LAFCO
Covelo CSD, 2021
Read the report at Local Agency Formation Commissions ↗
ADOPTED
(The Press Democrat, 2012)
C
OVELO
C S D
OMMUNITY ERVICES ISTRICT
Municipal Service Review and
Sphere of Influence Update
Prepared for:
MENDOCINO LAFCO
200 South School Street
Ukiah, California 95482
http://www.mendolafco.org/
Workshop: July 12, 2021
Public Hearing: September 13, 2021
Adopted: September 13, 2021
LAFCo Resolution No: 2021-22-01
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MSR/SOI Update | Covelo CSD
TABLE OF CONTENTS
1 INTRODUCTION .......................................................................................................................................... 1-2
1.1 LOCAL AGENCY FORMATION COMMISSION ......................................................................................... 1-2
1.2 MENDOCINO LAFCO ............................................................................................................................ 1-2
1.3 SPHERE OF INFLUENCE ........................................................................................................................ 1-2
1.4 MUNICIPAL SERVICE REVIEW ............................................................................................................... 1-3
1.5 MENDOCINO LAFCO POLICIES ............................................................................................................. 1-3
1.6 SENATE BILL 215 ................................................................................................................................. 1-6
2 AGENCY OVERVIEW .................................................................................................................................... 2-9
2.1 HISTORY ............................................................................................................................................. 2-9
2.1.1 FORMATION .................................................................................................................................................. 2-9
2.1.2 BOUNDARY .................................................................................................................................................... 2-9
2.1.3 SERVICES.......................................................................................................................................................2-12
2.2 GOVERNMENT STRUCTURE ............................................................................................................... 2-13
2.2.1 GOVERNING BODY ........................................................................................................................................2-13
2.2.2 PUBLIC MEETINGS .........................................................................................................................................2-14
2.2.3 STANDING COMMITTEES ...............................................................................................................................2-14
2.2.4 PUBLIC OUTREACH ........................................................................................................................................2-14
2.2.5 COMPLAINTS ................................................................................................................................................2-15
2.2.6 TRANSPARENCY AND ACCOUNTABILITY .........................................................................................................2-15
2.3 OPERATIONAL EFFICIENCY ................................................................................................................ 2-15
2.3.1 MANAGEMENT AND STAFFING ......................................................................................................................2-15
2.3.2 AGENCY PERFORMANCE ................................................................................................................................2-16
2.3.3 REGIONAL AND SERVICE-SPECIFIC PARTICIPATION .........................................................................................2-16
2.3.4 INTERAGENCY COLLABORATION ....................................................................................................................2-17
2.3.5 CONTRACT OR JPA SERVICES..........................................................................................................................2-17
2.3.6 SHARED SERVICES AND FACILITIES .................................................................................................................2-17
2.3.7 ENHANCED SERVICE DELIVERY OPTIONS ........................................................................................................2-17
2.3.8 GOVERNMENT RESTRUCTURE OPTIONS .........................................................................................................2-18
2.4 FINANCES ......................................................................................................................................... 2-18
2.4.1 CURRENT FISCAL HEALTH ..............................................................................................................................2-18
2.4.2 LONG TERM FINANCIAL CONSIDERATIONS .....................................................................................................2-21
2.5 GROWTH .......................................................................................................................................... 2-25
2.5.1 PRESENT AND PLANNED LAND USE AND DEVELOPMENT ................................................................................2-25
2.5.2 EXISTING POPULATION AND PROJECTED GROWTH.........................................................................................2-36
2.6 DISADVANTAGED UNINCORPORATED COMMUNITIES........................................................................ 2-37
3 MUNICIPAL SERVICES ................................................................................................................................. 3-1
3.1 SERVICE OVERVIEW ............................................................................................................................ 3-1
3.1.1 SERVICES........................................................................................................................................................ 3-1
3.1.2 OUT-OF-AGENCY SERVICES ............................................................................................................................. 3-1
3.2 WASTEWATER .................................................................................................................................... 3-1
3.2.1 SERVICE OVERVIEW ........................................................................................................................................ 3-1
3.2.2 COLLECTION SYSTEM ...................................................................................................................................... 3-1
3.2.3 WASTEWATER TREATMENT AND DISPOSAL SERVICES ..................................................................................... 3-1
3.2.4 OPERATIONS AND MAINTENANCE .................................................................................................................. 3-1
3.2.5 SYSTEM CAPACITY .......................................................................................................................................... 3-2
3.2.6 FACILITIES AND ASSETS................................................................................................................................... 3-3
MSR/SOI Update | Covelo CSD
3.3 DETERMINATIONS .............................................................................................................................. 3-4
3.3.1 MSR REVIEW FACTORS ................................................................................................................................... 3-4
4 SPHERE OF INFLUENCE ............................................................................................................................... 4-9
4.1 SOI UPDATE ........................................................................................................................................ 4-9
4.1.1 EXISTING SPHERE OF INFLUENCE .................................................................................................................... 4-9
4.1.2 STUDY AREAS ................................................................................................................................................4-10
4.1.3 AREA OF INTEREST DESIGNATION ..................................................................................................................4-10
4.1.4 PROPOSED SOI CHANGES ..............................................................................................................................4-10
4.1.5 CONSISTENCY WITH LAFCO POLICIES .............................................................................................................4-10
4.1.6 DETERMINATIONS .........................................................................................................................................4-11
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
8.3 APPENDIX C – APPLICABLE POLICIES .................................................................................................... 8-3
LIST OF TABLES
Table 2.1 CCSD Profile ......................................................................................................................................... 2-9
Table 2.2 CCSD Boundary Change History .......................................................................................................... 2-12
Table 2.3 CCSD Board of Directors ..................................................................................................................... 2-13
Table 2.4 CCSD Staffing Levels ........................................................................................................................... 2-16
Table 2.5 CCSD Financial Summary .................................................................................................................... 2-18
Table 2.6 Population Change in Mendocino County and Covelo CSD .................................................................. 2-36
Table 3.1 Summary of Residential Equivalent Units .............................................................................................. 3-2
Table 3.2 Wastewater Flow Data 2015-2019 ........................................................................................................ 3-3
LIST OF FIGURES
Figure 1-1 Covelo CSD Boundary and Sphere of Influence Map ............................................................................ 1-8
Figure 2-1 Round Valley Vicinity Map ................................................................................................................. 2-10
Figure 2-2 Location of Covelo CSD Wastewater Treatment Plant ........................................................................ 2-11
Figure 2-3 Covelo CSD Fiscal Year End June 30, 2020 Balance Sheet ................................................................... 2-22
Figure 2-4 Long-term Debt Activity for FY 2019-20 ............................................................................................. 2-24
Figure 2-5 Covelo CSD Zoning Map .................................................................................................................... 2-27
Figure 2-6 Covelo Community Map .................................................................................................................... 2-28
Figure 2-7 Covelo CSD Parcel Map ..................................................................................................................... 2-32
Figure 2-8 Flood Map for Covelo Area ................................................................................................................ 2-34
Figure 2-9 Housing Element Inventory of Buildable Sites in Covelo Planning Area ............................................... 2-35
Figure 3-1 Map of Collection System .................................................................................................................... 3-1
Figure 3-2 Fixed Assets FYE 2020 ......................................................................................................................... 3-4
MSR/SOI Update | Covelo 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 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
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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.
1.4 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.
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.
1.5 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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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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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 | Covelo 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 (RHNA)
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 | Covelo 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.
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Source: This map was prepared by the Mendocino County Information Services Department GIS Program, May 2021. 200100 0 200 400 600
Note: This map is not a survey product. Feet
MSR/SOI Update | Covelo CSD
2 AGENCY OVERVIEW
Table 2.1 CCSD Profile
Agency Name: Covelo Community Services District
Phone Number: (707) 983-6888
Mailing Address: P.O. Box 65, Covelo, CA 95428
District Office: 23950 Grange Street, Covelo, CA 95428
Website: http://ccsd.roundvalley.org/
General Email: covelocsd@hotmail.com
Date of Formation: April 5, 1960
Agency Type: Independent Special District, Multi-Service Provider
Enabling Legislation: Community Services District Law: Government Code §61000 et seq.
Board Meeting Schedule: 2nd Thursday of the month at 6:00 p.m. at the District Office (Alternate:
2nd Wednesday of the month as needed)
Source: CCSD, 2020a.
2.1 HISTORY
2.1.1 FORMATION
The Covelo Community Services District (Covelo CSD, District, or CCSD) was formed on April 5, 1960 to
protect the health and safety of the Covelo community associated with well water contamination from
private septic systems. (LAFCo, 2010a)
2.1.2 BOUNDARY
The District is located in the northeast region of Mendocino County between the Mendocino National
Forest to the east and the Eel River to the west. The Covelo CSD boundary encompasses approximately
264 acres and includes the central or core portion of the unincorporated community of Covelo within the
greater Round Valley area (see Figure 2-1).
Round Valley is approximately 23 square miles in size and is a north-south trending valley surrounded by
rugged mountains. It is located in the upper Eel River basin above the confluence of the Main Stem Eel
River and the Middle Fork Eel River. Communities within the valley are Covelo, which is located in the
central portion of the valley, and the Round Valley Indian Reservation, which is located in the
northwestern portion of the valley.
Access to the District is from State Highway 162, which traverses northeast from US Highway 101 for
approximately 29 miles. Covelo is located approximately 35 miles northeast of the City of Willits.
Much of the developed area of Covelo is within the District boundary; however, there are many structures
and small parcels adjacent to the District’s boundary. The District’s wastewater treatment plant property
is outside the District boundary and is located southeast of the District (see Figure 2-2).
The District boundaries include some Tribal Lands within the western portion of the District boundaries.
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5/15/2021, 3:16:28 PM 1:72,224
0 0.47 0.95 1.9mi
Incorporated Cities
0 0.75 1.5 3km
Community Services Districts
County Boundary
Sources: Esri, HERE, Garmin, Intermap, increment P Corp., GEBCO, USGS,
FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri
Japan, METI, Esri China (Hong Kong), (c) OpenStreetMap contributors, and
the GIS User Community
Web AppBuilder for ArcGIS
Bureau of Land Management, Esri, HERE, Garmin, INCREMENT P, USGS, METI/NASA, NGA, EPA, USDA |
MSR/SOI Update | Covelo CSD
Figure 2-2 Location of Covelo CSD Wastewater Treatment Plant
Source: Mendocino County, 2021.
Chapter 2 – Agency Overview Page 2-11
MSR/SOI Update | Covelo CSD
2.1.2.1 Boundary Changes
There have been two changes to the District boundary that were approved immediately following
adoption of the 2010 MSR/SOI Update, as shown in Table 2.2 below, annexing a total of approximately 62
acres.
Table 2.2 CCSD Boundary Change History
Year File Name Acreage Status LAFCo Reso No.
2010 Travis Annexation 10.14 Completed 2010-02
2010 Covelo Community Services District 52.06 Completed 2010-03
Reorganization 2010
(LAFCo, 2010b and 2010c)
2.1.3 SERVICES
The Covelo CSD is a single-service district providing wastewater services. For more information regarding
this service refer to Chapter 3. For more information regarding other services provided by contract or
agreement refer to Section 2.3.4.
2.1.3.1 Senate Bill 135
The Community Services District (CSD) Principal Act was comprehensively updated by Senate Bill (SB) 135
which took effect January 1, 2006. SB 135 consolidated the provisions for CSDs into a list of 31 services
and facilities and also changed the definition of latent powers.
Under the CSD statutes at the time of District formation, latent powers were those services or powers
authorized by the Principal Act but not designated in the petition for formation.
SB 135 redefined latent powers as those services and facilities authorized by the new CSD Principal Act
that were not provided before January 1, 2006, as determined by LAFCo. Therefore, SB 135 effectively
grandfathered in all services and facilities that CSDs provided before January 1, 2006.
The old CSD Principal Act from 1955 required voter approval of latent powers and predated the statewide
creation of LAFCo in 1963. With SB 135, all powers authorized for CSDs but not being exercised became
latent powers, regardless of the initial formation petition.
2.1.3.2 Active Powers
Consistent with SB 135, on December 29, 2005 LAFCo staff determined that the current services provided
by Covelo CSD were as follows.
