HomeMy WebLinkAboutMINUTES - 02152011 - C.18 (2)RECOMMENDATION(S):
APPROVE an amendment to the 2011 Federal Legislative Platform to include a policy
position in support of legislation that would modify the Internal Revenue Code and
corresponding regulations to permit public employees to make an irrevocable election
between their current pension formula and a less rich pension formula, as recommended by
the Legislation Committee.
AUTHORIZE Board members, the County’s federal and state legislative representatives
and the County
Administrator, or designee, to prepare and present information, position papers and
testimony in support of this policy position for consideration by CSAC, NACo, etc.
ACCEPT the report on the Carquinez Scenic Drive SF Bay Trail Improvement Project and
concur with its removal from the 2011 Federal Legislative Platform appropriations requests.
APPROVE OTHER
RECOMMENDATION OF CNTY
ADMINISTRATOR
RECOMMENDATION OF BOARD
COMMITTEE
Action of Board On: 02/15/2011 APPROVED AS RECOMMENDED OTHER
Clerks Notes:
VOTE OF SUPERVISORS
AYE:John Gioia, District I
Supervisor
Gayle B. Uilkema, District II
Supervisor
Karen Mitchoff, District IV
Supervisor
Federal D. Glover, District V
Supervisor
Contact: Lara DeLaney,
925-335-1097
I hereby certify that this is a true and correct copy of an action taken and entered on the minutes
of the Board of Supervisors on the date shown.
ATTESTED: February 15, 2011
David J. Twa, County Administrator and Clerk of the Board of Supervisors
By: June McHuen, Deputy
cc:
C.18
To:Board of Supervisors
From:Legislation Committee
Date:February 15, 2011
Contra
Costa
County
Subject:Amendment to 2011 Federal Legislative Platform
FISCAL IMPACT:
Like many local government entities nationwide, the County’s fiscal position would
benefit greatly from reduced pension costs. Allowing local government entities to
implement collective bargaining agreements and state legislation that permits employees
to elect less rich pension formulas would be a significant step in reducing pension costs.
BACKGROUND:
At its January 18, 2011 meeting, the Board of Supervisors adopted the 2011 Federal
Legislative Platform. At the meeting, the Board requested that a matter relating to the
implementation of Public Safety retirement provisions contained in SB 524 (Chapter 633,
Statutes of 2006) be referred to the Legislation Committee. The Board also requested that
the matter of the Carquinez Scenic Drive SF Bay Trail Improvement Project and its
recommended removal from the Federal Legislative Platform be discussed by the
Legislation Committee.
In 2006, Contra Costa County and the Deputy Sheriff’s Association jointly obtained state
legislation that would allow members of the Association to make a one-time irrevocable
election between their current pension formula and a less rich pension formula, called
Tier C. Orange County and its labor organizations obtained similar legislation in 2009.
However, neither County has been able to implement this state legislation because such
elections currently have negative tax consequences for employees and for retirement
plans under federal tax law as interpreted by the Internal Revenue Service.
Like many local government entities nationwide, the County’s fiscal position would
benefit greatly from reduced pension costs. Allowing local government entities to
implement collective bargaining agreements and state legislation that permits employees
to elect less rich pension formulas would be a significant step in reducing pension costs.
Therefore, the Legislation Committee recommends that the Board of Supervisors support
including the following policy position as an amendment to the 2011 Federal Platform:
The County will support legislation that would modify the Internal Revenue Code
and corresponding regulations to permit public employees to make an irrevocable
election between their current pension formula and a less rich pension formula.
The Legislation Committee also recommends that this matter be brought forward to
CSAC and to NACo, as well as to the National League of Cities and the United States
Conference of Mayors for consideration of support.
With regard to the Carquinez Scenic Drive SF Bay Trail Improvement Project, the
Legislation Committee received the following report and concurred with the project
removal from the appropriations requests in the 2011 Federal Platform:
In 2005, Contra Costa County received a federal earmark for $1.0 million for the
Carquinez Scenic Drive SF Bay Trail Improvement Project. The project was estimated to
cost $6.0 million. In October 2010, East Bay Regional Park District (EBRPD) was
awarded a TIGER II federal grant to construct a trail on Carquinez Scenic Drive. The
TIGER II funds and EBRPD’s Measure WW funds will fill the funding gap for the
proposed trail project. Hereafter, EBRPD will be the lead agency for the remaining
preliminary engineering, design, and construction of the Carquinez Scenic Drive SF Bay
Trail Improvements. EBRPD will assume ownership and maintenance of the trail once
constructed.
The trail will be constructed along the closed portion of Carquinez Scenic Drive. EBRPD
has requested the assignment of easement for a trail on Carquinez Scenic Drive. Once the
easement is accepted by EBRPD, Contra Costa County will be vacating the roadway
right-of-way within this closed segment. The Contra Costa County Real Property
Division is currently processing these requests and is expected to complete the
assignment and vacation sometime in April 2011.
A draft MOU between the County and EBRPD has been reviewed by our County
Counsel, and staff hopes to bring the agreement to the full Board for approval in the near
future. In conclusion, it appears the project is now fully funded and, therefore, no
additional appropriations/earmarks are required.
CONSEQUENCE OF NEGATIVE ACTION:
Unless this amendment to the 2011 Federal Legislative Platform is adopted, there will be
no authority for the Board, the County's federal advocate, or staff to pursue legislation
that would achieve the modifications to the Internal Revenue Code and corresponding
regulations to permit public employees to make an irrevocable election between their
current pension formula and a less rich pension formula.
CHILDREN'S IMPACT STATEMENT:
None.
ATTACHMENTS
2011 Federal Legislative Platform - FINAL
2/8/2011 1
2011 FEDERAL LEGISLATIVE PLATFORM
CONTRA COSTA COUNTY
Each year, the Board of Supervisors adopts a Federal Legislative Platform that
establishes project priorities and policy positions with regard to potential federal
legislation and regulation. The 2011 Federal Legislative Platform includes 11 requests
for FFY 2012 appropriations; 3 requests for the reauthorization of the federal
transportation act; and 4 requests for the reauthorization of the Water Resources
Development Act.
FFY 2012 FEDERAL APPROPRIATION REQUESTS
The following list is a preliminary ranking in priority order. Adjustments to the priority order may
be appropriate once the President releases his budget. The current priority ranking gives
preference to those projects that we know will not be included in the President’s budget, with
lower priority to Army Corps of Engineers projects which may be in the budget. Also, Army
Corps project requests will be adjusted to be consistent with Corps capability.
