LAFCO
Brooktrails Township CSD, 2019
Read the report at Local Agency Formation Commissions ↗
ADOPTED
(The Press Democrat, 2012)
B T
ROOKTRAILS OWNSHIP
C S D
OMMUNITY ERVICES ISTRICT
Municipal Service Review and
Sphere of Influence Update
Prepared for:
M LAFC
ENDOCINO O
200 South School Street
Ukiah, California 95482
http://www.mendolafco.org/
Workshop: June 3, 2019
Public Hearing: August 5, 2019
Adopted: August 5, 2019
LAFCo Resolution No: 2019-20-01
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MSR/SOI Update | Brooktrails Township CSD
TABLE OF CONTENTS
1 INTRODUCTION .......................................................................................................................................... 1-1
1.1 LOCAL AGENCY FORMATION COMMISSION ............................................................................................. 1-1
1.2 MENDOCINO LAFCO ................................................................................................................................. 1-1
1.3 MUNICIPAL SERVICE REVIEW ................................................................................................................... 1-1
1.4 SPHERE OF INFLUENCE ............................................................................................................................. 1-2
1.5 MENDOCINO LAFCO POLICIES .................................................................................................................. 1-2
1.6 SENATE BILL 215 ....................................................................................................................................... 1-5
2 AGENCY OVERVIEW .................................................................................................................................... 2-1
2.1 HISTORY.................................................................................................................................................... 2-1
2.1.1 FORMATION........................................................................................................................................................... 2-1
2.1.2 BOUNDARY ............................................................................................................................................................ 2-1
2.1.3 SERVICES ................................................................................................................................................................ 2-2
2.2 GOVERNMENT STRUCTURE ...................................................................................................................... 2-2
2.2.1 GOVERNING BODY ................................................................................................................................................. 2-2
2.2.2 PUBLIC MEETINGS ................................................................................................................................................. 2-3
2.2.3 STANDING COMMITTEES ....................................................................................................................................... 2-3
2.2.4 NON-PROFIT ORGANIZATION ................................................................................................................................ 2-3
2.2.5 PUBLIC OUTREACH ................................................................................................................................................ 2-3
2.2.6 COMPLAINTS ......................................................................................................................................................... 2-4
2.2.7 TRANSPARENCY AND ACCOUNTABILITY ................................................................................................................ 2-4
2.3 OPERATIONAL EFFICIENCY ....................................................................................................................... 2-4
2.3.1 MANAGEMENT AND STAFFING ............................................................................................................................. 2-4
2.3.2 AGENCY PERFORMANCE ........................................................................................................................................ 2-6
2.3.3 REGIONAL AND SERVICE-SPECIFIC COLLABORATION............................................................................................. 2-6
2.3.4 SHARED FACILITIES, RESOURCES, AND SERVICES .................................................................................................. 2-7
2.3.5 GOVERNMENT RESTRUCTURE OPTIONS ................................................................................................................ 2-8
2.4 FINANCES ................................................................................................................................................. 2-9
2.4.1 CURRENT FISCAL HEALTH ...................................................................................................................................... 2-9
2.4.2 LONG TERM FINANCIAL CONSIDERATIONS.......................................................................................................... 2-13
2.5 GROWTH ................................................................................................................................................ 2-19
2.5.1 PRESENT AND PLANNED LAND USE AND DEVELOPMENT ................................................................................... 2-19
2.5.2 EXISTING POPULATION AND PROJECTED GROWTH ............................................................................................ 2-26
2.6 DISADVANTAGED UNINCORPORATED COMMUNITIES .......................................................................... 2-28
3 MUNICIPAL SERVICES ................................................................................................................................. 3-1
3.1 SERVICE OVERVIEW .................................................................................................................................. 3-1
3.1.1 SERVICES ................................................................................................................................................................ 3-1
3.1.2 SERVICE AREAS ...................................................................................................................................................... 3-1
3.1.3 OUT-OF-AGENCY SERVICES .................................................................................................................................... 3-1
3.2 PLANNING AND DESIGN REVIEW .............................................................................................................. 3-1
3.3 PARKS AND RECREATION .......................................................................................................................... 3-3
3.4 FIRE PROTECTION AND EMERGENCY MEDICAL SERVICES ........................................................................ 3-4
3.4.1 SERVICE OVERVIEW ............................................................................................................................................... 3-4
3.4.2 SERVICE ADEQUACY ............................................................................................................................................... 3-7
3.4.3 FACILITIES AND ASSETS .......................................................................................................................................... 3-8
3.5 WATER .................................................................................................................................................... 3-10
3.5.1 SERVICE OVERVIEW ............................................................................................................................................. 3-10
MSR/SOI Update | Brooktrails Township CSD
3.5.2 WATER DEMAND AND CAPACITY ........................................................................................................................ 3-10
3.5.3 PAST WATER MORATORIUM ............................................................................................................................... 3-12
3.5.4 WATER SUPPLY ENHANCEMENT .......................................................................................................................... 3-12
3.5.5 OPERATIONS AND CAPITAL NEEDS ...................................................................................................................... 3-13
3.6 WASTEWATER ........................................................................................................................................ 3-14
3.6.1 SERVICE OVERVIEW ............................................................................................................................................. 3-14
3.6.2 WASTEWATER TREATMENT AND DISPOSAL SERVICES ........................................................................................ 3-15
3.7 DETERMINATIONS .................................................................................................................................. 3-15
3.7.1 MSR REVIEW FACTORS ........................................................................................................................................ 3-15
4 SPHERE OF INFLUENCE ............................................................................................................................... 4-1
4.1 SOI UPDATE .............................................................................................................................................. 4-1
4.1.1 EXISTING SPHERE OF INFLUENCE ........................................................................................................................... 4-1
4.1.2 STUDY AREAS ......................................................................................................................................................... 4-1
4.1.3 AREA OF INTEREST DESIGNATION ......................................................................................................................... 4-2
4.1.4 PROPOSED SOI CHANGES ...................................................................................................................................... 4-2
4.1.5 CONSISTENCY WITH LAFCO POLICIES .................................................................................................................... 4-2
4.1.6 DETERMINATIONS ................................................................................................................................................. 4-2
5 REFERENCES ............................................................................................................................................... 5-1
6 ACRONYMS ................................................................................................................................................ 6-1
7 ACKNOWLEDGEMENTS ............................................................................................................................... 7-1
7.1 REPORT PREPARATION ............................................................................................................................. 7-1
7.2 ASSISTANCE AND SUPPORT ...................................................................................................................... 7-1
8 APPENDICES ............................................................................................................................................... 8-1
8.1 APPENDIX A – OPEN GOVERNMENT RESOURCES ..................................................................................... 8-1
8.2 APPENDIX B – WEBSITE COMPLIANCE HANDOUT .................................................................................... 8-2
MSR/SOI Update | Brooktrails Township CSD
1 INTRODUCTION
1.1 LOCAL AGENCY FORMATION COMMISSION
Local Agency Formation Commissions (LAFCos) are quasi-legislative, independent local agencies that
were established by State legislation in 1963 to oversee the logical and orderly formation and
development of local government agencies including cities and special districts. There is one LAFCo for
each county in California.
LAFCo is responsible for implementing the Cortese-Knox-Hertzberg (CKH) Local Government
Reorganization Act of 2000 (California Government Code Section 56000 et. seq.) in order to promote
orderly growth, prevent urban sprawl, preserve agricultural and open space lands, and oversee efficient
provision of municipal services.
LAFCo has the authority to establish and reorganize cities and special districts, change their boundaries
and authorized services, allow the extension of public services, perform municipal service reviews, and
establish spheres of influence. Some of LAFCo’s duties include regulating boundary changes through
annexations or detachments and forming, consolidating, or dissolving local agencies.
1.2 MENDOCINO LAFCO
The CKH Act provides for flexibility in addressing State regulations to allow for adaptation to local needs.
Mendocino LAFCo has adopted policies, procedures and principles that guide its operations. These
policies and procedures can be found on Mendocino LAFCo’s website at the following location:
http://www.mendolafco.org/policies.html.
Mendocino LAFCo has a public Commission with seven regular Commissioners and four alternate
Commissioners. The Commission is composed of two members of the Mendocino County Board of
Supervisors, two City Council members, two Special District representatives, and one Public Member-At-
Large. The Commission also includes one alternate member for each represented category.
1.3 MUNICIPAL SERVICE REVIEW
The CKH Act (GC §56430) requires LAFCo to prepare a Municipal Service Review (MSR) for all local
agencies within its jurisdiction. MSRs are required prior to and in conjunction with the update of a
Sphere of Influence (SOI).
An MSR is a comprehensive analysis of the services provided by a local government agency to evaluate
the capabilities of that agency to meet the public service needs of their current and future service area.
An MSR must address the following seven factors:
1. Growth and population projections for the affected area.
2. The location and characteristics of any disadvantaged unincorporated communities within or
contiguous to the sphere of influence.
3. Present and planned capacity of public facilities, adequacy of public services, and infrastructure
needs or deficiencies including needs or deficiencies related to sewers, municipal and industrial
water, and structural fire protection in any disadvantaged unincorporated communities within
or contiguous to the sphere of influence.
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MSR/SOI Update | Brooktrails Township CSD
4. Financial ability of agencies to provide services.
5. Status of, and opportunities for, shared facilities.
6. Accountability for community service needs, including governmental structure and operational
efficiencies.
7. Any other matter related to effective or efficient service delivery, as required by commission
policy.
MSRs include written statements or determinations with respect to each of the seven mandated areas
of evaluation outlined above. These determinations provide the basis for LAFCo to consider the
appropriateness of a service provider’s existing and future service area boundary.
1.4 SPHERE OF INFLUENCE
The CKH Act requires LAFCo to adopt a Sphere of Influence (SOI) for all local agencies within its
jurisdiction. A SOI is “a plan for the probable physical boundary and service area of a local agency or
municipality as determined by the Commission” (GC §56076).
When reviewing an SOI for a municipal service provider, LAFCo will consider the following five factors:
1. The present and planned land uses in the area, including agricultural and open space lands.
2. The present and probable need for public facilities and services in the area.
3. The present capacity of public facilities and adequacy of public services that the agency provides
or is authorized to provide.
4. The existence of any social or economic communities of interest in the area if the commission
determines that they are relevant to the agency.
5. For an update of a sphere of influence of a city or special district that provides public facilities or
services related to sewers, municipal and industrial water, or structural fire protection, that
occurs pursuant to subdivision (g) on or after July 1, 2012, the present and probable need for
those public facilities and services of any disadvantaged unincorporated communities within the
existing sphere of influence.
Sphere of Influence Updates include written statements or determinations with respect to each of the
five mandated areas of evaluation outlined above. These determinations provide the basis for LAFCo to
consider the appropriateness of establishing or modifying a service provider’s SOI or probable future
boundary.
1.5 MENDOCINO LAFCO POLICIES
In addition to making the necessary determinations for establishing or modifying a SOI consistent with
the CKH Act, the appropriateness of an agency’s SOI is also based on an evaluation of consistency with
local LAFCo policies.
The following Sphere of Influence policies are from the Mendocino LAFCo Policies and Procedures
Manual, adopted November 5, 2018.
10.1.1 Legislative Authority and Intent
A sphere of influence is the probable 20-year growth boundary for a jurisdiction’s physical development.
The Commission shall use spheres of influence to:
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MSR/SOI Update | Brooktrails Township CSD
a) promote orderly growth and development within and adjacent to communities;
b) promote cooperative planning efforts among cities, the County, and special districts to address
concerns regarding land use and development standards, premature conversion of agriculture and
open space lands, and efficient provision of public services;
c) guide future local government reorganization that encourages efficiency, economy, and orderly
changes in local government; and
d) assist property owners in anticipating the availability of public services in planning for the use of
their property.
10.1.2 Definitions
The Commission incorporates the following definitions:
a) an “establishment” refers to the initial development and determination of a sphere of influence by
the Commission;
b) an “amendment” refers to a limited change to an established sphere of influence typically initiated
by a landowner, resident, or agency; and
c) an “update” refers to a comprehensive change to an established sphere of influence typically
initiated by the Commission.
10.1.3 Sphere Updates
In updating spheres of influence, the Commission’s general policies are as follows:
a) The Commission will review all spheres of influences every five years for each governmental agency
providing municipal services. Municipal services include water, wastewater, police, and fire
protection services.
b) Sphere of influence changes initiated by any agency providing a municipal service shall generally
require either an updated or new service review unless LAFCo determines that a prior service review
is adequate.
c) Spheres of influence of districts not providing municipal services including, but not limited to,
ambulance, recreation, hospital, resource conservation, cemetery, and pest control shall be updated
as necessary.
10.1.4 Reduced Spheres
The Commission shall endeavor to maintain and expand, as needed, spheres of influence to
accommodate planned and orderly urban development. The Commission shall, however, consider
removal of land from an agency’s sphere of influence if either of the following two conditions apply:
a) the land is outside the affected agency’s jurisdictional boundary but has been within the sphere of
influence for 10 or more years; or
b) the land is inside the affected agency’s jurisdictional boundary but is not expected to be developed
for urban uses or require urban-type services within the next 10 years.
10.1.5 Zero Spheres
LAFCo may adopt a “zero” sphere of influence encompassing no territory for an agency. This occurs if
LAFCo determines that the public service functions of the agency are either nonexistent, no longer
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MSR/SOI Update | Brooktrails Township CSD
needed, or should be reallocated to some other agency (e.g., mergers, consolidations). The local agency
which has been assigned a zero sphere should ultimately be dissolved.
10.1.6 Service Specific Spheres
If territory within the proposed sphere boundary of a local agency does not need all of the services of
the agency, a “service specific” sphere of influence may be designated.
10.1.7 Agriculture and Open Space Lands
Territory not in need of urban services, including open space, agriculture, recreational, rural lands, or
residential rural areas shall not be assigned to an agency’s sphere of influence unless the area’s
exclusion would impede the planned, orderly and efficient development of the area. In addition, LAFCo
may adopt a sphere of influence that excludes territory currently within that agency’s boundaries. This
may occur when LAFCo determines that the territory consists of agricultural lands, open space lands, or
agricultural preserves whose preservation would be jeopardized by inclusion within an agency’s sphere.
Exclusion of these areas from an agency’s sphere of influence indicates that detachment is appropriate.
10.1.8 Annexations Are Not Mandatory
Before territory can be annexed to a city or district, it must be within the agency’s sphere of influence
(G.G. §56375.5). However, territory within an agency’s sphere will not necessarily be annexed. A sphere
is only one of several factors that are considered by LAFCo when evaluating changes of organization or
reorganization.
10.1.9 Islands or Corridors
Sphere of influence boundaries shall not create islands or corridors unless it can be demonstrated that
the irregular boundaries represent the most logical and orderly service area of an agency.
10.1.10 Overlapping Spheres
LAFCo encourages the reduction of overlapping spheres of influence to avoid unnecessary and
inefficient duplication of services or facilities. In deciding which of two or more equally capable agencies
shall include an area within its sphere of influence, LAFCo shall consider the agencies’ service and
financial capabilities, social and economic interdependencies, topographic factors, and the effect that
eventual service extension will have on adjacent agencies. Where an area could be assigned to the
sphere of influence of more than one agency, the following hierarchy typically applies:
a) Inclusion within a city’s sphere
b) Inclusion within a multi-purpose district’s sphere
c) Inclusion within a single-purpose district’s sphere
Territory placed within a city’s sphere indicates that the city is the most logical provider of urban
services. LAFCo encourages annexation of developing territory (i.e., area not currently receiving
services) that is currently within a city’s sphere to that city rather than to one or more single-purpose
special districts. LAFCo discourages the formation of special districts within a city’s sphere. To promote
efficient and coordinated planning among the county’s various agencies, districts that provide the same
type of service shall not have overlapping spheres.
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MSR/SOI Update | Brooktrails Township CSD
10.1.11 Memorandum of Agreements (For City Sphere Amendments and Updates)
Prior to submitting an application to LAFCo for a new city sphere of influence or a city sphere of
influence update, the city shall meet with the County to discuss the proposed new boundaries of the
sphere and explore methods to reach agreement on development standards and planning and zoning
requirements as contained in G.C. §56425. If an agreement is reached between the city and County the
agreement shall be forwarded to LAFCo. The Commission shall consider and adopt a sphere of influence
for the city consistent with the policies adopted by LAFCo and the County, and LAFCo shall give great
weight to the agreement to the extent that it is consistent with LAFCo policies in its final determination
of the city sphere.
10.1.12 Areas of Interest
LAFCo may, at its discretion, designate a geographic area beyond the sphere of influence as an Area of
Interest to any local agency. (Resolution No. 2018-19-01)
a) An Area of Interest is a geographic area beyond the sphere of influence in which land use decisions
or other governmental actions of one local agency (the "Acting Agency") impact directly or indirectly
upon another local agency (the "Interested Agency"). For example, approval of a housing project
developed to urban densities on septic tanks outside the city limits of a city and its sphere of
influence may result in the city being forced subsequently to extend sewer services to the area to
deal with septic failures and improve city roads that provide access to the development. The city in
such a situation would be the Interested Agency with appropriate reason to request special
consideration from the Acting Agency in considering projects adjacent to the city.
b) When LAFCo receives notice of a proposal from another agency relating to the Area of Concern,
LAFCo will notify the Interested Agency and will consider its comments.
c) LAFCo will encourage Acting and Interested Agencies to establish Joint Powers Agreements or other
commitments as appropriate.
(LAFCo, 2018)
1.6 SENATE BILL 215
Senate Bill 215 (Wiggins) requires LAFCo to consider regional transportation plans and sustainable
community strategies developed pursuant to SB 375 before making boundary decisions. Senate Bill 375
(Sustainable Communities and Climate Protection Act) requires each metropolitan planning organization
(MPO) to address regional greenhouse gas (GHG) emission reduction targets for passenger vehicles in
their Regional Transportation Plan (RTP) by integrating planning for transportation, land-use, and
housing in a sustainable communities strategy.
Mendocino County is not located within an MPO boundary and therefore is not subject to the provisions
of SB 375. However, the Mendocino Council of Governments (MCOG) supports and coordinates the local
planning efforts of Mendocino County and the Cities of Fort Bragg, Point Arena, Ukiah, and Willits to
address regional housing and transportation needs and helps provide a framework for sustainable
regional growth patterns through the 2018 Mendocino County Regional Housing Needs Allocation
(RNHA) Plan and Vision Mendocino 2030 Blueprint Plan. MCOG is also responsible for allocating regional
transportation funding to transportation improvement projects consistent with the 2017 RTP for
Mendocino County.
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MSR/SOI Update | Brooktrails Township CSD
Mendocino County and the Cities of Fort Bragg, Point Arena, Ukiah, and Willits are the local agencies
primarily responsible for planning regional growth patterns through adoption and implementation of
general plan and zoning regulations. While Mendocino County is not subject to the provisions of SB 375,
LAFCo will review applicable regional transportation and growth plans when considering a change of
organization or reorganization application.
