09 - Costa Mesa Community Foundation Sponsorship Costa Mesa Sanitary District
…an Independent Special District
Protecting our community’s health and the environment by providing solid waste and sewer collection services.
www.cmsdca.gov
Memorandum
To: Board of Directors
From: Scott Carroll, General Manager
Date: September 26, 2013
Subject: Costa Mesa Community Foundation Sponsorship
Summary
Often, youth and non-profit organizations will ask CMSD to sponsor their events or support
their organization with monetary donations. In the past, CMSD has sponsored events
and/or organizations such as the MUZEO Trash Art C hallenge, the Costa Mesa Mayor’s
Celebration: The Art of Leadership, Estancia High School sports, City of Costa Mesa 60 th
Anniversary, etc. On July 31, 2013, the Board approved implementing new procedures for
sponsoring organizations and/or events.
Staff Recommendation
That the Board of Directors considers sponsorship levels for Concerts in the Park and
determine how being a sponsor will serve the District’s purpose.
Analysis
Attachment “A” is a memo from District Counsel about the gift of public funds and
expenditures for a proper public purpose. On July 31, 2013, The Board approved new
procedures to determine if the District can officially sponsor events and/or non-profit
organizations. Before the District can be a sponsor, the Board must follow the following
procedures.
Establish th e purpose CMSD is trying to serve by being a sponsor. This must be a
purpose established as one of the District’s statutory powers or a power that would
be incidental to those purposes. For example, District purposes are to properly
treat sewage, to prev ent SSOs, to reduce landfill dumping, and to recycle. While
the District might not be lawfully authorized to support “the Arts,” it could spo nsor
the Muzeo contest because the contest promoted waste reduction by using trash to
ITEM NO. 09
Board of Directors
September 26 , 2013
Page 2 of 3
make art . Attachment B is a prepared chart to assist the Board in making the
determination for the two current requests as well as future requests .
Then, describe how the expenditures will advance CMSD’s purpose.
On July 31, 2013, the Board of Directors heard a reques t from the Cos ta Mesa Community
Foundation (CM CF) to be a sponsor of Concerts in the Park in 2014 . CMCF is requesting
CMSD to sponsor Concerts in the Park and partner with them on promoting recycling and
waste dive rsion activities. Attachment C is the sponsoring re quest from CMCF along with
a list of different sponsorship levels. The District can be a Bronze Sponsor and display a
CMSD banner at the event or for $2,500 the District can be a Gold Sponsor that will
include a CMSD booth at all five concerts.
One such purpose the Board can consider for sponsoring Concerts in the Park is to
increase CMSD’s visibility in the community and/or bring awareness to the public by
making available all the programs CMSD has to offer. Being a Bronze, Copper, Silver or
Gold Spons o r will advance this purpose.
On July 31 st , the Board directed staff to bring this item back for further discussion at
today’s study session . On September 9 th the Board discussed this item at a study session
meeting and directed staff to bring it bac k for further discussion at your Board meeting
tonight.
Strategic Plan Element & Goal
This item complies wit h objective and strategy of Strategic Element 5 .0., Administrative
Management , which states:
“Objective: To create, maintain and implement policies and procedures to ensure sound
management of the District.
Strategy: We will conduct periodic reviews, refine and implement policies and procedures,
and assure the General Manager has the direction and tools necessary for successful
District oper ations.”
Legal Review
District Counsel has reviewed this report.
Financial Review
The cost to sponsor CMCF for Concerts in the Park ranges from $500 (Bronze Sponsor) to
$2,500 (Gold Sponsor). In addition, staff estimates it will cost the District $621.05 in
overtime for staffing a CMSD booth at all five concerts.
Sponsoring CMCF for Concerts in t he Park is not budged in FY 2013 -14 . This cost can be
split 50% where $250.00 or $1,250 can be appropriated from the Li quid Waste
Board of Directors
September 26 , 2013
Page 3 of 3
Contingency and $250.00 or $1,250 can be appropriated from the Solid Waste
Educational Programs. There is $33,430 budgeted in Liquid Waste Contingency and
$40,900 budgeted in Solid Waste Educational Programs.
