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AGENDA
YAKIMA CITY COUNCIL
SPECIAL MEETING
September 19, 2023
Fire Station 95 -807 E. Nob Hill Blvd, Yakima, WA
3:00 p.m. Special Meeting I This meeting will be conducted in person.
1. Roll Call
2. Regional Fire Authority Presentation
3. Adjournment
The next meeting will be a City Council regular meeting on September 19, 2023 at 5:30 p.m.
in the City Hall Council Chambers
Any invocation that may be offered before the official start of the Council meeting shall be the
voluntary offering of a private citizen, to and for the benefit of the Council. The views or beliefs
expressed by the invocation speaker have not been previously reviewed or approved by the Council,
and the Council does not endorse the religious beliefs or views of this, or any other speaker.
A Council packet is available for review at the City Clerk's Office and on-line at www.yakimawa.gov.
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interpreters, for City meetings.Anyone needing special assistance please contact the City Clerk's
office at(509) 575-6037 at least two business days prior to the meeting.All meetings are live streamed
on the City of Yakima website at www.yakimawa.gov and telecast live on Y-PAC, Spectrum Cable
Channel 194.
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BUSINESS OF THE CITY COUNCIL
YAKIMA, WASHINGTON
AGENDA STATEMENT
Item No. 2.
For Meeting of: September 19, 2023
ITEM TITLE: Regional Fire Authority Presentation
SUBMITTED BY: Aaron Markham, Yakima Fire Chief
SUMMARY EXPLANATION:
Agenda:
1. Roll Call
2. Regional Fire Authority Presentation
3. Open Forum
4.Adjournment
ITEM BUDGETED: NA
STRATEGIC PRIORITY: Public Safety
APPROVED FOR SUBMITTAL BY THE CITY MANAGER
RECOMMENDATION:
ATTACHMENTS:
Description Upload Date Type
0 Memo Snure 9/11/2023 Cover Memo
❑ Checklist Snure 9/13/2023 Cover Memo
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SNURE LAW OFFICE, PSC
A Professional Services Corporation
Brian K. Snure Clark B. Snure
brian@snurelaw.com 1930-2014
REGIONAL FIRE PROTECTION SERVICE AUTHORITIES
(Yakima County Presentation)
July 18, 2023
GENERAL CONSIDERATIONS
Chapter 52.26 RCW outlines the basic statutory framework for creating RFAs. The RFA statute
uses several key terms and contains several important provisions that guide much of the discussion
that follows:
Fire Protection Jurisdiction. Only"fire protection jurisdictions"may participate in the formation
of an RFA. RCW 52.26.020 defines fire protection jurisdictions as "fire district, city, town, port
district or Indian Tribe." As the participants in this study do not include port districts or Indian
Tribes the following discussion of legal considerations does not address the additional issues that
would be created by the participation of a port district of Indian Tribe.
Regional fire protection service authority Planning Committee.RFAs are formed by a formally
designated Planning Committee consisting of elected officials from the participating fire protection
jurisdictions. The formation and role of the Planning Committees is more fully discussed under
the Procedures section below. "Planning Committees."
Regional fire protection service authority plan. Planning Committees are tasked with forming
the"RFA Plan." The RFA Plan outlines the plan for governance,financing,operations,boundary
changes, etc. and is the Plan the voters are asked to approve when voting on the formation of the
RFA. The RFA plan is a critical document in the formation of the RFA and serves a role similar
to a charter or constitution for the ongoing operation of the RFA.
Governing Board. The legislative body of an RFA is referred to as a governing board.
FORMATION PROCEDURES.
Like any other type of significant consolidation, the formation of RFA requires careful planning.
Because the RFA creates a new entity, there is an added layer of complexity to the planning. The
new entity will need to register with the IRS, establish new accounts with the County and vendors,
contracts will need to be assigned and negotiated, labor agreements need to be negotiated, payroll
systems may need to be established, etc. In other words, the formation of a new entity can be
612 South 227'Street ♦ Des Moines,Washington 98198 • Telephone 206-824-5630 • Fax 206-824-9096
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incredibly time intensive and attention to detail is critical. The formation of an RFA is not subject
to review by a Boundary Review Board or a County legislative authority. The formation of an
RFA is, however, likely subject to compliance with the State Environmental Policy Act"SEPA".
The actual statutory procedures to form a RFA are fairly straightforward.