Chapter 1 – Introduction Page1-6
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Brooktrails Township Brooktrails SOI Lower Sherwood AOI City of Willits Service Specific Spheres:
Brooktrails Township Subviision- All Services
BrooktrailsTownship Upper Sherwood AOI Highways Spring Creek Subdivision- Water &Fire Service
Community Services District Sylvandale Subdivsiion- Fire Service
Spring Creek Willits Airport AOI Roads
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Source: This map was prepared by the Mendocino County Division
of Information Services GIS Program, May 2019. Gates AOI Adjacent Fire Protection Services °
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Note: This map is not a survey product. Miles
MSR/SOI Update | Brooktrails Township CSD
2 AGENCY OVERVIEW
Table 2.1 BTCSD Profile
Agency Name: Brooktrails Township Community Services District
Phone Number: (707) 459-2494
Fax Number: (707) 459-0358
Mailing Address: 24860 Birch Street, Willits, CA 95490
District Office: 24860 Birch Street, Willits, CA 95490
Website: http://www.btcsd.org
General Email: btcsd@btcsd.org
Date of Formation: 1962
Agency Type: Independent Special District, Multi-Service Provider
Enabling Legislation: Community Services District Law: Government Code §61000 et seq.
Board Meeting Schedule: 2nd and 4th Tuesday of the month (except Aug, Nov, & Dec - 1st
Tuesday only) at 7:00 p.m. at the Brooktrails Community Center
Source: BTCSD: 2018, 2019.
2.1 HISTORY
2.1.1 FORMATION
The Brooktrails Township Community Services District (Brooktrails Township CSD, District, or BTCSD)
was created in 1975. The District is the successor to the Brooktrails Resort Improvement District (BRID),
formed in 1962 by the Mendocino County Board of Supervisors pursuant to Public Resources Code
§13000 et seq. In response to legislation passed in 1971, limiting the powers of resort improvement
districts, the voters of the District approved becoming a community services district in 1975. In 1990,
the District added the word Township to their name per District Resolution No. 1990-36. (BTCSD, n.d.)
When the Board of Supervisors formed the District in 1962, it included the Brooktrails Township and
Spring Creek subdivisions. Later the Sylvandale subdivision became part of the District per further action
of the Board of Supervisors. Spring Creek and Sylvandale are not part of the original 6,605 lots created in
the Brooktrails Vacation Village subdivision known today as Brooktrails Township.
2.1.2 BOUNDARY
The District is located in the geographic center of Mendocino County and approximately 1-mile
northwest of the City of Willits and 20-miles inland of the City of Fort Bragg. The District is situated
within the mountains of a second growth mixed redwood forest located west of the Little Lake Valley
area (BTCSD, n.d.).
The District boundary is approximately 13-square miles (8,320-acres) in size and includes multiple
service areas associated with three residential subdivisions (Figure 1-1). The District’s primary service
area covers the community of Brooktrails Township, consisting of small acreage parcels and Brooktrails
Redwood Park. The District’s secondary service area includes Sylvandale and Spring Creek which consist
of large acreage rural parcels located northeast of Brooktrails Township. There have been no changes to
the District boundary since the prior 2010 MSR. (LAFCo, 2010)
Chapter 2 – Agency Overview Page 2-1
MSR/SOI Update | Brooktrails Township CSD
Brooktrails Township is approximately 7.7-square miles (4,943-acres) in size and is an unincorporated
semi-rural residential community consisting of 6,600 parcels. Brooktrails Township has been historically
known as a hyleopolis, which is a Wildland Urban Interface (WUI) community with a contiguous wooded
park where protection of the forest is paramount. Brooktrails Township has evolved from a second
home community during and up to the late-1980s, into one in which most of the homes are occupied by
year-round permanent residents. (Mendocino, 2004; LAFCo, 2010)
2.1.3 SERVICES
The Brooktrails Township CSD provides the following municipal services: Planning and Design Review,
Parks and Recreation, Fire Protection and Emergency Medical Services, Water, and Wastewater. For
more information regarding these services refer to Chapter 3. For more information regarding other
services provided by contract or agreement refer to Section 2.3.4.
2.2 GOVERNMENT STRUCTURE
2.2.1 GOVERNING BODY
The Board of Directors is the legislative body for the District and is responsible for establishing policy,
adopting and amending the annual budget, enacting ordinances, adopting resolutions, and appointing
committees. The District is governed by a five-member Board of Directors elected at-large to serve
staggered four-year terms (Table 2.2). In 2018, the District resolved to comply with Senate Bill X and
moved its elections to align with the General Election cycle, automatically extending the current terms
of sitting Directors by one year. In order to be elected to the Board, candidates must be registered
voters residing within the District boundaries. If there are insufficient candidates for election, or if the
number of filed candidates is equal to the number of vacancies, then Board members may be appointed
in lieu of election by the County Board of Supervisors. New Board members take office at noon on the
first Friday in December following their election.
The Board of Directors elects officers, including a President (Chairman) and Vice-President every year at
the December Organizational meeting of the Board. The Board may create additional offices and elect
Board members to those offices, provided that no member of a Board of Directors shall hold more than
one office. Board members receive compensation at the rate of $100 per meeting, regular or special
meetings, in accordance with Community Services District Law Section 61047(a), with a maximum of six
paid meetings per month, and not to exceed twenty-four paid meetings per year by District policy.
Board members may also receive compensation for their actual and necessary traveling and incidental
expenses while on official business. Staff support for the Board includes the General Manager, contract
Attorney, and contract Architect. (BTCSD: 2018, n.d., 2019; LAFCo, 2010)
Table 2.2 BTCSD Board of Directors
Name Title Term Expiration
Rick Williams President 12/3/2022
Tony Orth Vice-President 12/3/2022
Ed Horrick Member 12/3/2022
Ralph Santos Member 12/2/2020
Tina Tyler-O’Shea Member 12/2/2020
Source: BTCSD, 2019.
Chapter 2 – Agency Overview Page 2-2
MSR/SOI Update | Brooktrails Township CSD
2.2.2 PUBLIC MEETINGS
Regularly scheduled meetings for the District Board of Directors are held on the second and fourth
Tuesday of the month, with the exception of August, November, and December when the Board meets
on the first Tuesday only, starting at 7:00 p.m. at the Brooktrails Community Center located at 24850
Birch Street in Brooktrails Township. In accordance with the Brown Act, all meetings are open to the
public and are publicly posted in three places within the Township, including at the meeting location, a
minimum of 72 hours prior to regular meetings or a minimum of 24 hours prior to special meetings.
Public notice and meeting information including agendas, meeting minutes, reports, resolutions, and
ordinances are published on the District’s website and Facebook page and are available at the District’s
office upon request. Minutes are kept for all public Board meetings and are adopted at a subsequent
meeting. (BTCSD, 2018)
2.2.3 STANDING COMMITTEES
Committees assist in carrying out various functions of local government. The District has two standing
committees. To develop and make recommendations on long-term policy documents and resolutions or
ordinances that influence overarching District goals, the Planning Committee meets quarterly. To assist
in identifying and prioritizing recreation and conservation goals, the Recreation, Greenbelt, and
Conservation Committee meetings are held on the fourth Thursday of the month at 7:00 p.m. at the
Brooktrails Community Center.
2.2.4 NON-PROFIT ORGANIZATION
The Brooktrails Firefighters Association (BFA) is a 501(c)(3) non-profit organization that supports and
augments the activities of the BTCSD Fire Department. The BFA is run by and elects officers from the
Volunteer Firefighters. The BFA accepts charitable funds and hosts fundraisers and capital campaigns
that support donations to the BTCSD Fire Department for purposes of purchasing equipment and
making facility improvements. The relationship between the District and BFA is structured such that
finances are held separately and the District owns and maintains donated equipment and facility
improvements.
2.2.5 PUBLIC OUTREACH
The District maintains a website, at the following site http://www.btcsd.org/, which is a helpful
communication tool to enhance government transparency and accountability. The District’s website has
well organized and extensive information. The District is in the process of updating their website with
IWCP which will be as robust as the current website with a modern appearance, more user-friendly and
easier to navigate, and meet all the special district transparency requirements of State law including the
availability of agendas, policies, financial information. The District is also modernizing their technology
systems by migrating to Microsoft 365 concurrently with the website update. (LAFCo, June 2019)
The District also maintains a Facebook page at https://www.facebook.com/BrooktrailsTownship/. The
District’s Fire Department website information has been incorporated into an updated District website,
and they maintain a Facebook page at https://www.facebook.com/BrooktrailsFire. The District’s website
could be enhanced by posting the regular Board meeting schedule on the Board of Directors page and
by incorporating a content management system, such as DocuShare, to provide a searchable and
chronologically organized document archive system for Board meeting packets and adopted ordinances,
resolutions, annual budgets, financial audit reports, and other digital records. The Brooktrails
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Firefighters Association is involved in community events such as the Annual Spaghetti Feed fundraiser.
(BTCSD: 2018, 2019)
2.2.6 COMPLAINTS
The public can submit written or provide verbal comments or complaints in person or by phone at the
District office during business hours, Monday through Friday from 8:00 a.m. to 5:00 p.m., or at the
District Board of Directors meetings during the general public comment period. The District receives
regular complaints of poor road conditions, illegal dumping, and code enforcement violations on private
property. In 2018, the District received one complaint related to a potential Brown Act violation, and in
2017, the District received two complaints related to potential Brown Act violations and fire service call
response activity. These complaints were addressed in person by District staff and District operations
were found to be in compliance with applicable laws and regulations. (BTCSD: 2018, 2019)
2.2.7 TRANSPARENCY AND ACCOUNTABILITY
The District has adopted a Policy Manual, per District Resolution No. 2018-22, that addresses the Board
of Directors elections, officers, meeting conduct, conflicts of interest, decisions, rules of order, and
responsibilities. This is in addition to general operating policies and procedures for the District, financial
policies, and personnel policies that define the obligations, rights, privileges, benefits, and prohibitions
placed upon all District employees. (BTCSD; n.d., 2019)
The Political Reform Act requires all state and local government agencies to adopt and promulgate a
Conflict of Interest Code pursuant to Government Code §81000 et seq.
The Political Reform Act also requires persons who hold office to disclose their investments, interests in
real property, and incomes by filing a Statement of Economic Interests (Fair Political Practices
Commission Form 700) each year pursuant to Government Code §87203.
According to AB 1234, if a local agency provides compensation or reimbursement of expenses to local
government officials, then all local officials are required to receive two hours of training on public
service ethics laws and principles at least once every two years and establish a written policy on
reimbursements pursuant to Government Code §53235.
The District complies with the above requirements (BTCSD, 2018).
Refer to Appendix A for a brief list of educational resources regarding open government laws and
Appendix B for a website compliance handout.
2.3 OPERATIONAL EFFICIENCY
2.3.1 MANAGEMENT AND STAFFING
The Board of Directors appoints a General Manager to support their efforts and oversee the daily
operations of the District to ensure that the Board’s policies, programs, and priorities are implemented.
The responsibilities and specific duties of the District General Manager include the following:
o The implementation of the policies established by the Board of Directors for the operation of the
District.
o The appointment, supervision, discipline, and dismissal of the District's employees, consistent with
the employee relations system established by the Board of Directors.
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o The supervision of the District's facilities and services.
o The supervision of the District's finances.
(BTCSD, n.d.)
Figure 2-1 shows the District’s organizational chart. General government services provided under the
direction of the District General Manager include Administration, Finance, and Planning. Financial
activities include accounting, utility billing, purchasing, payroll, collections, and assisting with the annual
audit process. Administrative activities include preparing for public meetings, providing customer
service at the District office and other outreach opportunities, and maintaining the District’s official
records such as meeting minutes, ordinances, resolutions, legal documents, and legal opinions. Planning
activities include acting as a liaison between property owners and the contract District Architect during
the design review phase of the building permit process and implementing applicable policies of the
Brooktrails Township Specific Plan.
The Parks and Recreation Department is included under the General Government Department fund and
the District contracts for operation of the golf course. The District is currently comprised of five
budgetary departmental units organized by function or service including Water, Wastewater, Fire
Protective and Emergency Medical Services, Parks and Recreation, and General Government. District
operations are accomplished by three groups of District personnel including Administration, Fire, and
Utilities. The District also maintains part-time professional services contracts with an Attorney for
General Legal Counsel and an Architect for Planning and Design Review.
District personnel include full-time and part-time employees for a total staffing level of 11 Full Time
Equivalent (FTE) positions. Table 2.3 shows District staffing levels by personnel groups. There are also 15
volunteer firefighters to assist full-time Fire personnel. The District has authorization for 11 full-time
positions and currently has 10 full-time employees as follows: one General Manager, one Deputy
Finance Officer, one Account Clerk/Secretary, one Fire Chief, one Fire Prevention Officer/ Battalion
Chief, one Utility Superintendent who is certified as Water Distribution Operator D3, Water Treatment
Operator T4 and Wastewater Collection D1, and four Utility employees who are certified as Water
Distribution Operators D2 and D3, Water Treatment Operators T2 and T3, and Wastewater Collection
D1. A second Account Clerk/Secretary position has remained vacant for several years and was filled in
July 2019.
(BTCSD: 2018, 2019)
Table 2.3 BTCSD Staffing Levels
Personnel Groups FTE
Administration 4.0
Fire 2.0
Utilities 5.0
Total 11
Source: BTCSD, 2019.
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Figure 2-1 BTCSD Organizational Chart
Source: (BTCSD, 2019)
2.3.2 AGENCY PERFORMANCE
A component of monitoring agency performance is routinely evaluating staff productivity. The District
tracks employee workload through bi-weekly timesheets and conducts annual written performance
evaluations for all employees. In addition, the Fire Chief informally evaluates volunteer firefighters as
part of regular training sessions. The District also maintains an emergency response log and training
records.
The Board of Directors has an annual planning workshop prior to commencing the annual budget
development process to review the goals and objectives from the prior fiscal year and to modify or add
new goals and objectives for the upcoming fiscal year.
In the regular performance of duty, District staff identifies areas of improvement and takes corrective
action when feasible or informs the District General Manager when further direction is needed. District
staff also learns about new opportunities to achieve operational efficiencies by attending regional and
service-specific association meetings and communicating with colleagues regarding industry standards,
model programs, and best management practices implemented by other local agencies.
(BTCSD, 2018)
2.3.3 REGIONAL AND SERVICE-SPECIFIC COLLABORATION
The District participates in regional and service-specific associations and organizations including the
following:
o The Fire Chief is an active member of the Mendocino County Fire Chief’s Association.
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o The District’s Board of Directors maintains active participation in the Mendocino County Association
of Fire Districts, as well as providing staff assistance.
o The District participates in the Mendocino County Fire Safe Council.
o One District Board member serves on the Local Agency Formation Commission.
o One District Board member serves on the Board of Directors for the Association of California Water
Agencies Joint Powers Insurance Authority (ACWA-JPIA).
o District staff actively participates as a member of committees to the California Special Districts
Association (CSDA) and Association of California Water Agencies (ACWA).
o District staff also actively participates in several professional associations including the Government
Finance Officers Association, the International County and City Managers Association and their State
Chapters.
(BTCSD, 2018)
2.3.4 SHARED FACILITIES, RESOURCES, AND SERVICES
The District works cooperatively with other service providers to deliver services more effectively or
efficiently by sharing public facilities, resources, and/or service delivery responsibility when feasible.
Below is information regarding municipal services provided to District residents by other public agencies
or non-profit organizations through agreements or Joint Powers Authority (JPA) and by private
businesses through service contracts.
2.3.4.1 Wastewater Treatment and Discharge
The District provides wastewater collection services and receives wastewater treatment and disposal
services from the City of Willits by agreement (refer to Section 3.6.2 for more information). As part of a
legal dispute settled in 2015, the District and the City are exploring the possibility of forming a Joint
Powers Authority (JPA) to operate the City’s Wastewater Treatment Plant. District staff cooperates on
repairs and maintenance with the City’s wastewater staff. (BTCSD: 2018, 2019)
2.3.4.2 Recreation Facilities
The District has a contract with Operators Newby, Christian and Rice for operation and maintenance of
the District’s 9-hole golf and 18-basket disc golf course. This contract includes the operation of the shop
and grill. (BTCSD: 2018, 2019)
2.3.4.3 Solid Waste Disposal
The District contracts with Solid Wastes of Willits, Inc. (SWOW) for collection, transportation, disposal,
and recycling of garbage, refuse, and rubbish. SWOW pays a franchise fee to the District as the service
provider. Services include curbside pickup for both garbage and recycling and providing a recycle center
at the Willits Transfer Station located at 350 Franklin Street. The Board of Directors has established the
provision of this Franchise Fee as supplemental funding for the Parks and Recreation Department.
(BTCSD: 2018, 2019)
2.3.4.4 Pooled Insurance
The District participates in the Special District Risk Management Association (SDRMA) for the purpose of
providing liability, workers compensation for its facilities, operations, and employees. Health insurance
is provided by the Association of California Water Agencies Joint Powers Insurance Authority for District
employees and their dependents. (BTCSD: 2018, 2019)
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2.3.4.5 Other Arrangements
Below are additional examples of the District’s interagency collaborative arrangements:
o The District collaborates with other public agencies by providing fire protection and emergency
medical services through the countywide dispatch service call system and mutual aid agreements.
o The District and the Little Lake Fire Protection District maintain a joint ‘hands-on’ training program
for volunteer firefighters in cooperation with the Mendocino County Fire Academy.
o The District works with CAL FIRE in implementing vegetation fuel management grants to reduce
vegetative fire hazards in and around the District, especially surrounding District infrastructure sites.
o The District maintains a shared services and joint purchase agreement with the City of Willits for a
high speed camera for their respective Inflow and Infiltration (I&I) programs.
o The District and the City of Willits are exploring the possibility of an intertie agreement for the
purpose of wheeling potable water during an emergency.
(BTCSD: 2018, 2019)
No new opportunities for the District to achieve management or operational efficiencies were identified
during the preparation of this MSR.
2.3.5 GOVERNMENT RESTRUCTURE OPTIONS
The District is the primary municipal service provider in Brooktrails Township and the immediate
surrounding area. District services do not extend into the adjacent Little Lake Valley area except for
mutual aid responses and dispatched service calls for fire protection and emergency medical services.
The County of Mendocino provides law enforcement, code enforcement, transportation, and
stormwater collection services within the District. Municipal service providers adjacent to the District
include the City of Willits and the Little Lake Fire Protection District, which provides fire protection
services to the City of Willits and the surrounding Little Lake Valley area. Ambulance service is provided
to the Willits area by Verihealth, Inc., and the County of Mendocino is in the process of establishing an
Exclusive Operating Area (EOA) contract for ambulance services covering the inland area of Mendocino
County including the Highway 101 corridor, Covelo, and Anderson Valley. While not municipal services,
District residents rely on the City of Willits for commerce and employment opportunities, including
rental of commercial and office space.
There may be opportunities for the District and the City of Willits to establish or expand joint efforts to
provide municipal services such as emergency water supply and wastewater treatment and disposal.
The District is interested in establishing an alternative evacuation route for Brooktrails Township and the
surrounding area in the case of an emergency. In addition, a second access road to Brooktrails Township
and the surrounding area needs to be established to address current road safety and congestion issues
and improve circulation for the area in order to accommodate the current population level and ultimate
buildout of Brooktrails Township.
Government restructure options should be pursued if there are potential benefits in terms of reduced
costs, greater efficiency, greater accountability, or other advantages to the public. There is no
recommendation for a reorganization of local municipal service providers in the area at this time.