1. Collection and treatment of sewage, wastewater, recycled water and storm water in the same manner
as a Sanitary District with a plant located at 76001 Covelo Road.
The 2010 MSR/SOI study prepared for the District reaffirmed the above list of active powers. There have
been no changes to the District’s active powers since that time.
(LAFCo, 2010a)
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MSR/SOI Update | Covelo CSD
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 2.3). In 2018, the District requested to consolidate elections and was
approved by the County of Mendocino Board and Elections Office to move its elections to align with the
General Election cycle, automatically extending the current terms of sitting Directors by one year. Board
elections will now be held in even numbered years starting in 2024. (CCSD, 2019)
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 of Board vacancies, or if the number of filed
candidates is equal to the number of Board vacancies, then District Board members may be appointed in
lieu of election by the County Board of Supervisors per Elections Code §10515. New Board members take
office at noon on the first Friday in December following their election. (County of Mendocino, 2019)
Government Code §1780-1782 governs the process for appointment of Board of Director seats vacated
prior to the scheduled term expiration date. The District Board of Directors has 60 days to appoint an
interested and qualified individual to a vacant seat if proper notice requirements have been met. If the
District cannot fill the seat within the 60-day period, the Mendocino County Board of Supervisors can
appoint a Director to the District Board during a 30-day period following the initial 60-day period. If the
vacant seat is not filled during the total 90-day period, the vacant seat remains empty until the next
election.
The District Board of Directors elects Officers annually at the January regular meeting. Officers include a
Chair and Vice-Chair elected and served by Board members, and a Treasurer and Secretary appointed by
the Board and served by District staff. The Board may create additional offices and elect Board members
to fill those offices, provided that no Board member holds more than one office. District Board members
do not receive compensation for their public service. Staff support for the Board includes a General
Manager and Bookkeeper/Office Manager. The current District Board of Directors is shown in Table 2.3
below.
(CCSD, 2020a)
Table 2.3 CCSD Board of Directors
Serving
Term First Year
Name Office/Position Consecutive
Expiration of Service
Terms
Joseph Gauder Chair Nov. 2024 2005 Yes
Sherrie Lee Vice Chair Nov. 2024 2019 No
Paul Filler Director Nov. 2022 2006 Yes
Vacant Director N/A N/A N/A
Vacant Director N/A N/A N/A
Source: CCSD, 2020a.
Chapter 2 – Agency Overview Page 2-13
MSR/SOI Update | Covelo CSD
The District has difficulty filling vacancies, but has retained two long-term Board members. The last time
the Board had five members was in Fiscal Year 2010-11.
Prior to serving as the District General Manager (since 2017), Dane Downing served on the District Board
of Directors, and was the Chair during the preparation of the 2010 MSR/SOI Update. (LAFCo, 2010a)
2.2.2 PUBLIC MEETINGS
Regularly scheduled meetings for the Board of Directors are held on the second Thursday of the month at
6:00 p.m. at the District Office located at 23950 Grange Street in Covelo. Alternatively, the District Board
meets on the second Wednesday of the month as needed, according to District staff. During the COVID-
19 pandemic, meetings have been held via Zoom for Board members and the public; staff continues to
meet in the office following current health order protocols.
In accordance with the Brown Act, all District Board meetings are open to the public and are publicly
posted a minimum of 72 hours prior to regular meetings, or a minimum of 24 hours prior to special
meetings. Meeting notices are posted outside the District office, at the Covelo Post Office bulletin board,
Round Valley Library Commons bulletin board, and the Keith’s Family Market bulletin board.
The District maintains public notices regarding Board Director vacancies at its office, the Round Valley
Library Commons, Covelo Post Office, and the local radio station provides a “bulletin board” report which
includes the public notice on vacancies.
Public meeting information including past agendas and approved meeting minutes are posted on the
District’s website 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.
2.2.3 STANDING COMMITTEES
Committees may be assigned to assist in carrying out various functions of local government. The District
does not currently have any standing committees (CCSD, 2020a).
2.2.4 PUBLIC OUTREACH
The District has a website at https://ccsd.roundvalley.org , which can be a helpful communication tool to
enhance government transparency and accountability. The District’s website has the District’s contact
information and agendas and minutes from District Board meetings from October 2019 to June 2020. The
website is not current and does not appear to be maintained. (CCSD, n.d.(a))
The District’s website would be enhanced by keeping it current; posting the regular Board meeting
agenda, time, and location; posting the Board member contact information; and 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 website would also benefit from a search
engine prioritization overhaul to improve the website ranking and site traffic, as the website does not
currently appear in Google, Bing, or other searches for “Covelo Community Services District.” The District
should also consider maintaining additional social media outlets, and linking to relevant outside sources
such as the Round Valley Library Commons and Mendocino LAFCo’s website.
With the passage of SB 929, all District’s are required to be established and maintained with specific
information and accessibility requirements; a website compliance handout is provided in Appendix B.
Chapter 2 – Agency Overview Page 2-14
MSR/SOI Update | Covelo CSD
2.2.5 COMPLAINTS
The public can submit written or provide verbal comments or complaints on the District website, in person
or by phone at the District office during business hours, Monday through Friday from 8:00 a.m. to 3:00
p.m., or at the District Board of Directors meetings during the general public comment period. The District
received two complaints in the last two years, each one by individuals regarding suspected violation(s) of
District policies. Each complaint was addressed by conducting on-site visits of the parcels in question. The
District sent letters to the property owners requesting that they abate the violations per District
Ordinances. No complaints were received regarding the District’s conduct of business. (CCSD, 2020a)
2.2.6 TRANSPARENCY AND ACCOUNTABILITY
The District adopted a Policy Handbook at its July 12, 2006 regular Board meeting. The Handbook
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.
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. The District complies with the above requirements (CCSD, 2020a).
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. Although the District does not compensate its Board members, its
directors and staff attend Brown Act/Ethics trainings regularly.
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 District 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 District Manager is the Executive Officer and Treasurer of the District. The responsibilities and specific
duties of the District Manager include the following:
o Management and control of operations and works of the District, subject to the approval of the Board
of Directors.
o Attendance at all meetings of the District’s Board and other meetings as the Board determines
necessary.
o The appointment, supervision, training, evaluation, discipline, and dismissal of the District's
employees, consistent with the employee relations system established by the Board of Directors.
o The day-to-day supervision and leadership of the District's facilities and services.
o Maintenance of good customer service and customer and employee relationships.
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MSR/SOI Update | Covelo CSD
o Supervision of the District's finances, including investing District funds, maintaining the District’s
insurance policies, and formulating budgets for the district.
o Implementation of the policies established by the Board of Directors for the operation of the District.
(CCSD, n.d.(b))
General government services provided under the direction of the District 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 participating in the building permit process,
working with engineers to develop repair and maintenance designs for grant funded projects, grant
development and procurement.
District personnel include full-time and part-time employees for a total staffing level of two Full Time
Equivalent (FTE) positions. Table 2.4 shows District staffing levels by personnel groups. The District has
one full-time position and two part-time employees as follows: one General Manager (full-time), one
Bookkeeper/Office Manager (part-time), and one Plant Operator/Collection Manager (part-time). In
addition, the District employs a contract Certified Public Accountant (CPA) and legal counsel on an annual
basis. As needed the District also enters into contracts with engineers, construction contractors,
construction monitors, and others.
(CCSD, 2020a)
Table 2.4 CCSD Staffing Levels
Personnel Groups FTE
General Manager 1.0
Bookkeeping/Office Manager 0.5
Plant Operator/Collection
System Manager 0.5
Total 2.0
Source: CCSD, 2020a.
2.3.2 AGENCY PERFORMANCE
A component of monitoring agency performance is routinely evaluating staff productivity. The District
conducts organizational assessments and staff reviews annually upon negotiating the Employee
Agreements, which are finalized before the final budget is approved each fiscal year. The General Manager
also tracks non-salaried employee workload through bi-weekly timesheets. Employee workload
assessments are conducted at times daily to aid and support the proper functioning of the District.
The District has Board of Director oversight and provides input and suggestions deemed to improve daily
operations of the District. The General Manager also has authority to modify operations to increase
efficiency and safety. (CCSD, 2020a)
2.3.3 REGIONAL AND SERVICE-SPECIFIC PARTICIPATION
The District participates in the following regional and service-specific associations and organizations:
o The District General Manager participates in the California Special Districts Association.
o The District General Manager participates in the Special District Risk Management Authority.
Chapter 2 – Agency Overview Page 2-16
MSR/SOI Update | Covelo CSD
(CCSD, 2020a)
2.3.4 INTERAGENCY COLLABORATION
Below are examples of the District’s interagency collaborative arrangements:
o The District collaborates with other public agencies by sharing the office and Board meeting location
with the Round Valley County Water District (RVCWD).
o The District is developing a Memorandum of Understanding (MOU) with the RVCWD to share office
space with the Round Valley Area Municipal Advisory Council (RVMAC) for document storage.
o The District participates in the Special District Risk Management Association (SDRMA) for the purpose
of pooled insurance for providing liability, workers compensation for its facilities, operations, and
employees.
(CCSD, 2020a)
2.3.5 CONTRACT OR JPA SERVICES
No similar municipal services are provided to District residents by other public agencies or non-profit
organizations through agreements or Joint Powers Authority (JPA), or by private businesses through
service contracts.
2.3.6 SHARED SERVICES AND FACILITIES
Other than sharing office space with the RVCWD and RVMAC as described above, the District does not
have agreement with other local agencies to jointly provide public services or jointly own, manage, or
fund public facilities.
2.3.7 ENHANCED SERVICE DELIVERY OPTIONS
The District is the only agency providing wastewater services to the Covelo community, which primarily
covers the Covelo core area. The Round Valley Indian Tribes (RVIT) own and operate its own wastewater
facility to the north of Covelo that serves Tribal lands and development.
The County of Mendocino provides law enforcement, code enforcement, transportation, and stormwater
collection services within the District. RVCWD provides flood control and stream restoration services to
landowners in the Round Valley watershed. Firefighting and prevention services are provided by the
Covelo Fire Protection District. There is no water purveyor in the Covelo/Round Valley area. Ambulance
service in the Covelo and the greater Round Valley area are provided by Medstar Ambulance and by the
Covelo Fire Protection District. Additionally, the County of Mendocino is in the process of establishing an
Exclusive Operating Area contract for ambulance services covering the inland area of Mendocino County
including Covelo. There is no redundancy in the provision of municipal services to the District.
As a CSD, the District has the opportunity to provide additional municipal services upon activation of latent
powers through Mendocino LAFCo. Given the recent establishment of the RVMAC and the issues
identified in the Covelo area, there may be opportunity for the District to serve as a vehicle for achieving
some of the goals that are otherwise unattainable in such a rural, unincorporated area.
No new opportunities for the District to achieve organizational or operational efficiencies were identified
during the preparation of this MSR.
Chapter 2 – Agency Overview Page 2-17
MSR/SOI Update | Covelo CSD
2.3.8 GOVERNMENT RESTRUCTURE OPTIONS
Government restructure options should be pursued if there are potential benefits in terms of reduced
costs, greater efficiency, better accountability or representation, or other advantages to the public. There
is no recommendation for a reorganization of local municipal service providers in the area at this time.
2.4 FINANCES
The District’s financial resources are accounted for in different funds based on organizational units such
as programs, functions, and services. The District’s governmental activities, including administration,
finance, and planning, are accounted for in governmental funds. The District has one type of fund, the
Proprietary Fund, which is an enterprise fund that reports the business-type operations, but provides
more detail and additional information such as cash flows. The cost of providing enterprise services is
intended to be recovered through sewer fees. (Robertson, 2019)
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. The District also has annually audited financial statements prepared by a CPA which serves as
financial assurance for the use of public funds. This section includes District financial information for Fiscal
Year (FY) 2015-16, 2016-17, 2017-18, and 2018-19, and highlights specific revenue sources and long-term
financial considerations.
The following table (Table 2.5) provides year-end (not budget) financial information for the District. This
table summarizes the Statement of Revenues, Expenses, and Changes in Fund Net Position prepared by
Robertson & Associates, CPAs. The financial information in the table below represents the short-term
financial standing of the District based on reporting annual income, expenses, and profits/losses using the
accrual basis of accounting, which is an accounting method where revenue or expenses are recorded
when a transaction occurs rather than when payment is received or made.
