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HomeMy WebLinkAbout2.02 Service Plans Staff Report 7-28-10Rivers Edge Service Plans Planning Commission July 28, 2010 1 Proposed Metro District Lagena c::J ~~Y-CI a,/e!!tl O!s:tri:r .. Sar.G'eo: RM'.dl~Rrr~'«I ~~ 0 &11 Rivers Edge Service Plans Planning Commission July 28, 2010 2 PROJECT INFORMATION AND STAFF COMMENTS REQUEST Service Plan Review and Recommendation PROPERTY OWNER Carbondale Investments LLC REPRESENTATIVE Diane Miller – Miller Rosenbluth LLC LOCATION South of the City of Glenwood Springs on the west side of Highway 82 at Cattle Creek EXISTING ZONING Suburban COMPREHENSIVE PLAN Residential High Density I. BACKGROUND Special districts are quasi-municipal corporations and political subdivisions that are organized to act for a particular purpose. A metropolitan district is a special district that provides any two or more services which may include fire protection, parks & recreation, safety protection, sanitation, solid waste, street improvements or water, to name a few. A district has the ability to acquire bonds for the construction of the improvements and to levy taxes, to the area within their boundaries, to repay those bonds. We are familiar with the special district concept in Garfield County, particularly related to fire protection districts and water and/or sanitation districts. Several metropolitan districts currently exist in the County. The formation of a special district entails a three-part process that requires obtaining review and approval from the local governmental jurisdiction, review by district court, and a special election. The Garfield County Land Use Resolution of 2008, as amended does not contain specific provisions related to the review of service plans, therefore the process of submittal and review of the plans must be in compliance with statutory requirements contained in Title 32 of the Colorado Revised Statutes. Those statutory requirements include submittal of the service plans to the clerk for the board of county commissioners, referral of the plans to the planning commission for review and recommendation to the board within thirty (30) days of plan submittal, and a public hearing with the board not more than thirty (30) days after setting the public hearing date. II. GENERAL INFORMATION AND SITE DESCRIPTION The Clerk and Recorder (Jean Alberico) received petition for review of three (3) Rivers Edge service plans on July 1, 2010 and a public meeting was set with the Board of County Commissioners (the Board) on July 12, 2010. At that meeting the Board discussed the review process for the plans and joined in on the referral to the Commission for review and recommendation. The public hearing required for Board review is to be scheduled at a public meeting to be held at least ten (10) days after receipt of the Planning Commission recommendation. The public hearing must then occur within thirty (30) days of Rivers Edge Service Plans Planning Commission July 28, 2010 3 that meeting. The public meeting is scheduled on August 9, 2010 with an anticipated public hearing date on September 7, 2010. The three service plans are proposed to serve a, not-yet submitted, development plan which requires County zoning and subdivision review and approval. An application for re-zoning has not been submitted to the County. The service plans state that the “development” consists of approximately 239.94 acres, with up to 1,200 dwelling units, up to 50,000 square feet of commercial square feet, 12,000 square feet for an office/recreation/commercial structure, a 150-room hotel, a school site, parks and open space. The function of the districts will be to construct and maintain the public infrastructure necessary to provide service to the development. The public infrastructure may include some or all of the following: Certain roads/signage; Public trail system; Potable and non-potable water lines and associated facilities; Wastewater collection lines and associated facilities; Water tanks; Administrative and office facilities; Weed and pest control; Fire protection facilities and service; Fire hydrants; Vegetation manipulation and management; Drainage; Transportation facilities; Public recreation improvements; Other public improvements that may be necessary and appropriate. The proposed boundaries encompass an area of approximately ±240-acres that is divided into the three districts; the East District (11.9-acres), the North District (115.31-acres), and the South District (112.7-acres). Though each district will remain separate with individual statutory power and authority, intergovernmental agreements between the districts will designate the East District to serve as the coordinating district. The East District will be responsible for the review and approval of construction plans for the public improvements as well as the operation and maintenance of the public infrastructure. It is important to note that the service plan state that the districts may contract with other entities to manage, fund, construct and operate facilities, services and programs. Rivers Edge Service Plans Planning Commission July 28, 2010 4 The estimated cost of the