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2.4 FINANCES
The District’s financial resources are accounted for in different funds based on organizational units, such
as departments, divisions, programs, functions, and services. The District’s governmental activities,
including administration, finance, planning and design review, parks and recreation, and fire, are
accounted for in governmental funds. The General Fund is the District’s primary operating fund and
accounts for the financial resources of the District’s general government services. The Fire Services Fund
is maintained to account for the special fire tax levied and used to fund fire protection and emergency
medical services. The District enterprise or business-type operations include water and wastewater
services. These enterprise activities are accounted for in Enterprise or Proprietary Funds and the cost of
providing enterprise services are intended to be recovered through service rates. The Water Fund
accounts for the operations of the District water treatment and distribution system. The Wastewater
Fund accounts for the operation of the District wastewater collection activities. The District also
maintains a Fiduciary Fund for its other post-employment benefit plan trust assets and financial
operations. (TK, 2017)
2.4.1 CURRENT FISCAL HEALTH
2.4.1.1 Financial Summary
The District prepares and adopts an annual budget prior to the beginning of each fiscal year (July 1),
which serves as a financial planning tool and an expense control system. Expenses cannot exceed the
authorized budgeted amounts unless the budget is amended by the Board of Directors by resolution
during the fiscal year. Unused appropriations lapse at the end of the fiscal year (June 30) and are
available to be allocated in the following budget, known as zero-based budgeting. The District also has
annually audited financial statements prepared by a Certified Public Accountant (CPA) which serves as
financial assurance for the use of public funds. This section includes District financial information for
Fiscal Year (FY) 2014-15, 2015-16, 2016-17, and 2017-18 and highlights specific revenue sources and
long term financial considerations.
The following table (Table 2.4) provides year-end (not budget) financial information for the District. This
table summarizes the Statement of Activities prepared by Terry E. Krieg, CPA and represents the short-
term financial standing of the District based on reporting annual income, expenses, and profits/losses
using the full accrual basis of accounting. This involves depreciation, which is a method of spreading the
cost of a capital asset over its estimated useful life, as opposed to recognizing the cost of a capital asset
as an expenditure at the date of acquisition. The District’s capitalization policy defines a capital asset as
a fixed asset (land, buildings and improvements, equipment, and vehicles) with an initial cost greater
than $1,000 with an estimated useful life in excess of one year (TK, 2017). Refer to Figure 2-4 for the
most recent Statement of Net Position, which represents the long-term financial standing, or net
position, of the District based on reporting the difference between the District’s assets and liabilities.
Refer to the following hyperlink from the District’s website to download a full copy of the District’s FY
2017-18 Audit: https://docs.wixstatic.com/ugd/677c29_5d062a0a227a43cba36e56930656a95a.pdf.
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Table 2.4 BTCSD Financial Summary
FY 14-15 FY 15-16 FY 16-17 FY 17-18
Beginning Aggregated Net Position $9,426,883 $8,646,271 $9,006,763 $9,637,066
Prior Period Adjustments $0 $0 $0 $0
Ending Aggregated Net Position $8,646,271 $8,912,819 $9,323,574 $9,861,984
Revenue
General Revenues
Property Taxes $292,570 $304,399 $304,198 $315,455
Special Fire Tax $395,904 $507,794 $491,514 $486,838
Interest Income $781 $706 $1,224 $7,033
Social Security Section 218 $0 $0 $0 ($97,324)
Sub-total $689,255 $812,899 $796,936 $712,002
Program Revenues
Administration $381,241 $353,959 $388,794 $408,243
Fire $23,906 $19,310 $13,622 $38,477
Parks and Recreation $0 $0 $0 $0
Water $1,189,515 $1,181,757 $1,229,183 $1,429,358
Wastewater $1,349,286 $1,328,802 $1,503,144 $1,535, 3
Operating Grants/Contributions $60,000 $0 $20,464 $39,238
Capital Grants/Contributions $47,422 $0 $0 $150,1 0
Sub-total $3,051,370 $2,883,828 $3,155,207 $3,601,294
Total Revenue $3,740,625 $3,696,727 $3,952,143 $4,313,296
Expenses
Administration $472,698 $467,201 $433,548 $556,981
Fire $458,753 $337,288 $551,472 $690,864
Parks and Recreation $74,092 $91,015 $106,989 $97,752
Water $1,302,067 $1,267,767 $1,348,525 $1,395,527
Wastewater $2,213,627 $1,266,908 $1,194,798 $1,347,254
Total Expenses $4,521,237 $3,430,179 $3,635,332 $4,088,378
Net Income/(Loss) ($780,612) $266,548 $316,811 $224,918
Accumulated Depreciation $1,583,202 $1,554,695 $1,613,898 $1,670,774
Source: TK: 2016, 2017, 2018, 2019.
According to the audited financial information in the table above, the District generally operates at a net
income or revenue gain which is a key measure of fiscal health and indicates that the District does not
need to utilize reserve funds to balance the budget or meet current operating costs. The District has
maintained a balanced budget for the past several years and is working to build reserves to fund capital
improvements and replace equipment (BTCSD, 2018).
In FY 2016-17, the General Fund ended with a fund balance of $395,700, compared to a $264,116 fund
balance at the end of the prior fiscal year, and there were no transfers out to subsidize the Fire Fund. In
FY 2016-17, the Fire Fund ended with a decrease of $62,000 for a fund balance of $70,800. In FY 2016-
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17, water sales and wastewater fees increased by about $214,000 for a combined total revenue of $2.7
million for business-type activities, and a combined total of expenses at $2.5 million. (TK, 2018)
In FY 2015-16, the General Fund ended with a fund balance of $264,116, compared to a $158,159 fund
balance at the end of the prior fiscal year, and there were no transfers out to subsidize the Fire Fund. In
FY 2015-16, the Fire Fund ended with an increase of $5,772 for a fund balance of $132,788. The
turnaround in profitability of the District between FY 2015-16 and 2014-15 was directly related to one-
time wastewater expenses in 2015 and additional revenues from the first full year of receiving the voter
approved increase in the Special Fire Tax. In FY 2015-16, the governmental activities included $156,536
for costs related to the purchase of fire apparatus (breathing equipment), in the amount of $68,621, and
a fast attack fire vehicle, in the amount of $87,915, both funded by capital lease proceeds. (TK, 2017)
2.4.1.2 Fire Special Tax and Other Revenue
In December 2013, the Special Committee for Fire Department Revenue Enhancement provided a report
to the Board of Directors regarding financial options for the Fire Department including potential
consolidation with the Little Lake Fire Protection District and CAL FIRE providing contract fire services.
The Committee concluded that changing the structure of fire service provision was not financially
feasible and would not result in more efficient or effective delivery of services. This exploratory process
resulted in the District preparing a ballot initiative to increase the Special Fire Tax. (BTCSD, 2018)
On June 3, 2014, the voters in the District approved Measure K to increase the Special Fire Tax by $34 a
year from the existing $65 per single-family residential parcel tax and also increased the tax rates
applied to other classes of parcel improvements or uses as listed below.
o Single Family Residence - $99
o Duplex - $150
o Triplex - $200
o Fourplex - $250
o Multiplex other - $275
o Commercial use - $200
o Hotel-Motel - $300
o Vacant Parcels - $99
The revenue generated by this special tax must be used for a comprehensive fire prevention program,
including funding of fire department operations (exclusive of salaries), capital improvements,
depreciation, fire hazard programs, fire prevention programs, and reserves. This special tax increase
took effect in Fiscal Year 2014-15.
(Ballotpedia, 2014)
Mendocino County disbursed a share of Proposition 172 funds to BTCSD as follows: $20,464 in FY 2016-
17 and $20,787 in FY 2017-18 (BOS, 2018). These allocations are discretionary and reviewed annually
based on availability of funding. Based on the current adopted County Budget, the same level of
Proposition 172 funding will be provided in FY 2018-19 based on actual Proposition 172 receipts from
the most recent year (Mendocino, June 2018).
The BTCSD Fire Department participates in Strike Team assignments for wildland fire incidents
throughout the State and receives reimbursement averaging approximately $20,000 annually for
firefighters and the responding fire engine from the California Fire Assistance Agreement (CFAA).
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The Brooktrails Firefighters Association raises approximately $2,500 annually from donations and
fundraising activities to support the BTCSD Fire Department.
2.4.1.3 Enterprise Activities
The District’s business-type operations include water and wastewater services and these enterprise
activities are funded by service rates and accounted for in Enterprise Funds. The District reviews rates
and fees during the annual budget development process and proposes an increase when necessary to
support the on-going delivery of services. The District Board of Directors adopts rates and fees annually
at a duly noticed Public Hearing based on actual expenditures and cost recovery.
The District adopted Rates and Fees for Fiscal Year 2018-2019 per Resolution No. 2018-10. The District’s
Monthly Water Base Rate is $49.16, the Water Usage Rate is calculated at $.02961 per cubic foot, and
the one-time Water Connection Fee is $11,697. The District’s Monthly Wastewater Base Rate is $68.78,
the Annual Sewer Standby Charge for developed and vacant lots is $50, and the one-time Wastewater
Connection Fee is $12,01 . (BTCSD, 2019) The District’s enterprise services are currently operating at a
net income or revenue gain. In FY 2015-16, there was a significant reduction in expenses of the
Wastewater Fund from the prior fiscal year related to approximately $813,000 in legal fees, deferred,
and withheld contract costs related to the settlement agreement reached in FY 2014-15 between the
District and the City of Willits. (TK, 2017)
2.4.1.4 Teeter Plan
Taxes are apportioned to eligible local government agencies (counties, cities, schools, and special
districts) according to specific formulas and procedures established in the State Revenue and Taxation
Code (R&TC). Mendocino County distributes secured and supplemental taxes subject to the Teeter Plan,
per R&TC Sections 4701-4717, which is an optional alternative method for distributing and collecting
taxes including property taxes, special assessments, and special taxes. Under the Teeter Plan, the
County provides 100-percent of all the taxes levied on the original tax roll, less any corrections made
during the year, to each eligible agency in advance of collection. At the end of the fiscal year, any unpaid
taxes and assessments are owned by the County and are subject to the County’s collection efforts and
remedies, including penalties and interest on delinquent tax payments and selling tax delinquent
properties at public auction. (Mendocino, n.d.)
There is a long history in the District of properties defaulting on tax payments and tax delinquent
properties not selling at public auction. This is because the Brooktrails Township subdivision was
designed as a second-home community for part-time residents with an expected maximum occupancy
of 25-percent at any given time. However, Brooktrails Township is a community of predominately full-
time residents which has considerably intensified the original land use and demand for municipal
services (refer to 2.5.1.2 for more information). With limited water supply available for new service
connections and physical development constraints making construction of a modern home difficult and
expensive, over time many properties in the Brooktrails Township subdivision have become tax
delinquent and scheduled for sale at auction. For example, there were 232 Brooktrails Township
subdivision lots in default of property taxes and special assessments and subject to pending sale at
auction as of January 26, 2019. There are however still active real estate transactions ocurring in
Brooktrails Township and many property owners that continue to pay taxes. (LAFCo, June 2019)
In 2012, the Mendocino County Board of Supervisors removed or “de-Teetered” Brooktrails Township
CSD special assessments for water, wastewater, and fire services. Prior to this action, the County was
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effectively partially subsidizing the District’s water, wastewater, and fire services by providing the
District assessment revenues that ultimately were not collected or recovered through sale at auction.
Therefore, the District is currently distributed special assessment revenue upon collection instead of in
advance of payment by property owners. The District has remained under the Teeter Plan related to the
distribution of property taxes. Therefore, the District receives 100-percent of its tax base from property
taxes regardless of whether the County actually collects this tax revenue, but the District generally does
not receive 100-percent of special assessments due to non-payment by owners of tax delinquent
properties. For example, the District’s annual budget estimates receiving 60-percent of the fire special
tax based on actual collection history. (LAFCo, June 2019)
2.4.1.5 Brooktrails Township Lot Reduction Program
The Brooktrails Township subdivision was originally established with 6,605 lots. As described above, the
character of the community changed resulting in higher demand for services than was originally
planned. Currently the District can provide 1,578 water service connections. To address this discrepancy
in supply and demand, the Brooktrails Township Specific Plan identified a development projection or
estimated buildout for Brooktrails Township of 4,000 equivalent single family residential units, or 3,815
residential dwellings on 3,673 developed lots. The Specific Plan also included a District program
consisting of financial incentives to encourage voluntary lot mergers to help reach the projected
buildout level and bring the available number of lots in line with available resources. The District’s lot
reduction program has also involved accepting lot donations from property owners.
Due to the financial impact of non-payment of special assessments by owners of tax delinquent
properties in the Brooktrails Township subdivision and the need to maintain an adequate tax base, the
District has changed its policy related to accepting new lot donations and subsidizing the voluntary lot
merger program. The District Board reviews potential lot donations on a case by case basis and gives
priority to lots that adjoin another lot in the District’s existing inventory, are located at a trailhead, or
would improve the trail system or access to the greenbelt. The District encourages voluntary lot mergers
but can no longer subsidize the process through the General Fund. In addition, in an attempt to
streamline the process, the District will no longer submit batch filings to the County of lot merger
applications every six months, which creates another step in the process. This is in response to feedback
the District has received from property owners that they would prefer their application be processed on
an individual basis to save time.
(LAFCo, June 2019)
2.4.2 LONG TERM FINANCIAL CONSIDERATIONS
2.4.2.1 Reserves
The District has the following reserve accounts established for different purposes.
o Wastewater Capital Recovery Reserve: A wastewater capital recovery reserve account in the Sewer
Enterprise Fund with the sum of a maximum of $58,800 appropriated pursuant to an agreement
entered into between the District and the Farmers' Home Administration as a condition of bond
sale.
o Capital Reserve: A capital reserve account in the Water Connection Fund, the Sewer Connection Fee
Fund, the Fire Services, and the General Fund for the purpose of funding any needed expansion of
capital facilities or the acquisition of capital equipment.
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o Equipment, and/or Capital Replacement Reserve: Equipment and/or capital replacement reserve
accounts within all of the Funds to provide for acquisition of equipment to replace equipment
originally purchased and replace and repair existing capital facilities using revenues from those
funds.
o Contingency Reserve: Contingency reserve accounts within all of the Funds to be used for funding
unbudgeted and unforeseen expenditures during the fiscal year as authorized by a specific
appropriation resolution of the Board of Directors.
o Debt Service Reserve: A debt service reserve account within each fund from which payments to
principal and interest on debt or lease purchase obligations is made. An amount equal to the
payment due on such obligation during the next fiscal year is appropriated to said reserve at the end
of every fiscal year.
(BTCSD, 2018)
In the past, the District practiced zero-sum budgeting and reserves were zeroed out at the end of the
year. The District is currently in the process of accumulating capital and other reserves each year.
(LAFCo, June 2019)
The FY 2017-18 audit does not specify the amount of funds held in reserve by the District. Figure 2-4
shows that the District has restricted cash and cash equivalents in the amount of $309,980 for
governmental activities and $375,169 for business-type activities. (TK, 2019)
2.4.2.2 Outstanding Debt
The District has no publicly-issued debt. Figure 2-2 shows the District’s long-term debt activity for FY
2015-16, including capital leases for the purchase of fire equipment and vehicles in governmental
activities and multiple USDA series loans, Certificates of participation, and a bank loan for water and
wastewater improvements and equipment in business-type activities. The District will be obligated
through 2051 for current debt payments.
Figure 2-2 Long-term Debt Activity for FY 2017-18
Source: TK, 2019.
Chapter 2 – Agency Overview Page 2-14
MSR/SOI Update | Brooktrails Township CSD
2.4.2.3 Capital Improvement Plan
The District is responsible for prioritizing and budgeting for long-term capital needs in addition to on-
going operations and maintenance costs. The District does not have a Capital Improvement Plan (CIP).
The District defines capital improvement priorities on a five-year basis in the annual budget process
(Figure 2-3). Capital Improvements are primarily funded in one of two ways. Small to mid-range projects
of $5,000 to 100,000 are scheduled for the upcoming fiscal year through a capital outlay appropriation,
and larger projects over $100,000 are scheduled for future fiscal years through a capital reserves
appropriation. The Brooktrails Township Specific Plan also contains a financing program to maintain
community services and provide the infrastructure required to accommodate buildout of the
community. Two currently unused funding mechanisms available to the District to finance capital
facilities and improvements include Proposition 218 bond measures and Development Impact Fees
pursuant to the Mitigation Fee Act (GOV 66000 et seq.). Routine maintenance of equipment and
facilities is generally performed based upon the manufacturer’s recommended schedule, industry best
practices, and actual need, and is funded through the budget development process. (BTCSD, 2018)
Chapter 2 – Agency Overview Page 2-15
BTCSD Capital Projects from FY 2019-20 Financial Plan of Services
Water Division Project Goals
Ongoing
Replace water treatment filters
Replace end line blow offs
Replace water valves in streets
Rebuild one-to-two pump houses
Reline and reroof redwood tanks
Install radio read meters
FY 2019-20
Replace Tank three with a larger sized modern tank – 60,000 gallon redwood
Replace water lines throughout District as necessary
Acquire lot(s) adjacent to rock lot
GIS mapping of water distribution infrastructure
Recapture energy lost at pumping sites
Negotiate agreement for groundwater intertie in the Valley
FY 2020-21 and FY 2021-22
Upgrade Water Treatment Plant (Upsize Filters)
Replace Tank 14
Acquire parcel and/or water rights in valley
Design intertie
Construct Intertie
Replace Tank Two – 90,000 gallon redwood
WWaasstteewwaatteerr DDiivviissiioonn PPrroojjeecctt GGooaallss
Ongoing
Maintain vac truck and equipment for sewer lateral inspections and jetting
FY2019-20
Mallard Bypass Repairs
Repair slide on easement GIS mapping of sewer collection infrastructure
Acquire lot for Primrose Lift Station
Engineering for Primrose Lift Station
FY 2020-21 and FY 2021-22 Replace/move Primrose Lift Station
Replace deteriorated main lines
Future Goals
Replace 14” sewer main to Willits Rebuild engine for camera truck or replace vehicle
Fire Department Project Goals
Ongoing
Maintain a high level of service
Pursue grant funding for specialized equipment
Maintain community relations and forums
Continue Fire/EMS Training
Increase Volunteer Firefighter roster to 25
Pursue and maintain Emergency access/egress routes
Maintain Hazard Abatement Program
Continue Fire/EMS Training
Increase Volunteer Firefighter roster to 25
Pursue and maintain Emergency access/egress routes
Maintain Hazard Abatement Program
Continue funding Seasonal Staffing
Future Goals
Amend Fire Tax to reduce impacts from uncollected vacant parcel assessments
Pursue additional grant funding for Greenbelt Fuels Management
Amend Specific Plan to support home hardening against fire threats
Parks and Recreation Department Project Goals
Ongoing
Maintain and preserve department facilities
Clear trails and vegetated overgrowth in recreation areas
FY2019-20
Applied for Prop 68 Grant for two projects:
$710,000 on Par Course Revitalization Project
$700,000 on Ohl Grove Revitalization Project
General Government Department Project Goals
Ongoing
Maintain a high level of customer service
Monitor and refine personnel and financial information throughout the year
Pursue grant funding when available for any department revenue
Provide transparent and compliant public meetings and documents
Support and participate in community relations and forums
FY2019-20
Hire second Accounts Clerk/Secretary
Accrue necessary Specific Plan changes
Update LAFCo Municipal Service Review
BROOKTRAILS TOWNSHIP COMMUNITY SERVICES DISTRICT
Statement of Net Position
June 30, 2018
Governmental Business Type
Activities Activities Total
ASSETS
Current assets:
Cash and cash equivalents $ 2 26,278 $ 1 ,736,439 $ 1 ,962,717
Net receivables 1 95,364 3 33,507 5 28,871
Inventory - 2 0,313 2 0,313
Prepayments 9 ,917 1 2,246 2 2,163
Deposits 1 10,020 - 1 10,020
Internal balances (13,579) 1 3,579 -
Total current assets 528,000 2 ,116,084 2,644,084
Noncurrent assets:
Restricted cash and cash equivalents 309,980 3 75,169 685,149
Long-term receivables - delinquencies 348,239 3 77,324 725,563
Net capital assets 5,409,433 6 ,573,837 1 1,983,270
Total noncurrent assets 6,067,652 7 ,326,330 1 3,393,982
Total assets 6,595,652 9 ,442,414 1 6,038,066
DEFERRED OUTFLOWS OF RESOURCES
Pensions 215,580 3 85,364 600,944
Other postemployment benefits 4,972 1 0,094 15,066
Total deferred outflows of resources 220,552 3 95,458 616,010
LIABILITIES
Current liabilities:
Accounts payable 9 ,832 5 0,475 6 0,307
Accrued liabilities 3 5,367 1 2,443 4 7,810
Compensated absences 138,086 1 08,694 246,780
Interest payable 4,981 3 6,269 41,250
Capital leases due within one year 90,293 - 90,293
Loans, notes, certficates due within one year - 8 9,593 89,593
Total current liabilities 278,559 2 97,474 576,033
Liabilities due in more than one year:
Certificates of participation - 3 ,106,300 3,106,300
USDA loan - 2 83,402 283,402
Capital leases 545,527 - 545,527
Bank note payable - 4,212 4,212
Net other post employment obligation 58,477 1 18,724 177,201
Net pension liability 684,806 1 ,353,639 2,038,445
Total liabilities due in more than one year 1,288,810 4 ,866,277 6,155,087
Total liabilities 1,567,369 5 ,163,751 6,731,120
DEFERRED INFLOWS OF RESOURCES
Pensions 15,216 3 9,095 54,311
Other postemployment benefits 2,198 4,463 6,661
Total deferred inflows of resources 17,414 4 3,558 60,972
NET POSITION
Net investment in capital assets 5,193,613 3 ,090,330 8,283,943
Restricted for:
Capital additions and debt service - 3 75,169 375,169
Unrestricted 37,808 1 ,165,064 1,202,872
Total net position $ 5,231,421 $ 4,630,563 $ 9 ,861,984
See accompanying notes to the basic financial statements
12
MSR/SOI Update | Brooktrails Township CSD
2.5 GROWTH
2.5.1 PRESENT AND PLANNED LAND USE AND DEVELOPMENT
2.5.1.1 Brooktrails Township History
The Brooktrails area has historically been used for a wide range of land uses. In the 1880s, the
Brooktrails area was occupied by the Northwestern Lumber Company. As logging operations were
completed, the land was sold to the Diamond D Ranch and served as a dude ranch. In the 1960s a
developer proposed to convert the lands into a planned development and began subdividing the land.
