REPORT TO COUNCIL
SUBJECT
Title
Action on Modifications to P&P 049 Community Grant Policy
Report
COUNCIL PILLARS
Enhance Community Engagement and Transparency
Enhance Community Sports, Recreational and Arts Assets
EXECUTIVE SUMMARY
The Community Grant Policy (Policy) outlines the City’s process for awarding grants to qualifying non-profit community organizations, youth athletic groups or organizations, educational groups or organizations, or individuals, for events, activities, and competitions that provide a public benefit for Santa Clara and its residents.
Per Council’s previous direction to report on policy implementation, staff identified several areas for recommended policy updates. On August 18, 2021, the Economic Development, Communications and Marketing Council Committee (EDCM Committee) staff recommended modifications to the Policy as outlined in the Committee Report (Attachment 2) and highlighted in the Discussion section of this report. Modifications to the Policy are intended to provide more clarification for potential grantees and staff.
The EDCM Committee approved staff recommendation to forward policy modifications as proposed by staff to the full Council for its consideration.
BACKGROUND
Community grants are available to qualifying groups at a maximum amount of $10,000 per applicant, per year. To receive grant funds, grant applications must be submitted at least ninety (90) days before the planned event/activity being funded. Grants for attendance at youth state, national, or international competitions or performances (formerly Championship Team Fund) can be submitted within one week of advancing to such competitions and are limited to no more than 20% of the cost of eligible expenses defined as registration, hotel, transportation, and food for participants and coaches/chaperones.
Community Grant Program
For most non-profit and community groups, the Community Grant Program is the sole source of any City grant funds that they receive. The grants are intended to provide Santa Clara organizations with City assistance to produce events for the Santa Clara community. The City began accepting applications for Community Grants on October 1, 2018. Since the launch of the Community Grant Program, the City has received applications for various types of events and activities, including cultural events, social impact summits, fun runs, competitions, flower shows, car shows, meetings, and fundraising events.
General Events and Activities - The Policy requires applicants for a general event or activity that is not related to attendance at a youth competition or performance to demonstrate that the event or activity being funded by the City’s grant will satisfy the following eligibility criteria:
• Provides a benefit to Santa Clara residents
• Contributes positively to the recognition and image of the City of Santa Clara
• If the grant is for an event, then the event will be open to the general public and does not discriminate on the basis of race, gender, religion, sexual orientation, or any other protected characteristic under state or federal law
• Aligns with established Council goals
• Grant funds will not be used for political or religious purposes
• If the event or activity is a fundraising event, that the proceeds from the fundraising activity will support programs, services or events for residents of the City of Santa Clara
Youth-related Performances and Competitions
P&P 014 Funding Requests - Championship Teams/Individuals was rescinded when Council adopted P&P 049 Community Grant Policy, which merged P&P 014 and a draft Sponsorship Policy into a single policy for grant requests. Many of the guidelines and criteria for individual and group attendance at a youth competition or performance are identical to those in the rescinded P&P 014 Funding Requests - Championship Teams/Individuals.
The Policy requires individuals or groups applying for a grant to attend a youth state, national, or international competition or performance to demonstrate that the activity being funded by the City’s grant will satisfy the following criteria:
• Funding the activity provides a benefit to Santa Clara residents, students or schools
• Contributes positively to the recognition and image of the City of Santa Clara
• Aligns with established Council goals
• Grant funds will not be used for political or religious purposes
• The grant funds requested will only be used for a specific state, national, or international title or performance
• The grant funds requested do not exceed 20% of the allowable expenses (registration, hotel, transportation, and food) and comport with the other requirements stated in the application
• Individuals, teams or groups should either be from Santa Clara schools or have at least 50% of the students from the teams or groups be residents in the City of Santa Clara
• The student-to-coach/chaperone ratio is six students to one coach/chaperone
The adopted FY 2021/22 and FY 2022/23 biennial budget consolidated the Community Grants Program and Championship Teams budgets. During the June 22, 2021 budget adoption, City Council approved the reallocation of $10,000 from the Community Grants Program to the Santa Clara Ballet, bringing the total Community Grants/Championship Teams budget to $90,000.
Per Council’s previous direction to report on policy implementation, staff identified several areas for recommended policy updates.
DISCUSSION
On August 18, 2021, the Economic Development, Communications and Marketing Committee (Committee) voted (3-0) to approve staff recommended modifications to the Community Grant and forward the proposed amended version of the policy to the full Council for consideration. The Committee requested additional information at a future Committee meeting to discuss other grants such as the Cultural Commission grants, Santa Clara Sister Cities Association grant and Triton Museum Grant as well as information on the No Fee Parade Permit program. Due to staffing impacts, materials for this discussion have not been generated and an EDCM Committee meeting has not occurred.