1. Delta LTMS-Pinole Shoal Management, CA – $2,500,000 appropriation for the
Army Corps of Engineers to continue a Long Term Management Strategy (LTMS) for
levee rehabilitation, dredging and sediment reuse in the Delta, similar to the effort
completed in the Bay area. Levee work, reuse of dredged sediments, dredging and
other activities have been difficult to accomplish due to permitting problems and a
divergence of priorities related to water quality. Significant levee rehabilitation is critical
to the long term stability of these levees and to water quality and supply for the 23
million Californians who depend upon this water. Stakeholders from the Department of
Water Resources, Ports, Army Corps, levee reclamation districts, local governments
and other interested parties are participating in the LTMS. A Sediment or Dredged
Material Management Office will be established, and in the longer term, preparation of a
Sediment Management Plan will consider beneficial reuse of dredged materials as one
potential source of sediment for levees. (Note: $500,000 appropriated for FFY 2005;
$225,000 for FFY 2006; $500,000 for FFY 2007; $462,000 for FFY 2008; $235,000 for FFY
2009; $100,000 for FFY 2010.)
2. Safe and Bright Futures for Children Exposed to Domestic Violence –
$400,000 appropriation to implement the federally funded plan to diminish the damaging
effects of domestic violence on children and adolescents and to stop the cycle of
intentional injury and abuse. A three year assessment and planning process resulted in
a program plan that will align and create a system responsive to the needs of children
exposed to domestic violence through identification, intervention, a nd treatment; raising
awareness; training professionals; utilizing and disseminating data; establishing
consultation teams to support providers in intervening and using best practices; and
developing targeted services. The local domestic violence hotline received over 3,100
calls involving children last year (60% of all calls). Exposure to trauma like domestic
violence reshapes the human brain, influences personality, shapes personal skills and
behaviors, impacts academic performance, and substantially contributes to the high
2011 Federal Legislative Platform
Contra Costa County
2/8/2011 2011 Federal Platform 2
cost of law enforcement, civil/criminal justice and social services. (Note: $428,000
appropriated for FFY 2009; $550,000 for FFY 2010.)
3. Mt. Diablo Mercury Mine Clean-up – $483,000 appropriation for the Army Corps of
Engineers to complete phase 3 and 4 of the Technical Planning Process for the Mt.
Diablo Mercury Mine Demonstration Project. The project will clean up the mine in a
cost effective, environmentally-sound manner with minimal liability exposure for the
County and involving all stakeholders through an open community-based process. The
Corps initiated a Technical Planning Process in Jun e 2008 to develop a preliminary
remediation plan, identify applicable permit and environmental data requirements and
complete a data collection and documentation program for the clean -up of the Mt.
Diablo Mercury Mine. Phase 1 and 2 of the planning proces s has been completed and
this appropriation will allow the Corps to continue the planning process and complete
phase 3 and 4. The planning process will include looking at watershed issues
downstream of the mercury mine. The Corps will be focusing on the mine site and the
local Contra Costa County Flood Control District will be focusing on the broader
watershed issues. The mine site is located on private property on the northeast slope of
Mt. Diablo at the upper end of the Marsh Creek watershed. (Note: $517,000
appropriated in FFY 2008.)
4. Lower Walnut Creek, California – $600,000 appropriation for the Army Corps of
Engineers continue their general reevaluation of the lower five miles of the Walnut
Creek Channel to restore flood capacity, provide e nvironmental enhancement and
ecosystem restoration. The project is designed to help improve flood protection in a
densely populated area, while leaving the creek in a natural state, thus providing habitat
for migratory birds, fish and other wildlife; incre asing neighborhood livability; and
allowing for linkages with recreational and park land. (Note: $188,000 appropriated for
FFY 2006; no FFY 2007 appropriation; $562,000 for FFY 2008; $287,000 for FFY 2009; $0 for
FFY 2010.)
5. Grayson and Murderer’s Creeks (Walnut Creek Basin), California – $600,000
appropriation for the Army Corps of Engineers to analyze Grayson and Murderer’s
Creeks to determine the feasibility of providing improved flood protection for a
community that regularly experiences flood damages. The project is designed to help
improve flood protection in a densely populated area, while leaving the creeks in a
natural state, thus providing habitat for migratory birds, fish and other wildlife; increasing
neighborhood livability; and allowing for linkages with recreational and park land. (Note:
$100,000 appropriated for FFY 2006; no FFY 2007 appropriation; $98,000 for FFY 2008.;
$478,000 for FFY 2009; $90,000 for FFY 2010.)
6. CALFED Bay Delta Reauthorization Act Levee Stability Improvement Program
(LSIP) – $20,000,000 appropriation for the Army Corps of Engineers for levee
rehabilitation planning and project implementation. The CALFED Reauthorization Act,
passed in January 2004, authorized $90 million, which may be appropriated for levee
rehabilitation work. The Corps has prepared a “180 -Day Report” which identifies
projects and determines how these funds would be spent. Since that time, the
breakdown of CALFED, coupled with the Army Corps’ attempts to define an appropriate
2011 Federal Legislative Platform
Contra Costa County
2/8/2011 2011 Federal Platform 3
and streamlined process, has delayed funding and resultant levee work. (Note:
$500,000 appropriated for FFY 2006; $400,000 for FFY 2007; $4.92 million for FFY 2008;
$4.844 million for FFY 2010.)
7. Suisun Bay Channel/New York Slough Maintenance Dredging – $5,275,000
appropriation for the Army Corps of Engineers for maintenance dredging of this channel
to the authorized depth of minus 35 feet. Continued maintenance is essential for safe
transport of crude oil and other bulk materials through the San Francisco Bay, a long the
Carquinez Straits and into the Sacramento/San Joaquin Delta. Dredging for this channel
section is particularly costly due to requirements on placement of dredged materials in
upland environments. An oil tanker ran aground in early 2001 due to seve re shoaling in
a section of this channel, which creates a greater potential for oil spills (Note: $4.559
million appropriated for FFY 2005; $4.619 million for FFY 2006; $2.82 million for FFY 2007;
$2.856 million for FFY 2008; $2.768 million for FFY 2009; $3.819 million for FFY 2010.)
