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2020-10-26 Centre Pointe Dev - Letter to HOA re TOT October 26, 2020 Desert Resort Management 42635 Melanie Place, Suite 103 Palm Desert, CA 92211 Re: Centre Pointe HOA The La Quinta City Manager, City Directors, and City Attorney have discussed the Centre Pointe Development Agreement (DA). including the Transient Occupancy Tax (TOT) mitigation fee that is paid by the members of the Centre Pointe HOA. The City would like to continue good faith discussions with designated HOA board members that would allow for easier tracking of the TOT mitigation fee and make it more equitable for current and future homeowners. Attachment 1 to the letter is a summary of possible amendments. The City’s finance department is available to answer any questions, provide additional information, or consider any other amendments the HOA would like to discuss. The City would like to disclose that DA amendments and/or separate implementation agreements would require the following approvals before being implemented.  City Council review and approval  The City’s legal review and approval  Developer’s approval and legal review Thank you for your time and consideration. We look forward to future discussions with the HOA regarding the TOT mitigation fee. Respectfully, Karla Romero Finance Director/City Treasurer Kromero@laquintaca.gov 760-777-7073 ATTACHMENT 1 Centre Pointe HOA DA Amendments for Consideration A – Per unit TOT Mitigation Fee -  Reset the base year of the per unit fee starting in 2016 (versus 2013) and the base year payment ($150/unit) would be adjusted per the CPI starting in July 2017 for the 2017 billing and would then be adjusted every year thereafter. o If the base year is reset to 2016, only the outstanding 2020 year would be recalculated and with an adjusted bill. B – TOT Mitigation Threshold The annual TOT mitigation threshold was formulated based on the assumption that the Sanctuary Villas (formerly proposed 26 units, but now medical offices) and Casitas Development consisting of 136 units (40 have been built) would be built and subject to the fee. (Note: The developer, with the obligation to construct the 96 remaining units for the Casitas Development, is out of compliance with governing agreements, as amended, with the City.) Homewood Suite hotel operations are not associated with the HOA, therefore, the HOA does not have oversight of the hotels operations, projections, control of rental rates which determine TOT remitted, or the long-term use of the hotel cancelling the collection of TOT remittances. The average annual hotel TOT remittance from 2016 to 2019 was approximately $523,000, which is below the 2012 base amount of $546,131 and below the current threshold amount of $633,118.  Consider two alternatives to address the Homewood Suites TOT remittance threshold: o Recalculate the base amount of the Homewood Suites TOT remittance threshold ($546,131 in 2012) to a lower value based on actual and projected revenues. o Eliminate the Homewood Suites TOT remittance threshold and replace it with an agreed upon HOA TOT remittance threshold. Any recalculation of the threshold shall require a professional third-party fiscal analysis accepted by the City. o The threshold shall be attained for three years within an eight- year time frame to remove the TOT mitigation fee. C – Short-Term Vacation Rentals The current HOA’s Covenants, Conditions and Restrictions (CCR’s) prohibit short-term vacation rentals (STVR’s), which is in direct contradiction to the applicable, statutory Development Agreement (DA), which encourages 2 STVR’s. If the threshold is changed from the hotel to the HOA TOT remittances, the HOA shall amend its CCR’s to allow for STVR’s. D – Consumer Price Index for TOT mitigation fee and threshold The $546,131 hotel TOT remittance threshold “may” increase by the Consumer Price Index (CPI) annually. City Staff recommends the following updates:  Change “may” to “shall” within the DA, section 3.4.3 Casitas Development Annual Mitigation Fee: Termination to match section 3.4.7 Consumer Price Index Adjustments, which state the CPI “shall” be adjusted annually.  Updating the CPI index referenced in section 3.4.7 of the DA from Los Angeles-Riverside-Orange County to “Riverside-San Bernardino- Ontario (or successor Index)”. The latter CPI was not in existence when the DA was signed and adopted.  Add a CPI annual maximum of not to exceed 2% per year.  Allow for negative CPI adjustments should they occur during any year. E – Legal Fees Legal fees at City Council-approved rates for reimbursable work are 100% recoverable as a pass-through payment based on actual costs incurred by the City Attorney’s Office. The City may consider charging the HOA a fee based on the portion of the work to complete for the HOA’s requested items, which shall require DA amendments. F – Public Facility Fee Section 3.4.5 Payment of Casitas Development Public Facilities Fee refers to a 5% fee charged by the HOA and remitted to the City for Casitas Development rentals exceeding a period of more than 30 days.  The City and HOA do not track or have permits for long-term rentals.  This fee has never been charged in this development. Staff recommends removing any reference to the Public Facility Fee within the DA.