Table 2.5 CCSD Financial Summary
FY 15-16 FY 16-17 FY 17-18 FY 18-19
Beginning Net Position $3,101,344 $3,018,013 $2,872,182 $2,668,820
Prior Period Adjustments $0 $0 $0 $110,463
Ending Net Position $3,018,013 $2,872,182 $2,779,283 $2,569,942
Operating Revenues
Sewer Fees $211,300 $205,640 $268,515 $269,495
Other operating revenue $9,578 $9,707 $13,133 $19,318
Total Operating Revenues $220,878 $215,347 $281,648 $288,813
Operating Expenses
Salaries $70,645 $82,582 $105,883 $122,673
Casual labor $195 $642 $611 $516
Chapter 2 – Agency Overview Page 2-18
MSR/SOI Update | Covelo CSD
Table 2.5 CCSD Financial Summary
FY 15-16 FY 16-17 FY 17-18 FY 18-19
Employee benefits $8,021 $18,353 $21,380 $21,751
Payroll taxes $6,141 $7,684 $9,704 $13,465
Professional services $12,813 $14,240 $14,569 $12,425
Vehicle expenses $2,366 $3,284 $1,059 $3,221
Insurance $8,248 $8,371 $9,429 $10,540
Supplies $4,926 $6,386 $12,117 $,6236
Licenses and fees $7,497 $7,959 $7,104 $8,529
Maintenance $3,768 $2,453 $6,033 $8,847
Monitoring $9,614 $22,501 $12,371 $6,709
Utilities $26,266 $31,759 $22,683 $30,713
Office expenses $3,581 $12,873 $6,118 $5,197
Equipment $528 $1,694 $6,450 $1,825
Depreciation expense ($114,204) ($114,256) ($110,305) ($112,282)
Other expenses $1 $1,119 $4,088 $1,442
Total Operating Expenses $278,814 $336,156 $349,904 $363,487
Net Income/(Loss) ($57,936) ($120,809) ($68,256) ($74,674)
Other Non-Operating Revenues (Expenses)
Interest Income $64 $75 $49 $68
Interest Expense ($25,459) ($25,097) ($24,692) ($24,272)
Total Non-Operating Revenue
($25,395) ($25,022) ($24,643) ($24,204)
(Expenses)
Change in Net Position from
($83,331) ($145,831) ($92,899) ($98,878)
Prior FY
Source: Robertson: 2016, 2017, 2018, 2019.
The financial information in the table above involves depreciation expense, which is a method of
spreading the cost of a capital asset over its estimated useful life, as opposed to recognizing the full cost
of a capital asset as an expenditure at the date of acquisition.
The District’s annual financial reports define a capital asset as a fixed asset (land, buildings and
improvements, equipment, and vehicles) with an initial cost greater than $1,000. Additions,
improvements, and other capital outlays that significantly extend the useful life of an asset are also
capitalized. The length of useful life for each asset type is defined in the financial reports (Robertson,
2019).
According to the audited financial information in the table above, the District’s change in net position over
the last four fiscal years has been a decrease, using the depreciation expense method. Although a
decrease in net position signals a weakening in financial position, it does not always indicate a problem.
Refer to Figure 2-3 below 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.
Chapter 2 – Agency Overview Page 2-19
MSR/SOI Update | Covelo CSD
Year-end revenue over expenses is an important measure of an agency’s financial performance during a
fiscal year. When an agency operates at a net income, annual revenue exceeds annual expenses producing
a surplus. When an agency operates at a net loss, annual expenses exceed annual revenue producing a
deficit. When year-end revenue over expenses is compared with the adopted budget, it shows whether
the agency is generating sufficient annual revenue to continue the current level of operations.
If depreciation expense is removed, then the District’s year-end revenue over expenses results in a net
income of $30,873 for FY 2015-16, a net loss of $31,575 for 2016-17, a net income of $17,406 for 2017-
18, and a net income of $13,404 for 2018-19. The general trend of net income 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. Net income or revenue gain also indicates that the District maintains a sufficient
fund balance to protect against unexpected costs and/or build reserves to fund capital improvements and
equipment maintenance.
The District reports that capital improvements and equipment maintenance have been completed at the
Treatment Plant which were funded from the Maintenance Reserve and Capital Reserve accounts and
that were incorrectly identified as expense items funded from the operating budget in Note 2F in the 2016
Audit report. The Auditor agrees with the District’s identification of this accounting error and will take
corrective action in the FY 2019-20 annual audit, which is currently being prepared.
2.4.1.2 Enterprise Activities
The District’s operational type is considered an enterprise activity in that they are financed and operated
in a manner similar to private business operations enterprises where the intent is that the costs (including
depreciation) to provide the wastewater services to the general public are financed or recovered primarily
through user charges. These enterprise activities are 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’s adopted Rates and Fees per Resolution No. 2017-001 is a monthly wastewater rate per
equivalent dwelling unit is $65. (CCSD, 2020b) The District’s enterprise services are currently operating at
a net loss, and the District has indicated that the community cannot, generally speaking, pay more for
services than the current fees. Covelo CDP is a Severely Disadvantaged Community as described in more
detail in Section 2.5.2.
The following resolutions were passed in Fiscal Year 2019-20 regarding fees:
• Resolution 2019-003: “fees” amended the Residential Equivalent Unit Rate Schedule, which
defines how many Residential Equivalent Units (REU) are assessed per category of residential
and non-residential use;
• Resolution 2020-003 Eliminating Vacant Rate Category”;
• RES 2020-004 Established the Capacity Fee per Residential Equivalent Unit”, meaning the fee to
connect to the sewer system; and
• RES 2020-006 “Establishing the Septage Disposal Fee and After-Hours Gate Fee for all Septage
Haulers”
Chapter 2 – Agency Overview Page 2-20
MSR/SOI Update | Covelo CSD
The District is not subject to the Gann Limit or Proposition 4 because it does not receive tax revenues. All
revenues for the District are from user charges, fees, and penalties, as well as interest on the current fund
balance.
2.4.2 LONG TERM FINANCIAL CONSIDERATIONS
2.4.2.1 Reserves, Cash and Equivalents, and Investments
The District has two reserve accounts established for capital replacement and routine maintenance of the
wastewater treatment plant. These accounts are not governed by formal policy or resolution and are
considered unrestricted. (Robertson, 2019)
o Capital Reserve: A capital reserve account in the Proprietary Fund for the purpose of funding any
needed expansion of capital facilities or the acquisition of capital equipment. The Capital Reserve
account has an approximate current balance of $76,700.
o Maintenance Reserve: A maintenance account in the Proprietary Fund provides for maintenance,
repair, and replacement of equipment and/or capital assets. Large infrastructure repairs and
improvements have in the past been funded with grants and loan packages. The Maintenance Reserve
Account has an approximate current balance of $23,400.
(CCSD, 2020a and 2020b)
In addition to these reserve accounts, the District maintains funds within an investment account with the
State of California called the Local Agency Investment Fund (LAIF) the State of California. The LAIF account
currently has approximately $6,700, with interest accruing in the last budget year at $100 annually.
Figure 2-3 shows the District’s Balance Sheet for Fiscal Year End June 20, 2020. (CCSD, 2021)
Chapter 2 – Agency Overview Page 2-21
Covelo Community Services District
10:02 AM
Balance Sheet
06/24/21
Accrual Basis As of June 30, 2020
Jun 30, 20
ASSETS
Current Assets
Checking/Savings
1B 11010 CCSD General Checking 84,906.94
1B 11021 USDA Installment Pmt 10.00
1B 11022 USDA Payment Reserve 38,214.91
1B 11030 LAIF 6,284.04
1B 11070 Community Foundation (Community Foundation Grant 2019 $8,000) 8,000.00
1B 11080-Maintenance 21,873.88
1B 11090-Capital (Savings account) 76,760.05
Covelo Community Services Distr -5.00
Total Checking/Savings 236,044.82
Accounts Receivable
3R 11050 Accounts Receivable 60,453.85
Total Accounts Receivable 60,453.85
Other Current Assets
1C 11051 A/R Other -0.50
1C 11052 Allow for dbtful accts (Allowance Uncollectible A/R) -1,172.92
1C 11060 Prepaid Insurance 340.36
1C 11062 Other Current Asset 817.33
Total Other Current Assets -15.73
Total Current Assets 296,482.94
Fixed Assets
12000 Land 39,640.00
12050 1960 Sewage Plant 157,496.49
12051 1976 Sewage Plant 843,876.94
12052 Treatment plant upgrade 1,429,563.86
12054 East Lane Sewer Line 25,936.47
12055 Howard/162 Collection Upg 2,288,983.69
12060 Water Wells (Water Wells) 19,076.25
12065 LAFCO Annexation Maps 5,940.50
12090 Equipment 95,333.93
Total Fixed Assets 4,905,848.13
Other Assets
1C 13000 Accumulated Depr -1,804,411.69
Total Other Assets -1,804,411.69
TOTAL ASSETS 3,397,919.38
LIABILITIES & EQUITY
Liabilities
Current Liabilities
Accounts Payable
2P 21020 Accounts Payable 1,330.65
Total Accounts Payable 1,330.65
Other Current Liabilities
21030 Accounts Payable-Other -368.88
21050 Accrued P/R Taxes Payable 7,784.39
21100 P/R/ Taxes Payable-Other -57.04
21500 Accrued Interest Payable 7,299.54
Total Other Current Liabilities 14,658.01
Total Current Liabilities 15,988.66
Long Term Liabilities
1L 22020-Note PayableUSDA (4.125% - 40 years) 572,400.01
Page 1
Covelo Community Services District
10:02 AM
Balance Sheet
06/24/21
Accrual Basis As of June 30, 2020
Jun 30, 20
Total Long Term Liabilities 572,400.01
Total Liabilities 588,388.67
Equity
28000 Contributed Capital 816,660.49
29000 Retained Earnings -156,652.16
31000 Retaind Earn/PrevYear 2,132,107.12
Net Income 17,415.26
Total Equity 2,809,530.71
TOTAL LIABILITIES & EQUITY 3,397,919.38
Page 2
MSR/SOI Update | Covelo CSD
2.4.2.2 Outstanding Debt
The District has a 2007 loan of $677,000 from the United States Department of Agriculture (USDA). This
loan was used to complete Phase 1 of the Covelo Wastewater Facilities Improvement Project to upgrade
the collection system for wastewater to the treatment plant. The annual interest rate on the loan,
compounded semiannually, is 4.125 percent. The District has no other outstanding loans or debt
obligations.
Figure 2-4 shows the District’s long-term debt activity and schedule of future principal and interest as of
FY 2019-20 under the USDA loan. The District will be obligated through 2048 for current debt payments.
Figure 2-4 Long-term Debt Activity for FY 2019-20
Source: Robertson, 2019.
2.4.2.3 Grant Funds
The District has received financial assistance from federal and state agencies in the form of grants. The
disbursement of funds received under these programs generally require compliance with terms and
conditions specified in the grant agreements and are subject to audit by the grantor agencies. Any
disallowed claims resulting from such audits could become a liability of the Community Services Fund.
However, the District has indicated that any such disallowed claims should not have a material adverse
effect on the overall financial position of the District.
The NCRP Grant is a California Department of Water Resources (DWR) Grant that was administered by
NCRP to solicit and select grantees. The grant is being administered by Humboldt County and awards
$750,000 to the CCSD for repair of three sections of the collection system identified to be significant
contributors to groundwater inflow. Wet winter years create tremendous strain on the wastewater
treatment plant (WWTP/plant) to accommodate the high levels of inflows. The second component is
construction of a roof cover for the disinfecting ozone unit. Additionally, solar panels will be mounted to
the roof structure and will generate approximately 16 kilowatts per hour. The solar system is designed to
be expandable, which will allow for additional panels and wind generators as resources become available.
The District anticipates that the cost savings from these improvements, which are scheduled for
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MSR/SOI Update | Covelo CSD
implementation in FY 2021-22, will allow the District to include repairing the wastewater treatment plant
restroom facilities.
An additional grant through the Mendocino Community Foundation contributes $8,000 toward
installation of the ozone roof structure. The Community Foundation has also provided reporting
extensions, necessary due to delays with DWR funding.
