St. & Woodland Dr.267,200
Stormwater Infrastructure Projects
Corrugated Metal Pipe (CMP) Lining 500,000
Storm Drain System at 251 East Grand Avenue (Chevron Station)410,000
Oak Park Boulevard/El Camino Real Storm Drain System 400,000
Trash Capture Devices 214,000
Stormwater Master Plan Update/Watershed Management Plan 172,500
Stormwater GIS Layer (incorporate into the Stormwater Master Plan Update)50,000
1,746,500
Grand Total 2,493,950
Total ARPA Funds 4,300,241
Funds to allocate 1,806,291
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In addition, an ad hoc committee was created, consisting of Mayor Ray Russom and
Mayor Pro Tem Paulding, and assisted by City staff, to evaluate and provide
recommendations to Council for allocating the remaining $1,806,291 in ARPA funding.
The ad hoc committee met three times following the July 27, 2021 City Council meeting
and developed recommendations, which are being presented for consideration at this
time.
ANALYSIS OF ISSUES
Ad Hoc Committee Recommendations
In developing recommendations for allocating the City’s remaining ARPA funds, the ad
hoc committee prioritized uses known to be allowed under the US Treasury’s Interim Rule
and uses that are not otherwise eligible for other grant funding. In addition, the committee
discussed the intent and purpose of ARPA as well as the desire to invest in infrastructure
and other needs of the City that would lower overall costs to the City’s rate payers.
The committee considered several programs, projects, and funding requests received
from both external sources, such as the 5Cities Homeless Coalition (5CHC), First 5, and
SmartShare SLO, and internal City departments. Ultimately, the committee determined
that it would recommend funding additional identified water, sewer, and stormwater
infrastructure projects and three areas of anticipated City expenses related to the COVID-
19 pandemic, totaling approximately $1.2 million. The committee further recommended
that the remaining approximately $550,000 be discussed and allocated by the entire
Council, with a focus on allocations to non-profits, including homeless services providers,
and possibly small business assistance grants.
Water, Sewer, and Stormwater Projects
The ad hoc committee recommends allocating $1,211,900 to the following additional
water, sewer, and stormwater projects:
Additional Water Infrastructure Projects
Phased Main Replacement
Cornwall St - S. Halcyon to El Camino Real 578,700
Highway 101 Crossing Upgrade - El Camino Real to W. Branch 291,200
869,900
Additional Sewer Infrastructure Projects
Trenchless Sewer Rehabilitation
Pilgrim Way & Orchard Ave/W. Cherry to Freeway/CA and W. Cherry 282,000
282,000
Additional Stormwater Infrastructure Projects
Corp Yard Stormwater Compliance Plan Implementation 60,000
Total Additional Water, Sewer, and Stormwater Projects 1,211,900
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Funding water and sewer projects using ARPA revenue is anticipated to provide a benefit
to the City’s ratepayers, including those impacted by the COVID-19 health emergency.
The City last increased its water and sewer rates in 2018 and, since that time, revenues
have not kept pace with the costs of providing service to City customers. A rate study was
close to completion when the COVID-19 pandemic began, and, in light of the impacts of
the pandemic, the City’s water and sewer rates have not been increased to keep pace
with costs. A revised rate study is now nearing completion so that the City will able to
adjust its water and sewer rates to fund ongoing services, including necessary repairs
and upgrades to the City’s water and sewer infrastructure. Any water or sewer projects
that are funded using ARPA revenue will lower the costs that the City’s customers would
be required to pay to complete necessary improvements.
City Expenses
The committee also recommends allocating a total of $42,375 to expenses that are
anticipated to be incurred by the City to provide increased sanitation services at City
parks, to reimburse the City for paid leave expenses required for City employees who
may be exposed to COVID-19 at work, and to reimburse the City for the potential costs
of testing employees for COVID-19 infections pursuant to anticipated future OSHA
regulations. These funding recommendations are detailed as follows:
Together, the recommended allocations to additional water, sewer, and stormwater
projects and to City expenditures required by the COVID-19 health emergency total
$1,254,275.
Remaining Funds
If the allocations are made as recommended above, the remaining ARPA funds for
discussion and allocation by Council amounts to $552,016. This amount includes
approximately $95,000 in calculated lost revenue funds, which may be expended for
general government services.
There are several options that Council may wish to consider for this funding. The
committee recommends that Council consider the suggestions and requests identified
below, with a focus on homeless shelter/services funding, Community Service Grant
funding, and/or business assistance grant funding. All requests or proposals considered
COVID related City expenditures
Park Sanitation Support 10,000
Paid leave reimbursement 18,375
Testing reimbursement 14,000
42,375
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by the committee are summarized in the following table and discussed in more detail
below.
• 5CHC Homeless Shelter Funding
5CHC has requested that the cities of Arroyo Grande, Grover Beach, and Pismo Beach
commit to providing funding to enable it to purchase property that would be used to
develop a homeless shelter that would serve the Five Cities communities. 5CHC has
identified a potential location for the shelter and is entering into negotiations with the
current property owner(s). Other State, Federal, or County grant opportunities may be
available to help fund development of a shelter on these parcels; however, 5CHC is
seeking more immediate funding sources to enable it to acquire the property. The City of
Grover Beach has allocated a total of $800,000 of its ARPA funding for homeless
services, with $500,000 identified for temporary or permanent shelter space projects.