Formation of a Planning Committee. While the formation of a Planning Committee is the first
procedural step, this step will likely follow many informal meetings and discussions by the
participating jurisdictions. Most successful RFAs have established formal steering committees
composed of a wide variety of stakeholders to determine the feasibility of creating a RFA far in
advance of forming the actual Planning Committee. Each participating jurisdiction appoints 3
elected officials to the Planning Committee. The statute authorizes the Planning Committee
members to be paid$70.00 per day or portion thereof not to exceed$700.00 per year for services
for the Planning Committee. The statute also authorizes Planning Committees to receive state or
county loans if appropriated.
Operation of Planning Committee.At the first Planning Committee Meeting,the committee may
elect officers and adopt rule and operating procedures. The Planning Committee may dissolve
itself at any time by a majority vote and a participating jurisdiction may withdraw with 30 days
written notice. The role of the Planning Committee is to develop the RFA Plan addressing the
design, governance,financing and operation of the RFA (discussed in detail below). The Planning
Committee must allow and encourage public input in plan development and the Planning
Committee meetings should be held in compliance with the Open Public Meetings Act.
RFA Plan Approval. Once the Planning Committee adopts the Plan,the legislative bodies of each
of the participating jurisdictions must approve the Plan. If the Plan is approved by the participating
jurisdictions a joint resolution calling for an election within each jurisdiction must be approved
and submitted to the County to call for a single election throughout the proposed RFA boundaries.
RFA Election. The election to approve formation of the RFA requires a simple majority unless a
60% revenue source is included in the Plan (i.e. benefit charge, EMS levy or excess levy).
However, if all participating jurisdictions have an existing EMS levy, including an EMS levy in
the RFA Plan does not trigger the 60% voter approval requirement and the simple majority rule
would apply. If the voters do not approve the Plan, the Planning Committee may revise Plan and
repeat process twice. If voters fail to approve on third try the Planning Committee is dissolved.
RFA Formation. If approved by voters the formation date will be the date set forth in the RFA
Plan. The effective date of the RFA is an important decision for a number of reasons. If the
formation date is prior to October 1, the RFA will be able to levy a tax in the year it is formed for
collection the following year. Regardless, the RFA will not begin to collect its own revenues until
the year following formation. Accordingly, the Plan must address interim funding of the RFA
from the effective date until it actually begins to collect tax revenues, i.e. May or June of the year
following the effective date. This may be accomplished by the participating jurisdictions
contributing funding or through a short-term loan. This approach gives staff the opportunity to
create the new entity and to timely address the transfer of assets liabilities etc. prior to beginning
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actual operations. Under this type of approach, the existing entities would continue providing
service until the date specified in the Plan for the transfer of operations.
THE RFA PLAN.
The RFA Plan is the fundamental organizational document of the proposed RFA: The RFA plan
allows the participating jurisdictions to essentially create their own government, subject to
statutory and constitutional requirements. The Plan must include, at a minimum, the following
elements:
1. Form of governance
2. Revenue sources and funding.
3. Assets and Liabilities
4. Organizational structure, employment, operations
5. Jurisdictional boundaries
6. Ambulance Services
7. Plan Amendments
1. RFA PLAN-FORM OF GOVERNANCE.
RFAs are governed by a governing board consisting of elected officials of the participating
jurisdictions. The RFA plan determines the exact composition of the governing board.
As with most decisions in the formation of the RFA, the determination of the composition of the
governing board is a discretionary decision of the Planning Committee. The RFA plan may
provide that each participating jurisdiction is given an equal number of seats on the RFA governing
board. While this allows each participating entity to have equal representation, depending on the
respective populations of the participating jurisdictions, may or may not provide equal
representation to the citizens of the RFA.
If fire district commissioners are on a governing board the commissioners are elected as fire district
commissioners in the same manner as if the RFA had not been formed and the fire protection
district must remain in existence solely for the purpose of providing governing board members.
City council members of an RFA governing board will generally be appointed by the City council.
RCW 52.26.080(3) allows for the creation of RFA Commissioner positions. Under the statutory
provisions an RFA Plan may include one or more RFA Commissioners to serve on the governing
board. RFA Commissioners, unlike appointed fire commissioners or city council members, will
be directly elected by the voters of the RFA.
The term of RFA Commissioner positions must be established by the Plan and cannot exceed six
years. If there are multiple positions, the terms must be staggered. In other respects, the RFA
Commissioner positions are guided by Chapter 52.14 RCW,which governs fire protection district
commissioners. These provisions require that the RFA commissioners take an oath of office,
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permit compensation of the RFA Commissioners and allow RFA Commissioners to serve as
volunteer firefighters with the unanimous consent of the governing board.