The Brooktrails Company Ltd., of Beverly Hills and New York, acquired the land in 1967. Ultimately, the
land was subdivided into 6,605 lots ranging in size from one-sixth acre (7,260-square feet) to 230-acres.
The development was intended to be primarily for second homes and was conceived as a “Vacation
Village” resort of part-time residents with an expected occupancy of 25-percent at buildout.
(Mendocino, 2004)
2.5.1.2 Brooktrails Township Transition
Brooktrails Township has transitioned from the original concept of the Brooktrails Vacation Village to a
community of predominately full-time residents. Since Brooktrails Township was originally conceived as
a 25-percent occupancy second-home community, full buildout did not necessarily mean full occupancy
at any one time. Full buildout of Brooktrails Township under the current condition of occupancy involves
considerably more year-round use than was originally planned for in the approval of the Brooktrails
Vacation Village subdivision. This has resulted in major changes in the community such as intensifying
the original land use and circulation patterns, increasing the demand for municipal services, and
impacting the preservation of environmental resources. In addition, the small size of the residential
parcels may have been suitable for construction of a vacation cabin, but may not necessarily
accommodate development of a modern home due to physical contraints and environmental resources
such as steep slopes, soil instability, earthquake faults, water features, and sensitive habitat.
In order to plan for the future of Brooktrails Township, the County of Mendocino and the community of
Brooktrails Township prepared a Specific Plan to address the quality and character of new development,
the sequencing of community facilities and infrastructure, environmental protection and enhancement,
public safety, recreation, and other issues unique to the community. A key component of starting the
Specific Plan process was determining buildout potential for Brooktrails Township. Available water
supply, physical development constraints, desired protection of environmental resources, and the level
of willingness of property owners to pay for expanded services and facilities to accommodate growth
played a critical role in developing different growth scenarios.
The Specific Plan Advisory Committee, consisting of Brooktrails property owners, developed five
alternative development scenarios for the Brooktrails Township Specific Plan. Medium Growth Scenario
#3B at 4,000 units was selected to focus preparation of the Specific Plan. Based on the 1995 Alternative
Development Scenarios and Feasibility Analysis report prepared for the District, this development
scenario provides an optimum balance between the need for environmental protection and the
economic costs of expanding infrastructure and/or limiting growth. The 4,000 unit growth scenario is a
development estimate for planning purposes and is not intended to impose a limit upon future growth
in Brooktrails Township. BTCSD is committed to develop such facilities and infrastructure as is necessary
Chapter 2 – Agency Overview Page 2-19
MSR/SOI Update | Brooktrails Township CSD
to accommodate the ultimate demand for growth in the community and consistent with the level of
financial investment provided by those receiving services from the District. (Mendocino, 2004)
2.5.1.3 Brooktrails Township Specific Plan
The Brooktrails Township Specific Plan (Specific Plan or Plan) is a comprehensive planning document to
guide on-going development of Brooktrails Township in an orderly and systematic manner and refines
the broad development goals and policies of the Mendocino County General Plan to address the specific
social, physical, environmental, and economic characteristics of this specific area. The Specific Plan
provisions do not apply to the adjacent Spring Creek and Sylvandale subdivisions, except with regard to
existing service agreements.
The Specific Plan establishes a policy framework to guide the location, intensity, and character of land
uses, replaces the existing Development Review Board Ordinance and Interim Site Development
Standards with permanent Design Guidelines and Site Development Standards, and contains
implementation programs to realize the Plan recommendations. The Plan also establishes the circulation
pattern and financing mechanisms available to maintain existing community services and provide new
infrastructure and improvements to accommodate buildout of the Plan. The Specific Plan was prepared
in accordance with the requirements set forth in California Government Code Section 65451.
The Specific Plan was adopted on December 8, 1997 by the Mendocino County Board of Supervisors as
an amendment to the County General Plan. In January 2004, a five-year plan update with proposed
amendments was provided to the Board of Supervisors per Brooktrails Resolution No. 2004-1. On July
16, 2004, the Board of Supervisors adopted the proposed amendments per Resolution No. 04-113.
There have been no updates to the Plan since 2004. According to the Summary in the Brooktrails
Township Specific Plan, the major features of the plan are as follows:
1. The overall land use objective is to promote environmental stewardship; this encompasses careful
site design including measures to conserve water and energy; avoiding and minimizing impacts to
key environmental resources; and managing the Township Greenbelt. The Plan allows for a level of
development that balances protection of the forest ecosystem with environmentally sensitive
development. Conservation easements will be used to protect some environmentally sensitive areas
and to create fire hazard protection zones.
2. The continuation of a predominantly single-family community with up to 4,000 equivalent single
family residential units (SFRs). SFR is a unit of measurement for water use planning purposes. At
buildout with 4,000 SFRs, there would be 3,815 residential dwellings on 3,673 developed lots with a
total population of 9,919 individuals. These numbers are intended to represent a development
projection, not a growth limit or development cap.
3. The voluntary reconfiguration of some high constraint parcels to create larger parcels with fewer
allowable units. Reconfigured parcels will afford greater protection of public health and safety in
high-constraint areas as well as protection of visual resources and open space amenities.
4. A program consisting of incentives to encourage lot mergers. A public entity overseen by the
Brooktrails Township Board of Directors will be established to implement an incentive program,
including financial incentives, to encourage lot mergers. After a period of five years, the voluntary
merger program will be evaluated for updating and/or amendment.
Chapter 2 – Agency Overview Page 2-20
MSR/SOI Update | Brooktrails Township CSD
5. The plan makes adjustments to the zoning map to reflect changes in the manner in which the
community has developed. Remote commercial parcels have been rezoned for single-family
development, while appropriate commercial areas have been consolidated and preserved. This plan
identifies areas zoned for multi-family development in the earthquake fault zone and in the B1 zone
adjacent to the Ells Field Airport to be considered for future rezoning to single-family development.
This Plan does, however, preserve multi-family development areas, where environmentally suitable,
to ensure the provision of adequate affordable housing. In addition, the entire Specific Plan area will
be placed within a Specific Plan (SP) overlay combining district to highlight the fact that a different
set of goals, policies, regulations, and implementation programs apply to this area.
6. Circulation improvements which consist of two additional access roads to address existing access
and emergency evacuation constraints - one linking the Township with State Route 20 to the south,
and an access road connecting the Township with U.S. Highway 101 to the east. At two lanes, the
new Second Access Route would begin to reach capacity as the Township begins to reach buildout at
4,000 units. The third access route would then be required to relieve traffic on Sherwood Road and
the new Second Access Route. Additional circulation improvements include but are not limited to:
o Improvements at the Sherwood Road/Birch Street intersection.
o Improvements to Sherwood Road including adding paved shoulders (four-foot minimum width),
left-turn pockets between U.S. 101 and Poppy Drive, and a pathway along its entire length.
o Extension of Ridge Road between Iris Drive and Goose Road.
o Development of parking bays, as feasible, throughout the Township to address current narrow
roadway constraints.
7. A 1,600 acre-foot reservoir to meet domestic water supply requirements for a community of 4,000
equivalent dwelling units and a population of 9,919 individuals. Assuming development of 40 units
per year, the reservoir would be needed in the year 2023. This project will require subsequent
environmental analysis prior to development.
8. Community facility and infrastructure improvements that will serve the specific needs of the
Township as it develops over time. These improvements include, but are not limited to:
o Development of wells to supplement the existing water supply for up to 2,500 units.
o A new raw water main connecting the new reservoir to the existing raw water main at Lake
Emily.
o Expansion of the existing water treatment plant at Brooktrails in its present location to
accommodate growth to 4,000 units.
o A new wastewater trunk main to replace or parallel the existing trunk main from the Township
to the City of Willits Wastewater Treatment Plant to accommodate development beyond 2,000
units, and a second new line to accommodate 3,000 units.
o A third fire station is anticipated in the near term in the vicinity of the airport to serve existing
development. A fourth fire station and fire vehicles would be required to serve 2,000 units, and
a fifth fire station and vehicles would be required to accommodate 4,000 units.
9. Design Guidelines and Site Development Standards that: protect public health and safety; preserve
and enhance environmental resources and public amenities; and establish and enforce design
standards that will protect visual quality, and the community’s quality of life in the existing semi-
rural setting.
Chapter 2 – Agency Overview Page 2-21
MSR/SOI Update | Brooktrails Township CSD
10. Under the Specific Plan financing program, four bond issues are recommended. The first bond issue
will be needed in the near-term to finance the second access road which is needed at this time. The
second bond issue would be required to fund wells and preliminary reservoir work at about the year
2011. The third bond issue would be required for the new 1,600 acre-foot reservoir around the year
2023. The fourth bond issue would be required for the third access road, scheduled for construction
at 3,500 equivalent single-family residential units (SFRs) around the year 2048.
11. Development impact fees are also anticipated and an impact fee schedule is estimated based on a
proposed allocation of capital project funding between fees and bond assessments. Actual fee levels
will depend upon the timing of the projects and the authorization for assessments.
12. It is also noted in the Specific Plan that the success of the Plan depends on continuing community
support in implementing the Plan and the combined efforts of all applicable regulatory and service
delivery agencies, and particularly on the on-going close cooperation between the District and the
County of Mendocino.
(Mendocino, 2004)
The Specific Plan is due for an amendment based on recommendations of the District Planning
Committee to the Board of Directors, including those identified below. Amending the Specific Plan might
be accomplished through a minor update process which would be more cost-effective and time-efficient
than a complete overhaul of the Specific Plan, which could be cost-prohibitive and potentially
unachievable.
To bring its development standards in line with home hardening standards developed by the
State of California, to which the current standards are not consistent.
To alter the lot merger recommendations and role of the District in incentivizing them.
To change the language on donating and selling privately owned lots to the District.
To update other elements of the water and wastewater infrastructure, policy development, and
land use trends.
(BTCSD, 2019)
2.5.1.4 Land Use
Brooktrails Township is comprised of a semi-rural residential community with 6,605 parcels, a 2,500-
acre greenbelt area for open space and recreation, public facilities to support the community, and
community-oriented commercial uses. The specific zoning designations for Brooktrails Township are
listed below and are based on the Mendocino County Inland Zoning Ordinance:
o R-1 Single-family Residential
o R-2 Two-family Residential
o R-3 Multiple-family Residential
o S-R Suburban Residential
o C-1 Limited Commercial
o P-F Public Facilities
o F-L Forest Land
o T-P Timberland Production
Chapter 2 – Agency Overview Page 2-22
MSR/SOI Update | Brooktrails Township CSD
The Specific Plan Zoning Map for Brooktrails Township shows land uses, a proposed new 1,600 acre-foot
impoundment or reservoir for domestic water supply, and circulation and infrastructure improvements
to accommodate buildout of the community (Figure 2-5). When the community was originally laid out
by developers, various parcels were designated for commercial uses, consistent with the “Vacation
Village” concept. These commercial parcels were scattered throughout the community to serve seasonal
residents and were thought appropriate for gas stations and small retail businesses or convenience
stores to meet the daily needs for goods and services. However, commercial development on many of
the commercially designated parcels has not occurred for multiple reasons, including physical
development constraints such as steep slopes and heavily forested parcels, remote locations making the
parcels isolated from residential development and a source of potential shoppers, and small parcel size
making development of a parking lot difficult without extensive grading. Some commercially designated
parcels have been developed with residences and were rezoned to residential as a result of the Specific
Plan to reflect the existing land use.
The District boundary is also comprised of two adjacent rural residential subdivisions zoned U-R Upland
Residential. The areas adjacent to the District boundary are zoned R-L Rangeland (livestock grazing,
protection of natural resources), T-P Timberland Production (growing and production of timber), S-R
Suburban Residential (residential with some commercial uses), and U-R Upland Residential (low-density
agricultural/residential uses).
(Mendocino, 2004)
Chapter 2 – Agency Overview Page 2-23
MSR/SOI Update | Brooktrails Township CSD
2.5.1.5 Development
Existing development in Brooktrails Township is primarily residential; however, there is very limited
commercial development, recreational and open space areas, and public facilities and infrastructure.
Existing commercial development within Brooktrails Township includes a deli and small convenience
store. Existing community facilities and improvements include the District office, community center, fire
station, golf course and shop, water treatment plant, Lake Emily and Lake Ada Rose, Ohl Redwood Grove
Park, community garden, baseball field, and an extensive trail system. Adjacent to Brooktrails Township,
existing development is primarily residential and also includes the Ells Field Airport and Sherwood Valley
Rancheria.
The City of Willits owns the Willits Municipal Airport, also known as Ells Field. This public airport facility
is located directly east of Brooktrails Township and is accessed from Poppy Drive. The airport began
private operations in the 1960s by the Deerwood Corporation as a destination for flights from Oakland
to prospective buyers of parcels in the adjacent Brooktrails Vacation Village subdivision. (LAFCo, May
2019)
The Specific Plan projections for buildout of Brooktrails Township are that there will be 3,815 residential
dwellings on 3,673 developed lots with a total population of 9,919 individuals (Mendocino, 2004).
Brooktrails Township is currently at approximately 33% of the total number of dwellings and associated
population projected at full buildout (BTCSD, 2019). The Specific Plan assumed development of 40
dwelling units per year based on historic development levels; however, new development has been
limited due to overall water supply availability and a long standing State issued and now released water
moratorium. Two new residential dwelling units have been developed since the water moratorium was
removed on December 3, 2017. Figure 2-6 shows the 2004 and 2019 development conditions for
Brooktrails Township including the number of existing parcels, the number of developed residential
parcels, and other development characteristics.
In order to allow a significant increase in new development within Brooktrails Township, the District will
face the following infrastructure needs or growth constraints.
o Development of a Second Access Road to reduce congestion and improve emergency access.
o Expanded capacity of the wastewater trunk main between Brooktrails Township and the City of
Willits Wastewater Treatment Plant.
o Development of additional water supply to supplement the existing surface water supply.
(LAFCo, 2010)
The near-term water and wastewater infrastructure needs identified above and additional long-term
needs are further described in Sections 3.5 and 3.6 respectively. The need for a Second Access Road is
described below.
Brooktrails Township is currently served by one access road. Therefore, all vehicle traffic generated from
Brooktrails Township, Spring Creek, Sylvandale, Willits Municipal Airport, and Sherwood Valley
Rancheria flows into the City of Willits via Sherwood Road at the intersection of Main Street located just
north of downtown Willits. This intersection is currently being reconstructed and funded by Caltrans as
mitigation associated with the construction of the Highway 101 Bypass project (BTCSD, 2019). Sherwood
Road is a narrow, two-lane paved road with eleven-foot lanes and no shoulders. (KOA Corporation,
2009)
Chapter 2 – Agency Overview Page 2-25
MSR/SOI Update | Brooktrails Township CSD
Based on a 2009 Brooktrails Second Access Feasibility Study prepared by KOA Corporation, Sherwood
Road is designed for 2,500 vehicle trips per day (round trips) and is serving an average of approximately
10,000 vehicle trips per day and a maximum of 18,000 vehicle trips per day. Therefore, development of
a Second Access Road is important for the safety of the existing population. (LAFCo: 2010, June 2019)
There has been extensive discussion of the need for secondary access to Brooktrails Township and the
Sherwood Road corridor by various individuals, citizen groups, elected officials, and public agencies over
the past decade. Numerous studies have been completed since 1991. These studies primarily focused on
the need for adequate emergency evacuation routes out of Brooktrails Township, especially during
wildfire incidents. Over the years a need for additional circulation capacity has also emerged due to
growth and general development in the area. (KOA Corporation, 2009)
In regard to evacuation, if the southbound paved portion of Sherwood Road to Willits becomes
unavailable during an emergency, the currently designated evacuation route is approximately 11.5-miles
along the northbound unpaved portion of Sherwood Road to Highway 101 or approximately 17.5-miles
to Laytonville (BTCSD, n.d.). The District is interested in establishing an alternative evacuation route for
Brooktrails Township and the surrounding area in the case of an emergency. One potential opportunity
is creating a Benefit Zone along the Sherwood Road Corridor through County Service Area 3 to assess
affected property owners and generate revenue to fund additional access.