8. San Pablo/Mare Island Strait/Pinole Shoal Channel Maintenance Dredging –
$5,400,000 appropriation for the Army Corps of Engineers ($2.65 million for Mare
Island) for maintenance dredging of the channel to the authorize d depth of minus 35
feet. The Pinole Shoal channel is a major arterial for vessel transport through the San
Francisco Bay region, serving oil refineries and bulk cargo which is transported as far
east as Sacramento and Stockton. (Note: $1 million appropriated for FFY 2005; $2.988
million for FFY 2006; $896,000 for FFY 2007; $1.696 million for FFY 2008; $1.058 million for
FFY 2009; $2.518 million for FFY 2010.)
9. San Francisco to Stockton (J. F. Baldwin and Stockton Channels) Ship
Channel Deepening – $1,800,000 appropriation for the Army Corps of Engineers to
continue the Deepening Project. Deepening and minor realignment of this channel will
allow for operational efficiencies for many different industries, an increase in waterborne
goods movement, reduced congestion on roadways, and air quality benefits. Phase
one work focused on establishing economic benefit to the nation and initial salinity
modeling in the channel sections. The second and final phase includes detailed channel
design, environmental documentation, cost analysis, additional modeling, and dredged
material disposal options. (Note: $500,000 appropriated for FFY 2005; $200,000 for FFY
2006; $200,000 for FFY 2007; $403,000 for FFY 2008; $1.34 million for FFY 2009; $0 for FFY
2010.)
10. Contra Costa County’s VHF Public Safety Radio System – $1,063,200
appropriation for Contra Costa County operation of a VHF Public Safety Radio System
serving several governmental agencies (including emergency medical services) within
the county. This system will soon become a backup (VHF overlay) to the East Bay
Regional Communication System (EBRCS) once that system is completed and
actuated. To comply with upcoming Federal Communications Commission (FCC)
narrow band requirements, the VHF system must be upgraded to ensure seamless
compatibility with certain aspects of the EBRCS, should that system fail. To prevent the
VHF system from being compromised, several significant security enhancements are
necessary at various site locations. This includes camera monitoring and alert systems.
2011 Federal Legislative Platform
Contra Costa County
2/8/2011 2011 Federal Platform 4
11. State Route 4 / Old River Bridge Study – $1,000,000 appropriation to work with
San Joaquin County and the State of California on a study of improving or replacing the
Old River Bridge along State Route 4 on the Contra Costa / San Joaquin County line.
The study would determine a preferred alternative for expanding or replacing the
existing bridge, which is part of State Route 4. The existing bridge is narrow, barely
allowing two vehicles to pass each other, and is aligned on a difficult angle relative to
the highway on either side, requiring motorists to make sharp turns onto and off of the
bridge. The project would improve safety and traffic flow over the bridge. (Note: no
appropriations for this project as yet.)
2011 REAUTHORIZATION OF FEDERAL TRANSPORTATION ACT
The current federal transportation policy and spending act, a five-year act known as the Safe,
Accountable, Flexible and Efficient Transportation Equity Act – A Legacy for Users, or
SAFETEA-LU, expired in 2009. Its reauthorization will likely be crafted during the year. The
following are priority projects for inclusion in the next multi-year transportation bill.
1. Vasco Road Safety Improvement Project -- $30 million (reduced from $40 million
in 2009 platform, due to receipt of $10 million in ARRA funds) for improvements to a
2.5-mile accident-prone section of Vasco Road. Project components include widening
the roadway to accommodate a concrete median barrier and shoulders on either side of
the barrier, construction of the barrier, and extension of an existing passing lane. The
project will eliminate cross-median accidents which have caused numerous fatalities in
recent years, and will provide increased opportunities for vehicles to safely pass (unsaf e
passing is a major cause of accidents and fatalities on this segment of the increasingly
busy two-lane undivided road). The project will include provisions for wildlife
undercrossings to preserve migration patterns. The funds will complement $10 millio n
programmed for the project in the American Recovery and Reinvestment Act. (10th/11th
Districts, Garamendi/ McNerney)
2. North Richmond Truck Route -- $25 million (increased from $15.5 million in the
2009 platform due to engineering issues pertaining to levees and railroad right of way)
to construct a new road that will provide truck access between businesses and the
Richmond Parkway, moving the truck traffic away from a residential neighborhood and
elementary school. This project will increase safety, improve public health around the
school and residential area by reducing diesel particulate emissions from those areas,
increase livability of the neighborhood, improve local ac cess to the Wildcat Creek
Regional Trail, stimulate economic development in the industrial area of the community
and provide a better route for trucks traveling to and from the Richmond Parkway. The
alignment was developed through a community planning process funded through an
Environmental Justice planning grant from Caltrans. (7th District, Miller)
3. Eastern Contra Costa Trail Network -- $5 million for a joint planning,
environmental review, right-of-way acquisition and constructions of a coordinated
network of trails for walking, bicycling and equestrian uses in eastern Contr a Costa
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Contra Costa County
2/8/2011 2011 Federal Platform 5
County. Eligible trails include, but are not limited to, (1) the Mokelumne Trail
overcrossing of the State Route 4 Bypass; (2) Contra Costa segments of the Great
California Delta Trail; (3) a supportive network of East Contra Costa trails in
unincorporated County areas and the cities of Antioch, Brentwood, Oakley and Pittsburg
(All districts)
Following are priority programs for inclusion in the next multi-year transportation bill:
Rural Road Funding Program – The County supports the creation of a new funding
program that will provide funds for converting or upgrading rural roads into more
modern roads that can handle increasing commuter traffic in growing areas, such as
East County. These roads do not often compete well in current grant programs because
they do not carry as many vehicles as roads in more congested urban or suburban
areas. As a result, improvements such as widening, realignment, drainage
improvements and intersection modifications often go unfunded, leaving such roads
with operational and safety problems as well as insufficient capacity. (All districts)
Transportation Funding for Disabled, Low-income, and Elderly Persons – The
County supports continuation and increased funding levels for the three federal funding
programs dedicated to transit services for these population groups -- the New Freedom
Program for senior transit services, the Job Access and Reverse Commute Program
which funds transit services to job locations for low-income persons, and the Section
5310 transit funding program for the elderly and individuals with disabilities. SAFETEA-
LU provided a total of $1.7 billion nationwide for these programs. By comparison, $200
billion was provided for highway projects; even transportation research got more funding
($2.3 billion) than transit for elderly, disabled and low-income persons. All of the
demographic trends point to a growing need for such services in the future. For
example, the 65-and-older population in the Bay Area is projected to more than double
by the year 2030.