The RFA plan may also create RFA commissioner districts and may create a governing board with
a combination of elected officials of participating fire protection jurisdictions with RFA
Commissioners, with or without commissioner districts. If commissioner districts are used, the
districts must have approximately equal population and may be based, in part, on the jurisdictional
boundaries of the participating fire protection jurisdictions.
2. RFA PLAN-REVENUE SOURCES AND FUNDING.
The RFA Plan must establish the how the RFA is to be funded. Chapter 52.26 RCW establishes a
number of potential funding sources that must be considered. The specific funding mechanism
chosen will determine the voter approval requirements for the RFA Plan and will determine the
financial impact of the formation of the RFA on any participating cities.
Property Taxes. RFAs have statutory authority to impose a regular property tax levy of up to
$1.50 per thousand of assessed valuation within its jurisdictional boundary pursuant to RCW
52.26.140. The statute authorizes three separate $.50 cent levies.
In the event a city is one of the participating jurisdiction in an RFA,the city's tax capacity, but not
necessarily its tax rate, is reduced. If a city becomes part of an RFA the city's property tax capacity
can be no more than the City's maximum tax rate of$3.375 per thousand of assessed valuation,
less the amount levied by the RFA.1 In addition, in the event the City has annexed into a library
district RCW 84.52.044(2) provides that the City's maximum tax rate can be no more than $3.60
less the amount levied by the Library District, less the amount levied by the RFA.
Although the formation of an RFA will reduce the City's tax levy capacity, the formation of the
RFA will also directly reduce the City's expenses by the amount the City is currently paying
toward fire protection and emergency medical services. In most situations,the loss of tax revenue
is more than offset by the reduction in City expenses. In many situations this will create a scenario
where the City taxpayers could experience an increase in taxation as a result of the formation of
an RFA. The Planning Committee must be aware of these impacts and the City will either need to
convince its voters that an increase is necessary or the City will need to take action to decrease its
tax levy.
EMS Levy.RFAs,with voter approval,may also levy a six-year,ten year or permanent emergency
medical services levy under RCW 84.52.069 of up to $.50 per thousand of assessed valuation. If
another entity is levying an EMS tax within the boundaries of the RFA, the RFA will not be able
to levy an EMS tax. If the County is levying an EMS tax of less than $.50 the RFA may levy the
unused portion.
1 If the City has a firemen's pension fund, the City can levy an additional $.225 is added to the
City's maximum rate so the effect would be to reduce the city levy rate from$3.60 rather than
$3.375. (This is similar to what occurs when a city annexes into a fire protection district).
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Excess Levies. RFAs have statutory authority for the levying of taxes, if approved by the voters,
in excess of statutory limitations. 84.52.052 contains specific authorization and procedural
requirements for a taxing district to impose an excess levy within its boundaries. An excess levy
authorization requires a sixty percent voter approval and the election must be validated. Excess
levies are also often combined with the issuance of general obligation bonds and such levies will
generally remain an obligation of the property owners that approved the excess levy even if there
are subsequent boundary changes. Unlike fire protection districts, which may levy up to 4-year
maintenance and operation excess levies and up to six years for capital projects, RFAs are limited
to one-year maintenance and operation excess levies.
Benefit charge. RCW 52.26.180 - .270 authorize a regional fire authority to impose a benefit
charge.A benefit charge is a service fee and not a tax. The benefit charge applies to improvements
to real property and personal property and professional assistance is required to establish the
formula and basis for assessing the charge. If the RFA Plan submitted to the voters includes a
finance plan that incorporates a benefit charge the plan must be approved by a 60% vote. If
approved by the voters the benefit charge can constitute no more than 60%of the operating budget.
The approval of a benefit charge also reduces the maximum tax levy from$1.50 to $1.00 but does
not affect the EMS tax levy rate. If the RFA uses a benefit charge approach to financing, the
impact on the City's taxing capacity discussed in the prior section is reduced by $.50 as the
maximum levy rate reduction will be $1.00 rather than$1.50.
EMS Fees. RCW 52.12.131 authorizes RFA to establish and collect charges for emergency
medical services to reimburse it for the cost of providing the services.
Impact Fees/Mitigation Fees. Fire Districts and RFAs have authority, in conjunction with
counties and cities to impose impact fees under RCW 82.02.050 or voluntary mitigation fees under
RCW 82.02.020 to address the impacts of growth on a fire district/RFA level of service. City Fire
Departments also have this authority.