A Second Access Road to Brooktrails Township and the surrounding area needs to be established to
address current road safety and congestion issues and improve circulation for the area in order to
accommodate the current population level and ultimate buildout of Brooktrails Township. Development
of a Second Access Road for general and emergency purposes is a significant infrastructure or growth
constraint for the District and is needed at the current level of development. Until the Second Access
Road infrastructure need is resolved, developing additional water supply and increasing sewer line
capacity likely will not be needed at the level required for full buildout. (LAFCo, 2010)
(BTCSD, 2019)
2.5.2 EXISTING POPULATION AND PROJECTED GROWTH
Figure 2-7 shows the District boundary compared with Block Group 2, Census Tract 106, which is the
census boundary with the closest shape to the District boundary. This census boundary follows the road
centerline, and excludes over 700 parcels located within the District and outside the boundary of Block
Group 2. The Census Blocks adjacent to Block Group 2 can extend far beyond the District boundary.
Therefore, the population and demographic characteristics of Census Block Group 2 have been
extrapolated to the remainder of the District boundary that is not covered by Block Group 2. (LAFCo,
2010)
Chapter 2 – Agency Overview Page 2-26
MSR/SOI Update | Brooktrails Township CSD
Based on the 2013-2017 American Community Survey 5-Year Estimates, the population estimate for
Block Group 2 is 3,365 (USCB, 2018b). Another way to determine the estimated population size for the
District is the number of residential units, or water service connections, multiplied by the average
household size. Based on 1,548 residential water connections (BTCSD, 2019) and an average household
size of 2.36 persons (USCB, 2018b), the District has an approximate population of 3,654. For
comparison, the estimated buildout population of 9,919 from the Specific Plan is based on an average
household size of 2.6 persons (Mendocino, 2004). The Brooktrails Census Designated Place (CDP)
boundary shape is similar to the Brooktrails Township subdivision boundary, but smaller than the
District boundary, and has an estimated population of 3,235 (USCB, 2018a).
For the purposes of this study, the current District population is estimated to be approximately 3,500,
which is the average of the low and high end estimates of 3,365 and 3,654.
Figure 2-7 BTCSD and Block Group 2 Boundaries
Source: LAFCo, 2010
Chapter 2 – Agency Overview Page 2-27
MSR/SOI Update | Brooktrails Township CSD
Population growth is expected to increase at an annual rate of approximately 0.5% for Mendocino
County (DOT, 2017). Based on this growth rate, the District can expect a small population increase of
175 people within the next five years. While the State removed the water moratorium in 2017, it is
anticipated that the District will experience very limited growth until constraints related to
infrastructure needs are sufficiently addressed.
2.6 DISADVANTAGED UNINCORPORATED COMMUNITIES
Senate Bill (SB) 244, which became effective in January 2012, requires LAFCo to evaluate any
Disadvantaged Unincorporated Communities (DUCs), including the location and characteristics of any
such communities, when preparing an MSR that addresses agencies that provide water, wastewater, or
structural fire protection services. A DUC is an unincorporated geographic area with 12 or more
registered voters with a median household income (MHI) that is less than 80% of the State MHI of
$63,783, or $51,026 (USCB, 2017). This State legislation is intended to ensure that the needs of these
communities are met when considering service extensions and/or annexations in unincorporated areas.
Brooktrails Township is a Census Designated Place (CDP) and the primary population center within the
District. Brooktrails CDP has an MHI of $49,420 and qualifies as a DUC (USCB, 2018a). Financial
information based on Block Group 2, Census Tract 106, is also representative of the District. Block Group
2 has an MHI of $45,670 and qualifies as a DUC (USCB, 2018b). The areas surrounding Brooktrails CDP
and Block Group 2 may also qualify as a DUC. Special consideration will be given to any DUCs affected by
future annexation proposals consistent with GC §56375(8)(A) and LAFCo Policy.
Chapter 2 – Agency Overview Page 2-28
MSR/SOI Update | Brooktrails Township CSD
3 MUNICIPAL SERVICES
A Municipal Service Review (MSR) is a comprehensive analysis of the services provided by a local
government agency to evaluate the capabilities of that agency to meet the public service needs of their
current and future service area. The MSR determinations inform the SOI Update process and assist
LAFCo in considering the appropriateness of a public service provider’s existing and future service area
boundary. The information and analysis presented in Chapters 2 and 3 of this document form the basis
for the MSR determinations provided under Section 3.7.
3.1 SERVICE OVERVIEW
3.1.1 SERVICES
Brooktrails Township CSD provides the following municipal services:
o Planning and Design Review
o Parks and Recreation
o Fire Protection and Emergency Medical Services
o Water
o Wastewater
Additional municipal services are provided to District residents by other public agencies or non-profit
organizations through agreements and Joint Powers Authority (JPA) and by private businesses through
service contracts, as detailed in Section 2.3.4. This MSR only reviews services provided by the District.
This is the second MSR prepared for the District; the first one was adopted by the Commission on
December 6, 2010 (LAFCo Resolution No. 2010-04).
3.1.2 SERVICE AREAS
The District is divided into three service areas:
o The Brooktrails Township subdivision receives all District services.
o The Spring Creek subdivision receives water and fire protection services from the District.
o The Sylvandale subdivision receives fire protection services from the District.
(LAFCo, 2010)
3.1.3 OUT-OF-AGENCY SERVICES
The District provides water and wastewater services to the Willits Municipal Airport as authorized by the
Board of Directors by resolution in the 1960s when the airport was constructed. The District does not
provide any other out-of-agency services (OAS), except for mutual aid responses and dispatched service
calls for fire protection and emergency medical services, including to the Sherwood Valley Rancheria and
”The Gates” area. (BTCSD: 2018, 2019)
3.2 PLANNING AND DESIGN REVIEW
Comprehensive planning and regulation of private land use is normally limited to cities and counties in
California. Unlike a city, BTCSD is not the exclusive provider of local government services within its
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boundaries. The County is the general-purpose local government agency for unincorporated areas and
created the District’s predecessor, the Brooktrails Resort Improvement District, at the time Brooktrails
Township was subdivided in order to provide municipal services.
The latent authority for resort improvement districts to exercise planning authority was deleted by the
legislature. However, BTCSD derived its authority to exercise a full range of municipal powers by
reorganizing from a resort improvement district to a community services district in 1975. This
reorganization was in response to the legislative limitation on the powers a resort improvement district
could provide and allowed BTCSD the powers to supply water, dispose of sewage and storm water,
provide fire protection, provide parks and streets, and provide and maintain other public facilities and
improvements as necessary.
The authority of BTCSD to regulate private land use was based on subdivision Covenants, Conditions,
and Restrictions (CC&Rs). The CC&Rs for Brooktrails Township (excluding the golf course and Cobb area)
expired on June 30, 1994. Prior to the expiration of the CC&Rs, the Mendocino County Board of
Supervisors adopted Ordinance No. 3885 establishing a Development Review Board consisting of the
District Board of Directors, responsible for development review of all new construction in the District,
and further acting as an appeals board for discretionary appeals from decisions of an Architectural
Review Commission appointed by the Board of Directors. General standards for the exterior design of
structures, landscape preservation, relationship between structures and site, building materials and
colors and parking and circulation were included. The actual Interim Site Development Standards
adopted by the Board on April 19, 1994 (Resolution 1994-16) were included in Ordinance No. 3885 by
reference. Ordinance No. 3885 specifically excluded the Spring Creek and Sylvandale subdivisions from
development review by the Board.
After several years of effort, BTCSD obtained special legislation through Assembly Bill No. 266 and voter
approval (69%) authorizing BTCSD to become the first special district in California to engage in land use
planning decision-making. Mendocino County Ordinance No. 3829 adopted by the Board of Supervisors
on August 18, 1992, established BTCSD as the Brooktrails Area Planning Commission (planning authority
granted by the State of California as delegated through Mendocino County), and noted it was the
“function and duty” of the Planning Commission to prepare a Specific Plan pursuant to Section 65450 of
the California Government Code and related General Plan amendments.
Ordinance 3829 excluded the Spring Creek and Sylvandale subdivisions from the area to be covered by
the Specific Plan. Both subdivisions have associations and are active in the community planning process.
The BTCSD Board has expressed its intent to refrain from preparing planning studies which would relate
to land use and criteria by which development would proceed in the Spring Creek and Sylvandale
subdivisions.
(Mendocino, 2004)
In January of 2006, Senate Bill 135 became effective. This Bill reorganized and changed the Principal Act
for a Community Services District. With the reorganization of CSD law, the Legislature provided a broad
list of powers that a CSD may assume. One of those powers is the ability to finance the operations of
area planning commissions formed pursuant to G.C. Section 65101. (LAFCo, 2010)
The Brooktrails Township Specific Plan contains requirements for lot clearing, building, and remodeling
in Brooktrails Township. The District contracts with an Architect to review plans and projects in
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accordance with the Specific Plan Design Guidelines and Site Development Standards and other
applicable County development regulations. Many projects require approval by the District Architect
before a building permit will be accepted by Mendocino County. In addition, the District Architect
reviews applications for the removal of individual trees on developed lots and proposals for the District’s
lot merger program for consistency with the Specific Plan. The District Administrative staff provides
basic information to property owners regarding the development process and requirements and acts as
a liaison between property owners and the District Architect. (BTCSD, 2018; LAFCo, 2010)
3.3 PARKS AND RECREATION
In a December 17, 1969 article in the New York Times, Brooktrails Township was noted as being the first
community in the United States to blend a 2,500-acre (4-square mile) redwood and mixed-growth forest
conservation park with a contiguous, fully improved residential area. The term coined for this residential
area built in a forest was hyleopolis. The term hyleopolis essentially refers to the fact that Brooktrails
Township functions as an urban-to-forest interface. It is a suburban development within a contiguous
wooded park. Hyleopolis also refers to the character of the urban-forest interface where protection of
the forest is paramount. That was the objective in Brooktrails Township from the beginning, and is the
purpose of Ordinance No. 63 adopted by the BTCSD Board of Directors on June 23, 1988. (Mendocino,
2004)
The original dedication of the forest greenbelt was for any use permitted to a resort improvement
district. County zoning is consistent with this interpretation of the range of potential uses, designating
that property for Public Facilities (PF). Ordinance No. 63 narrowed the use of the property by creating
Brooktrails Redwood Park and including all of that greenbelt property within it. The Ordinance states
that the Park constitutes much of the watershed of BTCSD, and as such is a facility incidental to the
water system of BTCSD. The Ordinance further states that the primary public purpose of the Park is to
protect, conserve, and manage trees, other vegetation, and wildlife in order to retain and create a
natural environment readily available for the enjoyment of property owners and residents of BTCSD.
(Mendocino, 2004)
On November 17, 1988, the BTCSD Board of Directors adopted Ordinance No. 68 establishing a Master
Plan for Brooktrails Redwood Park which controls the use of the property. The plan divided the Park into
three categories:
o Active use areas
o Neighborhood use areas
o Passive use areas
The Recreation, Greenbelt, and Conservation Committee prepared a Greenbelt Stewardship Plan
between 2006 and 2013, which the Board of Directors adopted by Resolution No. 2013-14. (BTCSD, n.d.)
The District owns various park and recreation facilities in Brooktrails Township including:
o Brooktrails Redwood Park with a 2,500-acre greenbelt that entails 30 hiking trails, Lake Emily, and
Lake Ada Rose. Fishing is allowed from the shore of Lake Emily and fish are stocked that were
especially bred for the upstream Eel River habitat areas. Lake Emily is a drinking water storage
facility; therefore, swimming, boating, and pets are prohibited in the lake.
o Ohl Grove Redwood Park with picnic tables, barbecues, and restrooms.
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o Community Center.
o Nine-hole golf course with a shop and grill. This course is also now being used as an 18-basket disc
golf course that attracts tournaments.
o Par course with a fitness trail and workout stations.
o Baseball field.
o Children's playground.
The District manages the operation and maintenance of the Community Center located next to the
District Office. Community groups, residents and visitors rent the Community Center for functions and
events. District Board of Directors meetings and committee meetings are also held at the Community
Center. The District has upgraded the facility for ADA compliance with the goal of providing continued
recreational opportunities. (BTCSD: 2018, 2019)
There is no charge to use any of the park and recreation facilities except for the golf course, rental of the
community center, and special events held at Ohl Grove Redwood Park. Residents of the City of Willits,
unincorporated County of Mendocino, and other areas regularly make use of the recreation facilities in
the District. The addition of disc golfing attracts destination participants from as far away as San
Francisco and beyond.
The District would like to refurbish the non-functioning tennis courts on Birch Street and improve them
for full-court basketball and volleyball. The District has reconstructed the children’s playground to
include more modern play facilities. A Proposition 68 grant to fund Par Course trail connectivity and play
surface upgrades will be submitted in 2019.
The District partners with private/public groups to provide special events and activities including Movies
on the Grove and seasonal child-oriented special events such as a pumpkin hunt. The District also works
with the Willits Kids Club to offer a two-week summer camp at the community center and picnic grove.
District Administrative staff oversees the park and recreation facilities including finances, contract
management, and grant administration, and District maintenance staff is responsible for maintaining
park and recreation facilities.
(BTCSD: 2018, 2019; LAFCo, 2010)
3.4 FIRE PROTECTION AND EMERGENCY MEDICAL SERVICES
3.4.1 SERVICE OVERVIEW
3.4.1.1 Services
The District provides structural fire protection, suppression, and prevention, first responder for
emergency medical services and hazardous materials incidents, and rescue/extrication. The District does
not provide ambulance service or have a hazardous materials response team. The County REHIT team
would be the response group for a HAZMAT incident for the purpose of direct management and control
of the event. (BTCSD, 2018; LAFCo, 2010)
As part of fire prevention services, the BTCSD Fire Department provides fire safety education, conducts
arson investigations, and manages a Hazard Abatement Program with standards requiring private
property owners to eliminate specific hazards defined for grass and wooded parcels and create
defensible space by July 1st of each year. The District also works with CAL FIRE on fire safety efforts to
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construct fuel breaks in Brooktrails Redwood Park and has special fire regulations, including a burn ban
from June 1st until the first rains of each year, and prohibits the discharge of firearms and the use of off-
road vehicles in Brooktrails Redwood Park. In addition, the Fire Prevention Officer performs annual
business inspections and assists residents with information about defensible space, fuel loads, fire rated
roofing, and fire resistive materials. (BTCSD: 2018, n.d.; LAFCo, 2010)
The BTCSD Fire Department has received and is currently working under Fuels Management Grants from
CAL FIRE to abate overgrown vegetation in and around District property and infrastructure throughout
the Township.
The entire District is located within the State Responsibility Area (SRA); this designation means that the
State of California has the primary financial responsibility for the prevention and suppression of wildland
fires. The District responds to all fire-related services calls within the District boundary, and is often the
first to respond to wildland fire incidents. During wildland fire season, the California Department of
Forestry and Fire Protection (CAL FIRE) is also dispatched to wildland fires in the SRA, and the first
agency to respond generally assumes the role of Incident Command (IC).
The District boundary is coterminous with the jurisdictional boundary of the Little Lake Fire Protection
Distrit (LLFPD) to the east of Brooktrails Township. The areas located north, west, and south of the
District are not within the jurisdiction of a local fire agency. These areas are within the SRA and receive
wildland fire protection services from CAL FIRE during wildfire season and local fire agencies when
dispatched. These adjacent areas are primarily owned by timber production companies and are difficult
to serve due to the distance from existing District fire stations, remote location, and access issues. CAL
FIRE is the appropriate service provider in these areas for the foreseeable future.
3.4.1.2 Staffing
The District has a combined Fire Department with professional and volunteer personnel. The BTCSD Fire
Department is staffed with 2 paid positions including a full-time Fire Chief and a full-time Fire Prevention
Officer/Battalion Chief and 15 Volunteer Firefighters of various skill levels.
The District recruits and relies on volunteers to provide services through the Brooktrails Firefighters
Association. The maximum number of volunteers that the District can support is 25. The District reports
that the current staffing level is adequate to deliver services. The District is recruiting new volunteer
firefighters and needs more volunteer firefighters that are available during daytime hours. (BTCSD:
2018, 2019)
The following table provides information regarding the current staff resources dedicated to providing
fire protection services.
Table 3.1 BTCSD Fire Department Staffing
Title Career Paid On-Call Volunteer
Fire Chief 1
Assistant Chief
Battalion Chief
Fire Captain 2
Engineer 4
Firefighter 8
Fire Prevention Officer 1
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Table 3.1 BTCSD Fire Department Staffing
Title Career Paid On-Call Volunteer
Maintenance Engineer
Admin. Staff
Temporary Interns 1
Source: BTCSD: 2018, 2019.
3.4.1.3 Training
Volunteer Firefighters have a regular training schedule of one Thursday and one Saturday per month for
three hours in addition to on-duty training. Volunteers are encouraged and trained to Firefighter Level 1
standards. (BTCSD: 2018, 2019)
3.4.1.4 Dispatch
In Mendocino County, dispatch for fire protection services and emergency medical services (EMS) are
provided by the CAL FIRE Emergency Communications Command Center (ECC) at the Howard Forest
Station near Willits. Mendocino County pays for dispatch services from a portion of Proposition 172
funds.
Due to the dynamic and unpredictable nature of emergencies, multiple public agencies could be
dispatched to a single service call. In responding to medical emergencies, local fire protection and
ambulance service providers are often dispatched simultaneously. In many cases, local fire agencies are
the first to arrive on scene and provide first aid and basic life support while preparing the patient for
transport to a hospital.
3.4.1.5 Mutual and Automatic Aid Agreements
Mutual aid refers to reciprocal service and support provided to another agency upon request under a
mutual aid agreement between one or more agencies. Automatic aid differs in that no request for aid is
necessary in order for reciprocal service and support between agencies within the automatic aid
agreement. These types of pre-arrangements allow for the dispatch and use of additional equipment
and personnel that a single jurisdiction cannot provide on its own and also entails a reciprocal return of
resources when needed. The District maintains an Automatic Aid Agreement with the Little Lake Fire
Protection District and continues to cooperate in the development of opportunities to assist regional
firefighting organizations.
The District primarily serves residents and property within its jurisdictional boundary. However, due to
the critical need for rapid response in emergency situations, when a call for service is received, the
nearest available response unit is dispatched regardless of jurisdictional boundary. Therefore, the BTCSD
Fire Department response area is larger than the District boundary based on the Countywide Mutual Aid
System. According to the 2015 Mendocino County Community Wildfire Protection Plan, the District is
within Mutual Aid/Planning Zone 1, which includes the Little Lake Fire Protection District, Covelo Fire
Protection District, Long Valley Fire Protection District, Leggett Valley Fire Protection District, Piercy Fire
Protection District, and Whale Gulch Volunteer Fire Company (MCFCA, 2015).
In addition to the local mutual aid system, the District participates in the California Fire Service and
Rescue Emergency Mutual Aid System for wildland fire incidents throughout the State. The District
responds to out-of-County fire incidents upon request for strike teams and when the remaining
equipment and personnel are capable of providing service to the District.
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3.4.2 SERVICE ADEQUACY
3.4.2.1 Service Calls
The following table provides a summary of the total number and types of service calls the District
responded to during years 2012 through 2018.
Table 3.2 BTCSD Summary of Service Calls
Service Call Type 2012 2013 2014 2015 2016 2017 2018
Fire Suppression 14 9 8 25 41 38 52
EMS/ALS 118 154 127 157 165 131 172
Rescue 32 36 24 20 18
Hazardous Materials 4 2 7 22 22 20 20
Other/Public Assists 27 55 36 48 15 41 42
TOTAL 195 256 202 272 261 230 288
Source: BTCSD: 2018, 2019.