Historically, the Five Cities region has been severely underserved in the area of
permanent homeless shelter space, with only a warming shelter being open at a different
location each year during the winter months on nights of severe cold or rain. The COVID-
19 pandemic has worsened the situation for those facing homelessness as well as for the
nonprofit service providers such as 5CHC. COVID outbreaks at the 40 Prado shelter in
San Luis Obispo have caused greater strains on the City’s unhoused population and has
increased incidences and reports of negative impacts associated with homelessness in
the City. Permanent shelter space will serve the existing unhoused population in Arroyo
Grande, as well as the surrounding local communities, and enable participants who
receive services from 5CHC to become housed. Development of shelter space will also
facilitate the enforcement of camping prohibitions and reduce the number of individuals
sleeping outdoors on public and private property throughout the City.
The US Treasury’s Interim Rule allows funding to be provided to support non-profits that
have been negatively impacted by the COVID-19 health emergency. In addition, funds
may be provided to populations that have been disproportionately impacted by the
pandemic, such as those experiencing homelessness. It is anticipated that ARPA funding
Qualified ARPA Projects (non-infrastructure)
Additional Options
for Council
Homeless Shelter Support ???
Non-Profit Assistance/Community Service Grants ???
Small Business Assistance Grants ???
Childcare Assistance - First 5, 5% request 215,012
Smart Share ADU SLO Proposal 37,887
Other City Projects:
Neogov HR Software Upgrade 36,000
Elm St. Playground Replacement Matching Funds 135,532
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may be provided to 5CHC for the purchase of parcels to be developed with homeless
shelter space that will benefit the City’s unhoused population.
Alternatively, Council may wish to consider allocating a portion of ARPA funds for
homeless services more generally and publishing an application process for service
providers to request funding for their programs or projects. This approach may be used
in conjunction with the City’s Community Service Grant application process or as a stand-
alone Notice of Funding Availability process, with a focus in the application and review
process being made for the provision of homeless services.
• Non-Profit Assistance/Community Service Grants
Many non-profit organizations have been unable to conduct their ordinary fundraising
activities due to restrictions on gatherings since the pandemic began. In addition, a
number of local non-profits provide necessary services that help members of the Arroyo
Grande community who have been disproportionately impacted by the COVID-19
pandemic. The City’s Fiscal Years 2021-22 and 2022-23 Budget appropriates $25,000
each year to the City’s Community Service Grant program. This program provides funding
for non-profit organizations operating in the City, allocated following an application and
review process set forth by City Resolution. A Community Service Grant Review Panel is
convened each year to review the applications and make funding recommendations to
Council. In the last two years, the Review Panel’s recommendations were focused on
funding applications seeking funding for impacts created by the COVID-19 pandemic. In
Fiscal Year 2019-20, $20,000 was provided to Community Service Grant recipients and
in Fiscal Year 2020-21, $50,000 was granted to recipients. Funding for the Fiscal Year
2020-21 program included $5,000 redirected from the City’s contribution to the Tourism
Business Improvement District and $25,000 in revenue received as a result of the CARES
Act. Council may wish to allocate ARPA funds to supplement the budgeted Community
Service Grant funds through Fiscal Years 2021-23. Any such ARPA funding directed to
the Community Service Grant program must be allocated to non-profits to address needs
created by the COVID-19 public health emergency.
• Small Business Assistance Grants
The US Treasury’s Interim Rule allows ARPA funding to be allocated to small businesses,
including through grants, loans, in-kind assistance, technical assistance, or other
services, that respond to the negative economic impacts of the COVID-19 public health
emergency. The City previously issued two rounds of assistance grants to Arroyo Grande
businesses impacted by the COVID-19 pandemic. The first round used $60,000 in
unanticipated revenue resulting from the CARES Act to provide $1,000-$5,000 grants to
eighteen Arroyo Grande businesses in December 2020. The first grant used $110,000 in
SB 1090 funds to provide $1,350-$7,500 grants to twenty-four businesses in June 2021.
Council may consider allocating remaining ARPA funds to conduct a third round of
Business Assistance Grants for small Arroyo Grande businesses.
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• Childcare Assistance
The US Treasury’s Interim Rule describes the many ways in which households with young
children have been negatively and disproportionately impacted by the COVID-19
pandemic due to disruptions in childcare. ARPA funds may be used to help address these
impacts through new or expanded childcare programs offered to communities
disproportionately impacted by the COVID-19 public health emergency, through
assistance to households in the form of childcare subsidies, through grants to small
childcare businesses, or through grants to non-profit organizations that provide childcare.
The City has received a request from First 5 San Luis Obispo County, in association with
several other organizations, to allocate 5% of the City’s ARPA funding to support
childcare initiatives. The request is provided in Attachment 1. For the City of Arroyo
Grande, 5% is equivalent to $215,012.05. The request suggests that funding be allocated
to eight initiatives, including: (1) financial support for the established SLO County Child
Care Planning Council (the California Department of Education designated advisory body
to the Superintendent of Schools and Board of Supervisors) to strengthen local child care
system infrastructure; (2) funding improvements to Family Resource Center operations
and facilities; (3) funding for additional childcare vouchers for low-income families; (4)
grants to small businesses for childcare services; (5) support for workforce development
for childcare workers; (6) investing in childcare facility space and capacity; (7) funding for
mental and behavioral health support for children and families; and (8) funding for family
housing stabilization programs, such as rent and/or or utility payments, rapid rehousing
funds, and eviction protection programs.
• Smart Share ADU SLO Proposal
The US Treasury’s Interim Rule allows ARPA funds to be used for affordable housing
programs provided to households, businesses, or populations disproportionately
impacted by the COVID-19 public health emergency. Smart Share Housing Solutions has
submitted a request to the County and its seven cities for ARPA funding to support a one-
year pilot program designed to increase the production of accessory dwelling units
(ADUs) throughout the region. The request is provided in Attachment 2 and seeks
$37,887 in ARPA funding from the City. As described in the request, Smart Share
proposes to provide education and outreach, technical assistance, project management
services, affordability advocacy, lending and finance support, tenant screening and
management assistance, and research, innovation, and community partnership support,
to increase the development of new ADUs in the City. Due to the restrictions of the current
US Treasury Interim Rule, it is likely that any ARPA funds dedicated to Smart Share would
need to be limited to assisting households that have been disproportionately impacted by
the COVID-19 pandemic. Any ARPA funding for this program would be in addition to
$20,000 in funding allocated to the City under an SB 2 grant that provides reimbursement
of staff time for education and outreach associated with the updated ADU Ordinance and
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in addition to the Regional Early Access Planning grant being used for the development
of regional pre-approved ADU plans.