Proposed Community Grant Policy Changes
Define Allowable Expenses as City Permits, Fees and Services, Venue, Food and Beverage, Trash/Recycling, and Stage/Tents Rentals -The Policy already limits the types of reimbursable expenses for attendance at a youth state, national, or international competition or performance to (no more than 20% of) the costs of registration, hotel, transportation and food for participants and coaches/chaperones only. The proposed Policy update defines allowable expenses as costs associated with: City permits, fees, and services; venue rental; food and non-alcoholic beverage; permits issued by other government agencies trash and recycling; and rental of staging and tents. These items are typically the most costly expenses associated with an event/activity.
Limit the Amount of Grant Funds for Food and Beverage - The proposed Policy update limits the amount of grant funds that can be used on this expense category. Staff recommends setting a cap of fifteen percent (15%) of the total grant amount (for a maximum of $1,500) as the limit per event/activity being funded.
Require Grantees to Refund City Any Unspent Grant Funds - The current Policy requires that grantees, regardless of the type of activity, submit proof that all approved expenses were incurred to the City Manager’s Office within thirty (30) days after the competition. In some cases, the applicant may not be able to spend full amount of awarded grant funds on approved expenses and therefore have a balance of unspent grant funds after staff reviewed submitted proof of receipts. This has already occurred for two events and staff has requested those organizations to reimburse the City for the amount of unspent grant funds. For these reasons, staff recommends including language in the policy that requires grantees to return any unspent grant funds to the City within 30 days after completion of the audit.
Provide the City with the Ability to Audit - The current Policy doesn’t provide the City the ability to audit applicants’ records beyond the time that they submit proof of receipts for allowable expenses. There may be instances when the City would need to audit previous grant records to ensure that grant funds were spent in the manner and for the purposes stated in the approved application. Staff recommends updating the policy to enable to City to audit books and records of applicants for up to four (4) years from the date of disbursement of grant funds. Similar language is already included in the City’s grant agreements with community organizations.
Restrict the Location of General Events and Activities to Santa Clara - The current Policy doesn’t restrict where general events and activities are held and only states that “If the grant is for an event, then the event will be open to the general public and does not discriminate on the basis of race, gender, religion, sexual orientation, or any other protected characteristic under state or federal law.” Several community groups have already submitted applications for events held outside of Santa Clara. While many of those applicants couldn’t clearly explain how their event located outside of Santa Clara would directly benefit Santa Clara residents and were therefore denied grant funding, the lack of policy language that requires the funded event to be held in Santa Clara is misleading to community groups in the general South Bay and Peninsula region that are looking for general support through grant funding. Without this amendment to the policy, the City will continue to receive grant requests for events held outside of Santa Clara.
Staff recommends including a requirement that the event or activity being funded must be held within Santa Clara as part of the eligibility criteria. This amendment would allow for a restriction on virtual events and will ensure events and activities being funded are open to the general public in Santa Clara, and therefore directly benefits Santa Clara residents, and will avoid misleading community groups that wish to hold events outside of Santa Clara with the City’s assistance.
The following recommended policy changes apply to both general events and activities and attendance at a youth state, national, or international competition or performance:
Limit Advance Submittal of Applications to Six Months - The Community Grant Policy requires that grant applications be submitted at least ninety (90) days prior to the event/activity being funded but doesn’t limit how far in advance an individual or organization can submit their application. As result, the City Manager’s Office has received requests up to eleven months in advance of the planned event/activity being funded. Without setting a time constraint for advance application submittal, applicants can submit grant requests for events/activities scheduled years out. It is challenging from an accounting perspective because permit and facility costs are subject to change at the start of every fiscal year and the funding for Community Grants is subject to budget appropriations. For example, the City received several grant applications in FY 2018/19 for events/activities that were scheduled nine or more months in the future, so their approvals were based on FY 2018/19 estimates for City permits, facilities, and staffing costs that were subject to change with the FY 2019/20 municipal fee schedule. The processing of grants for non-City related costs for events scheduled more than six months in advance also presents a potential liability to the City with grantees in possession of grant funds many months ahead of their scheduled event. Staff recommends updating the Policy to limit application submittals up to six months prior to the event or activity being funded to ensure that there is sufficient funding for the grants and to allow for a more competitive process.
Limit Eligibility to Competitive Grantees - The Policy currently doesn’t prevent organizations that currently receive annual grant funding from the City from applying for additional grant funds. Miss Santa Clara Scholarship Organization and Santa Clara Sister Cities Association are examples of non-profits that have previously received both annual funding from the City to support their programming and grant funds through the Community Grant Program.