public improvements for the proposed development is ±$60,000,000 which includes the acquisition of land, engineering services, legal services, administrative services, initial proposed indebtedness, as well as other major expenses related to the facilities and improvements to be constructed. The proposed indebtedness of the districts will not exceed $40,500,000, with repayment by revenue generated by a proposed 45.00 mill levy (of which 35.00 mills will be for debt obligation and the remainder for operating expenses). Additional property taxes will result for those properties within the district boundaries and the future residents will also be subject to HOA dues; user fees for various improvements including community facilities, internal transit, water/sanitation, and raw water; and a facility fee of 1% of the home sale price. III. ZONING AND ADJACENT USES The Highway 82 corridor between Glenwood Springs and Carbondale contains several residential PUD’s, Ironbridge to the west and Aspen Glen to the south, as well as other residential subdivisions as shown on the adjacent map. The CR 114 / CR 154 area to the north of the site contains commercial zoning with retail uses such as the Thunder River Market area and semi-industrial commercial uses such as Gallegos stone yard, warehouses and fabrication activities and a mini storage facility. The high density H Lazy F Mobile Home Park is also located north of the service area boundary. Rivers Edge Service Plans Planning Commission July 28, 2010 5 The adjacent zoning map indicates that property within the service area boundary is predominantly zoned Residential-Suburban with a small (±1-acre) area zoned Commercial General (the former site of Sopris Restaurant). Commercial zoning, both limited and general, is located immediately to the north and east of the site. The ULUR contains general provisions of basic zone districts in §3-101. Subsection I. states that the “The Residential-Suburban zone district is comprised of low-density suburban residential uses developed to maintain a rural character.” IV. HISTORY This site, less the one acre commercial-zoned parcel, was zoned Sanders Ranch PUD by the Board in 2001 and memorialized in Resolution 2001-27. This action rezoned the property from ARRD (Rural) to PUD to allow a site specific development plan that included a golf course, 62 single-family units, and 168 multi-family units for an average density of .82 dwelling units per acre. A preliminary plan compliant with the PUD was submitted under the name of Bair Chase and approved by the Board in 2004, memorialized in Resolution 2004-98. A one-year extension for the Preliminary Plan was granted however that extension expired on September 13, 2006 rendering the Preliminary Plan invalid. The expiration of the Bair Chase Preliminary Plan, together with the fact that the development was not in compliance with the approved Sanders Ranch PUD phasing plan, the entire PUD Plan was determined to be invalid. The Board initiated action to revoke the PUD and rezone the site. Resolution 2008-112 memorializes both the revocation of the PUD and the rezoning of 228 acres of the property from PUD to Residential-Suburban, but maintained the Sanders Ranch PUD conservation and open space zoning on the 53-acre conservation easement held by Roaring Fork Conservancy. This 53 acres is part of the property owned by Carbondale Investments, LLC and it is unclear to what extent this acreage is within any of the proposed district boundaries. A sketch plan application was submitted in 2008 and reviewed by the Planning Commission. That plan proposed a high-density urban-style residential community comprised of a wide variety of residential types totaling 979 units, a 25,000 sq. ft. neighborhood commercial center, 24,000 sq. ft. of community facilities, a school site, a 10,000 sq. ft. firehouse and several community parks / fishing ponds. In October 2008 an application for Planned Unit Development rezoning of the site was reviewed by County staff however the application was withdrawn prior to any hearing on the request. That plan ±1-acre commercial zoning Rivers Edge Service Plans Planning Commission July 28, 2010 6 proposed 1,006 dwelling units, 25,000 square feet of commercial, a school site, 25,000 square foot community center, recreation and open space. HISTORIC PROPOSALS V. COMPREHENSIVE PLAN The property is located within Study Area I which designates the area of the property, outside of the conservation easement, as “High Density Residential” on the Proposed Land Use Districts Map which proposes properties in this area develop residentially at a density of 0 Rivers Edge Service Plans Planning Commission July 28, 2010 7 to <2 acres per dwelling unit. The Suburban zoning complies with this designation. The density recommended in the Comprehensive Plan for this are contains a very wide range – from 2 acres to 0 acres. The determining factor on the appropriate density would be compliance with the goals, objectives and policies related to housing, transportation, commercial and industrial uses, recreation and open space, water and sewer services, natural environment, and urban area of influence. The