The CCSD was also awarded a $250,000 California Technical Assistance Grant, which funded a team of
engineers and support staff in assembling a preliminary funding package for a CA Waterboards Grant. The
CCSD is now positioned to procure a California State Waterboard Grant to fund the project, which will
allow the District to replace the influent well and pumping station. The comprehensive grant packet has
been completed and is expected to be considered by the Waterboard within the 2020/2021 fiscal year.
No matching funds are required for the grants; however, the CCSD has authorized covering cost overages
in the ozone unit roof construction.
2.4.2.4 Capital Improvement Plan
The District is responsible for prioritizing and budgeting for long-term capital needs in addition to ongoing
operations and maintenance costs. The District does not have a Capital Improvement Plan (CIP). The
District defines capital improvement priorities on an as-needed basis and in the annual budget process.
Capital improvements are primarily funded in one of two ways. Small to mid-range projects that have not
been defined in District policy are scheduled for the upcoming fiscal year through a capital outlay
appropriation, while the District seeks loans or grants for larger projects. 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. (CCSD, 2020a)
2.5 GROWTH
2.5.1 PRESENT AND PLANNED LAND USE AND DEVELOPMENT
The District is located in the unincorporated community of Covelo, a census-designated place (CDP) and
a commercial hub of the larger Round Valley area. The CDP has a total area of 7.1 square miles or
approximately 4,544 acres. Round Valley is a remote area devoted to agricultural uses including grazing
lands and orchards, and rural residential home sites. The Round Valley Indian Reservation, including the
Hidden Oaks Casino, Round Valley Indian Health Center and housing developments, covers 405 acres of
the CDP at the north end of Round Valley, with forest and rangelands extending further to the north.
(Mendocino County, 2009)
2.5.1.1 Land Use
The specific zoning designations for Covelo are listed below and are based on the Mendocino County
Zoning Ordinance (Figure 2-5):
o AG Agricultural Lands
o C-1 Limited Commercial
o C2 Inland General Commercial
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MSR/SOI Update | Covelo CSD
o C2-IS Inland General Commercial (Isolated Service)
o FL Forest Land
o I1 Inland Limited Industrial
o PF Public Facilities
o R-3 Multiple-family Residential
o RL Rangeland
o RR1 Rural Residential
o RR10 Rural Residential
o RR5 Rural Residential
o SR Suburban Residential
o TP Timberland Production
o UR Upland Residential
Chapter 2 – Agency Overview Page 2-26
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MSR/SOI Update | Covelo CSD
As shown in Figure 2-6 below, the Community Plan Map for Covelo designates a commercial core area
around State Route 162, surrounded by residential uses that become less dense farther from the
commercial core. Outside of the District boundaries, agricultural uses and rural residential home sites
prevail, with RL Rangeland (livestock grazing, protection of natural resources), TP Timberland Production
(growing and production of timber), SR Suburban Residential (residential with some commercial uses), UR
Upland Residential (low-density agricultural/residential uses), and PF Public Facilities (airport and school
uses) predominating. (Mendocino 2013)
Figure 2-6 Covelo Community Map
Source: Mendocino County, 2009.
Chapter 2 – Agency Overview Page 2-28
MSR/SOI Update | Covelo CSD
The following goals, policies, and action items from the Mendocino General Plan Community-Specific
chapter could apply to public services and wastewater in particular in the Covelo area.
Covelo Community Goals
Goal CP-C-1: Conserve Round Valley’s natural, visual and historical resources while maintaining
agricultural operations including grazing lands.
Goal CP-C-2: Expand economic opportunities in Round Valley consistent with the desired rural character
of the valley.
Goal CP-C-3: Maintain compact development patterns by focusing commercial, residential and community
uses in Covelo.
Covelo Community Area Policies
Policy CP-C-1: Preserve and enhance the established historic character of downtown Covelo.
Action Item CP-C-1.1: Enhance Covelo’s downtown and incorporate beautification improvements
through circulation, streetscapes, signage, landscaping and other means.
Policy CP-C-2: Retain and restore historic buildings and sites.
Policy CP-C-4: Discourage subdivision activity in the outlying Rural and Remote Residential lands, including
on lands adjacent to Rangelands and Forest Lands.
Policy CP-C-5: Encourage higher density residential uses, including affordable housing units, in or near the
commercial centers as part of a mixed-use strategy.
Policy CP-C-6: Encourage improvements to existing residential structures.
Policy CP-C-7: Establish places and facilities that create a sense of community.
Action Item CP-C-7.1: Revitalize the commercial core of Covelo as the focal point of the
community, with mixed-use potential for convenience retail, office and residential uses, focusing
on the State Route 162 (Covelo Road) corridor and Greely Street.
Action Item CP-C-7.2: Consider installation of a central plaza or gazebo in the downtown.
Policy CP-C-8: Expand and diversify economic ventures.
Policy CP-C-9: The County encourages the expansion of commercial uses in Covelo.
Policy CP-C-10: Commercial uses should be focused near the established core areas along State Route 162.
Policy CP-C-11: Actively pursue light industrial manufacturing employers for Round Valley.
Action Item CP-C-11.2: Designate the mill site northwest of the town center as a study area to
consider a range of future land uses, including industrial, light industrial, commercial and other
uses supporting jobs creation for local residents
Policy CP-C-12: Increase economic and social ties with the Round Valley Indian Tribes.
Policy CP-C-13: Encourage joint-use opportunities with Round Valley Indian Reservation.
Policy CP-C-14: Support a community fire hydrant system to facilitate economic and public safety.
Chapter 2 – Agency Overview Page 2-29
MSR/SOI Update | Covelo CSD
Policy CP-C-15: Encourage the Covelo CSD to plan for the provision of a public water system.
Action Item CP-C-15.1: Assist the Covelo Community Services District (CSD) in its efforts to serve
future growth with water capacity consistent with the land use patterns and densities established
in the General Plan.
Policy CP-C-16: Consider upgrades to the Round Valley Airport to support economic development and
emergency services.
In addition to these policies, the County amended its cannabis regulations on December 4, 2018 to allow
Cannabis Accommodation combining districts which apply in the Covelo core area and on Fairbanks Road
in Round Valley. Commercial Cannabis Accommodation Combining Districts (Opt-In Districts) are areas
intended to support continued operations by existing growers. From January 3, 2019 to July 1, 2019, the
Department of Agriculture accepted applications for cultivation permits within the Cannabis
Accommodation Combining Districts. (Mendocino County, n.d.)
2.5.1.2 Development
The District is centered on the core of the Covelo community area as shown in Figure 2-1. The population
at the 2010 census was 1,255 people, an increase of 80 people from the 2000 census. (Current Community
Survey 5-Year Estimates show an estimated population of 1,140 with a margin of error ±239 (USCB,
2019b).) However, the population is likely much higher and, common with transient populations,
fluctuates throughout the year. Covelo contains a range of commercial enterprises, churches, a lodging
establishment, food establishments, grocery store, convenience store, gas station, Post Office, the Round
Valley Airport, Round Valley Public Library, Round Valley Elementary School (K–8), Round Valley High
School (9-12), Eel River Charter School (K-8), and residential areas interspersed throughout the
community. A majority of the land within the District consists of a mixture of commercial and residential
uses, with some agricultural and grazing lands on the outskirts. The core area of Covelo until recently
retained the historic character embodied by older commercial buildings and residences. In 2019 a fire
destroyed the majority of a remaining block of historic buildings. Rebuilding has not yet been initiated.
The community proper is a mixture of commercial uses (retail, office, etc.) and limited industrial uses. The
remainder of the valley is developed as a mix of suburban residential, rural residential, and agricultural
land uses. Agricultural land uses are predominantly pastureland devoted to cattle grazing, with a relatively
small pear orchard on the south end of the valley.
The Round Valley Indian Reservation occupies the north end of Round Valley and is home to the Round
Valley Indian Tribes (RVIT), which is made of several Native American tribes. The RVIT is a federally
recognized, sovereign nation of confederated tribes: the Yuki, who were the original inhabitants of Round
Valley, as well as the Pit River, Pomo, Nomlacki, Concow, and Wailacki tribes, who were forced onto the
reservation with Yuki. The Reservation was one of five reservations in California legislated by the United
States Government in 1870 pursuant to the Four Reservations Act of 1864. (Mendocino County, 2008a)
Residents have expressed interest in retaining Covelo’s historic nature and the rural character of the
valley, while increasing economic development and affordable housing opportunities. Historically,
Covelo’s economy was focused on the timber industry. The Round Valley Flour Mill is an identified
historical resource in the Mendocino County General Plan.
Covelo is accessed by State Route 162 and Round Valley Airport. Mendocino National Forest borders the
community of Covelo to the north and east. Mendocino County has land use authority over privately
Chapter 2 – Agency Overview Page 2-30
MSR/SOI Update | Covelo CSD
owned lands within the District boundary and makes land-use decisions based on the County General Plan
and Zoning Regulations.
The Round Valley Area Municipal Advisory Council is comprised of citizens of Round Valley and acts as a
liaison between the community and Mendocino County and State agencies. The RVAMAC is a County
recognized and community-driven forum for engaging in both County-wide and local topics and by
presenting the needs and ideas of the community to decision making officials.
Chapter 2 – Agency Overview Page 2-31
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THIS MAP AND DATA ARE PROVIDED WITHOUT WARRANTY OF ANY KIND.
Map produced by the Mendocino County Planning & Building Services, April, 2015
MSR/SOI Update | Covelo CSD
Some factors affecting community growth include limited vehicular access, distance to employment
centers such as Willits and Ukiah, lack of a public water system, and limited wastewater capacity provided
by the Covelo Community Services District. Covelo is also the site of an alluvial basin that is locally
susceptible to liquefaction. (Mendocino County, 2009)
Infrastructure and other nonresidential and residential development located along Town Creek is
susceptible to flooding. Town Creek runs through Covelo in a generally west to east direction, as well as
much of the area south and east of Covelo, as shown on Figure 2-8. The RVCWD is responsible for flood
control and stream restoration on Town Creek.
The most recent Housing Element adopted by Mendocino County in 2015 conducted an analysis of
development potential for Covelo. Although there are many parcels throughout Covelo that are vacant or
underutilized, only three were included in the Housing Element inventory due to development restrictions
such as zoning and lack of centralized water services. See Figure 2-9 below. At the time of the 2015
Housing Element, it was reported that the District was pursuing expansion of its authority to include water
service, initially for fire hydrants and suppression and in the longer term for a potable water system. The
RVMAC has also recently expressed interest in these services for the benefit of the community. However,
such an expansion has not materialized, primarily due to concerns of placing a large revenue burden on
the residents of the District. In addition to a lack of water, the three parcels evaluated in the Housing
Element are also close to the airport, which poses an additional development constraint with noise and
safety impacts to any new residences.
Mitigating this challenge somewhat is the presence of a large, easily accessible aquifer that could be
tapped by individual or communal wells to serve new multifamily structures. Three sites in the core of the
Covelo currently have multifamily zoning and undeveloped. Since it is possible to utilize onsite wells for
water supply and connect to the CSD for sanitation service, these properties do have development
potential. However, the lack of a centralized water system would likely limit the potential number of units
to half their development potential.
(Mendocino County, 2015)
The entire District is currently under a temporary Mitigatable Moratorium due to the winter infiltration
and inflow (I&) issues and treatment plant capacity shortfalls discussed in Section 3 of this document.
Increased monthly rates are unaffordable for the community, so the only way to mitigate these issues to
enable additional development is through external funding sources. The District has received a grant to
remedy these issues and will be implementing that shortly (See Section 2.4.2.3). (North Coast Resource
Partnership, 2018)
Chapter 2 – Agency Overview Page 2-33
MSR/SOI Update | Covelo CSD
Figure 2-8 Flood Map for Covelo Area
Source: FEMA, 2011.