• Other City Projects
Two additional City projects were considered by the committee for potential funding
through the ARPA: funding for the Elm Street Park playground equipment upgrade, and
a new Neogov software program supporting internal human resources functions. The
City’s Recreation Department is currently planning to seek grant funding from the State,
as well as support from the Arroyo Grande Valley Kiwanis Club, to cover a portion of the
costs for upgrades to the playground equipment at Elm Street Park. The equipment is
proposed to provide accessible and inclusive play opportunities to children of all ages, as
well as exercise equipment for adults. It is anticipated that $135,532 will be needed from
the City to complete construction, in addition to anticipated grant funds. Information
published by the US Treasury in its Frequently Asked Questions indicates that park
equipment replacement might be an eligible use of ARPA funds due to the heavy increase
in park usage seen in most public spaces during the pandemic. However, the Interim Rule
itself does not mention public parks specifically as an acceptable use of funds. Similarly,
upgrades to the City’s internal human resources software will reduce paperwork and help
limit the potential spread of COVID-19 through increased automation. However, the
Interim Rule does not address this potential use of ARPA funds. Therefore, any
allocations of APRA funding to these other City projects would likely be limited to the
amount of lost revenue that the City has calculated using the formulas stated in the Interim
Rule, approximately $95,000.
In sum, the ARPA ad hoc committee recommends that Council allocate the remaining
ARPA funds as follows:
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In addition, the committee recommends discussing and allocating the remaining $552,016
to other categories of uses described above.
ALTERNATIVES:
The following action is provided for City Council consideration:
1. (1) Appropriate $1,254,275 of ARPA Funds to additional Water, Sewer, and
Stormwater Infrastructure projects and qualified anticipated City expenditures related
to the COVID-19 pandemic as recommended by the ad hoc committee; and (2)
Consider and provide direction regarding allocation of the remaining $552,016 of
anticipated ARPA funds to other qualified uses consistent with US Treasury guidance.
2. Appropriate the ARPA funds to other programs or for other amounts, or provide
direction to staff to return with additional information regarding specific funding
recommendations or programs;
3. Provide further direction to staff.
ADVANTAGES:
Allocating ARPA funding to the projects recommended by the ad hoc committee will provide
funding for necessary water, sewer, and stormwater projects and lower costs to the City’s
ratepayer for those projects. Considering and providing direction regarding the remaining
ARPA funds will enable the City to meet reporting requirements issued by the US Treasury
COVID related City expenditures
Ad Hoc
Recommendations
Park Sanitation Support 10,000
Paid leave reimbursement 18,375
Testing reimbursement 14,000
42,375
Additional Water Infrastructure Projects
Phased Main Replacement
Cornwall St - S. Halcyon to El Camino Real 578,700
Highway 101 Crossing Upgrade - El Camino Real to W. Branch 291,200
869,900
Additional Sewer Infrastructure Projects
Trenchless Sewer Rehabilitation
Pilgrim Way & Orchard Ave/W. Cherry to Freeway/CA and W. Cherry 282,000
282,000
Additional Stormwater Infrastructure Projects
Corp Yard Stormwater Compliance Plan Implementation 60,000
Ad Hoc Recommendations Total 1,254,275
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and will provide support for programs and needs of the community and the City created by
the COVID-19 pandemic.
DISADVANTAGES:
Allocating more than $50,000 of ARPA funds to any subrecipient will require increased
monitoring and reporting requirements for City staff in administering the grant.
ENVIROMENTAL REVIEW:
No environmental review is required for this item.
PUBLIC NOTIFICATION AND COMMENTS:
The Agenda was posted at City Hall and on the City’s website in accordance with
Government Code Section 54954.2.
Attachments:
1. First 5 of San Luis Obispo County, et al. Request
2. Smart Share Housing Solutions ADU SLO Request
Item 10.a. - Page 11
American Rescue Plan Act Funding Proposal for Young Children
June 16, 2021
Dear Arroyo Grande City Council Members & City Manager,
The American Rescue Plan Act (ARPA) of 2021 presents a historic opportunity to support our youngest,
most vulnerable population like never before. Families with young children, aged 5 and under, have been
disproportionately impacted by the COVID-19 Pandemic; this year has created a mountain of uncertainty,
loss, and worry for families, whether they are facing health concerns, loss of child care and early
education opportunities, social isolation, or employment struggles. Investments in the first 5 years of life
have a higher rate of return than any period later in life. And at this critical time when the entire
community is focused on economic recovery, investment in children is directly tied to the estimated 50%
of the local labor force who are raising them.
Local child-serving organizations are ready to partner with county and city governments in mobilizing
successful implementation and execution of local ARPA funds in a way that ensures the unique needs of
children 0-5 are not overlooked. Children under the age of 6 represent 5%of the population of San Luis
Obispo County. On behalf of children and families, we urge you to invest five percent ($170,000) of the
City ARPA allocation in support of your youngest residents and their families.
First 5 San Luis Obispo County, in collaboration with a coalition of local partners, offers the City of Arroyo
Grande a suite of 8 proposed strategies for one-time local investments. We have identified these
strategies for their combined potential to bolster local systems of support in child care, mental health
and stable housing at a critical time and in ways that will help keep our community, our economy, our
families and our children on the road to recovery. The proposal is being submitted to all seven Cities and
the County; we urge you to consider collaborative approaches to addressing need and allocating funds.