proposed “development” to be served by the districts may result in .2 acres per dwelling unit when utilizing the whole property, however it is likely that the residential component will occur on less than the whole property (due to the amount of commercial floor space proposed to occur) thereby reducing the actual acres per dwelling unit. Section III. Goals, Policies and Objectives of the Comprehensive Plan include the following statements: Goal: To ensure the provision of legal, adequate, dependable, cost-effective and environmentally sound sewer and water services for new development. OBJECTIVES: 7.2 Development located adjacent to municipalities or sanitation districts with available capacity in their central water/sewer systems will be strongly encouraged to tie into these systems. POLICIES: 7.2 Where logical, legal and economic extension of service lines from an existing water and/or sewage system can occur, the County will require development adjacent to or within a reasonable distance, to enter into the appropriate agreements to receive service. The burden of proof regarding logical, legal and economic constraints will be on the developer. VI. REVIEW CRITERIA & STANDARDS Action on service plan – criteria §32-1-203 (1) The board of county commissioners of each county which has territory included within the proposed special district, other than a proposed special district which is contained entirely within the boundaries of a municipality, shall constitute the approving authority under this part 2 and shall review any plan filed by the petitioners of any proposed special district. With reference to the review of any service plan, the board of county commissioners has the following authority: (a) To approve without condition or modification the service plan submitted; (b) To disapprove the service plans submitted; (c) To conditionally approve the service plan subject to the submission of additional information relating to or the modification of the proposed service plan. (2) The board of county commissioners shall disapprove the service plan unless evidence satisfactory to the board of each of the following is presented: (a) There is sufficient existing and projected need for organized service in the area to be serviced by the proposed special district. Rivers Edge Service Plans Planning Commission July 28, 2010 8 (b) The existing service in the area to be served by the proposed special district is inadequate for present and projected needs. (c) The proposed special district is capable of providing economical and sufficient service to the area within its boundaries. (d) The area to be included in the proposed special district has, or will have, the financial ability to discharge the proposed indebtedness on a reasonable basis. (2.5) The board of county commissioners may disapprove the service plan if evidence satisfactory to the board of any of the following, at the discretion of the board, is not presented; (a) Adequate service is not, or will not be, available to the area through the county or other existing municipal or quasi-municipal corporations, including existing special districts, within a reasonable time and on a comparable basis. (b) The facility and service standards of the proposed special district are compatible with the facility and service standards of each county within which the proposed special district is to be located and each municipality which is an interested party under § 32-1-201 (1), C.R.S. (c) The proposal is in substantial compliance with a master plan adopted pursuant to section §30-28- 106, C.R.S. (d) The proposal is in compliance with any duly adopted county, regional or state long-range water quality management plan for the area. (e) The creation of the proposed special district will be in the best interest of the proposed area to be served. (3) The board of county commissioners may conditionally approve the service plan of a proposed special district upon satisfactory evidence that it does not comply with one or more of the criteria enumerated in subsection (2) of this section. Final approval shall be contingent upon modification of the service plan to include such changes or additional information as shall be specifically stated in the findings of the board of county commissioners. (4) The findings of the board of county commissioners shall be based solely upon the service plan and evidence presented at the hearing by the petitioners, planning commission and any interested party. VII. STAFF CONCERNS AND ISSUES REQUIRED SUBMITTAL CRITERIA §32-1-202 (2), C.R.S. The service plan shall contain the following: (a) A description of the proposed services; Staff Comment: The plans provide a list of potential services which may – or may not – be services that the districts provide. Metropolitan District is defined by State Statute as a special district that provides any two or more of a list of potential services. The following is excerpted from the East District however each of the plans includes the same language: Rivers Edge Service Plans Planning Commission July 28, 2010 9 This does not clearly describe the proposed service, rather it is simply a list of all the possible