Chapter 2 – Agency Overview Page 2-34
MSR/SOI Update | Covelo CSD
Figure 2-9 Housing Element Inventory of Buildable Sites in Covelo Planning Area
(Mendocino County, 2015)
Chapter 2 – Agency Overview Page 2-35
MSR/SOI Update | Covelo CSD
2.5.2 EXISTING POPULATION AND PROJECTED GROWTH
According to District staff, the District currently serves approximately 430 residents with 265 service
connections. The U.S. Census Bureau has designated Covelo as a Census Designated Place (CDP). Census
Designated Places are Census Bureau estimates of what an incorporated city boundary would be if a
concentrated population area were a city. The Covelo CDP is much larger than the District boundaries, but
for general informational purposes, the Census data for the Covelo CDP indicates that as of the 2010
census, 1,255 people resided within the CDP, from which a population density of 164.9 people per square
mile can be extrapolated. By comparison the average population for Mendocino County is 24.16 persons
per square mile. However, it is likely that the population of the area is quite a bit higher than reported.
The rate of growth in Mendocino County from 2010 (87,850 residents) to 2019 (86,749) was -1.3%.
However, the population of the District has been increasing more than the population of the County as a
whole. District and Census Tract boundaries are noncontiguous, but Census Tract 010100 encompasses
approximately 80 percent of the District and is therefore used in the table below.
Table 2.6 Population Change in Mendocino County and Covelo CSD
1980 1990 2000 2010 2019
Census Tract 010100 2,137 2,066 2,374 2,617 2,674
Percent Change 13% -3% 15% 10% 2%
Mendocino County 66,738 80,345 86,265 87,841 86,749
Percent Change 30% 20% 7% 2% -1%
Source: USCB, 2019a; Mendocino County 2008b.
As shown in Table 2.6, the population growth of the Round Valley area was lower on average until 2000,
when it began to see more growth on average than the rest of Mendocino County. If the last ten years is
an indication of average growth for the next ten years, the District might expect to see 2% growth;
however, the decades-long trend demonstrated by the data appears to be sagging, and growth may
continue to slow. Growth projections published by Caltrans indicate a very slow overall County population
growth of approximately 0.15%. (Caltrans, 2019) Based on this growth rate, the District can expect a small
population increase of three people within the next five years. Although there are a number of parcels
just outside the District of similar size as those within, and several which could be subdivided for
development, there are no proposed or anticipated significant land use changes, new development
projects, or redevelopment of existing sites within the District’s boundary over the next five years (CCSD,
2020a). The District will likely experience limited growth until constraints related to infrastructure needs
are sufficiently addressed.
The District has a maximum number of REU’s available due to capacity limitations of the WWTP. Given
that there is currently a temporary mitigatable moratorium in effect, there are no new developments
possible. Although there are indications that populations within the District have increased as there seems
to be an increase in residents per residence, there is no documentation available.
Chapter 2 – Agency Overview Page 2-36
MSR/SOI Update | Covelo CSD
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 $80,440 or $64,000
(USCB, 2019c). 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.
Covelo is a CDP and the primary population center within the District. Covelo CDP has an MHI of $23,600
(USCB, 2019d) and qualifies as a DUC. It is also considered a Severely Disadvantaged Community (SDAC)
under California Public Resources Code Section 75005, which is defined by an average MHI of less than
60% the statewide average. 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 2-37
MSR/SOI Update | Covelo 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
Covelo CSD provides wastewater services within its boundaries with a single service area.
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.
3.1.2 OUT-OF-AGENCY SERVICES
The District does not provide any out-of-agency services, and there are no pending or anticipated requests
for or commitments from the District to provide out-of-agency services over the next five years. (CCSD,
2020a)
3.2 WASTEWATER
3.2.1 SERVICE OVERVIEW
The District owns, operates, and maintains a public wastewater collection system, treatment plant, and
disposal system for the treated water and sludge (biosolids) byproducts from the wastewater treatment
plant (WWTP). The District is currently under a temporary Mitigatable-Moratorium (MM) due to winter
infiltration and inflow (I&I) issues and treatment plant capacity shortfalls. (North Coast Resource
Partnership, 2018)
The District currently does not have a capital improvement plan (CIP). A CIP identifies current and long-
term District facility and equipment needs, including upgrades, renovations, and major maintenance,
capital improvements and purchases, and facility expansions, and identifies potential revenue sources for
addressing those capital needs. The District currently addresses these needs through its annual budget
development process.
3.2.2 COLLECTION SYSTEM
The District’s wastewater collection system channels wastewater from the source (a residence,
commercial, school, or other building) to the WWTP via pipes that run from each structure (laterals) to a
sewer main in the street. The street sewer mains connect to progressively larger pipes until their
culmination at the WWTP. Residential mains are usually four inches in diameter. Street mains vary in size
with the smallest being six inches in diameter. The District operates and maintains 20,000 feet
(approximately 3.75 miles) of 6-, 8-, 10- and 12-inch sewer lines, and one pump station.
Chapter 3 – Municipal Services Page 3-1
MSR/SOI Update | Covelo CSD
Ideally, sewer collection systems are completely gravity powered with the WWTP located at the lowest
elevation of the collection system territory. In regions where gravity flow cannot be utilized, pumping
stations known as lift stations are necessary. As shown in Figure 2-9 below, the District sewer system
consists of four major collection basins, three of them north of Town Creek and one south of the Creek.
The largest collection basin is located north of Town Creek and primarily west of Commercial Street. All
wastewater from these two northern collection basins flows by gravity toward Town Creek and passes
under the creek through an inverted siphon. The sewer main piping includes approximately 3,900 linear
feet of 8-inch diameter and 14,575 linear feet of 6-inch diameter asbestos-cement pipe (transite pipe).
There are approximately 45 manholes and 10 mainline cleanouts in this portion of the overall system. A
main interceptor sewer line located just south of Town Creek conveys collected wastewater east to the
WWTP.
A mixed development area known as the “Business Park” comprises the third collection basin located
north of Town Creek and is the second largest of the three northern sewer basins. This collection area was
annexed into the District boundary in 2010. The Business Park basin consists of 2,200 linear feet of 6-inch
diameter pipe, 1,085 linear feet of 12-inch diameter pipe, and 800 linear feet of 12-inch pipe that
terminates within the WWTP property. An independent gravity sewer line conveys wastewater from the
Business Park directly to the WWTP influent pump station on the north side of Town Creek.
The smallest of the three northern basins lies along East Lane within the northeast corner of the District
and includes 800 feet of 6-inch diameter sewer main, 4 manholes and 1 mainline cleanout. Wastewater
in this basin flows by gravity to a lift station near the northern limit of the Commercial Street sewer main.
The lift station pump lifts collected wastewater to the terminal manhole on the Commercial Street main
where it joins wastewater generated in the largest northern collection basin situated within and west of
Commercial Street.
The fourth sewage collection basin is located entirely south of Town Creek. This collection area is smaller
in size than the combined areas located north of Town Creek, but potentially serves a significant amount
of developable area between the Round Valley Airport on the east and Highway 162 on the west. The
wastewater generated within this basin flows north and joins wastewater generated within the main
northern basins on the south side of Town Creek before being conveyed through the main sewage
interceptor to the WWTP. The main interceptor includes a second inverted siphon below Town Creek, just
upstream of the influent pump station at the WWTP.
The overall collection system serves a geographic area of approximately 264 acres. The collection system
serves the customer breakdown as noted in Table 2.7
Table 3.1 Summary of Residential Equivalent Units
Type of Development Residential Equivalent Units (REU)
Single-Family Dwelling 189
Business 59
Fire House 1
Church 4
Motel 4.25
Chapter 3 – Municipal Services Page 3-2
MSR/SOI Update | Covelo CSD
Schools 47.5
Mobile Home Park 33
Restaurant 14
Total 347.75
Source: CCSD, 2021
Upgrades to the system were performed in 2008, but due to design and construction errors in some of
these pipes, as well as aging infrastructure that was not replaced in 2008, much of the collection system
now requires improvements due to I&I seepage. A collection system upgrade is currently being
implemented under a North Coast Resource Partnership grant to remedy these issues as discussed further
under Section 3.2.5. (North Coast Resource Partnership, 2018)
Chapter 3 – Municipal Services Page 3-3
MSR/SOI Update | Covelo CSD
Figure 3-1 Map of Collection System
Chapter 3 – Municipal Services Page 3-1
MSR/SOI Update | Covelo CSD
3.2.3 WASTEWATER TREATMENT AND DISPOSAL SERVICES
The District’s WWTP is located just outside the District’s boundary to the southeast, adjacent to Town
Creek immediately upstream from its confluence with Grist Creek. The plant was first constructed in the
1960s and underwent major construction upgrades as part of the Clean Water Grant Program in 1976-77.
The existing facility consists of an influent pump station, headworks, two treatment ponds, two holding
ponds, a sand filter, an ozone disinfection process, and an outfall into Grist Creek.
The groundwater level is much higher under the WWTP than in almost all of Round Valley. Tests before
the plant was constructed showed free groundwater four to eight feet below the surface during the
summer. During winter the groundwater rose to only a foot below the surface.
There are two groundwater levels in the general region of the WWTP. The first, the Covelo Aquifer,
extends to a depth of approximately 40 feet. It is heavily influenced by surface water and sewage disposal
systems. An “aqualude” between 40 to 60 feet below the surface separates and isolates a second
groundwater supply, the Round Valley Aquifer. This aquifer receives very little inflow from the surface
directly above it; recharge derives from the surrounding hills and terraces. Water quality is good from the
Round Valley Aquifer. Most well depths in the Valley are in the 100- to 200-foot depth range.
Historically, Coho salmon and steelhead were known to occur in Mill Creek, into which Grist Creek flows,
and Coho were even observed in Grist Creek; however, it has been decades since any have been observed
in the tributaries. The plant is just outside the 100-year flood zone, but is partially within the 500-year
zone.
(LAFCO, 2010a)
Raw sewage is pumped through a bar screen to two oxidation ponds, 4.7 and 2.2 million gallons in size
(total surface area 4.5 acres), which function as semi-mixed, aerobic-anaerobic lagoons. Under its NPDES
permit, the District may discharge into Grist Creek if there is a dilution ratio of 100:1. No discharge is
allowed from May 15 through September 30 of each year under any circumstances. (North Coast Regional
Water Quality Control Board, 2017)
Holding ponds are designed to store treated effluent subject to these limitations. Before discharge,
treated effluent is filtered through four separate sand filters in two cycles and is then passed through a
disinfection process similar to a tablet-type chlorination system. Current capacity is 70,000 gallons a day.
The existing equipment could be upgraded to double that volume. (LAFCO, 2010a)
3.2.4 OPERATIONS AND MAINTENANCE
The District does not have an operation and maintenance program, nor a CIP as discussed in Section
2.4.2.4. The Plant Operator/Collection System Manager determines all maintenance and repair needs for
the sewer system based upon the manufacturer’s recommended schedule, industry best practices, and
actual need. Maintenance is funded through the annual budget development process. (CCSD, 2020a)
It is recommended that the District maintain a System Operation and Maintenance Program (SOMP) which
establishes procedures intended to prevent or minimize the potential for sanitary sewer overflows. The
program can include guidelines for the operation and maintenance of the sanitary sewer collection
system, such as a plan for drafting and maintaining the District’s collection system maps, operation and
maintenance activity schedules, a plan to prepare the District’s CIP, system rehabilitation and replacement
plans, and District personnel training schedules. As part of the SOMP, a schedule for monitoring and
cleaning sewer lines and lift stations can be developed. SOMPs also typically include prevention and
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containment measures identifying emergency pump-around and containment equipment, and training
schedules for staff to use this equipment in an emergency. Hot spots - areas where visual or video
inspections indicate repeated or unusual accumulation of grease, grit, roots or other debris, or in areas
with a past history of sewage blockages – can be identified, mapped, and placed on a routine cleaning
schedule.
The District may also find efficiencies in developing Geographic Information Systems (GIS) mapping for
the wastewater system with manhole, sewer line, and lift station layers, as well as an attribute table with
manhole and sewer line information georeferenced to each manhole and sewer line, which lists the line
type, line material and the pipe diameter. The District would be able to use the attribute table and map
displays for collection system maintenance scheduling, to query information about the system, and to
create maps and labels.
The District is required by the State Water Resources Control Board (SWRCB) to prepare a Sewer System
Management Plan (SSMP) that includes an operation and maintenance program, design and performance
provisions, an overflow emergency response plan, and a system evaluation and capacity assurance plan,
among other items. The District approved a SSMP at its September 12, 2019 regular board meeting.