Problem
The pandemic has been devastating for our children and families and has brought to the forefront huge
disparities that exist in our communities. People of color and those with the fewest resources have
borne the brunt of this pandemic, facing extreme economic insecurity and emotional trauma. Impacts
include:
●A spiraling child care crisis: Before the pandemic, SLO County was already short child care slots.
Since the start of the pandemic, as a county, we have lost over a thousand additional slots. This
lack of capacity has staggering implications for families returning to work, as well as for early
childhood educators. Without reliable, quality, and accessible child care, parents cannot return
to work, food and housing insecurity persist, child poverty is exacerbated, and the resulting
family stress increases the incidence of child maltreatment, substance abuse, and family
fracture. The economy depends on working parents returning to the job.
●Persistent financial and mental hardship for families and children: Nearly half of families across
the nation are worried about paying for at least one basic need such as food, rent, or utilities.
These financial hardships and job losses have also widened existing gaps in opportunity and/or
reversed prior progress. A significant percentage of entry-level workers in hospitality and leisure
-- those industries hardest hit by the pandemic -- are BIPOC individuals. Women, especially, have
1
Attachment 1
Item 10.a. - Page 12
been forced out of the workforce in record numbers. Many children within families in financial
hardship are facing emotional distress. Prolonged community stress is an Adverse Childhood
Experience (ACE) that -- especially for the youngest children -- can have negative health
outcomes in life.
Solution
Set aside 5% of your American Rescue Plan funding provided to the City of Arroyo Grande for the first 5
years of life. The local ARPA funding helps enable our community to commit toward the success of
children by investing in them as early as possible, and addressing the economic, racial, and health
disparities made worse by the pandemic. Stable families help create a bolstered economy, which
strengthens the communities in which infants and toddlers can learn, grow, and thrive.
8 Proposed Strategies (detailed in Attached Document)
STABILIZATION OF CHILD-SERVING SYSTEMS
1. Strengthening Local Child Care System Infrastructure
2. Family Resource Center Operations and Facilities
CHILD CARE
3. Access to Child Care through Vouchers
4. Small Business Grants for Child Care Programs
5. Workforce Development for Child Care Professionals
6. Child Care Facility Capacity
MENTAL AND BEHAVIORAL HEALTH SUPPORTS
7. Mental and Behavioral Health Support for Children & Families
HOUSING NEEDS
8. Family Housing Stabilization
Summary
The time to act is now. We urge you to dedicate 5%of American Rescue Plan Act funding provided to
your City government for the first 5 years of life. The pandemic has truly laid bare where our systems fall
short for too many children and families. We believe ARPA dollars can lay important groundwork in
understanding where our systems need repair, reimagining and restructuring so that all children in the
City of Arroyo Grande can realize their full potential.
Signed,
First 5 SLO County
SLO County Office of Education
SLO County Child Care Planning Council
CAPSLO Child Care Resource Connection
We Are the Care Initiative
5 Cities Homeless Coalition
Quality Counts SLO County
Help Me Grow SLO County
Center for Family Strengthening The LINK
2Item 10.a. - Page 13
American Rescue Plan Act Funding Proposal for Young Children
City of Arroyo Grande Strategies: $170,000 (5%)
STABILIZATION OF CHILD-SERVING SYSTEMS
1- Strengthening Local Child Care System Infrastructure
Expanded infrastructure to coordinate and complement the local child care system will strengthen the
recovery of our local mixed delivery system.
To meet the needs of working families and child care providers with a comprehensive approach that
leverages policy and funding from the federal and state governments, there must be expanded staffing
infrastructure and support of this sector that focuses on strengthening our local child care system. The
intricate demands of coordinating and planning for local child care have grown exponentially through the
pandemic. On the road to economic recovery, child care programs will need to blend and leverage
funding and opportunities to revitalize a mixed delivery system that is able to meet the needs of children
and families. The success of this countywide priority -- identified by a wide cross-section of community
members -- will need the guidance and oversight of an enhanced infrastructure system to support
coordinated efforts.
Augmented financial support for the established SLO County Child Care Planning Council (the CA Dept of
Education designated advisory body to the Superintendent of Schools and Board of Supervisors) will
accelerate implementation of an informed, unified, integrated, comprehensive family support
perspective through which we ensure that families can achieve their own goals through individualized
and streamlined approaches. This approach is in line with the Governor’s vision for comprehensive
family support services under the new State Department of Child Care and Development within the CA
Department of Social Services and would position the County for success as new State program
requirements are released, in a way that supports economic development.
2- Family Resource Center Operations and Facilities
Adaptable grants to expand current facilities for Family Advocates to meet with families, shore up
administrative functions to expedite ongoing resource and referral and financial support distributions
for families in crisis, and expanded Family Advocate staffing to conduct private parent education
sessions, and hold parent advisory meetings in a confidential setting. Increased flexible hours of
operation to better meet the needs of families.
Family Resource Centers are local community centers that support parents and families. The embedded
network of Family Resource Centers throughout San Luis Obispo County has continued to provide
dependable Family Advocate services to support families in accessing emergency assistance and support
re-entry into schools and work. Since March 16, 2020, Family Resource Centers have experienced
significant increases in demand for services, resulting in a squeeze on operational and personnel
3
Item 10.a. - Page 14
capacities. Family Resource Centers are currently operating in small modular buildings or co-located in
government or school district offices.
One-time funds to reinforce staffing and facilities within our already-established Family Resource Centers
can directly support families during this critically important recovery period. Centers are prepared to
grow and meet the needs of the families who live in rural and remote regions of San Luis Obispo County
with culturally appropriate, bilingual, reliable Family Advocate services on which many families depend.
