HomeMy WebLinkAboutMINUTES - 09102013 - SD.8RECOMMENDATION(S):
APPROVE the response to Civil Grand Jury Report No. 1312, entitled, "Comparative View of Elected Officials Cost
of Compensation" and DIRECT the Clerk of the Board to forward the response to the Superior Court no later than
September 13, 2013.
FISCAL IMPACT:
No fiscal impact.
BACKGROUND:
On June 13, 2013 the 2012/13 Civil Grand Jury filed the above-referenced report. The attached response clearly
specifies:
Whether a finding or recommendation is accepted or will be implemented;
If a recommendation is accepted, a statement as to who will be responsible for implementation and by what
target date;
A delineation of the constraints if a recommendation is accepted but cannot be implemented within a six-month
period; and
The reason for not accepting a finding or recommendation.
Please see the attached report.
APPROVE OTHER
RECOMMENDATION OF CNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
Action of Board On: 09/10/2013 APPROVED AS RECOMMENDED OTHER
Clerks Notes:
VOTE OF SUPERVISORS
AYE:John Gioia, District I Supervisor
Candace Andersen, District II Supervisor
Mary N. Piepho, District III Supervisor
Karen Mitchoff, District IV Supervisor
Federal D. Glover, District V Supervisor
Contact: Lisa Driscoll, County Finance
Director (925) 335-1023
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: September 10, 2013
David Twa, County Administrator and Clerk of the Board of Supervisors
By: Chris Heck, Deputy
cc: Ted Cwiek, Human Resources Director
SD. 8
To:Board of Supervisors
From:David Twa, County Administrator
Date:September 10, 2013
Contra
Costa
County
Subject:Response to Grand Jury Report 1312: Comparative View of Elected Officials Cost of Compensation
CONSEQUENCE OF NEGATIVE ACTION:
In order to comply with statutory requirements, the Board of Supervisors must provide a response to the Superior
Court no later than September 13, 2013. The Board must take timely action in order to comply with the statutory
deadline.
CHILDREN'S IMPACT STATEMENT:
Not Applicable.
CLERK'S ADDENDUM
Speaker: Rollie Katz, Public Employees' Union Local One, commented on salary information. APPROVED the
response to Civil Grand Jury Report No. 1312 entitled "Comparative View of Elected Officials Cost of
Compensation" and DIRECTED the Clerk of the Board to forward the response to the Superior Court no later
than September 13, 2013.
ATTACHMENTS
Grand Jury Report 1312
Response to Grand Jury Report 1312
Exhibit A
Page 1 of 6
BOARD OF SUPERVISORS RESPONSE TO CONTRA COSTA COUNTY GRAND
JURY REPORT 1312:
Comparative View of Elected Officials Cost of Compensation
Who is Minding the Store?
Findings:
1. Contra Costa County does not have a formal policy regarding compensation adjustments for elected
officials.
Response: The respondent agrees with the finding.
2. The average compensation of the five Supervisors is at the 37th percentile, within the determined range, but
below the mid-point, when compared to the twelve-county sample.
Response: The respondent partially disagrees with the finding. Using the same database as the Grand
Jury (http://publicpay.ca.gove/Reports/Counties/Counties.aspx), the average compensation of the five
Supervisors is at the 37th percentile, within the determined range, but below the mid-point, when compared to
the twelve-county sample; however, as is noted below, the database and/or analysis is flawed.
3. The cost of compensation for the Clerk-Recorder role is beyond the 99th percentile, far above the Upper
Boundary of the determined range.
Response: The respondent partially disagrees with the finding. Using the same database as the Grand
Jury (http://publicpay.ca.gove/Reports/Counties/Counties.aspx), the cost of compensation for the Clerk-
Recorder role is beyond the 99th percentile, far above the Upper Boundary of the determined range; however,
as is noted below, the database and/or analysis is flawed.
4. The cost of compensation for the Sheriff-Coroner role is at the 17th percentile, below the Lower Boundary
of the determined range.
Response: The respondent partially disagrees with the finding. Using the same database as the Grand
Jury (http://publicpay.ca.gove/Reports/Counties/Counties.aspx), the cost of compensation for the Sheriff-
Coroner role is at the 17th percentile, below the Lower Boundary of the determined range; however, as is
noted below, the database and/or analysis is flawed.