Although no engineering report was available for review in the preparation of this MSR, a 2006
engineering analysis of the system by SHN Engineers listed a number of plant deficiencies. (SHN Consulting
Engineers & Geologists, 2006) In 2008, repairs made to the system improved some of these issues, but
they did not remedy them completely, and the District has had unauthorized surface discharges that have
failed toxicity tests since that time. The District also currently has a moratorium on new service
connections due to the maximum capacity and I&I issues.
The District recently received a North Coast Resource Partnership grant that includes funding for
collection system improvements and wastewater treatment plant improvements. The grant award of
$750,000 will allow the District to address one of the moratorium mitigation measures: reduce inflow and
infiltration by replacing faulty laterals, a manhole, and a section of main pipe. The construction design and
bid package are to be completed by June 2021 and construction to begin and to be completed summer/fall
of 2021, respectively.
The collection system’s I&I issues compromise the treatment facility’s capacity and have resulted in raised
rates (in 2017) by $15 a month to offset the testing and administrative costs needed during wet weather
events. The project will redesign the treatment plant ponds to increase water treatment efficiency, thus
reducing processing costs and timing of influent. The improvements will also allow the District moratorium
to be lifted, allowing increased revenue from new development. Improvements will replace portions of
the collection system to reduce approximately 0.2 MGD of wet weather I&I, and will upgrade the
treatment plant to adjust inlets and outlets through various parts of the plant, separate some of the
treatment facilities (wetlands and percolation pond), and install aerators/mixers in the primary oxidation
pond to improve the treatment capacity and maintenance abilities of the WWTP. These improvements
would also reduce the toxic ammonia in the plant’s effluent.
(North Coast Resource Partnership, 2018)
3.2.5 SYSTEM CAPACITY
The District’s wastewater collection, treatment, and disposal facilities serve 430 people with 265 service
connections. The District serves predominantly commercial, residential, and school uses. The District is
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located in a larger community, which if appropriately characterized by the CDP boundaries, has an
approximate resident population of 1,255, covering an area of approximately 7.1 square miles, with sparse
development outside the District boundaries.
The permitted design capacity of the WWTP is 77,000 gallons per day or .077 million gallons per day
(MGD). The most recently available daily wastewater flows are summarized in Table 3.2.
Table 3.2 Wastewater Flow Data 2015-2019
Parameter Unit 2015 2016 2017 2018 2019 20201 Average
Average Daily Flow MGD .054 .093 .098 .054 .083 .044 .071
Average Dry Weather Flow MGD .037 .041 .033 .040 .039 .037 .038
Average Wet Weather Flow MGD .072 .137 .120 .061 .106 .046 .090
Maximum Daily Flow MG .144 .329 .455 .184 .369 .087 .261
Maximum Monthly Flow MG 3.195 5.946 8.163 3.334 5.381 1.771 4.632
12020 was a significant drought year.
As shown in Table 3.2, most of the average flows were less than.077 million MGD in any given year.
However, years with higher precipitation levels have produced some exceedances of the maximum
permitted flow rate. Wet weather flows exceeded the maximum flow rate in three of the last five years
(2016, 2017, and 2019). These service peaks are primarily related to high rainfall years due to I&I issues.
In the summer months (non-school year months), service demand drops due to less overall inflow.
Funding for expansion of the wastewater collection and treatment system could occur through new
development within the boundaries of the District or extension of the system to serve existing areas
adjacent to the District currently utilizing onsite sewage disposal systems (septic systems). Although there
are a number of parcels just outside the District boundaries that could be subdivided for development,
there are no proposed or anticipated significant land use changes, new development projects, or
redevelopment of existing sites within the District’s boundary over the next five years (CCSD, 2020a). The
District will likely experience limited growth until constraints related to infrastructure and capacity needs
are sufficiently addressed. After the system has been upgraded, it is anticipated that the District will see
occasional requests for service and annexation.
3.2.6 FACILITIES AND ASSETS
The District owns, operates, and maintains multiple capital assets including land, structures, equipment,
and infrastructure to provide services to its customers. As of December 31, 2019, the District’s capital
assets totaled $3,198,990. (CCSD, 2020c)
The District owns two parcels totaling 22.5 acres on which the WWTP is located. The treatment plant
facilities are owned and operated by the District, including pumping stations, office/storage buildings,
backup generators, and ozone disinfection unit. The District has easements to all sewer lines from the
terminus at the plant on throughout the District up to each property line cleanout. Most facilities are
approximately 20 years old and in generally good operating condition. However, some facilities have been
identified as needing upgrading. The District also owns office equipment, vehicles to support its
operations, and other equipment for maintenance and operations. Capital assets as of June 30, 2019, with
depreciation, are shown in Figure 3-2 below.
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Figure 3-2 Fixed Assets FYE 2020
As mentioned, the District is currently in the process of implementing a North Coast Resource Partnership
grant to replace faulty sections of the collection system as well as to install solar panels at the WWTP.
Additionally, the CCSD has applied for a California Waterboard Grant to rebuild the influent well and
pumping station. See Section 2.4.2.3 for more information.
3.3 DETERMINATIONS
This section presents the required MSR determinations pursuant to California Government Code
§56430(a) for the Covelo Community Services District.
3.3.1 MSR REVIEW FACTORS
3.3.1.1 Growth
Growth and population projections for the affected area
1. The 2010 Census for the Covelo CDP, which includes the District and is 7.1 square miles, estimates a
population of 1,255 residents and is estimated to grow very slowly due to infrastructure deficiencies.
2. The Covelo CSD is estimated to serve a population of approximately 430 residents.
3. Population growth is expected to increase at an annual rate of approximately 0.15% for Covelo CDP.
Based on this growth rate, the District can expect a small population increase of three 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.
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3.3.1.2 Disadvantaged Unincorporated Communities
The location and characteristics of any disadvantaged unincorporated communities within or contiguous
to the sphere of influence
5. Covelo CDP has an MHI of $23,600 and qualifies as both a disadvantaged unincorporated community
(DUC) with less than 80% of the States Median Household Income (MHI) and a several disadvantaged
community (SDAC) with less than 60% of the State’s MHI. Special consideration will be given to any
DUCs affected by future annexation proposals consistent with GC §56375(8)(A) and LAFCo Policy.
6. The Round Valley Indian Reservation is located adjacent to the District in the northwest portion of
Round Valley. However, the Round Valley Indian Tribes (RVIT) own and operate its own wastewater
treatment facility for the Reservation.
3.3.1.3 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
7. The District provides wastewater services within its boundaries with no distinct service areas.
8. The District does not provide any wastewater services outside its boundaries. However, the District
has a policy and septage disposal fee for septage haulers.
9. The District’s wastewater system serves a total of 265 connections with residential equivalent units
(REUs) assigned as follows: single family dwellings, 189; businesses, 59; schools, 47.5; motel, 4.25;
mobile home park, 33; restaurants, 14; churches, 4; fire house, 1.
10. The District’s wastewater system facilities and infrastructure includes a WWTP with a design capacity
of 77,000 gallons per day, 20,000 feet (approximately 3.75 miles) of sewer lines and one pump station.
The average total annual demand on the District’s water system regularly exceeds the plant capacity,
with three of the last five years exceeding average daily flow due to high precipitation years when I/I
issues impacted the system.
11. There are wastewater capacity issues and infrastructure needs for the District that need to be
addressed within the timeframe of this MSR. The plant requires upgrades to prevent I/I issues during
storm events, and some of the infrastructure requires replacement, such as the plant restroom
facilities.
12. It is recommended that the District maintain a System Operation and Maintenance Program (SOMP),
which establishes procedures intended to prevent or minimize the potential for sanitary sewer
overflows. The program can include guidelines for the operation and maintenance of the sanitary
sewer collection system, such as a plan for drafting and maintaining the District’s collection system
maps, operation and maintenance activity schedules, a plan to prepare the District’s capital
improvement program, system rehabilitation and replacement plans, and District personnel training
schedules. As part of the SOMP, a schedule for monitoring and cleaning sewer lines and lift stations
can be developed. Prevention and containment measures can also be planned for in an SOMP with
emergency pump-around and containment equipment, and training schedules for staff to use this
equipment in an emergency. Hot spots - areas where visual or video inspections indicate repeated or
unusual accumulation of grease, grit, roots or other debris, or in areas with a past history of sewage
blockages – can be identified, mapped, and placed on a routine cleaning schedule.
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13. It is recommended that the District develop a Geographic Information Systems (GIS) map for the
wastewater system with manhole, sewer line, and lift station layers, as well as an attribute table with
manhole and sewer line information georeferenced to each manhole and sewer line, which lists the
line type, line material and the pipe diameter. The District would be able to use the attribute table
and map displays for collection system maintenance scheduling, to query information about the
system, and to create maps and labels.
3.3.1.4 Financial Ability of Agency
Financial ability of agencies to provide services
14. 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
financial audit reports (starting with Fiscal Year 2019-20) 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.
15. According to audited financial information from Fiscal Years 2015-16 through 2017-18, the District
was generally operating at a net deficit each year. In late 2017, the District increased its fees to achieve
a balanced budget which is has done since Fiscal Year 2018-19. The trend in net position is a key
measure of fiscal health and indicates that the District has achieved a balanced budget and meets
current operating costs with the 2017 increase fees. The District has adequate finances to meet
current and future demands for public services within the next five years. However, the District should
continue working to maintain a balanced budget as well as toward building reserves to fund capital
improvements and replace equipment.
16. The District does not have a Capital Improvement Plan and relies on the annual budget development
process to identify and fund maintenance and capital needs. It is recommended that the District
prepare and adopt a 5-year Capital Improvement Plan to ensure that financial planning occurs for
future capital infrastructure needs.
3.3.1.5 Shared Services and Facilities
Status of, and opportunities for, shared facilities
17. The District does not participate in any shared services. There is no redundancy in the provision of
municipal services to the District.
18. The District collaborates with other public agencies by sharing the office and Board meeting location
with the RVCWD.
19. The District is developing an MOU with the RVCWD to share office space with the Round Valley Area
Municipal Advisory Council for document storage.
20. The District participates in the SDRMA for the purpose of pooled insurance for providing liability,
workers compensation for its facilities, operations, and employees. Health insurance is provided by
the Association of California Water Agencies (ACWA) Joint Powers Insurance Authority for District
employees and their dependents.
21. No new opportunities for the District to achieve organizational or operational efficiencies were
identified during the preparation of this MSR.
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3.3.1.6 Accountability, Structure, and Operational Efficiencies
Accountability for community service needs, including governmental structure and operational
efficiencies
22. The District is governed by a Board of Directors elected to serve 4-year terms. The Board is comprised
of five seats, only three of which are filled as has been the case since Fiscal Year 2010-11. The District
has difficulty filling vacancies, but has retained two long-term Board members, 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. It is recommended that the District conduct public outreach to the community through
physical bulletin board notification sites as well as local media and/or free social media to attract
additional Board members. A small stipend for Board members may also attract more members.
23. Regularly scheduled meetings for the District Board of Directors are held on the second Thursday of
the month at 6:00 p.m. at the District Office located at 23950 Grange Street in Covelo. Alternatively,
the District Board meets on the second Wednesday of the month as needed, according to District
staff. 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.
24. 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.
25. With the passage of Senate Bill 929 in 2018, all special districts are required to maintain a website
that includes contact information and all other requirements by January 2020 (Compliance checklist
included in Appendix B). The District has a website at https://ccsd.roundvalley.org, which contains the
District’s contact information and agendas and minutes from District Board meetings from October
2019 to June 2020. However, the website is not current and does not appear to have been maintained
in the last year. A search of the District in any major search engine does not yield the District’s website,
and it is not linked on the Mendocino LAFCo webpage. The District’s website would be enhanced by
keeping it up to date; posting the regular Board meeting agenda, time, and location; posting the Board
member contact information; and incorporating a content management system 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 website would also benefit from a search engine prioritization overhaul to improve the website
ranking and site traffic. The District should also consider maintaining community outreach,
particularly prior to and during construction of capital improvements, through social media outlets
and linking to relevant outside sources such as community websites and Mendocino LAFCo’s website.
