HomeMy WebLinkAboutReview of Formal and Informal Actions Under COVID-19 Status of Emergency Orders-ProceduresCITY OF PALM DESERT
CITY MANAGER'S DEPARTMENT
MEMORANDUM
To: Mayor and Councilmembers
From: Andy Firestine, Assistant City Manager
Date: June 11, 2020
Subject: Review of Formal and Informal Actions Under COVID-19 Emergencv
Authority
The City Manager's Office, in coordination with legal counsel, is preparing an account of
the City's formal and informal emergency actions since the Governor of California issued a
Proclamation of a State of Emergency, including a review of the Proclamation of Local
Emergency. It will also provide an assessment of those actions the City may want to take
using its emergency powers. This analysis will be provided as supplemental information
prior to the City Council meeting.
AF:glr
STAFF REPORT
CITY OF PALM DESERT
CITY MANAGER'S OFFICE
MEETING DATE: June 11, 2020
PREPARED BY: Lauri Aylaian, City Manager
REQUEST: Review of Formal and Informal Actions under COVID-19 Emergency
Authority and Considerations for the Future
Recommendation
Review the City's formal and informal actions taken during the COVID-19 pandemic and
discuss next steps as the State begins to reopen. City staff believes that the Proclamation
of Local Emergency should stay in place to support any future public health needs,
promote the City's economic recovery, and maintain the City's eligibility to seek existing
and future funding opportunities.
Background
In early March 2020, just days after the Governor of California issued a Proclamation of
a State of Emergency, Riverside County reported its first known case of the 2019
coronavirus disease ("COVID-19"). The following week, on March 10, 2020, the Riverside
County Board of Supervisors approved Resolution No. 2020-062 proclaiming existence
of a local emergency. The President of the United States issued a proclamation declaring
a national emergency on March 13, 2020.
The purpose of this staff report is to review the City's current emergency orders, the City's
informal actions under emergency authority, actions the City may want to take during the
recovery period, and next steps into the future.
Analvsis
I. City's Formal Emergency Actions
The City has formally enacted a Proclamation of Local Emergency and an Executive
Order requiring that face coverings be worn in certain places.
A. Proclamation of Local Emerqencv
On March 17, 2020, the City Manager proclaimed a local emergency in the City, pursuant
to the California Emergency Services Act (California Government Code Section 8360,
8550, et. seq.) and Palm Desert Municipal Code Section 2.48.090 (hereinafter referred to
as the "Proclamation"). During the local emergency, the City Manager has acted and
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Potential Implications of Lifting COVID-19 Local Emergency Orders
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continues to act as Emergency Corps Commander. (Municipal Code, § 2.48.110.) The
City Council ratified the Emergency Corps Commander's Proclamation on March 20,
2020.
The City's Proclamation generally:
• Authorizes the undertaking of extraordinary police powers;
• Provides limited immunity for emergency actions of City employees and the
City Council;
• Authorizes the issuance of orders and regulations to protect life and property
(e.g., face covering requirements);
• Activates pre -established local emergency provisions such as special
purchasing and contracting; and
• Is the first step in process to access state/federal disaster relief programs.
The City's informal actions to date that have been generally authorized by the
Proclamation are discussed in further detail, below.
B. Executive Order Reauirinq Face Coverings
As authorized by the City Council on May 14, 2020, on May 15, 2020 the Emergency
Corps Commander issued an Executive Order requiring persons to use a face covering
and social distancing when inside a grocery store or drug store consistent with the "stay-
at-home" order issued by California Governor Executive Order N-33-20, as supplemented
by Order N-60-20, and guidance related thereto issued by the California Department of
Public Health ("Executive Order").
II. City's Informal Emergency Actions
In addition to the formal actions detailed above, the City has taken informal actions under
its emergency authority.
A. Purchasinq
The Municipal Code's Purchasing System requirements found in Chapter 3.30 detail the
City's formal bidding procedure including notice and publication requirements and the
alternative method of obtaining price quotes. During the local emergency, in the interest
of saving time and resources, the City has made relatively minor purchases without
posting notices or getting competitive quotes, notably the printing of temporary vinyl
banners in conjunction with the Palm Desert Area Chamber of Commerce businesses
operating in accordance with the State essential business guidelines. Overall, while the
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authority exists, purchases have been limited as the City has sought to minimize
discretionary expenditures during a period of economic uncertainty.
B. Sign Ordinance
Municipal Code Chapter 25.26 Signs includes certain restrictions limiting the size of
"Open" signs and prohibiting temporary and banner signs displayed for more than thirty
days, in addition to other commercial sign rules. Due to the nature of the pandemic, with
many businesses shutting down under the Governor's Executive Order while others
remained open or have subsequently opened over the course of the phased reopening
of the economy, there has been increased demand for temporary signage to denote those
businesses that are open and providing service to the public. While not all of this signage
is explicitly permitted in the Municipal Code, the City has not enforced against such
signage as it has worked to lessen confusion over which businesses are open and
operated as a catalyst for economic recovery.
C. Workplace Protocol
Municipal Code Chapter 2.52 Personnel System, Article V Workplace Policies
memorializes the City's general workplace protocol including attendance, dress code, and
technology use rules. The City continues to enforce general standards of conduct, and
harassment and discrimination policies. The City has also instituted policies to promote
remote work where practical during the pandemic, such as being adaptive to the place
where work is conducted and assigning City equipment to staff to take home, enabling
them to perform work remotely. The City has also altered work schedules, both to
minimize the staffing level at City Hall and in recognition that each remote work place is
different and that the City needs to be responsive to those unique circumstances and the
challenges faced by staff adapting to these conditions.