5. The average compensation of the six role officials is at the 50th percentile, at the mid-point of the
determined range, when compared to comparable counties.
Response: The respondent partially disagrees with the finding. Using the same database as the Grand
Jury (http://publicpay.ca.gove/Reports/Counties/Counties.aspx), the cost of compensation for the Sheriff-
Coroner role is at the 17th percentile, below the Lower Boundary of the determined range; however, as is
noted below, the database and/or analysis is flawed.
6. The compensation of the two positions falling outside of their determined ranges can be adjusted to fall
within those ranges without increasing the average compensation cost for Contra Costa County’s elected
role officials.
Response: The respondent agrees with the finding.
Page 2 of 6
Recommendations
1. The Board of Supervisors (a) not adjust their own compensation in such a manner that their average
compensation cost exceeds the 50th percentile of the determined range and (b) not adjust the compensation
for any individual supervisor outside of the determined range (see Table 1).
Response: The recommendation will not be implemented because it is not reasonable. As is noted
below, the database and choice of selected sample counties does not reflect Contra Costa County;
therefore, the determined range is not appropriate for Contra Costa County.
2. The Board of Supervisors not adjust the compensation cost of any role official in such a manner that it
falls outside of the determined range for that role.
Response: The recommendation will not be implemented because it is not reasonable. As is noted
below, the database and choice of selected sample counties does not reflect Contra Costa County;
therefore, the determined range is not appropriate for Contra Costa County.
3. The Board of Supervisors not adjust the compensation cost of any of the six role officials in such a manner
that the average compensation cost for the role officials as a group exceeds the 50th percentile of the
determined range (see Table 8.2).
Response: The recommendation will not be implemented because it is not reasonable. As is noted
below, the database and choice of selected sample counties does not reflect Contra Costa County;
therefore, the determined range is not appropriate for Contra Costa County.
4. The Board of Supervisors, at its next opportunity, adjust the compensation cost of the Clerk Recorder
position to bring it within the determined range as defined in this report (see Table 4.2), subject to any
restrictions in taking such an action pursuant to Government Code section 1235, "Salary for Elected Public
Office, Reduction During an Election Year."
Response: The recommendation will not be implemented because it is not reasonable. As is noted
below, the database and choice of selected sample counties does not reflect Contra Costa County;
therefore, the determined range is not appropriate for Contra Costa County.
5. The Board of Supervisors, at its next opportunity, consider adjusting the compensation cost of the Sheriff-
Coroner position to bring it within the determined range as defined in this report (see Table 7.2).
Response: The recommendation will not be implemented because it is not reasonable. As is noted
below, the database and choice of selected sample counties does not reflect Contra Costa County;
therefore, the determined range is not appropriate for Contra Costa County.
6. The Board of Supervisors adopt a written policy for determining and setting the compensation of elected
officials.
Response: The recommendation has not yet been implemented, but will be implemented within the
next six months.
7. The Board of Supervisors consider retaining a compensation consultant to review the Grand Jury's
Findings and Recommendations.
Response: The recommendation will not be implemented because it is not warranted. A call to the
State Controller’s Office quickly identified a flaw in the materials used by the Grand Jury.
Page 3 of 6
The following is additional information regarding Grand Jury Report 1312 and the State
Controller’s website database used for all cost of compensation data.
Total compensation analysis is very complex. Unless the researcher is intimately acquainted with the
specific classifications under review in each surveyed municipality, flawed conclusions are often
drawn. The County Administrator’s Office recognizes there to be at least three major flaws in the
materials provided to the Grand Jury by their compensation expert. The three flaws are in the
selection of the “Selected Sample Counties”, the identification of “same or similarly titled roles”, and
the database used for compensation comparison.
Selected Sample Counties
The Grand Jury report acknowledges that each California County is unique and that Contra Costa
County is no exception. The report also noted that an exact comparable does not exist. The
compensation expert looked for counties that were closest to Contra Costa County in population,
annual funds expended and the extent of urban development within their boundaries. Exhibit A
(attached) is taken from the State Controller’s website; it lists the California counties data and
highlights in yellow the counties in the selected sample, also listed below:
1. Alameda
2. Fresno
3. Kern
4. Orange
5. Riverside
6. Sacramento
7. San Bernardino
8. San Diego
9. San Joaquin
10. San Mateo
11. Santa Clara
12. Ventura
The significant weakness in selecting this group of sample counties is that eight of them do not
represent the Bay Area’s cost of living. In fact, discounting regional areas in the selection of counties
completely ignored the fact that several of the counties selected are located in areas where costs of
living as considerably lower than that of the Bay Area. The nine Bay Area counties are listed below,
with those selected by the Grand Jury’s expert highlighted.