CHILD CARE
3- Access to Child Care through Vouchers
Child care vouchers for working parents, student parents, and parents seeking work; targeting families
that are at or below 85% State Median Income (SMI).
Supporting access to child care is a critical prevention and recovery investment in family and economic
well-being. The purpose of a local voucher is to provide relief to families in San Luis Obispo County who
are in desperate need of child care so that parents, who cannot access the existing and highly limited
State voucher allocation due to funding availability, can work -- or look for work, or attend school or
training.
San Luis Obispo County typically has a waiting list of around 400 eligible children who meet SMI criteria
for the state’s subsidized child care system. Local support for even 10% of these children will greatly ease
the significant need to pay for care, and support SLO child care businesses that are an important part of
our mixed delivery system of care. With more families economically struggling due to pandemic-related
job losses, child care vouchers are desperately needed to help parents get back to work or up-skill/reskill
for the post-pandemic economy.
4- Small Business Grants for Child Care Programs
Flexible small grants for child care programs to stabilize our local system and fill some of the lost
revenue gaps due to COVID related restrictions.
Immediate economic assistance is needed to support this essential field, which underpins our economic
recovery ahead. Licensed child care professionals are often small business owners and have faced a host
of challenges during the COVID-19 pandemic even while striving to stay open and in service to local
families. Without intervention, the child care field will continue to spiral as more providers shutter after
a year of crisis. Grants will help sustain San Luis Obispo’s child care supply and set providers up to
support children and their families, while allowing the providers flexibility to decide what is best for their
business.
Investments in child care businesses have been key strategies throughout the pandemic, but businesses
continue to struggle to provide safe spaces for children to grow and learn. Increased costs related to
cleaning, protective equipment, and staffing coupled with reduced income because of smaller group
sizes continue to undermine business viability. Cleaning and Supply Grants, Quality Counts Health and
4
Item 10.a. - Page 15
Safety Grants, voucher-connected grants, city business grants, California Small Business Grants, and First
5 COVID-19 Relief Grants have all provided critical beginnings to prop up the child care system during
the pandemic. ARPA funds will help move the child care sector from “survival mode” to “sustainable
recovery.”
5- Workforce Development for Child Care Professionals
Investment in the child care professional workforce, including workforce development and
compensation to address the crisis of dwindling child care labor pool due to low wages coupled with
high cost of living and post-pandemic financial stressors.
San Luis Obispo County child care providers were already struggling to fill open staff positions
pre-pandemic. The demand for child care access is spiking, but supply continues to shrink due to lack of
providers. Statewide, a recent study found that half of child care workers turn over each year. This is
expensive for child care businesses and detrimental to children’s relationships with their caregivers. Low
wages are the primary culprit in this crisis, as individuals passionate about early learning often choose to
double their wages by acquiring a teaching certificate to work in K-12. The scarcity of child care workers
is now even more desperate and will impede the recovery of the sector, which has implications for the
recovery of the economy since the absence of child care options will keep many parents (mainly women)
from rejoining the labor force.
It is critical that we invest in a child care workforce. Stabilization, through adequate workforce
compensation and training will provide consistent and reliable care for our community's children and
families. This includes coordinated professional development across all systems and stipends for
continuing education to attract, retain, and advance the existing workforce. Established infrastructure
and partnerships exist to move this initiative forward. Leveraged, strategic and expanded investments
will extend reach and impact as programs are facing additional challenges of recovery and children and
families have additional developmental needs post-pandemic.
6- Child Care Facility Capacity
Address limited facility capacity through inventory and possible renovation of city-owned spaces or
new construction on city-owned land that can be used for no-cost leasing (long-term) to child care.
A significant barrier facing the community regarding child care supply is limited facility capacity. Child
care facilities are costly and time-consuming to develop due to multiple state and local requirements and
lack of financing for those opening child care facilities. Strategies to address the shortage of physical
facilities must be considered in context of the complexity of program operations and current conditions.
Public and private agency partners, including the child care provider community, must work
collaboratively to inform actions. Assigning a portion of ARPA funds toward one-time costs to utilize
existing space owned by the city or construction on city-owned with no-cost leasing can increase
capacity and decrease operating costs for providers. Both new facilities and renovations of existing
facilities can help address this barrier.
5
Item 10.a. - Page 16
MENTAL AND BEHAVIORAL HEALTH SUPPORTS
7- Mental and Behavioral Health Support for Children & Families
Expand training and technical assistance for clinicians serving children birth to five, expand trauma-
informed training across systems, reinforce partnerships across agencies to support children and
families, reduce barriers to access for families needing mental health support, and increase Parent
Cafes.
Mental health supports are needed for parents, caregivers, providers, as well as mental and
behavioral health supports for children. Access to preventative mental health services within the
community is extremely limited, with extensive waiting lists, and few options for 0-5 year olds. The
pandemic has resulted in an increase in Adverse Childhood Experiences (ACEs) and aligned stressors to
their primary caregivers. Flexible funding is needed to meet parents, caregivers, providers, and children
where they are, as well as a family-centered approach to achieve this as a protective factor. Access to
support in a time of need, including access to mental health supports, align to the Family Strengthening
model to support young children's development. Families need expedited access to culturally
competent, family-centric services to mitigate the impact of, and respond to, potential ACEs connected
to the pandemic. Existing models in the county can be leveraged and funded to reach more families.
8- Family Housing Stabilization
Rent and/or utility payments, extension of eviction protection programs, augmentation of rapid
rehousing funds, or other mechanisms to help ensure that no child becomes or remains unhoused
during this critical recovery period.