Extra Territorial Service Fees.RCW 52.12.111 authorizes services outside the boundaries of the
District/RFA "under conditions prescribed by the fire commissioners." This would allow the
District/RFA to establish a fee schedule for out of area responses. If there are areas where the
District/RFA knows in advance that it will regularly respond, the property owners in those areas
should be notified in advance of the policy. This power is often used as an incentive to convince
residents in an unincorporated area outside of a fire district/RFA to consent to annexing into the
fire district/RFA.
Burn Permit Fees and Response Recovery. RCW 52.12.108 and provisions of the Washington
Clean Air Act authorizes a fire protection district/RFA that has elected to issue and require fire
permits,to recover the costs of unauthorized burns from the property owner.
Miscellaneous Revenue sources. A number of additional revenue sources are available for fire
districts/RFAs including HAZMAT fees, donations, grants DUI cost recovery etc.
Debt Financing. RFAs have authority to incur general indebtedness, issue bonds and general
obligation bonds in a manner similar to fire protection districts.
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3. RFA PLAN-ASSETS AND LIABILITIES.
Chapter 52.26 RCW does not contain any mandatory asset transfer provisions. Accordingly, the
transfer of assets and liabilities is largely a function of negotiation. The one exception to this may
be voter approved bonded indebtedness where, as in other forms of consolidation, the voters that
approved the debt will remain liable for the debt and,unless the debt is renegotiated,the properties'
subject to a debt tax levy will remain subject to that levy until such time as the debt is repaid.
The RFA Plan must clearly address the asset and liability transfer issues. In addition to the Plan
there may be a need for additional agreements between the City and RFA designed to address asset
and liability transfers.
4. RFA PLAN—ORGANIZATIONAL STRUCTURE,EMPLOYMENT, OPERATIONS.
The organization, operations and service levels of the RFA should also be addressed in the Plan.
The Plan should contain language addressing the transfer of services from the existing providers
to the RFA. Chapter 52.26 RCW does not provide any specific guidance on operations and service
levels and, accordingly,the decisions of how to structure the operations, the level of services to be
provided, and the organization of the RFA etc. are all left to the discretion of the participating
jurisdictions.
If a city is a participating jurisdiction the role of the RFA in fire inspections and investigations
within city limits must be addressed either in the RFA plan or in a separate interlocal agreement.
While RFAs have specific statutory authority to enforce fire codes, RFAs do not independently
have police powers or the power to adopt fire codes. Many fire districts and RFAs provide code
enforcement and fire investigation services to cities but the scope of services and the relationships
between the fire service organization and the city must be carefully defined.
Chapter 52.26 RCW establishes specific statutory protections and rights for the employees of the
participating jurisdictions. RCW 52.26.100(4) establishes that all employees of the participating
fire protection jurisdictions are transferred to the RFA on its creation date. Absent any agreements
or RFA Plan provisions to the contrary, the employees are entitled to the rights, benefits and
privileges they would have been entitled to as an employee of the participating jurisdiction
including, rights to compensation, benefits, promotions etc. The statute prohibits the creation of
new probationary periods. If one of the entities has a civil service system,the issue of whether the
RFA will have civil service must be negotiated by the entity with civil service and its represented
employees covered by civil service. If none of the participants have civil service, civil service is
optional.
Personnel issues are most appropriately handled by negotiations between the participating
jurisdictions and their labor groups and by and between labor groups if different locals are to be
combined as a result of the formation of an RFA.
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5. RFA PLAN -JURISDICTIONAL BOUNDARIES.
Creation of RFA. Unlike mergers and annexations, RFAs do not change the boundaries of the
participating jurisdictions. Instead the participating jurisdictions continue to exist after the
formation of the RFA. The jurisdictional boundaries of the RFA are coextensive with and overlay
the jurisdictional boundaries of the participating fire protection jurisdictions. RCW 52.26.120
does authorize the dissolution of a participating fire protection district with voter approval. If the
fire protection district commissioners are part of the governance board, the fire protection district
would need to remain. However, if the fire district commissioners do not serve on the governance
board, dissolution of the fire protection district would make sense.
Expansion of RFA Boundaries. RFA's have the authority to annex adjacent fire protection
jurisdictions. The annexation process requires the following procedural steps: 1) Consent of the
RFA governing board to an amendment of its RFA plan to expand the boundaries of the RFA to
include the adjacent fire protection jurisdiction; 2) Consent of the legislative body of the adjacent
fire protection jurisdiction to the annexation and the RFA Plan and; 3)A simple majority vote of
the voters of the adjacent fire protection jurisdiction approving the annexation and the RFA plan
amendment.