1. San Francisco*
2. San Mateo
3. Santa Clara
4. Alameda
5. Contra Costa
6. Marin
7. Solano
8. Napa
9. Sonoma
*Salary comparisons performed in Contra Costa County often use Sacramento in place of San Francisco and add Santa Cruz for a ten
county comparison.
Same or Similarly Titled Roles
Without a clear understanding of the roles and responsibilities of the offices held by Elected Officials
it would be understandably difficult to complete an accurate comparison of positions. It would appear
that the Grand Jury’s expert attempted to apply a ‘formula’ to comparison of titles rather than an
analysis of the duties performed by those assigned the titles. For instance, the Grand Jury Report
indicated that when comparing multiple titles, the first title was considered to be the more important.
The entire comparative analysis appears to be on the basis of the title. This comparison is defective
and caused critical errors in the conclusions drawn in the report.
Page 4 of 6
For example, in Contra Costa County the Clerk-Recorder is also the Registrar of Voters for the
County. Only one (Ventura) of the five selected sample counties has a position that should be
considered an “exact” role because the position is also the Registrar of Voters, as it is in Contra Costa
County. Two counties (Santa Clara and Orange) considered “exact” role counties, don’t actually
match the Grand Jury’s definition of “exact” role counties since their Clerk-Recorder positions do not
perform the functions of a third position, nor do they function as the Registrar of Voters. The last two
counties (Riverside and San Diego) do include positions that function in three capacities; however,
they both have a lower Total Annual Compensation ($225,547 and $211,182) than Contra Costa
County’s Clerk-Recorder / Registrar of Voters. The salaries of these two tertiary positions may be
lower due to the role of Assessor not being a comparable role to a Registrar of Voters position.
Of the 5 selected sample counties, four maintain separate Registrar of Voters offices with much
different (higher) salaries. Santa Clara, Orange, Riverside and San Diego do maintain separate
Registrar of Voters offices. The table below shows the populations for each county, which may be
indicative of the four Counties needing a separate Registrar of Voters office, as compared to Contra
Costa and Ventura counties, which are the two lowest populated counties.
Clerk-
Recorder*
Assessor-
Clerk-
Recorder* Assessor*
Registrar of
Voters*
County
Population*
Santa Clara $194,298 - $258,677 $200,309 1,797,375
Ventura $195,978 - $209,958 - 828,383
Orange $195,978 - $258,680 $257,178 3,029,859
Riverside - $225,547 - $199,649 2,217,778
San Diego - $211,182 - $235,916 3,118,876
Contra Costa $262,379 - $270,088 - 1,056,064
*Numbers may be rounded
Santa Clara Clerk-Recorder is appointed not elected with a Total Annual Compensation of $194,298
and the county has a separate Registrar of Voters position with a Total Annual Compensation of
$200,309. The population of Santa Clara is about 70% greater than Contra Costa’s, which may
indicate a need for separate positions.
Riverside has an Assessor-Clerk-Recorder with a Total Annual Compensation of $225,547 and
Registrar of Voters with a Total Annual Compensation of $199,649. Ventura County has a population
of 828,383 and has a Clerk-Recorder / Registrar of Voters with a Total Annual Compensation of
$195,978.
It is understandable why the conclusions drawn from the title data analyzed in the Grand Jury’s Report
produced a flawed result. Of the seven different classes of elected official in Contra Costa County,
there are at least 21 variations of classes performing this work in the nine Bay Area Counties (see
below).