The ravages of the pandemic have left many families with young children in a precarious financial
position, which has in turn threatened their ability to provide the very basics, including a safe home. The
impact of COVID-19 on the right to housing reflects pre-existing social, legal, and political divisions along
racial, gender and other lines, with marginalised groups disproportionately experiencing largely
preventable suffering. Temporary eviction protections are about to disappear, and sufficient rent relief is
not guaranteed at this time. Many households are experiencing increased "shadow debt" utilizing credit
cards and payday loan companies (e.g. Check ‘N Go) to keep up with expenses. They will eventually have
to pay back these loans at extremely high rates, an expense that is not eligible under most assistance
programs, leaving them in a far worse financial position. Families with safe, stable and affordable
housing show fewer health problems, improved school performance, less psychological stress, and more
self-assured parents. Additionally, frequent moves can negatively affect the financial and physical health
of a household, but stability allows people to make investments in their communities, social
relationships, health, and education. Rent subsidies, eviction moratoriums, and mortgage forbearance
programs all encourage housing stability.
6
Item 10.a. - Page 17
ARPA Funding Request:
Executive Summary: Economic recovery and affordable housing production are of current high
priority and intricately intertwined. As such, Smart Share Housing Solutions, a San Luis Obispo
non-profit, requests that the County and seven incorporated cities leverage new state ADU
allowances and Smart Share funding and allocate one to two percent of ARPA funds from each
jurisdiction for a 3-year pilot ADU promotion and production program, ADU SLO, described in
the following pages. The relatively small investment could bring meaningful progress in terms of
affordable housing production and mitigating negative economic impacts from Covid-19,
particularly to lower-income households disproportionately affected by the pandemic.
Goals & Targeting: As Table I, below, illustrates, the County and cities rely heavily on ADUs to
meet RHNA mandates for both moderate and low income housing in the current housing
elements cycle, with joint production targets of approximately 400 ADUs per year with
approximately half projected moderate-income and half low-income affordable. The County, for
example, anticipates that in the unincorporated areas 96% of moderate-income targets will be
met with ADUs and a sizable share of low and very-low-income unit requirements through
ADUs.
The program would: 1) help meet housing element production targets, with roughly half of
ADUs produced moderate income affordable and half low income affordable; 2) target
assistance to lower income resident homeowners so they can share benefits; and 3) aim to
maintain ADU affordability over time.
Smart Share Housing Solutions ADU SLO smartsharehousingsolutions.org 805-215-5474 1
Attachment 2
Item 10.a. - Page 18
New state laws eliminate hurdles to ADU production and housing elements estimate theoretical
production. However, neither make production happen, make the ADUs produced affordable or
bring benefit to lower income San Luis Obispo residents. Many homeowners do not understand
how they can create safe, affordable ADUs on their property, while project management is
daunting for many, and permitting, construction and funding remain major obstacles.
Moreover, barriers to production tend to be greater for lower-income homeowners, also harder
hit by economic impacts related to covid--and more likely to rent ADUs produced to
lower-income tenants. As such, nonprofit programs that can function to keep costs down, help
explain the possible and “hand hold” from concept to rental process--particularly for
lower-income residents-- can increase affordable ADU production and bring benefits to
economically challenged homeowners & renters--often otherwise deprived of such benefits and
most impacted by the pandemic and in need of assistance and relief to recover from its
economic impacts.
Cost estimates and project summary: The ADU SLO pilot program is a 3 year $925,329
program to be funded leveraging $137,379 available Smart Share funding with one-time ARPA
funds from the County and the seven incorporated cities.
The program leverages Smart Share’s existing capacity to provide education, outreach and
technical support to lower-income homeowners and its community partnerships, such as a new
ADU loan program for participating clients through CoastHills Credit Union, resources of its
social investor pool to help with upfront design and permitting costs for low-income
homeowners, and a vetted contractor pool now ready to innovate to construct safe, basic,
community enhancing, affordable ADUs.
Efforts will assist understaffed planning departments with public outreach and client services to
meet or exceed affordable housing requirements and gain HCD bonus credits as designated
“prohousing” jurisdictions, potentially bringing more funding for affordable, sustainable housing
construction to each jurisdiction. A successful pilot, showing measurable impact, could be
continued with increased fees-for-service, SB2, LEAP, HEAP, inclusionary and other affordable
housing funds after the 3 year trial, or for-profit entities may have been formed to adequately fill
the gap and facilitate production.
ADU SLO Pilot Project and American Rescue Plan Act (ARPA):
Introduction: Housing challenges impact a wide range of San Luis Obispo County
residents — from extremely-low-income earners to middle-income workers who struggle to pay
for rental housing or purchase modest starter homes to an increasing number of single seniors
attempting to survive on limited social security benefits. Moreover, as the California Department
of Housing & Community Development (HCD) increases penalties for not meeting regional
housing need allocation (RHNA) targets, jurisdictions will face added incentives and increasing
penalties for failure to provide housing for residents in all income sectors. This will make
meeting RHNA targets increasingly valuable.
Smart Share Housing Solutions ADU SLO smartsharehousingsolutions.org 805-215-5474 2
Tot. project Smart Share County City SLO Paso
Robles AG MB GB Atasc Pismo
Beach
Total--3
year pilot $925,329 $137,379 $493,521 $65,211 $39,784 $37,887 $37,887 $37,887 $37,887 $37,887
Item 10.a. - Page 19
On the economic side, lower-income households have disproportionately been affected by
covid, and employers now have difficulties attracting, hiring and retaining qualified employees
due to high local housing costs. ADU construction can provide much needed long term
investment in affordable housing infrastructure, extra income for struggling homeowners and as
an economic driver, supporting design, construction and other relatively high-paying San Luis
Obispo County jobs.