Transit services for elderly, disabled, and low-income persons are provided by the
County, by some cities, by all of the bus transit operators, and by many community
organizations and non-profits that provide social services. Increased funding is needed to
provide and maintain more service vehicles, operate them longer throughout the day,
upgrade the vehicle fleet and dispatching systems, improve coordination between public
providers and community groups that also provide such services to their clients, and
expand outreach programs to inform potential riders of the available services, among
other needs. (All districts)
REAUTHORIZATION OF WATER RESOURCES DEVELOPMENT ACT (WRDA)
The Water Resources Development Act of 2007 became law in November, more than seven
years after the last authorization bill. The House and Senate Committees may propose a
WRDA bill in 2011. The following are projects the County would submit for inclusion.
2011 Federal Legislative Platform
Contra Costa County
2/8/2011 2011 Federal Platform 6
1. Mt. Diablo Mercury Mine Clean-up - Authorize the Army Corps of Engineers,
through their Remediation of Abandoned Mine Site program (RAMS), to perform and
complete the Technical Planning Process and site characterization of the Mt. Diablo
Mercury Mine in Contra Costa County as a demonstration project with no local match,
and authorize the Army Corps of Engineers to construct the clean-up project at the Mt.
Diablo Mercury Mine. This mine remediation project is the first to combine the Corps’
RAMS program and partnering agreements with local government to resolve liability
issues associated with a clean-up project on private property and address mercury
pollution on a watershed basis. Since this is a demonstration project, the Corps would
fund the full Technical Planning Process Remedial Investigation, design and project
construction.
A 1995 study of Marsh Creek indicated the Mt. Diablo Mercury Mine tailings are
responsible for 88% of the mercury in Marsh Creek. In addition, mercury levels in fish in
Marsh Creek Reservoir downstream of the mine exceed the health standard
concentration of 0.5 ppm.
2. Sacramento San Joaquin Delta Infrastructure Improvements –Contra Costa
County, together with the four other Delta counties of Sacramento, San Joaquin, Solano
and Yolo, is requesting authorization for the Army Corps of Engineers to repair
infrastructure in the Delta. This includes levees rehabilitation projects in the Delta as
part of an overall system, rather than on a county-by-county or island-by-island basis.
As the Administration has recognized, this ecosystem is among the mos t important in
the nation, providing a source of drinking water for more than 25 million people ,
supporting a $28 billion agricultural industry, and fostering a thriving commercial and
recreational fishing industry that contributes millions to the California and national
economies. The project is a request for an authorization of $2.5 billion for the Army
Corps of Engineers to upgrade the levee system, including stockpiling rock to rebuild
collapsed levees for emergency response purposes at selected areas of the Delta.
Because of the importance of the Delta to the nation’s agriculture and economy, the
request includes a modification of the Federal/local cost share to 90% federal and 10%
local.
3. Rodeo Creek, Section 1135 Project – The Contra Costa Flood Control and Water
Conservation District is seeking an 1135 project authorization for the Army Corps of
Engineers to prepare a study of the feasibility of restoring and enhancing wildlife
resources in Rodeo Creek between San Pablo Bay and Highway 80. The channel was
designed and constructed to provide adequate flood protection for the community of
Rodeo and to control erosion of the creek. The channel currently does this, but
requires extensive, environmentally insensitive maintenance to keep the channe l
functioning properly. In addition, the current channel design includes barriers to
migration of anadromous fish. The Contra Costa Flood Control and Water Conservation
District would like to partner again with the Corps of Engineers under the Corps' 1135
program to transform this outdated design into a sustainable, environmentally sensitive
facility that better serves the community and the environment.
2011 Federal Legislative Platform
Contra Costa County
2/8/2011 2011 Federal Platform 7
4. Rheem Creek, Section 1135 Project – The Contra Costa Flood Control and Water
Conservation District is seeking an 1135 project authorization for Rheem Creek
between the mouth at San Pablo Bay and Giant Road. The Army Corps of Engineers'
existing flood protection project on Rheem Creek protects a number of commercial,
industrial, residential and open space areas in the Richmond / San Pablo area of Contra
Costa County. Surrounding the mouth of the creek is a large undeveloped parcel
(Brunner Marsh) which has been acquired by the East Bay Regional Park District for a
future public park. Development of the adjacent lands as a regional park provides a
unique opportunity for an enhanced creek environment in an area that will be very
visible to the public.
APPROPRIATIONS AND GRANTS – SUPPORT POSITIONS
The following support positions are listed in alphabetic order and do not reflect priority order.
Please note that new and revised positions are highlighted and in italics.
Buchanan Field Airport – The County approved a Master Plan for the Buchanan Field
Airport in October 2008, which includes a Federal Aviation Regulation Part 150 Noise
Study and a Business Plan for project implementation. The comprehensive planning
effort has ideally positioned Buchanan Field Airport for future aviation (general aviation,
corporate aviation and commercial airline service) and aviation-related opportunities. To
facilitate the economic development potential, the Business Plan prioritizes necessary
infrastructure improvements for Buchanan Field Airport. Further, as the Airport is
surrounded by urban residential uses, enhancing the noise program infrastructure is
deemed essential for balancing the aviation needs with those of the surrounding
communities. The Federal government, primarily through the Federal Aviation
Administration (FAA), provides funding for planning, analysis, and infrastructure
improvements. The County will support funding in all these areas for protection and
enhancement of our aviation facility and network.
Byron Airport – The Byron Airport is poised for future general and corporate aviation
and aviation-related development, but that future growth is dependent upon
infrastructure improvements both on and around the Airport. The Byron Airport Business
Plan prioritizes infrastructure and possible additional land acquisition to assist the Byron
Airport in fulfilling its aviation and economic development potential. The Federal
government, primarily through the Federal Aviation Administration (FAA), provides
funding for planning, analysis, infrastructure improvements and aviation land
acquisition. The County will support funding in all these areas for protection and
enhancement of our aviation facility and network.
East Bay Regional Communication System (EBRCS) – $3 million appropriation to
build the East Bay Regional Communication System (EBRCS), a P25 Radio Sys tem
infrastructure for Contra Costa and Alameda County. This system will provide
interoperable voice communication in both the 800 MHz and 700 MHz frequencies to all
public safety and public services agencies within Contra Costa County and Alameda
County.