The annexation of a new participating fire protection jurisdiction into an existing RFA requires the
same type of planning that occurred in the original formation of the RFA. The RFA governing
board will need to work with the adjacent participating fire protection jurisdiction to determine
how the annexation will affect governance, financing, employment and operations of the RFA. In
addition,the RFA Plan amendment should address asset and liabilities transfers between the RFA
and the annexing jurisdiction.
Two additional provisions of chapter 52.26 RCW directly address boundary changes.
RCW 52.26.110 contains provisions allowing an RFA to withdraw areas and reannex areas to
address tax limitation and uniformity issues. This statute has a narrow purpose and requires
coordinated action between the RFA and the city, town or fire protection district depending in
which jurisdiction the property to be withdrawn or annexed is located.
RCW 52.26.290 provides limited guidance for annexations by participating jurisdictions while part
of an RFA:
Territory that is annexed to a participating jurisdiction is annexed to the authority as of
the effective date of the annexation. The statutes regarding transfer of assets and
employees do not apply to the participating jurisdictions in the annexation.
Finally, RCW 52.26.090(l)(g) provides that for RFAs that include a fire protection district, the
provisions of Title 52 RCW will,unless provided otherwise in the RFA plan,control.Accordingly,
absent specific provisions to the contrary, such a RFA will be governed by the provisions of RCW
52.04 (annexations) and RCW 52.06 (mergers). This approach works well for annexations of
incorporated areas by the RFA and for partial mergers between the RFA and neighboring fire
protection jurisdictions.
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6. RFA PLAN—AMBULANCE SERVICES.
The Plan may also provide for the establishment of an ambulance system provided that there are
no existing ambulances services adequately serving the jurisdictions. This restriction on
competing with existing ambulance systems is common to cities but not fire protection districts.
Accordingly, if a fire district and a City are contemplating formation of an RFA and the district
provides its own ambulance service while the city receives services from a private ambulance
company, the fire district could be required to terminate its ambulance service as a condition of
participating in the RFA. If termination of the ambulance service is not feasible, the city and
district could consider an annexation of the city into the district as an alternative.
7. RFA PLAN—PLAN AMENDMENTS.
The plan must also identify those portions of the plan that may be amended by the governing board
and those that can only be amended with voter approval. Jurisdictions should be cautious in
requiring voter approval for plan changes as the restriction could unnecessarily limit the ability of
the RFA to address changing circumstances. However, the Plan cannot override statutory election
requirements. For example, the a RFA could not establish a financing plan based on a property
tax and after voter approval amend the plan to adopt a benefit charge without a vote of the people.
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RFA Creation - Procedural Checklist
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RFA CREATION - PROCEDURAL CHECKLIST
Two or more adjacent Fire Protection Jurisdictions"FPJ"may participate in the creation of a Regional
Fire Protection Service Authority"RFA".
Each FPJ appoints 3 elected officials, by resolution,to Planning Committee. This formal step
will likely follow informal planning meetings between the FPJs.
First Planning Committee Meeting
Appoint officers(optional)
Adopt rules and board operating procedures(optional)
Planning Committee develops Regional Fire Protection Service Authority Service Plan"Plan"
addressing design,financing and development of RFA.
Must allow and encourage public input in plan development
Plan will include,at a minimum,the following elements:
Revenue sources and funding plan.
Form of governance
Organizational structure,employment,operations
Asset transfers, capital facilities planning
Planning Committee adopts Plan and forwards to governing boards of FPJs to call a single
election in the entire proposed RFA area.
Election to approve formation of RFA requires simple majority unless a 60% revenue source
is included in the Plan(i.e.benefit charge, EMS levy or excess levy).
If not approved Planning Committee may revise Plan and repeat process twice,if voters
fail to approve on third try,Planning Committee is dissolved.
If approved by voters, formation date will be the date established in Plan. Note, RFA will not
begin to levy taxes or collect its own revenues until the year following formation (unless
formed on or before September 30). Plan must address interim funding.
Thirty days from election certification validity of the RFA may be challenged.
RFA begins operation under governing board as defined in Plan.
Fire district board may, by resolution, initiate proceedings for dissolution of any fire district
within the RFA, by majority vote of the fire district's registered voters, pursuant to RCW
52.26.120.
Snure Law Office,PSC
612 S.227th St.
Des Moines,WA 98198
206-824=5630
Brian@snurelaw.com