The District responds to an average of 244 service calls per year, varying from structure fires to public
assistance. The majority of service calls are related to emergency medical responses. The District can
successfully and simultaneously manage multiple service calls in one day.
3.4.2.2 Response Times
Response time relates to the time elapsed between the dispatch of personnel and the arrival of the first
responder on the scene of an incident. There are different response time expectations and first
responder capabilities in serving urban, suburban, and rural areas. In general, the faster the response
time the higher the likelihood of a positive outcome related to managing and addressing the incident. A
fast response time for medical care is especially important for incidents involving patients who are
suffering from a life-threatening condition. Further, a fast response time for fire suppression is
important to prevent a structure fire from rapidly spreading to other structures and/or wildland
interface areas.
Emergency response time standards vary by the level of urbanization of an area; the more urban an
area, the faster a response should be. The Coastal Valleys EMS Agency has established recommended
guidelines for response times which apply to Mendocino County. For 90% of emergency responses,
response times for first responders should not exceed 5-minutes in metropolitan to urban areas, 15-
minutes in suburban to rural areas, and 30-minutes for wilderness areas (CVEMSA, 2012). These
standards are intended for ambulance contract providers; however, they indicate what is considered
appropriate response times for medical emergencies. The National Fire Protection Association (NFPA)
has also established industry standards for response time performance based on the service structure of
the agency: NFPA 1710 for agencies with paid staff and NFPA 1720 for agencies with volunteer staff.
NFPA 1720 recommends the following response times: 9-minutes in urban areas 90% of the time, 10-
minutes in suburban areas 80% of the time, 14-minutes in rural areas 80% of the time, and in remote
areas response time is directly dependent on travel distance (NFPA, 2010). The District would fall under
the NFPA 1720 category.
The District’s average response time is less than nine minutes due to the majority of calls being from
within the Township boundary. The District’s response time varies by call location and is approximately
10-minutes in Brooktrails Township and less than 15-minutes in Spring Creek and Sylvandale. (BTCSD:
2018, 2019)
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3.4.2.3 ISO Rating
Fire services in communities are classified by the Insurance Service Office (ISO), which is an advisory
organization depended on by insurance companies for establishing the availability and costs for fire
insurance. The ISO rating classifies fire service in communities with a ranking from 1 to 10, indicating the
general adequacy of coverage. Communities with the best fire protection facilities, systems for water
distribution, fire alarms, communications, equipment, and personnel receive a rating of 1. Primary
factors assessed in establishing ISO ratings are maintaining more than one fire station within a district
boundary to meet the 5-mile radius requirements, ensuring appropriate facility maintenance and
upgrades are made, and sufficient personnel and volunteers exist to respond to each station.
Brooktrails Township has an ISO rating of 4 and Spring Creek and Sylvandale have an ISO rating of 4X.
(BTCSD, 2018). The current ISO ratings were improved based on fire prevention activities and increased
water storage capacity.
3.4.3 FACILITIES AND ASSETS
The District owns, operates, and maintains multiple capital assets including land, buildings, equipment,
and infrastructure to provide services to its constituents.
3.4.3.1 Facilities
The BTCSD Fire Department operates two fire stations. The main two-bay fire station is in good
condition and is located at 24680 Birch Street. The second single-bay fire station is located in the Spring
Creek area at the intersection of Ridge Road and Blue Lake Road and is currently used primarily for
equipment housing. Fuels reduction in and around these facilities was completed in 2019 to provide
clearance and protection against fire-related impacts. There are no plans for additional facilities.
(BTCSD: 2018, 2019; LAFCo, 2010)
The Brooktrails Township Specific Plan will be the document, once amended, used to develop plans for
future fire protection facility improvements and equipment to serve the needs of Brooktrails Township
as it develops over time. Currently, the Specific Plan identifies the following capital needs:
o A third fire station is anticipated in the vicinity of the airport to serve existing development. A fourth
fire station and fire vehicles would be required to serve 2,000 units, and a fifth fire station and
vehicles would be required to accommodate 4,000 units.
(Mendocino, 2004)
3.4.3.2 Equipment
The District owns and maintains multiple fire engines and emergency response vehicles, as shown in
Figure 3-1.
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Figure 3-1 BTCSD Vehicle Inventory
Vehicle Inventory
Original Cost
Year Make/Model Type Use GVW
$325,000
2018 Water Tender Fire Truck Fire Protection
20,000
$27,131
2016 Ford/F150 Pick-Up Truck Water/Sewer
7,050
$8,000
1984 Ford Truck Pick-Up Truck Maintenance
6,380
2008 Ford Ranger 4WD $17,904
Pick-Up Truck Maintenance
Pickup 2,010
2009 International Vac $264,327
Extra Heavy Truck Water/Sewer
Truck 30,900
$15,982
2003 Ford Ranger Pick-Up Truck Water/Sewer
3,358
$4,500
1982 AMGNL/UT Jeep Light Truck
5,999
$49,402
1990 Ford F-350 #5230 Fire Truck - Full-sized Fire Protection
11,000
2006 Ford Ranger 4x4 S16,222
Pick-Up Truck Maintenance
w/ Attachments 3,600
2009 Ford S-DTY $63,000
Fire Truck Fire Protection
F350S #5240 11,200
2004 Ferrara Pumper $282,505
Fire Truck Fire
Model #5281 32,300
1988 Ford Fire Engine $150,428
Fire Truck Fire Protection
#5285 26,320
$49,715
1993 lnt'I Dump Truck Dump Truck Maintenance
13,880
Fire $105,000
1995 FORD/PUMPER Fire Truck
Protection 25,180
$5,422
1997 Ford PU #5242 Fire Pick-Up or Light Duty Fire
4,490
1981 Ford Flatbed $30,000
Medium Truck Maintenance
w/Rodder 20,000
$20,287
2005 Chevy PU #5200 Fire Pick-Up or Light Duty Fire Protection
4,862
1982 International $100,000
Fire Truck Fire Protection
Pumper #5280 24,920
$39,915
2015 Ford F350 S Pick-Up Truck Water/Sewer
9,800
2016 Dodge Ram 3500 $87,815
Fire Truck - Full-sized Fire Protection
Quick Response 9,000
1996 F250 Ford Utility $20,850
Pick-Up Truck Maintenance
Truck 8,600
$26,633
1978 Ford Pumper Pick-Up Truck Water/Sewer
9,890
$
Total Count: 22
1,710,038.00
Source: BTCSD, 2019
The current fire protection fleet is adequate to deliver services with the purchase of a water tender in
2019. The Board of Directors has developed a schedule for the replacement or acquisition of fire
apparatus and equipment as part of the capital priorities identified during the annual budget
development process (refer to Section 2.4.2.3 for more information). The capital priorities are updated
annually to reflect the actual condition of vehicles and equipment and to address unanticipated needs.
(BTCSD, 2018)
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3.4.3.3 Water Supply
Available water supply for fire suppression varies based on location in the District. In Brooktrails
Township, water for fire suppression is available from the District’s 2 water storage tanks with a
combined storage capacity of 977,000-gallons available from 256 fire hydrants. The Spring Creek
subdivision maintains a water tank for community domestic water supply which fire apparatus can
pump from for fire suppression. The Sylvandale subdivision has private water sources including wells
and surface water diversions.
Water supply also includes such resources as one 2,000-gallon water tender, on-board tanks on fire
engines, the District’s two reservoirs with a maximum storage capacity of 120,564,000 gallons, and
other water supplies available for drafting such as ponds, rivers, and water tanks with fire department
hook-ups on private property.
(BTCSD, 2018; LAFCo, 2010)
3.5 WATER
3.5.1 SERVICE OVERVIEW
The District owns, operates, and maintains a public water system for water supply, treatment, and
distribution. The District’s water system facilities and infrastructure includes two reservoirs, Lake Emily
which feeds into Lake Ada Rose, on Willits Creek and a tributary within the Eel River watershed, a Water
Treatment Plant (WTP) with a design capacity of 1.2 million gallons per day (MGD), 24 water tanks with
1.7 million gallons (MG) of storage capacity, 18 pump stations, and 64 miles of water mains. The District
also has a four-bay utility department garage located at the WTP. The District’s water system is classified
as a Large Water System because it has more than 500 connections and is under the jurisdiction of the
State Water Resources Control Board (SWRCB) Division of Drinking Water Supply Permit No. CA2310009.
The District’s water system serves a total of 1,555 connections, including 1,505 in Brooktrails Township,
49 connections in Spring Creek, and 1 connection to the City of Willits for the Willits Municipal Airport.
The District’s water system serves 1,548 residential, 4 commercial, and 3 public service connections.
Lake Emily has a physical storage capacity of 251 acre-feet (AF), and allowed water rights of 300 AF
under SWRCB Water Right Permit No. 015913, and Lake Ada Rose has a storage capacity of 138 AF
under SWRCB Water Right Permit No. 014218, for a total available water storage supply for the District
of 389 AF.
(BTCSD: 2018, 2019; LAFCo, 2010)
3.5.2 WATER DEMAND AND CAPACITY
The District’s total demand on the water system in 2018 was 62,240,775 gallons, averaging to 170,553
gallons per day (GPD), or 110 GPD per service connection. The District’s average dry weather daily
demand (May 1 through September 30) is 202,324 GPD. The District’s peak day demand for water is
approximately 247,751 gallons. These water use levels are well below the design capacity of the WTP.
The District’s total annual water consumption level or demand is provided in the table below.
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Table 3.3 BTCSD Historic Total Annual Water Demand
2010 2011 2012 2013 2014 2015 2016 2017 2018
77.7 MG 74.2 MG 80.8 MG 80.1 MG 58.4 MG 61.8 MG 67.8 MG 69.4 MG 62.2 MG
238 AF 228 AF 248 AF 246 AF 179 AF 190 AF 208 AF 213 AF 191 AF
Source: BTCSD: 2018, 2019.
Based on the actual total annual water demand, the average total annual demand on the District’s water
system is approximately 70.3 MG (216 AF), or 55% of the total available water storage supply of 389 AF.
If the District’s total available water storage supply was applied to equivalent single-family residential
units (SFRs) based on the assumption that a typical single-family residence consumes an average of 220
gallons of water per day as identified in the Specific Plan, but well below actual consumption amounts,
the District’s current 1,555 water service connections would account for 383 AF or 98% of available
supply with a remaining 2% available for growth (Mendocino, 2004). However, this estimation accounts
for 192 AF more water use per year than what was demonstrated in 2018, indicating that the District’s
water customers use considerably less water than standard estimates.
The Brooktrails Township Specific Plan indicates that the District’s existing water system will reach
capacity as it approaches 2,000 water service connections (Mendocino, 2004); although, this does not
account for additional water supply established since 2004.
In January 2010, a Water Capacity Study was completed by Wagner and Bonsignore, Inc., an engineering
firm that specializes in the overall water yield of watersheds. The following summary and conclusion is
from that report.
A spreadsheet model with daily time step was created to simulate daily operation of the BTCSD water
system over a 42-year period corresponding to historical hydrological conditions. The model
incorporated estimated runoff to the lakes, WTP demand, golf course demand, return well pumping,
constraints on diversion permits, required streamflow bypass, evaporation reservoir capacity and spill.
Annual WTP demand was set at 373 AF, which is slightly more than average annual production over the
past 7-years, and significantly greater than the 320 AF of actual production in 2009. Runoff to the lakes
was estimated based on Willits Creek gage above Lake Emily and correlation of that gage to another
nearby gage with a longer period of record.
The probability of drought recurrence was evaluated and the year of record with the least precipitation
and runoff (1977) was deemed to have a probability of recurrence of far less than 4 percent. Under such
a condition, significant supply shortages would likely occur at BTCSD and some level of demand-side
reduction and relaxation of regulatory constraints would be necessary to provide a minimum level of
service. However, while runoff levels similar to 1977 could occur in any year, it is not reasonable to plan
for a level of reliability that is needed very rarely.
Setting aside 1977, the BTCSD reservoirs filled and spilled in all other years studied. Indeed, other than
1977, the least amount of spill was 562 AF. This indicates the Lakes will be filled at the start of the dry
season in a year with 4 percent recurrence probability. Other than 1977, the greatest drawdown of the
BTCSD reservoirs during the dry season in the 42-year study period was a low of 84 AF of residual
storage in 2008 and a low of 86 AF in 1988. Accordingly, in a severe dry season such as occurred in 1988
or 2008, BTCSD has sufficient supply and capacity to meet the needs of its current 1,554 connections
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without imposing demand-side reductions and with a cushion of about 85 AF of water remaining in
storage when the reservoirs are at their lowest levels.
(Wagner and Bonsignore, 2010)
3.5.3 PAST WATER MORATORIUM
In February 2003, the California Department of Public Health, Drinking Water Field Operations Division
(CDPH), now the SWRCB Division of Drinking Water, issued an order indicating that the District had
insufficient water source capacity to serve its water customers and prohibited further water service
connections. In order to remove the water moratorium and allow additional growth, the District had to
provide adequate water source capacity to satisfy State requirements. (LAFCo, 2010; TK, 2017)
In response to the water moratorium, the District adopted a Water Conservation Plan and began efforts
to increase water supply, such as a well drilling program and increasing the water storage capacity of
Lake Emily. Between 2003 and 2010, the District spent approximately $4.5 million in water capital
projects. The result of this investment was the State increased the cap on new water service
connections to 1,578 in March 2010, which ended the 2003 water moratorium. The 1,578 cap granted
the District 23 more service connections and is still in effect. (LAFCo, 2010; TK, 2017; BTCSD, 2019)
On June 30, 2014, the State Water Resources Control Board (SWRCB) issued a Curtailment Order
affecting Post-1914 Water Right Holders, which included Brooktrails Township CSD, due to the impact of
the statewide drought on the Eel River. This order was lifted on October 24, 2014 and essentially
replaced with a new order on October 17, 2014 establishing a moratorium on new water connections
which was issued to all the municipal water providers around the Little Lake Valley, including Brooktrails
Township CSD (Water System ID #2310009). (BTCSD, n.d.)
The SWRCB Curtailment Compliance Order No 02_03_14R_002 directed the District to secure a reliable
long-term supply of water related to the District’s surface water rights to Willits Creek, which is part of
the Eel River watershed that was curtailed in June 2014 due to drought conditions and senior water right
demands. The order also prohibited new water service connections to residences and businesses in the
service area, required metering for all customers, established a schedule to develop a reliable alternate
source of water supply, and determined that the water moratorium would remain in effect until a new
source of water was identified and established for regular water service to existing customers. (SWRCB,
2014a)
On December 3, 2017, the District issued a press release confirming that the SWRCB removed the water
moratorium on new water connections in the District. There is only one active water rights curtailment
in Mendocino County in 2019 and it does not affect the District’s water rights. (BTCSD: n.d., 2019)
3.5.4 WATER SUPPLY ENHANCEMENT
In response to the 2003 water moratorium, the District implemented several projects to increase water
supply, as outlined below.
3.5.4.1 Water Conservation
A Water Conservation Plan was adopted by the Board of Directors in 2014 per Ordinance No. 134, which
restricts how much water can be used per service connection, as well as establishing an excessive usage
cap. In 2014, the District declared a State of Water Emergency and imposed further limitations on water
use. The State of Water Emergency ended on January 12, 2017 per Resolution No. 2016-24 which was
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MSR/SOI Update | Brooktrails Township CSD
adopted December 13, 2016. On May 22, 2018, the District Board of Directors adopted Ordinance No.
159, amending Ordinance No. 76, to decrease the water usage cap from 20,645 to 9,000 gallons per
month per service connection. Water customers who exceed the water usage cap are subject to the
mandatory installation of water restrictors by the District or may have their service terminated until
such time as the excessive use is satisfactorily addressed. (BTCSD: n.d., 2019; LAFCo, 2010)
3.5.4.2 Well Drilling Program
Between 2003 and 2006, the District implemented a Well Drilling Program to supplement its surface
water supply with a consistent water source that is not prone to seasonal water quality and quantity
issues like surface water sources. This program was terminated after drilling efforts produced multiple
dry holes. However, a single well near the WTP yields approximately 2 gallons per minute (gpm) and is
used to supplement surface water supplies through a blending program that directs the groundwater
through the clarifier and treats it in the WTP prior to entering the distribution system. Since Brooktrails
is located on the Pacific Shelf, wells do not yield a cost-effective supply solution for the District. The
Little Lake Valley area is sitting on the Continental Shelf and produces high-yielding wells. Therefore, the
District is exploring the potential of securing a groundwater supply in the Little Lake Valley area, by
either developing wells or purchasing water from the City of Willits, in order to support adequate water
supplies for existing and future development in Brooktrails Township and Spring Creek. However, this
potential long-term solution would be very expensive to develop pump stations, storage tanks, and
pipelines to move water from the valley uphill to the District’s customers and which would also incur a
significant cost for electricity to run the system. (BTCSD: n.d., 2018, 2019; LAFCo, 2010; TK, 2017)
3.5.4.3 Lake Emily Expansion
The District completed a major expansion project for Lake Emily at the cost of $3.5 million. This project
increased the capacity of Lake Emily from 200 AF to 251 AF by removing the existing dam and replacing
it with a redesigned dam. The new dam and associated infrastructure was officially put into service in
November 2008. (LAFCo, 2010)
3.5.4.4 Conceptual Study to Increase Lake Ada Rose Capacity
Based on a 2007 engineering study prepared by Hanson Engineering, Lake Ada Rose could potentially be
raised by 38-feet, increasing the dam crest to approximately 95-feet, and creating a maximum water
depth of 85-feet. This would increase the surface area of the lake from 6-acres to 24-acres and would
increase the storage capacity from 138 AF to 725 AF. The redesigned reservoir would be almost three
times larger than Lake Emily and the project would provide enough water storage for approximately
3,873 SFRs. (LAFCo, 2010)
3.5.5 OPERATIONS AND CAPITAL NEEDS
The District’s Utility Department staff is responsible for maintaining the water system including the
water collection, treatment, and distribution facilities and infrastructure. The District’s water system
was developed at the time of District formation and included water service connections to every lot in
Brooktrails Township and Spring Creek subdivisions. Many of these water connections serve
undeveloped lots and the distribution pipes are rotting. This aging infrastructure results in 90% of the
leaks in the District’s water system, especially in Spring Creek due to the geography of the area. The
District is working on identifying specific target areas with significant leaking to repair.
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MSR/SOI Update | Brooktrails Township CSD
The Brooktrails Township Specific Plan identifies the following water facility and infrastructure
improvements to serve the needs of Brooktrails Township as it develops over time.
o Development of wells to supplement the existing water supply for up to 2,500 units.
o A new raw water main connecting the new 1,600 AF reservoir to the existing raw water main at Lake
Emily.
o Expansion of the existing Water Treatment Plant in the current location to increase capacity and
accommodate buildout or growth to 4,000 units.