26. The District has one full-time position and two part-time employees as follows: one General Manager,
one Bookkeeper/Office Manager, and one Plant Operator/Collection Manager. In addition, the
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District contracts with a Certified Public Accountant (CPA) and legal counsel on an annual basis. As
needed, the District also enters into contracts with engineers, construction contractors, construction
monitors, and others.
27. 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.
28. There are no government restructure options for the District to achieve organizational or operational
efficiencies identified during the preparation of this MSR.
3.3.1.7 Other Service Delivery Matters
Any other matter related to effective or efficient service delivery, as required by commission policy
29. There are no other matters related to service delivery required by Mendocino LAFCo Policy.
30. As a CSD, the District has the opportunity to provide additional municipal services upon activation of
latent powers through Mendocino LAFCo. Given the recent establishment of the RVAMAC and the
community issues identified in the Covelo area, there may be opportunity for the District to serve as
a vehicle for achieving some of the goals that are often otherwise unattainable in such a rural,
unincorporated area. Attachment C includes a list of municipal services that are authorized under
Community Services District Law that could potentially be activated for the Covelo CSD through
appropriate LAFCo processes.
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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 Covelo Community Services District.
4.1 SOI UPDATE
This update is prepared as part of a CKH Act mandated (GC §56076) process. As stated in that section, “In
order to carry out its purposes and responsibilities for planning and shaping the logical and orderly
development and coordination of local government agencies so as to advantageously provide for the
present and future needs of the county and its communities, LAFCo shall develop and determine the
Sphere of Influence (SOI) of each local governmental agency within the county”. A “SOI” under the CKH
Act (GC §56076) definition is “…. a plan for the probable physical boundaries and service area of a local
(government) agency”.
Decisions on organizational changes must be consistent with the SOI boundary and determinations. The
adopted SOI is used by LAFCo as a policy guide in its consideration of boundary change proposals affecting
each city and special district in Mendocino County. Other agencies and individuals use adopted SOIs to
better understand the services provided by each local agency and the geographic area in which those
services will be available. Clear public understanding of the planned geographic availability of urban
services is crucial to the preservation of agricultural land and discouraging urban sprawl.
The following update will assess and recommend an appropriate Covelo Community Services District
(CCSD) Sphere of Influence (SOI). The objective is to establish CCSD SOI relative to current legislative
directives, local policies, and agency preferences in justifying whether to (a) change or (b) maintain the
designation. The update draws on information from the CCSD Municipal Services Review (MSR) in Section
3, which includes the evaluation of availability, adequacy, and capacity of services provided by the District.
SOI reviews and updates typically occur every five years, or as needed. A local agency’s services are
analyzed with a 20-year planning horizon, and a sphere is determined in a manner emphasizing a probable
need for services within the next 5 to 10 years. Actual boundary change approvals, however, are subject
to separate analysis with particular emphasis on determining whether the timing of the proposed action
is appropriate.
If the CSD were to annex in the future, and/or potentially activate additional latent powers, that would
be an appropriate time to establish possible service zones within the District, identifying where various
services, such as water, are provided. LAFCo oversight during the establishment of service zones would
ensure the policies of the Commission, such as preserving agricultural land and open space, are addressed.
4.1.1 EXISTING SPHERE OF INFLUENCE
The Sphere of Influence (SOI) for Covelo CSD is coterminous (identical to) with the District boundary and
was established by LAFCo on October 4, 2010 (LAFCo Resolution No. 2010-01). Concurrent annexations
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consistent with the 2010 SOI were also approved on October 4, 2010 (LAFCo Resolutions No. 2010-02 and
2010-03). There have been no changes to the District boundary or SOI since then. (LAFCo, 2010a)
4.1.2 STUDY AREAS
There are no additional study areas beyond the present SOI. Based on current wastewater treatment
system capacity, which has reached its maximum extent and regularly exceeds its capacity in the rainy
season, as well as the repair and capital improvement needs of the system, it appears that the District
does not have the capacity to provide wastewater services beyond its proposed service area. There may
be a future need for services outside the proposed jurisdictional boundaries of the District; however, the
District is presently unable to provide those services. The territory of the District and the proposed
coterminous SOI are in the County, which is the land use authority for all lands within the Covelo area.
There are no present or planned land uses within the proposed coterminous SOI that differs with existing
County zoning.
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 AOI will be treated the same as if these areas were within
the city or district SOI boundary, particularly regarding notification to and consideration of input from the
city or district.
As noted above, there are no Study Areas established in this MSR due to the District indicating that the
existing District boundary and SOI are adequate, as well as current limitations associated with capacity
and infrastructure needs that should be addressed prior to any new annexations.
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, the current lack of capacity in the wet-weather
season, other repair and capital needs that must be addressed, and the lack of financial ability to add
additional service connections and new infrastructure that would require financial resources to maintain
and operate. There are no proposed SOI changes for the Covelo CSD (Figure 1-1). (CCSD, 2020a)
4.1.5 CONSISTENCY WITH LAFCO POLICIES
The District is comprised of a community with residential, commercial, and public facility (school) uses.
Maintaining the existing District SOI is consistent with Mendocino LAFCo Policies (refer to Section 1.5 for
the specific SOI policies).
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4.1.6 DETERMINATIONS
It is recommended that the Commission affirm the existing Sphere of Influence for Covelo Community
Services District that is coterminous with the District boundary. 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
The District service area is comprised of the semi-rural unincorporated community of Covelo within the
greater Round Valley area. Land uses within the District include residential and residential-supporting
commercial and public facility uses. Round Valley is a remote area devoted to agricultural uses including
grazing lands and orchards, and rural residential home sites. The Round Valley Indian Reservation,
including the Hidden Oaks Casino, Round Valley Indian Health Center, and housing developments, covers
405 acres of the CDP at the north end of Round Valley, with forest and rangelands extending further to
the north. Outside of the District boundaries, agricultural uses and rural residential home sites prevail,
with RL Rangeland (livestock grazing, protection of natural resources), TP Timberland Production (growing
and production of timber), SR Suburban Residential (residential with some commercial uses), UR Upland
Residential (low-density agricultural/residential uses), and PF Public Facilities (airport and school uses)
predominating. Mendocino County has land use authority over privately-owned lands within the District
boundary and makes land-use decisions based on the County’s General Plan and Zoning Regulations.
(Mendocino County, 2009)
4.1.6.2 Need for Facilities and Services
The present and probable need for public facilities and services in the area
General government services provided under the direction of the District Manager include Administration,
Finance, and Planning. The Covelo CSD is estimated to serve a population of approximately 430 residents.
Population growth is expected to increase at an annual rate of approximately 0.15% for the Covelo area.
Based on this growth rate, the District can expect a small population increase of three people within the
next five years. Although there are a number of parcels just outside the District of similar size as those
within, and several which could be subdivided for development, there are no proposed or anticipated
significant land use changes, new development projects, or redevelopment of existing sites within the
District’s boundary over the next five years. The District will likely experience 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. (CCSD, 2020a)
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
Since Fiscal Year 2018-2019, the District’s enterprise services have been operating within a balanced
budget, and the District’s overall net position has been maintained. The trend in net position is a key
measure of fiscal health and indicates that the District has stabilized in recent years. The District does
maintain a Capital Reserve account, which currently has $76,748.19, but the District should be working
toward building additional reserves to fund capital improvements and replace equipment. In addition, the
District’s capacity has been regularly exceeded during storm events in three of the last five years, in
violation of the current NPDES permit. The District is currently working on a number of projects to improve
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the facilities and provide some cost-saving measures (such as installation of solar panels at the treatment
plant). However, it is unclear whether these planned improvements will provide the additional capacity
needed as well as the finances needed to bring the project into a stronger net position annually. The
Covelo CSD has adequate finances, facilities, and equipment to meet current demands for public services
within the next five years, and should periodically review its rate structure to ensure future CIP and
operations needs are met, particularly in light of the current Mitigable Moratorium.
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 Covelo
CSD boundary or SOI.
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
Covelo is a Census Designated Place (CDP) and the primary population center within the District. Covelo
CDP has an MHI of $23,600 and qualifies as a disadvantaged unincorporated community (DUC), and is also
considered a severely disadvantaged community (SDAC) under California Public Resources Code Section
75005 with a MHI of less than 60% the statewide average. Special consideration will be given to any DUCs
affected by future annexation proposals consistent with GC §56375(8)(A) and LAFCo Policy.
The Round Valley Indian Reservation is located adjacent to the District in the northwest portion of Round
Valley. The Round Valley Indian Tribes (RVIT) own and operate its own wastewater treatment facility for
the Reservation.
Chapter 4 – Sphere of Influence Page 4-12
MSR/SOI Update | Covelo CSD
5 REFERENCES
Covelo Community Services District (CCSD). No date (n.d.(a)). Covelo Community Services District
website. [Online] Available at: http://ccsd.roundvalley.org/. Accessed April 16, 17, 27, 2021.
Covelo Community Services District (CCSD). No date (n.d.(b)). Policy Handbook. Policy Title: Job
Description – District Manager. Policy Number 2300.
Covelo Community Services District (CCSD). November 7, 2019. Minutes of Regular Board Meeting.
[Online] Available at: http://ccsd.roundvalley.org/. Accessed April 17, 2021.
Covelo Community Services District (CCSD). March 2020 (2020a). 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.
Covelo Community Services District (CCSD). June 3, 2021 (2021). 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.
Covelo Community Services District (CCSD). 2020c. Fixed Assets 2018-19. Updated by Robertson &
Associates.
California Department of Transportation (Caltrans). 2019 County-Level Economic Forecast: Mendocino
County Economic Forecast. [Online]. Available at: Mendocino_County_Economic_Forecast. Accessed
May 14, 2021.
Federal Emergency Management Agency (FEMA). Flood Map Service Center. Map 06045C0536F.
Effective 06/02/2011. [Online] Available at:
https://msc.fema.gov/portal/search?AddressQuery=covelo%2C%20ca#searchresultsanchor.
Accessed May 8, 2021.
LAFCo, County of Mendocino. October 4, 2010 (2010a). Covelo CSD Sphere of Influence/Municipal
Service Review Report. [Online]. Available at
https://www.mendolafco.org/files/14279c261/Covelo_CSD_MSR.pdf. Accessed April-May 2021.
LAFCo, County of Mendocino. November 4, 2010 (2010b). Certificate of Completion of Covelo
Community Service District Reorganization 2010. Doc. No. 2010-15607.
LAFCo, County of Mendocino. November 4, 2010 (2010c). Certificate of Completion of Travis Annexation
to Covelo Community Service District. Doc. No. 2010-15608.
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 May 15, 2021.
Chapter 5 – References Page 5-1
MSR/SOI Update | Covelo CSD
Mendocino County. No date (n.d.). Mendocino County: Cannabis Permits and Licenses: Cannabis Overlay
Zones website. [Online] Accessed at: https://www.mendocinocounty.org/business/cannabis-
permits-and-licenses. Accessed May 14, 2021.
Mendocino County. September 2008a. Mendocino General Plan Update: Draft Environmental Impact
Report: Chapter 4.9 Land Use.
Mendocino County. September 2008b. Mendocino General Plan Update: Draft Environmental Impact
Report: Chapter 4.11 Population/Housing/Employment.
Mendocino County. August 2009. Mendocino County General Plan: Chapter 6 Community Specific
Policies.
Mendocino County. 2013. Mendocino County Planning and Building Services. Zoning Display Map Sheet
15: Covelo East.
Mendocino County. 2013. Mendocino County Planning and Building Services. Zoning Display Map Sheet
15: Covelo West.
Mendocino County. August 4, 2015. Mendocino County General Plan: Housing Element 2014-2019
Update.
Mendocino County. August 15, 2019. “Approval of Appointments In-Lieu of Election for the November 5,
2019, Consolidated District Election for Candidates Who Filed their Declaration of Candidacy
Paperwork, and Authorize, Prior to November 5, 2019, Additional Appointments of Qualified
Persons be Made for the Covelo Community Services District, Calpella County Water District,
Laytonville County Water District, Willow County Water District, and Caspar South Water District,
Where There Were Insufficient Candidates.” Certificate (Section 10515 Election Code). [Online]
Available at: https://mendocino.legistar.com/LegislationDetail.aspx?ID=4126267&GUID=68244474-
19E2-4C27-975F-98DB3157C7B9&Options=&Search. Accessed April 27, 2021.