Page 5 of 6
1. Assessor
2. Assessor-Recorder
3. Assessor-Recorder-County Clerk
4. Auditor-Controller
5. Auditor-Controller/Clerk-Recorder
6. Auditor-Controller/Treasurer-Tax Collector
7. Board of Supervisor Member
8. Clerk-Recorder (Not Elected)
9. Clerk-Recorder (Registrar of Voters)
10. Controller
11. Controller-Treasurer (Not Elected)
12. Coroner
13. District Attorney
14. District Attorney/Public Administrator
15. Registrar of Voters
16. Sheriff
17. Sheriff-Coroner
18. Sheriff-Coroner/Public Administrator
19. Tax Collector (Not Elected)
20. Treasurer-Tax Collector
21. Treasurer-Tax Collector-County Clerk
Database Used for Comparative Purposes
The Grand Jury’s Report defines total annual compensation cost as the sum of the following seven
elements:
1. Regular Pay
2. Lump sum Pay
3. Other Pay
4. County’s Contribution to a Defined Benefit Plan
5. Retirement Cost Covered by the County
6. Deferred Compensation
7. Health/Dental/Vision Contribution by the County
The data used for comparison was not adjusted in any way. It was applied as it was taken from the
database. There are issues with using data straight from a database that was not designed specifically
for the same purpose for which it is being used.
A simple example of why it is important to understand the base elements of a database is that in San
Diego County the Assessor-Clerk- Recorder data failed to consider that the incumbent is retired,
therefore, benefit costs are not incurred by the County.
Page 6 of 6
It is also important to note that the manner in which the elected department heads are compensated for
non-accruing vacation/sick time etc., varied greatly. Some entities like Contra Costa provide deferred
compensation, some likely include it in salary, and others don’t appear to have an option for dealing
with it at all. The reporting of just that one item alone can create real problems in understanding the
complex issues of total compensation. We address the specific issue of deferred compensation in
further detail below.
After reading the Grand Jury’s Report, we compared actual payroll data for several Contra Costa
County elected officials to the data in the State Controller’s website database. We found a significant
issue with the reported information for one of the first positions analyzed – Auditor-Controller.
The State Controllers’ website provided the following information:
It would appear that the State Controllers’ database uses “box 5" from the W2 statement (Medicare
taxable wage base). Part of the Medicare taxable wage base (regular pay) includes the counties
portion of the deferred compensation contributions. The State database shows the deferred
compensation information as an employer paid benefit thus double counting the deferred
compensation and other Medicare taxable employer paid benefits. This does not provide an accurate
picture of wages and employer paid benefits. Arguably the most significant error in using the State
database to determine comparable salary is that the State website incorporated both “elected”
compensation and “employee” compensation into the total for the Auditor-Controller. This had the
effect of increasing comparable salary by $21 thousand. These errors alone accounted for material
errors of approximately $34 thousand.
The Auditor-Controller has been in contact with the State Controller's Office regarding the reporting
of compensation information to them and their posting the information on the WEB. State Controller
staff now recognizes the problem and are working with us to more accurately reflect compensation
information on their website. It is unclear how wide spread the errors are and how many comparative
counties are affected.
Conclusion
In conclusion, the County Administrator’s Office will develop a policy for determining and setting the
compensation of elected officials specific to Contra Costa County. A recent comparison of annual salaries
for all Contra Costa County elected officials with those of the nine Bay Area counties clearly demonstrates
significant gaps between those of several of the elected officials and their cohort counties. The first three
classifications analyzed will be those of the Assessor, Auditor-Controller, and Treasurer-Tax Collector.