(Mendocino, 2004)
Based on more recent studies and changing circumstances, the development of groundwater wells in
Brooktrails Township and the 1,600 AF reservoir is not feasible. Therefore, the next Specific Plan Update
will need to address these changes accordingly. (LAFCo, 2010)
3.6 WASTEWATER
3.6.1 SERVICE OVERVIEW
The District owns, operates, and maintains a public wastewater collection system and receives
wastewater treatment and disposal services from the City of Willits. The District’s wastewater collection
system infrastructure includes three lift stations with backup generators at various elevations, 56 miles
of sewer lines approximately 4 to 6 inches in diameter, 1,025 manholes which were sealed in 2005 to
prevent inflow, and a 15-inch diameter trunk main to the City of Willits Wastewater Treatment Plant
(WWTP). The District allows the installation and incorporation of gray-water systems in an effort to
reduce the flow of wastewater to the WWTP. (LAFCo, 2010; BTCSD: n.d., 2019)
The District’s wastewater collection system serves a total of 1,435 connections, including 1,434 in
Brooktrails Township and 1 connection to the City of Willits for the Willits Municipal Airport. There are
approximately 660 lots that do not have wastewater collection service within Brooktrails Township,
primarily located at higher elevations of the subdivision on the following roads, Ridge, Iris, Blue Lake,
and Alcott. This includes about 616 lots that are unimproved and 44 lots that are improved and on septic
systems. (Mendocino, 2004; BTCSD: n.d., 2018, 2019)
The District’s Utility Department staff is responsible for maintaining the wastewater collection system
and uses a high speed camera to annually inspect sewer lines for root intrusion, cracked pipes, and
displacement by ground shifting as part of their Inflow and Infiltration (I&I) program. When signs of I&I
are found, staff either replaces a section of pipe or installs a pipe patch. When staff finds problems that
are not isolated to a small section of pipe, staff schedules a major line replacement project. District staff
has also completed a smoke test of the entire wastewater collection system to locate and remove
sources of unauthorized I&I into the system. The expected useful life of a properly developed and well
maintained wastewater collection system is approximately 60 to 80 years. Brooktrails Township was
initially developed in the mid-1960s and approximately 95% of the wastewater collection system was
installed before 1970; therefore, the infrastructure installed at that time is about fifty-years old and in
fair condition. (BTCSD: 2018, n.d.; LAFCo, 2010)
The Brooktrails Township Specific Plan identifies the following wastewater collection infrastructure
improvements to serve the needs of Brooktrails Township as it develops over time.
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MSR/SOI Update | Brooktrails Township CSD
o Expanded capacity of the wastewater trunk main by replacing or paralleling the existing 15-inch
diameter pipe between Brooktrails Township and the City of Willits Wastewater Treatment Plant to
accommodate development beyond 2,000 units, and a second new line to accommodate 3,000
units. (Mendocino, 2004)
3.6.2 WASTEWATER TREATMENT AND DISPOSAL SERVICES
The District and the City of Willits entered into an agreement on September 11, 1967 for the City to
provide wastewater treatment and disposal services to the District. This agreement has been amended
over time. Contract amendment No. 2 in 1975 granted the District an exclusive right to dispose of 0.16
MGD of effluent and a subsequent contract amendment in 1982 increased the allowable volume of
effluent from the District to 0.49 MGD. Per the contract terms, the District agreed to reimburse the City
for costs allocated to the District based on the ratio of total flow entering the City’s treatment plant. The
District contributes approximately 30% of the effluent treated at the City’s WWTP. In 2018, the District’s
average daily flow volume of effluent to the City’s WWTP was 0.28 MGD. The District’s 0.49 MGD
allowable volume of effluent level is likely not enough to accommodate full buildout of Brooktrails
Township. (LAFCo, May 2019; BTCSD, 2019)
In 2012, the City completed a two-phase project involving major improvements and upgrades to the
City’s Wastewater Treatment Plant (WWTP). The expanded WWTP facility has a design discharge
capacity of 7.0 MGD and a permitted average monthly flow of 4.0 MGD. The City requested that
permitted flow be limited to 4.0 MGD based on projected needs through 2025. The treatment plant
currently treats an average of 0.65 MGD dry weather flow (without I&I) and 1.20 MGD wet weather
flow. (LAFCo, May 2019)
In 2010, the District filed a lawsuit against the City seeking, declaratory relief regarding wastewater
accounting methods and allocation of operating costs and annual audits. The City filed a cross complaint
against the District to recover certain costs and expenses incurred by the City related to the WWTP
improvement project. On April 6, 2015, the District and the City settled the lawsuit stipulating a new
cost allocation to the District of $22,000 for a fixed monthly fee beginning July 1, 2015 in addition to
36% of the City’s bond payments or debt service for the WWTP improvement project (MLH, 2018). The
settlement required that a forensic audit be completed by June 30, 2019, identifying the costs and
volumes of wastewater contributed by the District, in order to establish a fair accounting of the true cost
of treating and disposal of the District’s wastewater. The forensic audit is currently underway (BTCSD,
2019).
3.7 DETERMINATIONS
This section presents the required MSR determinations pursuant to California Government Code
§56430(a) for the Brooktrails Township Community Services District.
3.7.1 MSR REVIEW FACTORS
3.7.1.1 Growth
Growth and population projections for the affected area
1. The Brooktrails Township CSD is estimated to serve a population of approximately 3,500 residents,
including Spring Creek and Sylvandale.
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MSR/SOI Update | Brooktrails Township CSD
2. The Brooktrails Township Specific Plan projections for buildout of Brooktrails Township are that
there will be 3,815 residential dwellings on 3,673 developed lots with a total population of 9,919
individuals. Brooktrails Township is currently at approximately 33% of the total number of dwellings
and associated population projected at full buildout.
3. Population growth is expected to increase at an annual rate of approximately 0.5% for Mendocino
County. Based on this growth rate, the District can expect a small population increase of 175 people
within the next five years. It is anticipated that the District will experience very limited growth until
constraints related to infrastructure needs are sufficiently addressed.
4. Mendocino County has land use authority over privately-owned lands within the District boundary
and makes land-use decisions based on the County’s Inland General Plan and Zoning Regulations.
3.7.1.2 Disadvantaged Unincorporated Communities
The location and characteristics of any disadvantaged unincorporated communities within or contiguous
to the sphere of influence
5. Brooktrails CDP has an MHI of $49,420 and qualifies as a DUC. Block Group 2, Census Tract 106, has
an MHI of $45,670 and qualifies as a DUC. The areas surrounding Brooktrails CDP and Block Group 2
may also qualify as a DUC. Special consideration will be given to any DUCs affected by future
annexation proposals consistent with GC §56375(8)(A) and LAFCo Policy.
3.7.1.3 Capacity of Facilities and Adequacy of Services
Present and planned capacity of public facilities, adequacy of public services, and infrastructure needs or
deficiencies including needs or deficiencies related to sewers, municipal and industrial water, and
structural fire protection in any disadvantaged unincorporated communities within or contiguous to the
sphere of influence
6. The District provides a wide range of municipal services including Planning and Design Review, Parks
and Recreation, Fire Protection and Emergency Medical Services, Water, and Wastewater.
7. The District is divided into three service areas: Brooktrails Township subdivision receives all District
services, Spring Creek subdivision receives water and fire protection services from the District, and
Sylvandale subdivision receives fire protection services from the District.
8. The District has provided water and wastewater services to the Willits Municipal Airport since the
1960s. The District does not provide any other out-of-agency services, except for mutual aid
responses and dispatched service calls for fire protection and emergency medical services.
9. The District’s water system serves a total of 1,555 connections, including 1,5 residential,
commercial, and 3 public service connections. The District’s water system facilities and
infrastructure includes two reservoirs, Lake Emily (251 AF) and Lake Ada Rose (138 AF) for a total
available water storage supply of 389 AF, a Water Treatment Plant with a design capacity of 1.2
million gallons per day, 24 water tanks with 1.7 million gallons of storage capacity, 18 pump
stations, and 6 miles of water mains. The average total annual demand on the District’s water
system is approximately 70.3 MG (216 AF), or 55% of the total available water storage supply of 389
AF. The District’s total demand on the water system in 2018 was 62,240,775 gallons (191 AF). The
District has a cap on new water service connections of 1,578, allowing 23 more service connections
before additional water source or storage capacity needs to be established.
10. The District owns, operates, and maintains a public wastewater collection system and receives
wastewater treatment and disposal services from the City of Willits at an allowable volume of
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MSR/SOI Update | Brooktrails Township CSD
effluent of 0. 9 MGD. The District’s wastewater collection system serves a total of 1, 35
connections, including 1,434 in Brooktrails Township and 1 connection to the City of Willits for the
Willits Municipal Airport. In 201 , the District’s average daily flow volume of effluent to the City’s
Wastewater Treatment Plant was 0.28 MGD. There are approximately 660 lots, including 44 lots that
are improved and on septic systems, that do not have wastewater collection service within
Brooktrails Township, primarily located at higher elevations of the subdivision. On April 6, 2015, the
District and the City of Willits settled a wastewater lawsuit stipulating a new cost allocation to the
District of $22,000 per month beginning July 1, 2015 in addition to 36% of the bond payments for
the upgraded City of Willits Wastewater Treatment Plant.
11. Brooktrails Township is currently served by one access road and all vehicle traffic generated from
Brooktrails Township, Spring Creek, Sylvandale, Willits Municipal Airport, and Sherwood Valley
Rancheria flows into the City of Willits via Sherwood Road, a narrow, two-lane paved road with
eleven-foot lanes and no shoulders. Sherwood Road is designed for 2,500 vehicle trips per day and is
serving approximately 10,000 vehicle trips per day. A Second Access Road to Brooktrails Township
and the surrounding area needs to be established to address current road safety and congestion
issues and improve circulation for the area in order to accommodate the current population level
and ultimate buildout of Brooktrails Township.
12. The District provides structural fire protection, suppression, and prevention, first responder for
emergency medical services and hazardous materials incidents, and rescue/extrication. The District
Fire Department is staffed by a full-time Fire Chief and a full-time Fire Prevention Officer/Battalion
Chief and fifteen Volunteer Firefighters. The current staffing level is adequate to deliver services.
13. The District operates two fire stations including the main two-bay fire station located at 24680 Birch
Street and a second single-bay fire station located in the Spring Creek area at the intersection of
Ridge Road and Blue Lake Road. The District owns and maintains multiple fire engines and
emergency response vehicles. The current fire stations and fire protection fleet are adequate to
deliver services.
14. The District responds to an average of 244 fire protection and emergency medical service calls per
year and the average response time is less than nine minutes for Brooktrails Township and less than
fifteen-minutes in Spring Creek and Sylvandale. Brooktrails Township has an ISO rating of 4 and
Spring Creek and Sylvandale have an ISO rating of 4X.
15. Water for fire suppression includes a 2,000-gallon water tender, on-board tanks on fire engines, and
other water supplies available for drafting such as lakes, ponds, rivers, and water tanks with fire
department hook-ups on private property. In addition, water is available in Brooktrails Township
from the District’s water system via 256 fire hydrants, in Spring Creek subdivision from a community
water storage tank, and in Sylvandale subdivision from private water sources.
16. The District has adequate capacity to serve current demand for fire protection services and assist
CAL FIRE and adjacent fire districts through mutual aid services and dispatched services calls.
17. There are no significant water, wastewater, or fire protection capacity issues or major infrastructure
needs for the District that need to be addressed within the timeframe of this MSR.
3.7.1.4 Financial Ability of Agency
Financial ability of agencies to provide services
18. The District prepares an annual Budget and has annual Independent Financial Audits prepared by a
qualified Certified Public Accountant. The District shall provide LAFCo a complete copy of all future
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MSR/SOI Update | Brooktrails Township CSD
financial audit reports (starting with Fiscal Year 2018-19) prepared by a Certified Public Accountant
within 12-months of the end of the fiscal year or years under examination consistent with the
timeframes established by Government Code Section 26909(a)(2)(b)(ii) as amended by SB 448.
19. According to audited financial information from Fiscal Years 2014-15, 2015-016, and 2016-17, the
District generally operates at a net income or revenue gain to sufficiently cover operating costs and
maintains a sufficient fund balance to protect against unexpected costs. This indicates that under
the current level of service delivery, the District is able to meet its ongoing financial obligations. The
District has adequate finances to meet current and future demands for public services within the
next five years.
20. The District’s enterprise services are currently operating at a net income or revenue gain. In FY
2015-16, there was a significant reduction in expenses of the Wastewater Fund from the prior fiscal
year related to approximately $813,000 in legal fees, deferred, and withheld contract costs related
to the settlement agreement reached in FY 2014-15 between the District and the City of Willits.
21. As of June 30, 2017, the District’s cash and cash equivalents balance was $30 ,5 9 for governmental
activities, $722,592 for water enterprise activities, and $611,255 for wastewater enterprise
activities.
22. On June 3, 2014, the voters in the District approved Measure K to increase the Special Fire Tax by
$34 a year from the existing $65 per single-family residential parcel tax.
23. The District does not have a Capital Improvement Plan; however, the District defines capital
improvement priorities on a five-year basis in the annual budget process.
3.7.1.5 Shared Facilities
Status of, and opportunities for, shared facilities
24. The District provides wastewater collection services and receives wastewater treatment and
disposal services from the City of Willits by agreement.
25. The District contracts with Solid Wastes of Willits, Inc. for collection, transportation, disposal, and
recycling of garbage, refuse, and rubbish.
26. The District participates in the Special District Risk Management Association for the purpose of
providing liability, workers compensation for its facilities, operations, and employees. Health
insurance is provided by the Association of California Water Agencies Joint Powers Insurance
Authority for District employees and their dependents.
27. Dispatch services are provided by the CAL FIRE Emergency Communications Command Center (ECC)
at the Howard Forest Station near Willits.
28. The District participates in Zone 1 of the Mendocino Countywide Mutual Aid System and works
closely with the Little Lake Fire Protection District and CAL FIRE.
29. The District and the Little Lake Fire Protection District maintain a joint ‘hands-on’ training program
for volunteer firefighters in cooperation with the Mendocino County Fire Academy.
30. There are no additional opportunities for the District to achieve management or operational
efficiencies identified during the preparation of this MSR.
3.7.1.6 Accountability, Structure, and Operational Efficiencies
Accountability for community service needs, including governmental structure and operational
efficiencies
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31. The District is governed by a five-member Board of Directors elected to serve 4-year terms.
Constituents of the District are well represented by the fully seated and elected governing body.
Several of the Board members have served the District for multiple consecutive terms which can be
a significant benefit in establishing long-standing positive working relationships in the community,
understanding the history and unique aspects of the organization, and maintaining institutional
knowledge.
32. Regularly scheduled Board meetings are held on the second and fourth Tuesday of the month, with
the exception of August, November, and December when the Board meets on the first Tuesday only,
starting at 7:00 p.m. at the Brooktrails Community Center located at 24850 Birch Street in
Brooktrails Township. All meetings are open to the public and are publicly posted a minimum of 72
hours prior to the meeting in accordance with the Brown Act.
33. The District Board of Directors conducts business and takes action by approving motions and
adopting resolutions and ordinances by a majority vote of a sufficient quorum. The District Board of
Directors has adopted policies and procedures related to elected officials including conflict of
interest and reimbursement, finances, and personnel. The District Board members file a Statement
of Economic Interests (Fair Political Practices Commission Form 700) each year pursuant to
Government Code §87203 of the Political Reform Act and receive two hours of training on public
service ethics laws and principles at least once every two years pursuant to AB 1234. The District
Board of Directors considers proposed increases to rates and fees at a properly noticed Public
Hearing and subject to mailing a Notice of Hearing for Protests to all property owners pursuant to
Proposition 218. The District complies with local government ethics laws and regulations and
operates with accountability and transparency.
34. The District maintains a website, at the following site http://www.btcsd.org/, which is a helpful
communication tool to enhance government transparency and accountability. The District’s website
is in the process of being updated and includes well organized and extensive information.
35. The District is comprised of five budgetary departmental units organized by function or service
including Water, Wastewater, Fire Protective and Emergency Medical Services, Parks and
Recreation, and General Government. District personnel include full-time and part-time employees
for a total staffing level of 11 Full Time Equivalent (FTE) positions. A second Account Clerk/Secretary
position has remained vacant for several years and will be filled Spring 2019. The District also
maintains part-time professional services contracts with an Attorney for General Legal Counsel and
an Architect for Planning and Design Review.
36. The public can submit written or provide verbal comments or complaints in person or by phone at
the District office during business hours, Monday through Friday from 8:00 a.m. to 5:00 p.m., or at
the District Board of Directors meetings during the general public comment period.
3.7.1.7 Other Service Delivery Matters
Any other matter related to effective or efficient service delivery, as required by commission policy
37. There are no other matters related to service delivery required by Mendocino LAFCo Policy.
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4 SPHERE OF INFLUENCE
LAFCo prepares a Municipal Service Review (MSR) prior to or in conjunction with the Sphere of Influence
(SOI) Update process. An SOI Update considers whether a change to the SOI, or probable future
boundary, of a local government agency is warranted to plan the logical and orderly development of
that agency in a manner that supports CKH Law and the Policies of the Commission. The MSR and
required determinations are presented in Chapters 2 and 3 of this document and form the basis of
information and analysis for this SOI Update. This chapter presents the SOI Update and required
determinations pursuant to California Government Code §56425(e) for Brooktrails Township Community
Services District.
4.1 SOI UPDATE
4.1.1 EXISTING SPHERE OF INFLUENCE
The Sphere of Influence (SOI) for Brooktrails Township CSD is coterminous (identical to) with the District
boundary and was established by LAFCo on December 6, 2010 (LAFCo Resolution No. 2010-04). There
have been no changes to the District boundary or SOI since then. (LAFCo, 2010)
4.1.2 STUDY AREAS
4.1.2.1 Lower Sherwood Road
There is a small area accessed from Sherwood Road and located directly southeast of the District and in
between the District and City of Willits boundaries. This area is not within the boundary of a local fire
protection agency and receives fire protection and emergency medical services from CAL FIRE when
staffed and from the District and the Little Lake Fire Protection District (LLFPD) when dispatched.
4.1.2.2 The Gates
There is a large area accessed from First Gate, Second Gate, and Third Gate Roads and located directly
northeast of the District and in between the District and LLFPD boundaries. This area is mostly not
within the boundary of a local fire protection agency and receives fire protection and emergency
medical services from CAL FIRE when staffed and from the District and LLFPD when dispatched. The
District is the first to respond to fire service calls in this unserved area since LLFPD must travel through
the District to respond to this area.
4.1.2.3 Upper Sherwood Road
There is a large area accessed from Sherwood Road and located directly north of the District and in
between the District boundary and the intersection of Highway 101 and Sherwood Road. This area is not
within the boundary of a local fire protection agency and receives fire protection and emergency
medical services from CAL FIRE when staffed and from the District when dispatched.
4.1.2.4 Willits Airport
The Willits Municipal Airport is accessed from Poppy Drive and located east of the District. The District
provides water and wastewater services to this property per a longstanding agreement with the City of
Willits. This area is not within the boundary of a local fire protection agency and receives fire protection
and emergency medical services from CAL FIRE when staffed and from the District when dispatched.
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MSR/SOI Update | Brooktrails Township CSD
4.1.3 AREA OF INTEREST DESIGNATION
LAFCo’s Area of Interest Policy, per Section 10.1.12, provides for the designation or identification of
unincorporated areas located near to, but outside the jurisdictional boundary and established SOI of a
city or district, in which land use decisions or other governmental actions of another local agency
directly or indirectly impact the subject local agency.