D. Applications for Grant Fundinq
Once the local emergency was proclaimed, the City became eligible to request available
funding from a variety of sources.
For example, the Federal Emergency Management Agency ("FEMA") has simplified the
Public Assistance application and funding process to address the magnitude of impacts
from the COVID-19 pandemic. The City has applied for a FEMA grant, which is now
pending, as the City gathers documentation to submit for reimbursement.
In addition, the City is currently working on an Economic Development Administration
("EDA") grant application and if funding becomes available, the City plans to use any
funds obtained to cover lost transient occupancy tax ("TOT") revenue for March, April,
and May.
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City staff continues to review available opportunities for funding, as the future is not
entirely certain. So far, however, expenditures have remained in budget.
III. Actions the City May Want to Take Using Emergency Powers
A. Public Health
The public health situation is uncertain. The curve may continue to flatten and we may
see a consistent reduction in cases and deaths. On the other hand, reopening may lead
to an increase in cases, a new strain may form, or a "second wave" may occur. It is difficult
to predict what will happen in the near future and beyond.
Proclamation of Local Emergency
If the City and surrounding area experiences a reduction in cases, it may consider
modifying or rescinding the Proclamation of Local Emergency. The City is covered by the
Riverside County proclaimed local emergency, and does not technically need its own
proclamation (Government Code, § 8634); however, if the County rescinds its order and
the City continues to experience serious impacts, it would need its own Proclamation to
continue making public health orders, act under its emergency powers, and to be eligible
for funding.
Keeping the Proclamation active in no way prevents the City from reopening. In fact, the
Proclamation's authority can assist the City's economic recovery efforts and keep the City
eligible for State and federal funding, as discussed below.
Another practical reason for keeping the Proclamation in place is that City Hall is still
closed, and will likely not be reopened to the public before the end of the month due to
the time needed to procure and install safeguards to protect the health of staff and the
public. Terminating the Proclamation in the immediate future might lead the public to
believe that City Hall is physically open now.
2. Executive Order Regarding Face Coverings
The City may determine that the Executive Order regarding face coverings should be
modified or rescinded. By having the Proclamation of Local Emergency in place, the City
can continue to make public health orders, including ones regarding social distancing and
face coverings. As virus case and death statistics change and new studies provide
information on the effectiveness of face coverings, the Executive Order can be reviewed
and modified/rescinded as necessary.
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Potential Implications of Lifting COVID-19 Local Emergency Orders
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B. Economic Recovery
The City's Proclamation can assist economic recovery throughout the City.
Street Closures and Parking Waivers
The California Vehicle Code and City's Municipal Code Muni Code includes regulations
streets and parking regulations. The City is considering allowing certain street closures
and parking waivers so that restaurants are able to accommodate more persons for open
air dining and can do so under the Proclamation of Local Emergency. This can help
restaurants that are still required to limit occupancy in doors.
2. Sign Ordinance
As discussed above, the strict enforcement of City's sign regulations on temporary signs
have been relaxed in efforts to support commercial enterprise. Under the Proclamation,
the City can continue to suspend its enforcement of signs that may not be in strict
compliance with the Municipal Code for the purpose of supporting economic recovery.
C. Grant Fundinq
Terminating the Proclamation may impact funding opportunities. As mentioned above,
the City can begin reopening without rescinding the Proclamation and can loosen any
emergency rules, consistent with state and county reopening orders. However, once the
Proclamation is rescinded, it creates a justification for FEMA or other funding sources to
take the position that a City is ineligible for funds because it has affirmatively stated there
is no emergency. Additionally, it is uncertain as to what other funding might come down
the pipeline and what eligibility criteria there will be for those funds. To be conservative,
it is best to keep the emergency declaration in place as long as there are still
federal/state/county emergencies.
For example, Tulare County voted to reopen before receiving state authorization, and the
Governor's Office of Emergency Services ("Cal-OES") sent the County a letter stating that
the County would be ineligible for emergency funding because its action showed there
was no emergency.
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IV. Actions by other Jurisdictions in Riverside County
Riverside County released a report on May 29th including the following tally of the entities
that have proclaimed a local emergency:
Entities Proclaimed Local Emergency
Cities 28
Tribes 9
Special Districts 17
Utilities 0
As of the date of this report, none of these entities have terminated their Proclamations.
V. Where We Go From Here —Next Steps
The COVID-19 pandemic continues to impact public health, the economy, and our
community. At this point, City staff believes that the Proclamation of Local Emergency
should stay in place The Proclamation of Local Emergency supports the continuation of
similar formal and informal actions that have been taken thus far. Even as the City
begins to make efforts to reopen City Hall and as Riverside County advances a
reopening plan under the state, staff anticipates that there will be ongoing needs for the
flexibility granted through the Proclamation, including flexibility that the City may seek
to take positions on such things as the closure of streets or reduction of parking to permit
outdoor dining. It may also enable grant opportunities and the recovery of lost revenues.
There is little foreseen risk to remaining under the Proclamation as it does not inhibit
the City's ability to reopen.
LEGAL REVIEW
ma
DEPT. REVIEW
L-AC
Robert W. Lori Carney
Hargreaves Director of
City Attorney Administrative
Services
City Manager Lauri Aylaian: 29
FINANCIAL
REVIEW
Janet M. Moore
Director of Finance
ASSISTANT
CITY MANAGER
oq4 artt"ttae
Andy Firestine
Assistant City
Manager