services permitted by the statute. (b) A financial plan showing how the proposed service are to be financed, including the proposed operating revenue derived from property taxes for the first budget year of the district, which shall not be materially exceeded except as authorized pursuant to section 32-1-207 or 29-1-302, C.R.S. All proposed indebtedness for the district shall be displayed together with a schedule indicating the year or years in which the debt is scheduled to be issued. The board of directors of the district shall notify the board of county commissioners or the governing body of the municipality of any alteration or revision of the proposed schedule of debt issuance set forth in the financial plan; Staff Comment: BBC Research has been retained to review this aspect o f the service plans on behalf of the County. Ford Frick, Managing Director, has responded that (c) A preliminary engineering or architectural survey showing how the proposed services are to be provided; Staff Comment: The submitted plans do contain preliminary maps showing, in a very general manner, the location of several proposed services/facilities. (d) A map of the proposed special district boundaries and an estimate of the population and valuation for assessment of the proposed special district; Staff Comment: Maps of the proposed district boundaries were provided as well as the valuation for assessment. The estimate of the population is 3,120 persons. Rivers Edge Service Plans Planning Commission July 28, 2010 10 (e) A general description of the facilities to be constructed and the standards of such construction, including a statement of how the facility and service standards of the proposed special district are compatible with facility and service standards of any county within which all or any portion of the proposed special district is to be located, and of municipalities and special districts which are interested parties pursuant to section 32-1-204(1)1 Staff Comment: The service plans for the three areas includes conceptual maps for the public facilities and improvements which may be provided directly or by contract with Districts or other public and/or private entities to undertake such functions or perform such responsibilities. The conceptual plan includes “estimates only which are subject to modification as engineering, development plans, economics, and applicable requirements, and construction scheduling may require.” Public Improvements section of each of the plans, III. C., provides a statement, below, that primary improvements (services) that they will provide are streets, storm drainage, park and recreation and other: The standards are discussed in III B. of each of the plans: 1The governing body of any existing municipality or special district…within a radius of three miles of the proposed special district boundaries, which governmental units shall be interested parties… Rivers Edge Service Plans Planning Commission July 28, 2010 11 The ‘conceptual’ plan provides ‘general’ information regarding the facilities, such as parks and recreation facilities, and safety protection facilities - however the plan does not discuss, as required, how those facilities and the service standards may be compatible with other districts or municipalities. (f) A general description of the estimated cost of acquiring land, engineering services, legal services, administrative service, initial proposed indebtedness and estimated proposed maximum interest rates and discounts, and other major expenses related to the organization and initial operation of the district. Staff Comment: The plans provide estimated costs for the construction of improvements as follows: Preliminary Engineering Cost Estimates Note: Costs are based on unit linear foot prices for road, trail, sidewalk and utilities and unit square foot prices for recreation and landscaped areas as presented in plan exhibits. North Rivers Edge Service Plans Planning Commission July 28, 2010 12 South East Rivers Edge Service Plans Planning Commission July 28, 2010 13 The plans do not include the required estimated cost of acquiring land, engineering services, legal services, or administrative services. (g) A description of any arrangement or proposed agreement with any political subdivision for the performance of any services between the proposed special district and such other political subdivision, and, if the form contract to be used is available, it shall be attached to the service plan; Staff Comment: The plans state that they may enter into agreements with other districts, particularly the Carbondale and Rural Fire Protection District and the Roaring Fork Water & Sanitation District, however no arrangements or proposed agreements were made available. (h) Information, along with other evidence presented at the hearing, satisfactory to establish that each of the criteria set forth in section 32-1-203, if applicable, is met; Staff Comment: Section 32-1-203 contains the criteria for action on the plans. This section will be used to determine the findings and recommendation to the Board. (i) Such additional information as the board of county commissioners may require by