An Area of Interest (AOI) designation serves as a compromise approach that recognizes situations
involving challenging boundary or municipal service delivery considerations, or for which urbanization
may be anticipated in the intermediate or long range planning horizons. It is a tool intended to enhance
communication and coordination between local agencies.
An AOI designation is most helpful when the county and city or district can reach agreement that
development plans related to LAFCo designated Areas of Interest will be treated the same as if these
areas were within the city or district SOI boundary regarding notification to and consideration of input
from the city or district.
The four SOI Study Areas described above have been designated as an AOI as shown on Figure 1-1.
These areas are identified on the District’s Sphere map to further emphasize and support the District in
requesting consideration from the City of Willits and County of Mendocino regarding discretionary land
use entitlements or other development plans with the potential to impact District lands, facilities,
and/or services.
4.1.4 PROPOSED SOI CHANGES
The District has confirmed the adequacy of their existing District boundary and SOI. The coterminous SOI
is appropriate given the District’s current operating level. There are no proposed SOI changes for the
Brooktrails Township CSD. (BTCSD, 2018)
4.1.5 CONSISTENCY WITH LAFCO POLICIES
The District is comprised of a planned residential community with 2,500-acres of protected open space
and two rural residential subdivisions. Maintaining the existing District SOI is consistent with Mendocino
LAFCo Policies (refer to Section 1.5 for the specific SOI policies).
4.1.6 DETERMINATIONS
It is recommended that the Commission affirm the existing Sphere of Influence for Brooktrails Township
Community Services District that is coterminous with the District boundary and establish service-specific
spheres for Brooktrails Township (all services), Spring Creek (water and fire), and Sylvandale (fire)
subdivisions consistent with Figure 1-1. The following statements have been prepared in support of this
recommendation.
4.1.6.1 Land Uses
The present and planned land uses in the area, including agricultural and open space lands
Brooktrails Township is comprised of a semi-rural residential community, a 2,500-acre greenbelt area for
open space and recreation, public facilities to support the community, and community-oriented
commercial uses. The District boundary is also comprised of two adjacent rural residential subdivisions
zoned U-R Upland Residential (low-density agricultural/residential uses). The areas adjacent to the
District boundary are zoned R-L Rangeland, T-P Timberland Production, S-R Suburban Residential, and U-
R Upland Residential and existing development is primarily residential and also includes the Ells Field
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MSR/SOI Update | Brooktrails Township CSD
Airport and Sherwood Valley Rancheria. Mendocino County has land use authority over privately-owned
lands within the District boundary and makes land-use decisions based on the County’s Brooktrails
Township Specific Plan, Inland General Plan, and Zoning Regulations.
4.1.6.2 Need for Facilities and Services
The present and probable need for public facilities and services in the area
The District provides a wide range of municipal services including Planning and Design Review, Parks and
Recreation, Fire Protection and Emergency Medical Services, Water, and Wastewater. The Brooktrails
Township CSD is estimated to serve a population of approximately 3,500 residents, including Spring
Creek and Sylvandale. Population growth is expected to increase at an annual rate of approximately
0.5% for Mendocino County. Based on this growth rate, the District can expect a small population
increase of 175 people within the next five years. It is anticipated that the District will experience very
limited growth until constraints related to infrastructure needs are sufficiently addressed. The residents
and visitors currently receiving services from the District will continue to need these public services.
4.1.6.3 Capacity of Facilities and Adequacy of Services
The present capacity of public facilities and adequacy of public services that the agency provides or is
authorized to provide
As determined in the MSR prepared for the District, the Brooktrails Township CSD has adequate
personnel, finances, facilities, and equipment to meet current and future demands for public services
within the next five years.
4.1.6.4 Communities of Interest
The existence of any social or economic communities of interest in the area if the commission
determines that they are relevant to the agency
No social or economic communities of interest have been identified that should be included in the
Brooktrails Township CSD boundary or SOI. There are four SOI Study Areas that have been designated as
an Area of Interest, including Lower Sherwood Road, Upper Sherwood Road, The Gates subdivisions, and
Willits Airport. These areas have been identified to assist the District in requesting consideration from
the City of Willits and Mendocino County for discretionary land use entitlements or other development
plans with the potential to impact District lands, facilities, and/or services.
4.1.6.5 Disadvantaged Unincorporated Communities
The present and probable need for those public facilities and services of any disadvantaged
unincorporated communities within the existing sphere of influence
Brooktrails CDP has an MHI of $49,420 and qualifies as a DUC. Block Group 2, Census Tract 106, has an
MHI of $45,670 and qualifies as a DUC. The areas surrounding Brooktrails CDP and Block Group 2 may
also qualify as a DUC. Special consideration will be given to any DUCs affected by future annexation
proposals consistent with GC §56375(8)(A) and LAFCo Policy.
Chapter 4 – Sphere of Influence Page 4-3
MSR/SOI Update | Brooktrails Township CSD
5 REFERENCES
Ballotpedia: A digital encyclopedia of American politics and elections. 2014. Brooktrails Township
Community Services District Special Fire Tax Increase, Measure K (June 2014). [Online]. Available at:
https://ballotpedia.org/Brooktrails_Township_Community_Services_District_Special_Fire_Tax_Incre
ase,_Measure_K_(June_2014). Accessed March 22, 2019.
Board of Supervisors, County of Mendocino (BOS). January 23, 2018. Meeting Agenda Item 4c,
Attachment A- Corrected Footnote. [Online]. Available at:
https://mendocino.legistar.com/Calendar.aspx. Accessed January 26, 2018.
Brooktrails Township Community Services District (BTCSD). April, May, June, July 2019. District Response
to Information Request from the Local Agency Formation Commission of Mendocino County in
preparation for the Municipal Service Review and Sphere of Influence Update.
Brooktrails Township Community Services District (BTCSD). February 4, 2018. District Response to
Information Request from the Local Agency Formation Commission of Mendocino County in
preparation for the Municipal Service Review and Sphere of Influence Update.
Brooktrails Township Community Services District (BTCSD). No date (n.d.). Brooktrails Township
Community Services District website. [Online] Available at: http://www.btcsd.org/. Accessed
November 12, 2018.
California Department of Transportation (DOT). 2017. Mendocino County Economic Forecast. [Online].
Available at:
http://www.dot.ca.gov/hq/tpp/offices/eab/socio_economic_files/2017/Mendocino.pdf. Accessed
December 10, 2018.
KOA Corporation. September 15, 2009. Brooktrails Second Access Feasibility Study. [Online]. Available
at: http://www.btcsd.org/specific/access/pdf2/btcsd_final_report_9_15_09.pdf-rev2.pdf. Accessed
October 16, 2018.
LAFCo, County of Mendocino. June 3, 2019. Commission Meeting Agenda Item 6a: Public Workshop for
Brooktrails Township Community Services District Draft Municipal Service Review and Sphere of
Influence Update. [Online]. Available at: https://www.youtube.com/watch?v=tSRDrqxm-
h0&list=PLraKTU7AyZLQSWrivynWsfVnleKBpqK-f&index=5&t=0s. Accessed June 3, 2019.
LAFCo, County of Mendocino. May 6, 2019. City of Willits Municipal Service Review and Sphere of
Influence Update. [Online]. Available at: http://mendolafco.org/wp-content/uploads/2019/05/2019-
5-6-Willits-MSR-SOI-Adopted.pdf. Accessed May 24, 2019.
LAFCo, County of Mendocino. November 5, 2018. Policies & Procedures Manual. [Online]. Available at:
http://mendolafco.org/wp-content/uploads/2018/11/FINAL-Adopted-Mendo-LAFCo-PP-Manual-
2018-1.pdf. Accessed December 13, 2018.
Chapter 5 – References Page 5-1
MSR/SOI Update | Brooktrails Township CSD
LAFCo, County of Mendocino. October, 2010. Brooktrails Municipal Service Review. [Online]. Available
at: http://mendolafco.org/msr/brooktrails_msr.pdf. Accessed October 16, 2018.
Mendocino, County of. June 19, 2018. County of Mendocino State of California FY 2018-19 Adopted
Budget. [Online]. Available at: https://www.mendocinocounty.org/home/showdocument?id=23646.
Accessed December 13, 2018.
Mendocino, County of. 2004. Brooktrails Township Specific Plan. [Online]. Available at:
https://www.mendocinocounty.org/government/planning-building-services/plans/brooktrails-
township-specific-plan. Accessed October 10, 2018.
Mendocino, County of. No date (n.d.). Property Tax Information County of Mendocino Offices of
Assessor, Tax Collector & Auditor. [Online]. Available at:
https://www.mendocinocounty.org/home/showdocument?id=622. Accessed June 12, 2019.
Mendocino County Fire Chief’s Association (MCFCA). 2015. Mendocino County Community Wildfire
Protection Plan. [Online]. Available at:
https://www.co.mendocino.ca.us/bos/meetings/28658/28666/28667/28988/29050/ProtectionPlan
29050.pdf. Accessed June 28, 2017.
Moss, Levy & Hartzheim, LLP (MLH). April 30, 2018. City of Willits Annual Financial Report Fiscal Year
Ended June 30, 2017. Culver City, California.
National Fire Protection Association (NFPA). 2010. NFPA 1720 Standard for the Organization and
Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operations
to the Public by Volunteer Fire Departments, 2010 Edition. [Online]. Available at:
https://www.nfpa.org/Codes-and-Standards/ARCHIVED/Safer-Act-Grant/NFPA-1720. Accessed April
10, 2018.
State Water Resources Control Board (SWRCB). 2014a. State Water Board Drought Year Water Actions,
Public Water Systems Curtailment Compliance Orders - October 2014. [Online]. Available at:
https://www.waterboards.ca.gov/waterrights/water_issues/programs/drought/curtailment_compli
ance_orders.shtml. Accessed March 29, 2019.
State Water Resources Control Board (SWRCB). October 17, 2014b. Brooktrails Township Community
Services District Water System ID #2310009 Compliance Order No. 02_03_14R_002. [Online].
Available at:
https://www.waterboards.ca.gov/waterrights/water_issues/programs/drought/docs/curtailment_c
ompliance/brookstrails_township_csd.pdf. Accessed October 24, 2017.
Terry E. Krieg, CPA (TK). April 20, 2019. Brooktrails Township Community Services District Basic Financial
Statements June 30, 2018. Santa Rosa, California.
Terry E. Krieg, CPA (TK). March 1, 2018. Brooktrails Township Community Services District Basic Financial
Statements June 30, 2017. Santa Rosa, California.
Terry E. Krieg, CPA (TK). January 7, 2017. Brooktrails Township Community Services District Basic
Financial Statements June 30, 2016. Santa Rosa, California.
Chapter 5 – References Page 5-2
MSR/SOI Update | Brooktrails Township CSD
Terry E. Krieg, CPA (TK). January 31, 2016. Brooktrails Township Community Services District Basic
Financial Statements June 30, 2015. Santa Rosa, California.
The Press Democrat. 2012. At Mendocino County's Brooktrails, owners abandon lots, skip fees. [Online].
Available at: https://www.pressdemocrat.com/news/2316896-181/at-mendocino-countys-
brooktrails-owners. Accessed October 16, 2018.
U.S. Census Bureau (USCB). December 6, 2018a. American Fact Finder Community Facts. [Online].
Available at: https://factfinder.census.gov/faces/nav/jsf/pages/community_facts.xhtml. Accessed
March 27, 2019.
U.S. Census Bureau (USCB). December 6, 2018b. American Fact Finder Download Center. [Online].
Available at: https://factfinder.census.gov/faces/nav/jsf/pages/download_center.xhtml. Accessed
March 27, 2019.
Chapter 5 – References Page 5-3
MSR/SOI Update | Brooktrails Township CSD
6 ACRONYMS
AF Acre-feet
BTCSD Brooktrails Township Community Services District
CEQA California Environmental Quality Act
CKH Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000
CSD Community Services District
FY Fiscal Year
GPM gallons per minute
LAFCo Local Agency Formation Commission
LLFPD Little Lake Fire Protection District
MG million gallons
MGD million gallons per day
MSR Municipal Service Review
SOI Sphere of Influence
WTP Water Treatment Plant
WWTP Wastewater Treatment Plant
Chapter 6 – Acronyms Page 6-1
MSR/SOI Update | Brooktrails Township CSD
7 ACKNOWLEDGEMENTS
7.1 REPORT PREPARATION
This Municipal Service Review and Sphere of Influence Update was prepared by Hinman & Associates
Consulting, Inc., contracted staff for Mendocino LAFCo.
Uma Hinman, LAFCo Executive Officer
Larkyn Feiler, LAFCo Analyst
Beth Salomone, LAFCo Commission Clerk
7.2 ASSISTANCE AND SUPPORT
This Municipal Service Review and Sphere of Influence Update could not have been completed without
the assistance and support from the following organizations and individuals.
Tamara Alaniz, current General Manager
Brooktrails Township CSD
Denise Rose, former General Manager
Chapter 7 – Acknowledgements Page 7-1
MSR/SOI Update | Brooktrails Township CSD
8 APPENDICES
8.1 APPENDIX A – OPEN GOVERNMENT RESOURCES
The purpose of this appendix is to provide a brief list of some educational resources for local agencies
interested in learning more about the broad scope of public interest laws geared towards government
transparency and accountability. This appendix is not intended to be a comprehensive reference list or
to substitute legal advice from a qualified attorney. Feel free to contact the Mendocino LAFCo office at
(707) 463-4470 to make suggestions of additional resources that could be added to this appendix.
The websites listed below provide information regarding the following open government laws: (1) Public
Records Act (Government Code §6250 et seq.), (2) Political Reform Act – Conflict-of-Interest regulations
(Government Code §81000 et seq.), (3) Ethics Principles and Training (AB 1234 and Government Code
§53235), (4) Brown Act – Open Meeting regulations (Government Code §54950 et seq.), and (5) Online
Compliance regulations (Section 508 of the US Rehabilitation Act and Government Code §11135).
o Refer to the State of California Attorney General website for information regarding public access
to governmental information and processes at the following link:
https://oag.ca.gov/government.
o Refer to the State of California Attorney General website for information regarding Ethics
Training Courses required pursuant to AB 1234 at the following link: https://oag.ca.gov/ethics.
o The Fair Political Practices Commission (FPPC) is primarily responsible for administering and
enforcing the Political Reform Act. The website for the Fair Political Practices Commission is
available at the following link: http://www.fppc.ca.gov/.
o Refer to the California Department of Rehabilitation website for information regarding Section
508 of the US Rehabilitation Act and other laws that address digital accessibility at the following
link: http://www.dor.ca.gov/DisabilityAccessInfo/What-are-the-Laws-that-Cover-Digital-
Accessibility.html.
o Refer to the Institute for Local Government (ILG) website to download the Good Governance
Checklist form at the following link: www.ca-ilg.org/post/good-governance-checklist-good-and-
better-practices.
o Refer to the Institute for Local Government (ILG) website to download the Ethics Law Principles
for Public Servants pamphlet at the following link: www.ca-ilg.org/node/3369.
o Refer to the Institute for Local Government (ILG) website for information regarding Ethics
Training Courses required pursuant to AB 1234 at the following link: http://www.ca-
ilg.org/ethics-education-ab-1234-training.
o Refer to the California Special Districts Association (CSDA) website for information regarding
online and website compliance webinars at the following link:
http://www.csda.net/tag/webinars/.
Chapter 8 – Appendices Page 8-1
MSR/SOI Update | Brooktrails Township CSD
8.2 APPENDIX B – WEBSITE COMPLIANCE HANDOUT
Refer to the next page.
Chapter 8 – Appendices Page 8-2
California Website
Compliance Checklist
Use this checklist to keep your district's website compliant with
State and Federal requirements.
Public Records Act
SB 929 SB 272 AB 2853 (optional):
Our district has created and Our Enterprise System Catalog is We post public records to our
maintains a website posted on our website website
Passed in 2018, all independent special All local agencies must publish a catalog This bill allows you to refer PRA requests
districts must have a website that listing all software that meets specific to your site, if the content is displayed
includes contact information (and all requirements—free tool at getstream- there, potentially saving time, money,
other requirements) by Jan. 2020 line.com/sb272 and trees
The Brown Act State Controller Reports
AB 392: AB 2257: Financial Transaction Report: Compensation Report:
Agendas are posted to A link to the most recent A link to the Controller’s A link to the Controller’s
our website at least 72 agenda is on our home “By the Numbers” PublicPay website is
hours in advance of page, and agendas are website is posted on posted in a conspicuous
regular meetings, 24 searchable, machine- location on our website
our website
hours in advance of readable and platform
Report must be submitted by
special meetings independent Report must be submitted
April 30 of each year—you
within seven months after the
This 2011 update to the Act, Required by Jan. 2019— close of the fiscal year—you can also add the report to
originally created in 1953, text-based PDFs meet this can add the report to your your site annually, but
added the online posting requirement, Microsoft Word site annually, but posting a posting a link is easier
requirement docs do not link is easier
Healthcare District Section 508 ADA
Websites Open Data Compliance
AB 2019: AB 169: CA gov code 7405:
If we’re a healthcare district, we Anything posted on our website State governmental entities
maintain a website that includes that we call “open data” meets the shall comply with the accessibility
all items above, plus additional requirements for open data requirements of Section 508
requirements of the federal Rehabilitation Act
Defined as “retrievable, downloadable,
of 1973
Including budget, board members, indexable, and electronically searchable;
Municipal Service Review, grant policy platform independent and machine Requirements were updated in 2018—if
and recipients, and audits readable” among other things you aren't sure, you can test your site for
accessibility at achecker.ca
Website compliance made easy
csda.net getstreamline.com
The Brown Act: new agenda requirements
Tips for complying with AB 2257 by January, 2019
Placement:
What it says: An online posting of an agenda shall be posted on the primary Internet Web site
homepage of a city, county, city and county, special district, school district, or political subdivision
established by the state that is accessible through a prominent, direct link to the current agenda.
What that means: Add a link to the current agenda directly to your homepage. It cannot be in a
menu item or otherwise require more than a single click to open the agenda.
Exception:
What it says: A link to the agenda management platform may be added to the home page instead of a
link directly to the current agenda, if the agency uses an integrated agenda management platform that
meets specified requirements, including, among others, that the current agenda is the first agenda
available at the top of the integrated agenda management platform.
What that means: If you use an agenda management system, you may add a link to that system
directly to your homepage (again, not in a menu item), if the format of the agenda meets the
requirements below, and if the current agenda is the first at the top of the list.
Format:
What it says: [agenda must be] Retrievable, downloadable, indexable, and electronically searchable by
commonly used Internet search applications. Platform independent and machine readable. Available
to the public free of charge and without any restriction that would impede the reuse or redistribution of
the agenda.
What that means: You cannot add Word Docs or scanned (image-based) PDFs of your agenda to your
website–Word Docs are not platform independent (the visitor must have Word to read the file), and
scanned PDFs are not searchable. Instead, keep your agenda separate from the packet and follow
these steps:
1. From Word or other document system: Export agenda to PDF
2. Add that agenda to your website (or to your agenda management system), and include a link to
that agenda on your homepage
3. Then, you can print the agenda, add it to your pile of documents for the packet, and scan that
to PDF - just keep the packet separate from the agenda (only the agenda must meet AB 2257)
4. Keep the link on the homepage until the next agenda is available, then update the link
Questions? Contact sloane@getstreamline.com or dillong@csda.net