Exhibit ACounty Population*Annual Funds Expended**County Area***Urban Pop.***Urban Pop. %***Urban Area***Area % Urban***Urban Area Pop.***Urban Area Pop.***Area % Urban Area***Rural Pop.***Rural Pop. %***Area % Rural***Alameda1,521,1572,196,683,885 1,914,046,110 1,504,402 99.61 702,562,853 36.71 1,504,402 99.61 36.71 5,869 0.39 63.29Alpine1,17614,985,215 1,912,271,907 0 0 0 0 0 0 0 1,175 100 100Amador37,91156,480,528 1,539,962,991 15,075 39.58 19,966,234 1.3 0 0 0 23,016 60.42 98.7Butte221,388339,091,982 4,238,423,238 178,416 81.1 218,700,217 5.16 98,176 44.63 2.1 41,584 18.9 94.84Calaveras45,69368,757,036 2,641,819,725 11,208 24.59 26,827,851 1.02 0 0 0 34,370 75.41 98.98Colusa21,59344,835,344 2,980,379,369 14,624 68.28 12,809,605 0.43 0 0 0 6,795 31.72 99.57Contra Costa1,056,0641,306,321,748 1,854,268,836 1,040,709 99.21 791,912,999 42.71 1,026,665 97.87 42.05 8,316 0.79 57.29Del Norte28,59453,383,843 2,606,493,856 18,976 66.33 30,762,111 1.18 0 0 0 9,634 33.67 98.82El Dorado182,498266,477,138 4,423,396,606 118,231 65.3 195,032,584 4.41 61,422 33.92 2 62,827 34.7 95.59Fresno940,2201,210,298,088 15,431,126,407 829,913 89.19 553,441,936 3.59 654,628 70.36 2.87 100,537 10.81 96.41Glenn28,27363,863,241 3,403,106,702 16,628 59.13 21,882,441 0.64 0 0 0 11,494 40.87 99.36Humboldt135,263229,031,090 9,241,044,673 94,561 70.24 117,813,459 1.27 0 0 0 40,062 29.76 98.73Imperial176,258270,821,482 10,817,352,524 144,129 82.58 109,932,316 1.02 108,683 62.27 0.75 30,399 17.42 98.98Inyo18,63461,910,920 26,368,354,217 9,935 53.57 11,034,204 0.04 0 0 0 8,611 46.43 99.96Kern846,8831,276,127,973 21,061,565,098 753,938 89.79 569,689,805 2.7 578,366 68.88 1.82 85,693 10.21 97.3Kings153,365186,724,804 3,598,582,308 136,381 89.15 102,103,083 2.84 87,941 57.48 2 16,601 10.85 97.16Lake64,784113,072,639 3,254,227,528 43,257 66.89 68,937,372 2.12 0 0 0 21,408 33.11 97.88Lassen34,57756,252,156 11,761,612,172 10,285 29.47 13,783,798 0.12 0 0 0 24,610 70.53 99.88Los Angeles9,858,98915,115,254,704 10,509,869,649 9,759,181 99.39 3,685,227,472 35.06 9,743,650 99.24 34.87 59,424 0.61 64.94Madera151,949175,156,885 5,534,982,985 101,193 67.08 102,566,480 1.85 78,413 51.98 1.05 49,672 32.92 98.15Marin254,692425,584,214 1,347,585,521 235,952 93.48 209,297,929 15.53 235,952 93.48 15.53 16,457 6.52 84.47Mariposa18,26153,524,595 3,752,416,976 0 0 0 0 0 0 0 18,251 100 100Mendocino88,197177,775,338 9,081,386,386 48,110 54.77 75,110,409 0.83 0 0 0 39,731 45.23 99.17Merced257,984382,068,976 5,011,554,741 219,283 85.73 181,492,777 3.62 161,757 63.24 2.88 36,510 14.27 96.38Modoc9,70524,497,124 10,146,977,156 2,910 30.04 4,934,771 0.05 0 0 0 6,776 69.96 99.95Mono14,30855,440,247 7,896,827,391 7,693 54.17 8,604,971 0.11 0 0 0 6,509 45.83 99.89Monterey419,038588,225,591 8,496,702,738 374,315 90.18 276,567,256 3.25 306,096 73.75 2.75 40,742 9.82 96.75Napa137,639239,438,351 1,938,247,338 118,194 86.6 105,619,795 5.45 103,379 75.74 4.06 18,290 13.4 94.55Nevada99,111136,646,318 2,480,616,988 57,150 57.87 121,380,784 4.89 0 0 0 41,614 42.13 95.11Orange3,029,8592,904,431,492 2,047,561,084 3,005,917 99.86 1,356,792,197 66.26 3,005,917 99.86 66.26 4,315 0.14 33.74Placer352,380538,643,638 3,644,136,017 300,393 86.21 368,823,443 10.12 254,704 73.1 7.32 48,039 13.79 89.88Plumas20,02549,988,905 6,612,350,713 5,197 