As such, affordable ADU incentive and construction projects are an eligible use for ARPA funds,
directly meeting multiple ARPA goals, including:
● Strengthen support for vital public services and help retain jobs;
● Support immediate economic stabilization for households and businesses; and
● Address systemic public health and economic challenges that have contributed to the
unequal impact of the pandemic
Program(s) Description / Preliminary Scope of Services to Be Provided: Smart Share
Housing Solutions started its Tiny House Consulting program in 2020 which has evolved as
ADU SLO, a “one-stop ADU shop,” as many tasks required for ADU promotion are similar to
Smart Share’s HomeShareSLO existing program implementation activities, assisting primarily
lower-income homeowners and renters with affordable housing since 2017.
ADU SLO outreach, education and technical activities are currently provided. However, limited
funding sources minimize program capacity to scale and serve all County residents, particularly
capacity to seek out and assist lower-income households who may particularly struggle from
covid related impacts and find benefit from ADU construction. Local experience and a survey of
research statewide suggest the following activities are necessary to a successful uptick in
affordable ADU production:
•Outreach and education: Help (particularly lower-income) homeowners understand what
is possible
•Technical assistance: Free feasibility analysis and site visits
•Project management: Design, permitting, and construction assistance
•Affordability advocacy: Assistance targeted to lower income homeowners and renters &
toward smaller, simpler more “affordable by design” ADU construction
•Lending and finance : financial literacy training and access to loan funds
•Tenant screening and management assistance
•Research and Innovation and Community Partnerships: Forging pathways to decrease
construction costs through pre-fabricated components or homes; partnerships to
advance safe, effective waterless waste disposal systems, etc.
The project will operate in the unincorporated county area and in the seven incorporated cities
within San Luis Obispo County. Project costs would be shared by the 8 separate jurisdictions,
as shown in the project budget, below. The funding program is structured so that if some
jurisdictions opted not to join the program, it could still operate in unincorporated and
participating areas with County baseline operational funding.
Smart Share Housing Solutions ADU SLO smartsharehousingsolutions.org 805-215-5474 3
Item 10.a. - Page 20
Project Deliverables, Budget & Implementation Timeline: Because the conception to
ready-to-rent period will likely span multiple years for the average ADU project, meaning
measurable results may take years, a 3 year project implementation period is proposed,
January 1, 2022 through December 31, 2024.
•Outreach and Education: $76,860
o Website & e-news: step-by-step information for homeowners; worksheets;
handbook; agency contact information and resources
o Presentations and ADU Academy informational videos helping homeowners
understand opportunities, navigate the design, planning & construction process
and rent units;
o Targeted paid advertising to homeowners about ADU potential and benefits via
print, mail and digital media
•Technical assistance: $105,000
o Free feasibility analysis: phone consultation; Zoom and site visits: 100/year;
300/3 years
Smart Share Housing Solutions ADU SLO smartsharehousingsolutions.org 805-215-5474 4
Item 10.a. - Page 21
o Construction management for qualified homeowners: Linking homeowners to
technical help; vetting design builder specialists and matching to client need
•Affordability advocacy and incentives for low-income homeowners: $340,000
Smaller, more basic ADUs in some areas of the County will be naturally affordable at a
market rate. ADUs in some areas may not be affordable without requirements in place.
To promote affordability of ADUs created, program assistance and construction
incentives should be targeted to lower income (higher barrier) homeowners and renters
and toward lower cost to construct ADUs. Eligibility could require either homeowner
household income limit (e.g. <80% AMI or <120% AMI) or a commitment to charge an
affordable rent for a specified term from 5-10 years. Time and funds will be required for
both outreach and program implementation to strike the right balance between income
for homeowners and lower-income affordable ADU production.
•Lending and finance: $26,500
o Advocating and partnering for expansion of suitable ADU lending programs,
particularly to serve lower income San Luis Obispo County residents
o Connecting homeowners to loans to help fund affordable ADU production,
particularly for lower-income homeowners
•Tenant screening and management assistance to help homeowners manage rentals,
find, screen and maintain tenant occupancy: $42,125
o Tenant screening
o Tenant matching
o Ongoing monitoring & mediation and fair housing training services for portfolio of
program clients
•Research, Innovation and Community Partnerships: $141,000
Finding and sharing best practices for permitting, constructing and managing safe,
community-enhancing affordable housing. If affordable housing mandates are going to
be met, finding ways to bring ADU production costs down will be imperative. SLO
County ADU Task Force facilitation brings experts together around innovating solutions.
The ADU SLO program proposes a joint project with CalPoly’s Climate Institute to pilot a
waterless waste program for ADUs in order to minimize septic system tie in and
overloading challenges, reducing construction costs and water use.
Project Budget:
Smart Share Housing Solutions ADU SLO smartsharehousingsolutions.org 805-215-5474 5
Area Task units/$ Total
cost (3
years)
SmartShar
e
leverage County City
SLO Paso AG MB GB Atasc Pismo
Beach
Outreach &
Ed
Website; print
materials &
advertising
Set
up--1@$3500;
hosting fees
$300;
Weekly
updates--156@$
60=9360; $13,160 $3,500 9,660
Advertising--o
nline and print
newspaper
Print material
@$5000;
NT&Trib,
Google@$10,000
;
production@$2,5
00 $17,500 $2,500 15000
Postcard production &
mailing $15,000 $5,000 5000 3500 1500
Newsletters monthly--36@$2
00 $7,200 $3,600 3600
Informational
videos 10/year-30@$300 $9,000 $0 9000
Item 10.a. - Page 22
Smart Share Housing Solutions ADU SLO smartsharehousingsolutions.org 805-215-5474 6
Group
presentations
25/year--75@$20
0; 14/yr cities
and 11/yr county $15,000 $0 6600 1200 1200 1200 1200 1200 1200 1200
Outreach &
Ed Total: $76,860 $14,600 $48,860 $4,700 $2,700 $1,200 $1,200 $1,200 $1,200 $1,200
Technical
Assist Feasibility
analysis
100/year--300@$
150 (3-4 hr); 5/yr
for each city and
county 55; SLO
City 15 $45,000 $0 24750 6750 2250 2250 2250 2250 2250 2250
Project
management
assistance
50/year=150@$4
00; 3/yr per city;
26 county; 6 SLO
City $60,000 $0 31200 7200 3600 3600 3600 3600 3600 3600
Tech. Asst.