Miss Santa Clara Scholarship Organization’s annual funding for FY 2018/19 totaled $12,000 and the organization received an additional $5,185 in funding through the Community Grant Program to fund the use of the Mission City Center for Performing Arts for competition rehearsals and their Miss Santa Clara and Miss Santa Clara’s Outstanding Teen Competition event on January 19, 2019. Santa Clara Sister Cities Association’s annual funding for FY 2018/19 totaled $5,659 and the organization received an additional $2,533 to cover expenses for their February 9, 2019 Afternoon Tea event. Funds provided by the City to support community organizations should be covered in the City’s annual agreements with organizations so that their total grant amount is transparent and reflective of what they are receiving from the City.
Staff recommends limiting eligibility to groups that do not receive separate annual funding from the City during the fiscal year that their event is scheduled in. This amendment will ensure that the City’s grant processes for community and non-profit organizations remains transparent and City grant funds are not used for the same event or programming.
Ability to Consider Previous Event/Activity’s Success and Prior Ability to Meet Policy Requirements/Obligations for Reoccurring Applicants - Since launching the Community Grant Program, the City has received requests from both new and reoccurring applicants and anticipates that there will be an increase in requests as more non-profit and community organizations in the area become aware of the City’s new Community Grant program. As the grant process becomes more competitive, it would be helpful to provide staff with more discretion to approve or deny a request. The Policy currently allows the City Manager’s Office to approve and deny an applicant’s request based on the eligibility criteria described in the Community Grant Policy and/or if there is a potential or appearance of a conflict of interest. There are no other guidelines that allow the City Manager’s Office additional discretion to deny future grant requests.
Applicants that receive grant funds from the City tend to reapply in the future. These events are not always successful in meeting their projected attendance (i.e., actual attendance is a very small fraction of the projection); outside fundraising goals (and therefore city funds are used for generally ineligible expenses), or the grantee could not meet the requirements of the policy (e.g. submit appropriate receipts). However, the current policy does not allow the City Manager’s Office to consider these factors and potentially deny such requests.
Staff recommends including language in the policy that allows the City Manager’s Office to consider an event or activity’s past success, defined by measures such as ability to meet attendance and/or fundraising projections, and the organization’s previous ability to meet policy requirements before approving or denying a grant request for reoccurring grantees. This change will allow the City to ensure that grant funds are used to support events and activities that benefit Santa Clara and its residents and promote a standard of fiscal responsibility among grantees.
Require Grantees to Report on Funded Events/Activities - The Policy doesn’t require grantees to submit anything but proof that the grant funds were spent in the manner and for the purposes stated on the application within 30 days after a general event/activity and proof of all allowable expenses actually incurred, as well as allocation of grant funds, within 30 days after the competition. Grantees currently don’t share information about their events, which in turn makes it difficult to understand the value of the City’s investment of funds for the benefit of Santa Clara. For these reasons, the recommended policy modification would require grantees to submit a post-event report within 30 days of a funded activity includes a summary of the actual event, attendance numbers, any challenges that the grantee encountered while planning the event or the day of the event, and areas for improvement.
ENVIRONMENTAL REVIEW
The action being considered does not constitute a “project” within the meaning of the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines section 15378(b)(5) in that it is a governmental organizational or administrative activity that will not result in direct or indirect changes in the environment.
FISCAL IMPACT
There is no fiscal impact associated with the approval of the recommended action.
The adopted FY 2021/22 and FY 2022/23 biennial budget consolidated the Community Grants Program and Championship Teams budgets. During the June 22, 2021 budget adoption, City Council approved the reallocation of $10,000 from the Community Grants Program to the Santa Clara Ballet, bringing the total Community Grants/Championship Teams budget to $90,000.
COORDINATION
This report has been coordinated with the City Attorney’s Office, Finance, and Parks and Recreation Departments.
PUBLIC CONTACT
Public contact was made by posting the Council agenda on the City’s official-notice bulletin board outside City Hall Council Chambers. A complete agenda packet is available on the City’s website and in the City Clerk’s Office at least 72 hours prior to a Regular Meeting and 24 hours prior to a Special Meeting. A hard copy of any agenda report may be requested by contacting the City Clerk’s Office at (408) 615-2220, email clerk@santaclaraca.gov <mailto:clerk@santaclaraca.gov> or at the public information desk at any City of Santa Clara public library.
ALTERNATIVES
1. Approve Amended Council Policy 049 (“Community Grant Policy”)
2. Do not approve Amended Council Policy 049 (“Community Grant Policy”)
3. Any other Council direction.
RECOMMENDATION
Recommendation
Alternatives 1: Approve Amended Council Policy 049 (“Community Grant Policy”).
Staff
Reviewed by: Ruth Mizobe Shikada, City Manager’s Office
Approved by: Rajeev Batra, City Manager
ATTACHMENTS
1. P&P 049 Community Grant Policy
2. RTC No. 21-1129 Report Uploaded as Post Meeting Material
3. Proposed Amended Council Policy 049 Community Grant Policy (Redline Version)
4. Proposed Amended Council Policy 049 Community Grant Policy (Clean Version)