2011 Federal Legislative Platform
Contra Costa County
2/8/2011 2011 Federal Platform 8
EBRCS will allow for interoperable voice communication within the region that can be
integrated with other P25 radio systems outside the geographical area of the EBRCS,
for example, with San Francisco. This project will provide Level 5 communications
which is the highest level of interoperable communications. This project will allow for
everyday interoperable communications, not just various levels of interoperability during
big events or disasters in which radio caches are deployed or gateway devices used.
Energy Efficiency & Conservation Block Grant (EECBG) Program –
Advocate/support appropriation of funding up to the authorized amount of $2 billion for
the EECBG Program established and authorized under the Energy Independence and
Security Act (EISA) of 2007. The County’s ability to continue offering programs/services
improving energy efficiency and conservation while also creating jobs is contingent
upon additional federal funding being appropriated to the EECBG Program in 2012 and
beyond. Contra Costa and other local governments have identified and designed many
successful programs and financial incentives targeting both the private and public sector
which are now being implemented using EECBG funding authorized through the ARRA
of 2009. Appropriation of funding for the EECBG program 2012 is necessary to ensure
the nation’s local governments can continue their leadership in creating clean energy
jobs, reducing energy consumption and curbing greenhouse gas emissions.
Kirker Pass Road Truck Climbing Lane – $10 million appropriation (reduced from $31
million due to availability of other funding and focusing initially on the northbound
direction) for constructing northbound and southbound truck climbing lanes on Kirker Pass
Road, a heavily used arterial linking residential areas in eastern Contra Costa with job
centers and the freeway system in central Contra Costa. The truck climbing lanes are
needed to improve traffic flow and will also have safety benefits. The $31 million would
augment $3 million in State Infrastructure Proposition 1B funds which the County has
allocated for the project.
Regional Habitat Planning and Conservation – $100 million appropriation to the U.S.
Fish and Wildlife Service’s “Cooperative Endangered Species Conservation Fund” to
keep pace with land costs and the increasing number of Habitat Conservation Plans
(HCPs) throughout the country. In partnership with approximately a dozen counties in
northern and southern California, the County will support a request that funding for the
Fund increase from the $85 million 2010 level to $100 million in FY2012. This will
provide much needed support to regional HCPs in California and nationally, including
the East Contra Costa County HCP. Given the prolific growth in the number of regi onal
HCPs, the Fund needs to be increased even more substantially in subsequent years.
The East Contra Costa County HCP has received $28 million from the Cooperative
Endangered Species Conservation Fund in the past five years and continuing this grant
support is of vital importance to the successful implementation of that Plan. The County
will also request that the California State Association of Counties (CSAC) include this
Fund increase as a priority on CSAC’s federal platform.
2011 Federal Legislative Platform
Contra Costa County
2/8/2011 2011 Federal Platform 9
San Francisco Bay, Long Term Management Strategy (LTMS), Environmental
Windows, Science Projects – $3.45 million appropriation for the Army Corps of
Engineers’ “Environmental Windows Science Projects” as part of the Bay Area Long
Term Management Strategy (LTMS). Environmental Windows are limited timeframes
when dredging and, to some extent, disposal can occur within San Francisco Bay and
environs. However, the existing windows are based on old and, in some cases, little or
no scientific basis. This project would identify where add itional science is necessary,
prioritize science projects, obtain funding and oversee these scientific studies. The
broad-based coalition includes the Bay LTMS Agencies (EPA, BCDC, Corps, Regional
Water Board), resource agencies (USFWS, NOAA Fisheries, State Fish and Game) and
a number of other agencies, organizations and individuals.
San Francisco Bay Improvement Act– $1 billion restoration bill authored by
Congresswoman Jackie Speier in 2010 but not passed. The bill, if passed, will help
finance restoration of more than 100,000 acres of the Bay's tidal wetlands. Funds from
the bill would implement a restoration plan that was adopted in 1993. In addition to
benefits for fish and wildlife, wetlands restoration will create new jobs and provide
regional economic infusions, as well as protect against the effects of sea level rise on
the Bay's shores.
Sacramento-San Joaquin Delta National Heritage Area– $10 million bill authored by
Senator Dianne Feinstein in 2010 but not passed. The bill, if passed, will authorize and
fund a National Heritage Area (NHA) for the Sacramento-San Joaquin Delta. The
NHA designation would be a first step in providing federal resources to agencies in the
Delta for economic development and environmental protection.
Vasco Road-Byron Highway Connector – $30 million appropriation (increased from
$10 million in 2009 platform due to costs of state and federal environmental review, and
anticipated cost increases) for design, engineering and construction of an east-west
connector road between two major arterials that link Contra Costa County with Alameda
and San Joaquin Counties. The Vasco Road-Byron Highway Connector will improve
traffic circulation and linkages in the southeastern portion of the County and will provide a
new route for truck traffic that will remove a significant portion of truck trips which currently
pass through the rural community of Byron. Vasco Road is designated as State Route 84,
and Byron Highway is under study as the potential alignment for future State Route 239.
2011 FEDERAL LEGISLATIVE PLATFORM POLICY POSITIONS
The following support positions are listed in alphabetic order and do not reflect priority order.
Please note that new and revised policy positions are highlighted and in italics.
Affordable Housing and Homeless Programs –For Housing and Urban Development
(HUD)’s Homeless Assistance Grants, the County will support funding that does not
include set-asides or other requirements that limit local communities’ ability to respond
to the particular needs in their areas. For the Housing Assistance for People with AIDS
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(HOPWA) program, the County will support legislation to update the formula used to
allocate HOPWA grants to reflect local housing costs as well as the number of AIDS
cases.
The County supports full funding for HUD homeless assistance programs. As Congress
considers McKinney-Vento reauthorization legislation, the County will advocate for
greater local flexibility, including an expanded definition of homelessness that will allow
agencies to better respond to locally-determined needs.
Congress should include a formula-driven affordable housing production program in the
final version of Government Sponsored Enterprise reform legislation. The County also
supports the National Affordable Housing Trust Fund Act.
Resources made available through any new affordable housing production program
should be accessible to local housing and community development agencies, including
public housing authorities. As the present home mortgage crisis demonstrates,
homeownership is not for everyone. While we value and support the role that
homeownership plays in meeting affordable housing needs, any new production
program should prioritize efforts to address our nation’s acute shortage of affordable
rental housing.