Total: $105,000 $0 $55,950 $13,950 $5,850 $5,850 $5,850 $5,850 $5,850 $5,850
Lower
income
affordability Targeted
Outreach
Non-profit
partner
outreach/client
connect $10,000 $10,000
**optional
component-
incentives
Construction
affordability
incentives
lower income
homeowner ADU
construction
subsidy:
30@$10K plus
admin$30K $330,000 $30,000 150000 30000 20000 20000 20000 20000 20000 20000
Lower Inc.
afford.
Total: $340,000 $40,000 $150,00
0 $30,000 $20,00
0 $20,000 $20,00
0 $20,000 $20,00
0 $20,000
Finance &
Lending
Creating
lending tools
to finance
affordable unit
construction 100 hours@$40 $4,000 $4,000
Loan
matching
assistance/me
ntoring
50/year--150@$1
50: County 36
and cities 2 each $22,500 $0 16200 900 900 900 900 900 900 900
Lending
asst. Total: $26,500 $4,000 $16,200 $900 $900 $900 $900 $900 $900 $900
Tenant
match &
manage
Training--
landlord &
tenant 30/year--90@$10
0 $9,000 $9,000
Screening,
matching,
monitoring
25/year--75@$75;
25/year-75@$300
; 50@$100 $33,125 $0 19125 2000 2000 2000 2000 2000 2000 2000
Tenant asst.
Total: $42,125 $9,000 $19,125 $2,000 $2,000 $2,000 $2,000 $2,000 $2,000 $2,000
Research,
Innovation
&
Partnership
Research best
practices
program
implementatio
n 200 hours@$40 $8,000 $8,000
Sharing best
practices &
partnerships 200 hours@$40 $8,000 $8,000
***optional
component
waterless
waste &
recycling,
CalPoly
Climate
Institute contract price $125,000 $25,000 100000
Research
Total: $141,000 $41,000 $100,00
0 $0 $0 $0 $0 $0 $0 $0
Total $731,485 $108,600 $390,13
5 $51,550 $31,45
0 $29,950 $29,95
0 $29,950 $29,95
0 $29,950
Item 10.a. - Page 23
For more detail refer also to: SLO County ADU Task Force Report on Accessory Dwelling
Units in San Luis Obispo County, May 28, 2021
(https://static1.squarespace.com/static/60427c9d3ab3967e3905964a/t/60c50b59ea2a9b393ce7
cb8c/1623526235504/ADU-Report-Final-Task-Force-June-2021.pdf)
Partnerships & Precedent: The San Luis Obispo County ADU Task Force, facilitated by Smart
Share Housing Solutions ADU SLO team, includes for profit, nonprofit and government
members in the planning, design, engineering, construction, environmental health, affordable
housing, lending, real estate and other fields. Smart Share anticipates added project partners to
include: 7 Cities and County of San Luis Obispo; REACH; ERI; HBACC; EVC and others. Hello
Housing, a Bay Area nonprofit, received $500,000 from the County of San Mateo for a similar
pilot program offering free project management, starting in 2019. The pilot so far directly created
17 ADUs and currently has 70 ADUs in the pipeline. The Napa Sonoma ADU Center, a
nonprofit, offers similar services in Napa and Sonoma Counties and has been funded by
Community Foundations with private and government partnership.
Organizational Capability: Leadership & Team
●Project Director Anne Wyatt, MCRP, is a housing policy planning consultant and
frequent contributor to the national magazine Planning, Vice Chair of the San Luis
Obispo County Commission on Aging, National Shared Housing Resource Center board
member, and a former County Planning Commissioner.
●Current Executive Director Celeste Goyer’s background is in operations and marketing
for startups in a range of industries plus experience in multifamily development and
management.
●Program Coordinator Shona Pruitt has over 25 years of experience working in
non-profit housing and property management.
●Board of Directors Chair Marianne Kennedy has over 30 years of experience working
with community non-profit groups on housing and other social issues.
●Board of Directors Vice Chair Joanna Balsamo-Lilien is a Property Management
Specialist for Family Care Network, managing properties for youth aging out of the foster
care system and formerly homeless families. She has many years of working to create
and support affordable housing from both the non-profit and government sector.
Contact:
Celeste Goyer, Executive Director, Smart Share Housing Solutions
celeste@smartsharehousingsolutions.org
(805) 215-5474
Anne Wyatt, MCRP, Director, ADU SLO
anne@smartsharehousingsolutions.org
(805) 215-5474
Smart Share Housing Solutions ADU SLO smartsharehousingsolutions.org 805-215-5474 7
Admin
Overhead @15% $109,723 $16,290 $58,520 $7,733 $4,718 $4,493 $4,493 $4,493 $4,493 $4,493
Contingenc
y @10% $84,121 $12,489 $44,866 $5,928 $3,617 $3,444 $3,444 $3,444 $3,444 $3,444
Tot.
project Smart
Share County City
SLO Paso
Robles AG MB GB Atasc Pismo
Beach
Total--3
year pilot $925,329 $137,379 $493,52
1 $65,211 $39,78
4 $37,887 $37,88
7 $37,887 $37,88
7 $37,887
Item 10.a. - Page 24