Public Notice Process
Copies of this report are on file and will be included with the entire agenda packet for the
September 26 , 2013 Bo ard of Directors regular meeting at District headquarters and on
District’s website.
Alternative Actions
1. Direct staff to report back with mor e information
Attachments A: Memo from District Counsel, dated June 27, 2013
B: Gift of Public Funds Determination Chart
C: Request for Sponsorship from Costa Mesa Community Foundation
Reviewed by:
Stacey Cuevas
LAW OFFICES OF
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Alan R. Burns
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To: Honorable President and Board of Directors
From: District Counsel
Date: June 27, 2013
Re: Gift of Public Funds / Expenditures for a Prope r Public Purpose
______________________________________________________________________________
Article XVI, Section 6 of the Cal Constitution prov ides that a public entity may not make a gift
of public funds. The primary question to be asked is whether a private purpose is being served,
as opposed to a public purpose.
Over and above that primary test, one public entity cannot make a gift of its resources to another
public agency if it does not advance the public pur pose of the donor agency. In Golden Gate
Bridge and Highway District et al. v. Luehring et a l. (1970) 4 Cal.App.3d 204, the Court held
that a bridge district that collected tolls could n ot turn over the surplus to a county, since the
purposes of the two agencies were different. In an Attorney General opinion, it was also opined
that a sanitary district could not donate its prope rty to a park and recreation district but was
required to sell that property for full and fair co nsideration. (46 Ops.Cal.Atty.Gen. 138.)
Our sanitary district powers include the power to p lan and build sewer facilities, as well as
collect garbage and operate dumpsites. We are also authorized to make and enforce regulations
for other sanitary purposes not in conflict with st ate law. (HSC § 6521.) We are also given the
power to do any act necessary or proper to the comp lete exercise and effect of our powers
(incidental powers). (HSC § 6522) Using that autho rity, we have engaged in recycling and waste
reduction, as well as FOG reduction programs. We h ave in the past provided similar
sponsorships of programs that advanced our public p urposes. Those would include the recent
Muzeo trash/art project.
The courts will generally defer to the judgment of the legislative body making a determination
that a public purpose is being served if that judgm ent has a reasonable basis.
C ONCLUSION
To be able to justify a questionable expenditure as not being a gift of public funds, we must
establish what District purpose we are trying to se rve. After we identify that purpose, the Board
needs to make a determination that a public purpose is being served by articulating how the
Harper & Burns LLP | 453 South Glassell Street, Orange, California 92866 | Telephone (714) 771-7728 | Facsimile (714) 744-3350 | www.harperburns.com
Costa Mesa Sanitary District
Gift of Public Funds / Expenditures for a Proper Pu blic Purpose
June 27, 2013
Page 2
expenditure advances that purpose. The Board’s jud gment should not thereafter be disturbed by
the courts if its judgment on the matter had a reas onable basis. I recommend that the Board:
1. Articulate the purpose being served by identifying what District power we are advancing
(e.g, awareness of trash recycling, not dumping in the sewer, not allowing grease to
accumulate in sewerlines, etc.).
2. Describe how the expenditure advances that purpose.
3. Have the full Board vote on the matter so there is a Board judgment that a proper public
purpose is being served.
This needs to be determined in a properly noticed B oard meeting. Only Board approval will
entitle the decision to judicial deference. In fac t, if any staff person determined to make the
expenditure without Board approval, there could be personal liability. The fact a staff person
acted honestly and in good faith provides no defens e to personal liability. (Mines v. Del Valle
(1927) 201 Cal. 273.)
Respectfully submitted,
Alan R. Burns
District Counsel
cc: General Manager-District Clerk
Treasurer
GIFT OF PUBLIC FUNDS
DETERMINATION CHART
Does the request serve a District purpose?
NO : Gift of public funds
YES : IDENTIFY – What st atutory purpose might be served (s ewer system, grease reduction,
roots, divesting waste from landfill, recycling, other )?
If a statutory purpose is not served, what incidental purpose might be served?
NO NE : Gift of public funds
IDENTIFY
How will the expenditure of money advance the District purpose?
IT WILL NOT : Gift of public funds
IDENTIFY : District message is to be prominently displayed so as to reach our
constituents? Other?