25.98 9,528,530 0.14 0 0 0 14,810 74.02 99.86Riverside2,217,7782,662,570,257 18,664,696,661 2,088,429 95.38 1,836,403,747 9.84 2,022,683 92.38 9.46 101,212 4.62 90.16Sacramento1,428,3552,211,419,968 2,498,415,670 1,389,531 97.94 852,479,845 34.12 1,359,243 95.8 32.87 29,257 2.06 65.88San Benito55,61976,736,034 3,596,742,302 42,002 76 29,640,123 0.82 0 0 0 13,267 24 99.18San Bernardino2,052,3972,453,555,201 51,947,229,509 1,938,853 95.27 1,620,929,678 3.12 1,792,222 88.06 2.62 96,357 4.73 96.88
Exhibit ACounty Population*Annual Funds Expended**County Area***Urban Pop.***Urban Pop. %***Urban Area***Area % Urban***Urban Area Pop.***Urban Area Pop.***Area % Urban Area***Rural Pop.***Rural Pop. %***Area % Rural***San Diego3,118,8763,464,980,984 10,895,120,648 2,993,259 96.7 1,969,080,482 18.07 2,964,846 95.79 17.61 102,054 3.3 81.93San Joaquin690,899830,564,062 3,603,505,998 627,241 91.53 403,846,778 11.21 610,468 89.08 10.96 58,065 8.47 88.79San Luis Obispo270,966391,395,573 8,543,248,461 224,887 83.4 252,767,344 2.96 176,368 65.41 2.27 44,750 16.6 97.04San Mateo724,7021,042,921,551 1,161,371,825 704,865 98.11 364,670,230 31.4 684,152 95.23 29.74 13,586 1.89 68.6Santa Barbara426,189715,701,736 7,083,838,022 402,626 94.98 274,472,641 3.87 377,637 89.09 3.49 21,269 5.02 96.13Santa Clara1,797,3752,325,735,130 3,341,343,470 1,762,335 98.92 856,724,204 25.64 1,762,335 98.92 25.64 19,307 1.08 74.36Santa Cruz264,430411,937,327 1,152,986,019 230,793 87.96 205,269,225 17.8 230,793 87.96 17.8 31,589 12.04 82.2Shasta177,924244,929,085 9,778,246,966 125,321 70.71 198,059,354 2.03 117,731 66.43 1.88 51,902 29.29 97.97Sierra3,24818,826,394 2,468,813,797 9 0.28 18,398 0 9 0.28 0 3,231 99.72 100Siskiyou45,08489,793,908 16,259,652,221 15,344 34.17 31,777,924 0.2 0 0 0 29,556 65.83 99.8Solano414,509545,748,892 2,128,361,199 397,974 96.28 294,791,332 13.85 372,432 90.1 12.71 15,370 3.72 86.15Sonoma487,125749,320,859 4,081,430,136 424,102 87.65 372,935,115 9.14 372,309 76.94 7.57 59,776 12.35 90.86Stanislaus517,685675,140,351 3,871,582,888 473,396 92.02 309,637,865 8 433,288 84.22 7.33 41,057 7.98 92Sutter95,800138,261,633 1,560,235,601 80,718 85.2 63,361,980 4.06 72,171 76.18 3.75 14,019 14.8 95.94Tehama63,950100,584,333 7,639,709,781 30,787 48.51 42,023,154 0.55 0 0 0 32,676 51.49 99.45Trinity13,85337,755,436 8,234,229,734 0 0 0 0 0 0 0 13,786 100 100Tulare446,837643,924,834 12,494,658,169 373,730 84.52 289,402,246 2.32 289,726 65.52 1.74 68,449 15.48 97.68Tuolumne55,25689,735,588 5,752,062,580 28,255 51.03 80,816,252 1.4 0 0 0 27,110 48.97 98.6Ventura828,383965,848,637 4,773,691,889 797,593 96.88 575,552,166 12.06 752,770 91.43 11.67 25,725 3.12 87.94Yolo201,759237,310,783 2,628,032,408 186,931 93.07 121,121,985 4.61 176,572 87.91 4.23 13,918 6.93 95.39Yuba72,479128,403,192 1,636,454,192 53,234 73.78 48,139,566 2.94 44,548 61.74 2.55 18,921 26.22 97.06* Data based on California State Controller's Office data for 2011 (http://www.publicpay.ca.gov/Reports/Counties/Counties.aspx)** Data based on the "Counties Annual Report" for 2010-11 FY (http://www.sco.ca.gov/Files-ARD-Local/LocRep/counties_reports_1011counties.pdf)*** Data based on U.S. Census Bureau data from the "2010 Census Urban and Rural Classification" (http://www.census.gov/geo/reference/ua/urban-rural-2010.html)