Agricultural Pest and Disease Control – Agriculture and native environments in
Contra Costa County continue to be threatened by a variety of invasive/exotic pests,
diseases and non-native weeds. The Federal government provides funding for
research, regulation, pest exclusion activities, survey and detection, pest management,
weed control, public education and outreach. The County will support funding in all
these areas for protection of our agricultural industry and open space. Consistent with
the policy position, the County will also support legislation which would authorize and
direct the USDA to provide state and local funding for High Risk Prevention programs
(also called Pest Detection Funding).
Beneficial Use of Dredged Materials – As the beneficial reuse of dredged materials
has a clear public benefit, particularly in the Delta, the County will continue to support
beneficial reuse in general and also continue to advocate for funding for a federal study
to determine the feasibility of beneficial reuse, considering the benefits and impacts to
water quality and water supply in the Delta, navigation, flood control damage,
ecosystem restoration, and recreation. The study would include the feasibility of using
Sherman Island as a rehandling site for the dredged material, for levee maintenance
and/or ecosystem restoration. Language to authorize the study was included in the
Water Resources and Development Act (WRDA) which was passed into law on
November 8, 2007.
Child Care – The vulnerable children and families we serve face some of the most
difficult circumstances of their lifetimes, as unemployment and loss of health insurance
increase rapidly, more families are face foreclosure, and food assistance use hits record
highs. Our agencies confront sharply rising caseloads and service demands as state
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and local budget deficits grow. With respect to issues of child care, the County will
advocate for the following federal actions:
Increase funding to support employment of low-income families through greater access
to child care subsidies, and increase the access of children from eligible families to
high-quality care that supports positive child development outcomes. [Legislative]
Provide flexibility at the state and local levels so that quality care can be balanced with
access and parental choice.
Require coordination at the federal level among the various early child care and
education funding streams.
Child Support –The County will advocate for the following federal actions:
Eliminate the $25 fee for non-IV-A families.
Restore the incentive match payments that were prohibited in the Deficit
Reduction Act.
Allow the automatic use of cash medical support to reimburse Medicaid
expenditures.
Allow IV-D agencies to access Health Insurance records for the purposes of
Medical Support.
Child Welfare and Well-being –The County will advocate for the following federal
actions:
Provide states with financial incentives, as opposed to monetary penalties, under
the Child and Family Services Reviews and minimize the significant
administrative burden associated with the review process.
End Title IV-E disallowances from federal audits that take away funds from an
already resource-strapped child welfare system. Allow states to reinvest these
funds in preventing child abuse and neglect.
Increase prevention dollars to help maintain children safely in their own homes.
Federal funding currently gives disproportional support to out -of-home care
rather than to preventing children from coming into care.
Any increase in Federal Medical Assistance Percentage should include an
associated increase in the Title IV-E matching rate to help support children in
foster care.
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Community Development Block Grant and HOME Programs – The County’s ability
to continue to provide funding to a variety of nonprofit agencies that provide critical
services to lower income residents, including financing the development of affordable
housing, is threatened by the Administration’s proposal to cut the CDBG and program
as part of the FY 2012 federal budget. The County will oppose proposed cuts in these
vital community development programs.
In addition, the County will oppose any proposed changes in the CDBG allocation
formula. CDBG formula funding has declined by 17 percent si nce FY 2004 while the
HOME program’s funding has declined by 12 percent during the same period. Both
programs need to have funding restored.
At present, the HOME program is the only federal source of affordable housing
production funding. The County supports increased funding for HOME, particularly
formula grants.
Cost Shifts to Local and State Government – Contra Costa County performs many of
its services and programs pursuant to federal direction and funding. Other services and
programs are performed at the behest of the state, which receives funding through the
federal government. In the past, the Administration’s budget has contained significant
cuts to entitlement programs and/or caps on entitlements. Such actions could shift cost
of services from the federal government to the state and/or local governments (and to
the extent that costs would shift to the state, it is highly likely that these would be
passed on to the County). The County will oppose any actions that would result in cost
shifts on federal entitlement programs or which would result on greater dependency on
county funded programs. In addition, the County will support federal and state financial
assistance to aid county and local government efforts to meet unfunded federal
mandates, such as those contained in the National Response Plan (NRP), the National
Infrastructure Protection Plan (NIPP), and the National Incident Management System.
Criminal Debt Collection – Nonpayment of court-ordered victim restitution, fines and
fees is a problem of epidemic proportions for all jurisdictions. Literally billions of dollars
go uncollected each year across the country, resulting not only in financial suffering of
victims, but also the loss of public revenue. Many states already allow for the offset of
State Tax Refunds, and these programs are successful in achieving revenue recovery.
Federal Tax Refunds are already being successfully offset to pay for delinquent child
support. The County will support amendments to the Internal Revenue Code of 1986 to
allow an offset against income tax refunds to pay for court-ordered debts that are past-
due.
Designation of Indian Tribal Lands and Indian Gaming – The Board of Supervisors
has endorsed the California State Association of Counties ’ (CSAC) policy documents
regarding development on tribal land and prerequisites to Indian gaming. These policy
statements address local government concerns for such issues as the federal
government’s ability to take lands into trust and thus remove them from local land use
jurisdiction, absent the consent of the state and the affected county; the need for tribes
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to be responsible for all off -reservation impacts of their actions; and assurance that
local government will be able to continue to meet its governm ental responsibilities for
the health, safety, environment, infrastructure and general welfare of all members of its
communities. The County will continue to advocate for federal legislation and regulation
that supports the CSAC policy documents.
The County will also advocate for limitations on reservation shopping; tightening the
definition of Class II gaming machines; assuring protection of the environment and
public health and safety; and full mitigation of the off -reservation impacts of the trust
land and its operations, including the increased cost of services and lost revenues to the
County.
The County will also advocate for greater transparency, accountability and appeal
opportunities for local government in the decision-making processes that permit the
establishment of Indian gaming facilities. This includes sequencing the processes so
that the Indian Lands Determination comes first, prior to initiation of a trust land request
and associated environmental review.
The County will also consider support for federal action and/or legislation that allows
Class III gaming at the existing gaming facility only if it can be shown that any change
would result in a facility that would be unique in nature and the facility can demonstrate
significant community benefits above and beyond the costs associated with mitigating
community impacts.