Mendocino County. 2021. Mendocino County, CA Public Map Portal. [Website] Available at:
https://gis.mendocinocounty.org/portal/home/. Accessed May 14 and 15, 2021.
North Coast Regional Water Quality Control Board. 2017. Order No. R1-2017-0004, NPDES No.
CA0023574. WDID No 1B830090MEN. Waste Discharge Requirements for the Covelo Community
Services District Wastewater Treatment Plant, Mendocino County.
North Coast Resource Partnership. 2018 /19 Project Application. Covelo Community Services District.
Round Valley Indian Tribes. No date (n.d.). Round Valley Indian Tribes website. [Online] Available at:
https://www.rvit.org. Accessed May 8, 2021.
SHN Consulting Engineers & Geologists, Inc. June 2006. Covelo Wastewater Treatment Facilities
Improvement Project - USDA Amended Preliminary Engineering Report.
Robertson & Associates, CPAs (Robertson). June 20, 2016. Covelo Community Services District, County of
Mendocino, Covelo, California: Annual Financial Report.
Chapter 5 – References Page 5-2
MSR/SOI Update | Covelo CSD
Robertson & Associates, CPAs (Robertson). June 20, 2017. Covelo Community Services District, County of
Mendocino, Covelo, California: Annual Financial Report.
Robertson & Associates, CPAs (Robertson). June 20, 2018. Covelo Community Services District, County of
Mendocino, Covelo, California: Annual Financial Report.
Robertson & Associates, CPAs (Robertson). June 20, 2019. Covelo Community Services District, County of
Mendocino, Covelo, California: Annual Financial Report.
United States Census Bureau (UCSB). 2019a. Annual Estimates of the Resident Population: April 1, 2010-
July 1, 2019. American Community Survey. Table PEPANNRES: Mendocino. [Online]. Available at:
https://data.census.gov/cedsci/table?q=population&t=Populations%20and%20People&g=0500000U
S06045&tid=PEPPOP2019.PEPANNRES. Accessed May 8, 2021.
United States Census Bureau (UCSB). 2019b. ACS Demographic and Housing Estimates. American
Community Survey. Table DP05: Covelo CDP. [Online]. Available at:
https://data.census.gov/cedsci/table?g=1600000US0616728&tid=ACSDP5Y2019.DP05&hidePreview
=true. Accessed May 8, 2021.
United States Census Bureau (UCSB). 2019c. California: Income in the Past 12 Months (in 2019 Inflation-
Adjusted Dollars). American Community Survey. Table S1901: California. [Online]. Available at:
https://data.census.gov/cedsci/table?q=california%20median%20household%20income&tid=ACSST
1Y2019.S1901. Accessed May 14, 2021.
United States Census Bureau (UCSB). 2019d. Covelo CDP: Income in the Past 12 Months (in 2019
Inflation-Adjusted Dollars). American Community Survey. Table S1901: Cpvelo CDP. [Online].
Available at:
https://data.census.gov/cedsci/table?q=california%20median%20household%20income&tid=ACSST
1Y2019.S1901. Accessed 5/14/2021.
Wikipedia. Last edited September 8, 2020. Round Valley Indian Tribes of the Round Valley Reservation
website. [Online]. Available at:
https://en.wikipedia.org/wiki/Round_Valley_Indian_Tribes_of_the_Round_Valley_Reservation.
Accessed May 8, 2021.
Wikipedia. Last edited April 1. 2021. Wikipedia: Covelo, California website. [Online]. Available at:
https://en.wikipedia.org/wiki/Covelo,_California. Accessed May 8, 2021.
Chapter 5 – References Page 5-3
MSR/SOI Update | Covelo CSD
6 ACRONYMS
ACWA Association of California Water Agencies
AF Acre-feet
CCSD Covelo Community Services District
CDP Census Designated Place
CEQA California Environmental Quality Act
CKH Cortese-Knox-Hertzberg Local Government Reorganization Act of 2000
CPA Certified Public Accountant
CSD Community Services District
DUC Disadvantaged Community
FY Fiscal Year
FTE Full Time Equivalent
GPM gallons per minute
I&I Infiltration and inflow
JPA Joint Powers Authority
LAFCo Local Agency Formation Commission
MG million gallons
MGD million gallons per day
MHI Median Household Income
MOU Memorandum of Understanding
MSR Municipal Service Review
REU Residential Equivalent Unit
RVCWD Round Valley County Water District
RVIT Round Valley Indian Tribes
RVAMAC Round Valley Area Municipal Advisory Committee
SB Senate Bill
SDAC Severely Disadvantaged Community
SDRMA Special District Risk Management Association
SOI Sphere of Influence
SOMP System Operation and Maintenance Program
SWRCB State Water Resources Control Board
WWTP Wastewater Treatment Plant
Chapter 6 – Acronyms Page 6-1
MSR/SOI Update | Covelo 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, Executive Officer
Larkyn Feiler, Analyst
Kristen Meadows, 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.
Dane Downing, General Manager
Covelo CSD Tim Dennis, Treatment Plant Operator
Gail Cook, Clerk/Office Manager
Chapter 7 – Acknowledgements Page 7-1
MSR/SOI Update | Covelo 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 | Covelo CSD
8.2 APPENDIX B – WEBSITE COMPLIANCE HANDOUT
Refer to the next page.
Chapter 8 – Appendices Page 8-2
MSR/SOI Update | Covelo CSD
8.3 APPENDIX C – APPLICABLE POLICIES
County of Mendocino 2009 General Plan
Chapter 6: Community – Specific Policies: Covelo Goals and Policies
The following goals, policies, and actions are specific to Covelo, and supplement the countywide goals and
policies elsewhere in this General Plan.
Covelo Community Goals
Goal CP-C-1: Conserve Round Valley’s natural, visual and historical resources while maintaining
agricultural operations including grazing lands.
Goal CP-C-2: Expand economic opportunities in Round Valley consistent with the desired rural character
of the valley.
Goal CP-C-3: Maintain compact development patterns by focusing commercial, residential and community
uses in Covelo.
Covelo Community Area Policies
Policy CP-C-1: Preserve and enhance the established historic character of downtown Covelo.
Action Item CP-C-1.1: Enhance Covelo’s downtown and incorporate beautification improvements through
circulation, streetscapes, signage, landscaping and other means.
Policy CP-C-2: Retain and restore historic buildings and sites.
Policy CP-C-3: The design of new development should reflect the rural character of the Covelo community.
Policy CP-C-4: Discourage subdivision activity in the outlying Rural and Remote Residential lands, including
on lands adjacent to Rangelands and Forest Lands.
Policy CP-C-5: Encourage higher density residential uses, including affordable housing units, in or near the
commercial centers as part of a mixed-use strategy.
Policy CP-C-6: Encourage improvements to existing residential structures.
Policy CP-C-7: Establish places and facilities that create a sense of community.
Action Item CP-C-7.1: Revitalize the commercial core of Covelo as the focal point of the community, with
mixed-use potential for convenience retail, office and residential uses, focusing on the State Route 162
(Covelo Road) corridor and Greely Street.
Action Item CP-C-7.2: Consider installation of a central plaza or gazebo in the downtown.
Policy CP-C-8: Expand and diversify economic ventures.
Policy CP-C-9: The County encourages the expansion of commercial uses in Covelo.
Policy CP-C-10: Commercial uses should be focused near the established core areas along State Route 162.
Policy CP-C-11: Actively pursue light industrial manufacturing employers for Round Valley.
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Action Item CP-C-11.1: Consider placement of a community signboard along State Route 101 at the State
Route 162 intersection advertising services and special events in Round Valley.
Action Item CP-C-11.2: Designate the mill site northwest of the town center as a study area to consider a
range of future land uses, including industrial, light industrial, commercial and other uses supporting jobs
creation for local residents
Policy CP-C-12: Increase economic and social ties with the Round Valley Indian Tribes.
Policy CP-C-13: Encourage joint-use opportunities with Round Valley Indian Reservation.
Policy CP-C-14: Support a community fire hydrant system to facilitate economic and public safety.
Policy CP-C-15: Encourage the Covelo CSD to plan for the provision of a public water system.
Action Item CP-C-15.1: Assist the Covelo Community Services District (CSD) in its efforts to serve future
growth with water capacity consistent with the land use patterns and densities established in the General
Plan.
Policy CP-C-16: Consider upgrades to the Round Valley Airport to support economic development and
emergency services.
Chapter 3 Development Element: Water Supply and Sewer (Wastewater Treatment) Services Policies
Policy DE-186: Coordinate community water and sewer services with General Plan land use densities
and intensities.
Policy DE-187: The County supports efficient and adequate public water and sewer services through
combined service agencies, shared facilities, or other inter-agency agreements.
Action Item DE-187.1: Work aggressively with water and sewer service providers to overcome current
and projected system and supply deficiencies necessary to serve planned community growth.
Action Item DE-187.2: Support funding applications to improve and expand water and sewer service
capabilities in areas planned for future growth or to resolve existing deficiencies.
Action Item DE-187.3: Work with communities and public water and sewer service entities to monitor,
manage and/or maintain community-wide or decentralized water or sewer systems.
Policy DE-188: Encourage water and sewer service providers to incorporate water conservation,
reclamation, and reuse.
• Encourage the development and use of innovative systems and technologies that promote water
conservation, reclamation, and reuse.
• Encourage the development of systems that capture and use methane emissions from their operation.
• Encourage the development and use of innovative systems and technologies for the treatment of
wastewater.
Policy DE-189: Oppose extension of water or sewer services to rural non-community areas when such
extensions are inconsistent with land use and resource objectives of the General Plan, except where the
extension is needed to address a clear public health hazard.
Chapter 8 – Appendices Page 8-4
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Policy DE-190: Development of residential, commercial, or industrial uses shall be supported by water
supply and wastewater treatment systems adequate to serve the long-term needs of the intended
density, intensity, and use.
Policy DE-191: Land use plans and development shall minimize impacts to the quality or quantity of
drinking water supplies.
Chapter 3 Development Element: Infrastructure (Facilities and Services) Policies
Policy DE-117: Deliver programs and services to communities in an integrated, coordinated and equitable
manner, reflective of local conditions.
Policy DE-118: The County shall discourage the extension of sewer and water service outside of areas
designated by this General Plan or any city’s General Plan for urban uses.
Action Item DE-118.1: Work with the Local Agency Formation Commission and service providers to
coordinate service capabilities with this General Plan’s land use designations.
Policy DE-119: Consider infrastructure capabilities, spheres of influence and master service elements
adopted by the Local Agency Formation Commission, and city prezoning when adopting or revising
General Plan elements.
Policy DE-120: General Plan changes to increase density or intensity should not be granted when basic
infrastructure deficiencies are identified unless there is a program in place for timely resolution of the
problem.
Policy DE-121: New discretionary development will be required to demonstrate that basic infrastructure
is available and has adequate capacity to serve the project without degrading existing level of service
standards.
Policy DE-122: When committing to serve new development, the County will encourage service providers
to grant priority to allocation of available and future water resources to lower income housing
developments that help meet the regional housing need.
Policy DE-123: Plans for completion of basic infrastructure should be made concurrent with discretionary
development entitlement actions.
Policy DE-124: Plan for the expansion of commercial and industrial uses and sites for affordable housing
when planning and designing community spaces and infrastructure.
Policy DE-125: The County supports the extension of affordable broadband internet access to all areas of
the county, particularly rural areas which currently (2009) do not have broadband access.
Chapter 3 Development Element: LAFCo Policies
Policy DE-37: Work with LAFCO and other agencies to reduce suburban sprawl, promote efficient service
delivery, and protect agricultural, timber and open space areas from unintended conversion to urban
uses.
Policy DE-118: The County shall discourage the extension of sewer and water service outside of areas
designated by this General Plan or any city’s General Plan for urban uses.
Action Item DE-118.1: Work with the Local Agency Formation Commission and service providers to
coordinate service capabilities with this General Plan’s land use designations.
Chapter 8 – Appendices Page 8-5
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Policy DE-119: Consider infrastructure capabilities, spheres of influence and master service elements
adopted by the Local Agency Formation Commission, and city prezoning when adopting or revising
General Plan elements.
Chapter 8 – Appendices Page 8-6