Economic Development Programs – Congress should fund all the complementary
programs within HUD’s community and economic development toolkit, ensuring that
HUD does not lose sight of the development component of its mission. To that end, the
County will support continued funding for the Section 108 loan guarantee program, the
Brownfields Economic Development Initiative and the Rural Housing and Economic
Development program. Each of these programs plays a unique role in building stronger,
more economically viable communities, while enabling communities to leverage external
financing in a way the CDBG program alone cannot do.
Federal “Statewideness” Requirements – For many federally funded programs, there
is a “statewideness” requirement; i.e., all counties must operate the specific program
under the same rules and regulations. This can hamper the County’s ability to meet
local needs, to be cost effective and to leverage the funding of one program to reduce
costs in another program. Contra Costa County cannot negotiate for federal waivers or
do things differently because it is not a state, yet its population is greater than seven
states. Recognizing this is a very long-term effort, the County will advocate for
relaxation of the “statewideness” rule to allow individual counties or a consortium of
counties to receive direct waivers from the federal government and/or adopt the rules
and regulations currently in use in another state for specific programs.
Habitat Conservation Planning – The County will advocate for elevating the profile of
Habitat Conservation Plans (HCPs) such as the East Contra Costa County HCP within
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Congress and Administration so that these critical federal/state/local partnerships can
receive necessary attention and support. HCPs are flagship programs for the federal
government and supporting effective implementation of approved HCPs should be a top
priority for the U.S. Department of the Interior and U.S. Fish and Wildlife Service and
HCPs should be a key tool in any federal climate change or economic stimulus
legislation.
Health – The County will advocate for the following actions by the federal government:
provide enhanced Medicaid FMAP ("FMAP" is the "Federal Medical Assistance
Percentage") for Medicaid. It is the federal matching rate for state Medicaid
expenditures. Increasing the federal matching rate for states would free up state
general fund money for other purposes and would help counties as well.); suspend the
Medicare “clawback” rule; suspend the “60-day rule” that requires states to repay the
federal government overpayments identified by the state prior to collection, and even in
instances where the state can never collect; ease the ability to cover those eligible for
Medicaid by making documentation requirements less stringent; and prevent the
implementation of the following seven federal regulations:
Outpatient hospital
Case Management
School Based Administration & Transportation
Public Provider Cost Limit
Graduate Medical Education
Rehabilitation Services Option
Provider Tax
Pension– The County will support legislation that would modify the Internal Revenue
Code and corresponding regulations to permit public employees to make an irrevocable
election between their current pension formula and a less rich pension formula.
In 2006, Contra Costa County and the Deputy Sheriff’s Association jointly o btained state
legislation that would allow members of th e Association to make a one-time irrevocable
election between their current pension formula and a less rich pension formula, called
Tier C. Orange County and its labor organizations obtained similar legislation in 2009.
However, neither County has been able to implement this state legislation because
such elections currently have negative tax consequences for employees and for
retirement plans under federal tax law as interpreted by the Internal Reve nue Service.
Like many local government entities nationwide, the County’s fiscal position would
benefit greatly from reduced pension costs. Allowing local government entities to
implement collective bargaining agreements and state legislation that permits
employees to elect less rich pension formulas would be a significant step in reducing
pension costs.
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Public Housing Programs –Years of disinvestment threaten the viability of public
housing and the well-being of millions of our neediest citizens. Preservatio n of the
existing inventory of public housing units is critical not just to families currently residing
in public housing, but also to the millions of families waiting for assistance. The Public
Housing program is now in critical condition. The County will support full funding for
public housing operations; sufficient funding to help preserve the existing inventory of
public housing; funding for unforeseen emergencies or disasters at the former annual
levels; and reauthorizing legislation for the HOPE VI p rogram and funding HOPE VI at
least at its original level of $600 million.
The County will support funding of at least $72 million for Family Self Sufficiency (FSS)
coordinators. FSS is a mandatory program for any housing agency that received new
vouchers many years ago, but only about 22 percent of agencies receive funding to
operate the program, due to recent changes in the program’s competitive funding
process. Every agency that needs assistance to operate this mandatory program should
receive it.
The County will support the enactment of federal legislation to preserve existing public
housing stock by addressing the huge unfunded capital needs of public housing through
the use of federal income tax credits, tax credit supported bonds and other means.
The County will support putting to use public housing assets valued in excess of $100
billion by fully enabling public housing authorities to finance the rehabilitation and
preservation of public housing by encumbering public housing properties as
contemplated by the Quality Housing and Work Responsibility Act of 1998 (QHWRA).
The County will support the enactment of a Public Housing Conversion Pilot in which up
to 100 asset management projects are converted to project-based Section 8 assistance
with oversight transferred to HUD’s Office of Housing.
The County will support the development of legislation to reauthorize the HOPE VI
program that is workable and accessible to public housing authorities of varying sizes.
The County will support enactment of permanent authorization for the Moving to Work
Demonstration Program.
The County will support reform of the contractual relationship between public housing
authorities and the federal government, so that federal administrative and regulatory
demands fairly reflect resources provided, and federal subsidies for public housing are
predictable, adequate and stable.
The County will support a reasonable transition to asset management of public housing
with an optional exemption for agencies operating fewer than 500 public housing units.
The County will support the Administrative Reform Initiative (ARI) process begun at
HUD in 2007 for regulatory and administrative reform and seek meaningful, practicable
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reform of federal oversight activities pertaining to LHAs and the federal programs they
administer.
The County will support the development of alternatives to existing methods of
evaluating the performance of LHAs and their programs and properties.
The Section 8 HCV program has a demonstrated track record of success. Nonetheless,
the HCV program can be further improved to provide public housing authorities with
additional tools to help maximize the number of families served in their communities.
Legislative and regulatory reform should include enhancements to current voucher
subsidy and administrative fee funding distribution formulas; benchmarking important
program goals and appropriations; rent simplification; increased self-sufficiency;
improved housing affordability burdens and deconcentration of poverty for voucher
assisted households; and improving the use of tenant -based vouchers for project-based
assistance.
The County will support funding of $14.9 billion, at a minimum, for the renewal of
housing assistance vouchers. Congress should build upon the funding formula revision
found in the FY 2007 appropriations bill in order to restore effective funding policies in
authorizing language.
The County will also support funding of at least $1.5 billion for administrative fees and
reestablishing the administrative fee structure in place from 1998–2004. The County
will support vouchers being renewed at full levels and public housing authorities being
provided 100% of administrative funding.
Retiree and Retiree Health Care Costs – The County operates many programs on
behalf of the federal government. While federal funding is available for on -going
program operations, including employee salaries, the allocation is usually capped,
regardless of actual costs. For retiree and retiree health care, the County’s abilit y to
contain costs is extremely limited. The County will advocate for full federal financial
participation in funding the County’s retiree and retiree health obligations.
San Luis Drain – The U. S. Bureau of Reclamation is under a court injunction to
evaluate and implement options for providing drainage services for the west side of the
San Joaquin Valley. Drainage water from this area contains toxic concentrations of
selenium and other hazardous substances. The San Luis Drain is one of the options
that was studied. The Drain would pass through Contra Costa County to discharge in
the Delta. The U.S. Bureau of Reclamation has determined to address the problem
without building the Drain, but Congress would need to appropriate the funds before this
alternative could be implemented and the injunction requiring provision of drainage
service still looms. The County will continue to oppose the San Luis Drain option and
support, instead, drainage solutions in the valley, such as reducing the volume of
problem water drainage; managing/reusing drainage waters within the affected irrigation
districts; retiring lands with severe drainage impairment (purchased from willing sellers);
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and reclaiming/removing solid salts through treatment, bird safe/bird free solar po nds
and farm-based methods.
Supplemental Nutrition Assistance Program (SNAP) – The County will advocate for
the following federal actions:
Increase SNAP benefits as a major and immediately available element of
economic stimulus.
Increase administrative matching funds to a true 75/25 rate (with no cost
allocation reductions) so that states can deliver benefits in a timely and effective
manner.
Suspend the restrictions applying to ABAWDs. ("ABAWDs" stands for "Able-
Bodied Adults without Dependents" and pertains to adults receiving food stamps
who are considered employable.) They are subject to strict time limits on how
long they can receive food stamps. It is difficult administratively to track this, and
when unemployment is high, it can result in more adults going hungry.
Remove the current federal barriers that prevent some nutrition programs from
employing EBT technology.
Streamlining Permitting for Critical Infrastructure, Economic Stimulus, and
Alternative Energy Projects –“Green” Job Creation – Request that Congress and
the Administration recognize the value of Habitat Conversation Plans (HCPs) as a
reliable way of streamlining critical infrastructure, economic stimulus, and alternative
energy project permitting in a manner that is consistent with federal environmental
regulations. HCPs not only facilitate such projects through permit streamlining, but the
planning, implementation, management, and monitoring needs associated with regional
HCPs plans also create many quality “green” jobs.
Telecommunications Act of 1996 Revisions – The Telecommunications Act of 1996
governs local government’s role in telecommunications, primarily broadband cable that
uses the County’s right-of-way as well as consumer protections. As Congress works to
update the Act, the County will continue to advocate for strengthening consumer
protections and local government oversight of critical communications technologies;
local access to affordable and reliable high speed broadband infrastructures to support
the local economy; the right of local municipalities and communities to offer high-speed
broadband access: coordination and integration of private communication resources for
governmental emergency communication systems; preservation of local government’s
franchise fees; preservation of the local community benefits, including but not limited to
public, education and governmental (PEG) access channels; authority for provision of
municipal telecommunication services; preservation of local police powers essential for
health, safety and welfare of the citizenry; preservation of local government ownership
and control of the local public rights-of-way; and support for ensuring that
communication policy promotes affordable services for all Americans.
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Currently, the Community Broadband Act of 2007, S.1853, encourages the deployment
of high speed networks by preserving the authority of local governments to offer
community broadband infrastructure and services. The County will oppose all bills that
do not address the County’s concerns unless appropriately amended. In addition, the
Federal Communications Commission (FCC) has proposed rule-making (FCC Second
Report and Order Docket 05-311 “Franchising Rules for Incumbents”) that, in the
opinion of local government, goes beyond the scope of their authority in this area. The
County will oppose all such rule making efforts.
Telecommunications Issues – Support the Community Access Preservation (CAP)
Act introduced in 2009 by Wisconsin Congresswoman Tammy Baldwin. The CAP Act
addresses the challenges faced by public, educational and government (PEG) TV
channels and community access television stations. The CAP Act addresses four
immediate issues facing PEG channels. The CAP Act would: Allow PEG fees to be
used for any PEG-related purpose; require PEG channels to be carried in the same
manner as local broadcast channels; require the FCC to study the effect state video
franchise laws have had on PEG; require operators in states that adopted statewide
franchising to provide support equal to the greater of the support required under the
state law or the support historically provided for PEG; and make cable television -related
laws and regulations applicable to all landline video providers.
In addition, the County should support the widespread deployment and adoption of
broadband, especially as it serves to connect the educational community and libraries.
Temporary Assistance for Needy Families – The County will advocate for the
following federal actions:
Relieve states of work participation rate and work verification plan penalties for
fiscal years 2007, 2008, 2009 and 2010 in recognition of the serious downturn in
the national economy and the succession of more “process -based” regulations
issued in the last few years.
Permanently withdraw the August 8, 2008, proposal that would have repealed
the regulation that enables states to claim caseload reduction credit for excess
MOE expenditures.
Rescind the May 22, 2008, HHS guidance that effectively eliminated the ability of
states to offer pre-assistance programs to new TANF applicants for up to four
months.
Rescind the final Deficit Reduction Act regulation restricting allowable state
maintenance-of-effort expenditures under TANF purposes 3 and 4.
End federal efforts to impose a national TANF error rate.
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Volume Pricing – The National Association of Counties supports greater access for
local governments to General Services Administration (GSA) contract schedules.
These schedules provide volume pricing for state and local governments a nd make
public sector procurement more cost effective. However, current law does not provide
full access to state and local governments for GSA schedules. The County will support
legislation that gives local governments access to these schedules and provides the
option of purchasing law enforcement, security, and other related items at favorable
GSA reduced pricing.
Workforce Investment Act (WIA) Reauthorization – Congress may again consider
reauthorization of the Workforce Investment Act in 2011. The County will support
reauthorization of the W orkforce Investment Act at current funding levels or higher;
keeping the program at the federal level rather than block granting it; maximizing local
control, so that we can meet local needs; and establishing reasonable performance
measures. In addition, any reauthorization or new workforce legislation should: retain
private sector led state and local Workforce Investment Boards (local boards) as
governing bodies; expand, enhance and simplify the WIA Youth Program; redesign the
Dislocated Worker program to reflect the new economy; and redesign how the funding
of One-Stop facilities is structured.