resolution on which to base its findings pursuant to section 32-1-203; Staff Comment: Section 32-1-203 contains the criteria for action on the plans. This section will be used to determine the findings and recommendation to the Board. PREMATURE NATURE OF REQUEST Garfield County has several existing, functioning metropolitan districts including Mid-Valley Metropolitan District, the Battlement Mesa Metropolitan District and the Consolidated Metropolitan District (also Battlement Mesa). Non-functioning, but existing districts include Rose Ranch Metro and Landis Creek Metro 1 & 2. It appears that in a majority of instances that the service plans were reviewed concurrent with the development review for the proposed project that the district was to serve. The current review of the Rivers Edge service plans is different in that it is asking to serve a development that not only is not approved, has not even been submitted for review, and does not currently have the zoning to complete. Staff is concerned that the approval and creation of the districts by the County would be an implicit agreement of the proposed development plan. Further, the creation of a governmental entity may relieve the County of some review components of the proposed and highly speculative project. Staff has contacted numerous planners, attorneys, and other consultants familiar with formation of metropolitan districts and there was consensus that the petitioners would not be able to demonstrate a need for the districts if development were not already approved or being reviewed in conjunction with the service plan review. Exhibit I, the report from BBC Research provides that: Rivers Edge Service Plans Planning Commission July 28, 2010 14 REDUNDANCY OF SERVICE The Board and Commission should consider §32-1-107(2) which provides that a district may be organized wholly or partly within an existing special district, but shall not provide the same services as an existing district. Overlapping districts may be authorized to provide the same services only if: a) The Board approves inclusion of service as part of the service plan of an overlapping district; b) Improvements of facilities to be financed, established, or operated by an overlapping special district do not duplicate or interfere with existing or planned improvements or facilities to be constructed within portions of existing districts that new districts will overlap; and c) The board of directors of the overlapped district must consent. See maps contained in Exhibit H for special district boundaries. Clearly the proposed metropolitan district boundaries will overlap the Carbondale and Rural Fire Protection District as well as the service area of the Roaring Fork Water and Sanitation District. The plans propose that they “may” contract with these entities to provide service, but the petitioner has not provided consent from either the fire protection district or the water and sanitation district. Section 31-1-107(3)(c) provides that nothing in this section is to be construed to encourage unnecessary proliferation, duplication, overlapping, or fragmentation of a special or metropolitan districts. REVIEW CRITERIA 32-1-203 C.R.S. – (staff comments are provided after each section in italics). (2) The board of county commissioners shall disapprove the service plan unless evidence satisfactory to the board of each of the following is presented: (a) There is sufficient existing and projected need for organized service in the area to be serviced by the proposed special district. Staff Comment: Evidence has not been provided regarding the existing and projected need for organized service for the area contained within the service plans. Current entitlements for a majority of the property would allow for the construction of one single-family home, while the ±1-acre parcel of commercial zoned land would be permitted commercial development. It is highly unlikely that this area has an existing need, and any development on the parcel is highly speculative given the current zoning, and economic climate. Therefore there is no evidence of a projected need. Rivers Edge Service Plans Planning Commission July 28, 2010 15 Further, the service plans discuss the RE District provision of water and sanitation service and fire protection service, however these facilities will, or may, be dedicated to, and services will be contracted to, existing special districts. There is no evidence of existing or projected need for organized services to be provided by the RE Districts as some, if not all, of the proposed services are already provided by other districts. (b) The existing service in the area to be served by the proposed special district is inadequate for present and projected needs. Staff Comment: Evidence has not been provided that the existing service is inadequate for present and projected needs. As stated above, the existing districts – fire protection and water/sanitation, are sufficient to serve the proposed area as the service plans state that they will contract with these two entities for service. The proposed RE service area is currently entitled to ±1 acre of commercial development and one single family home. (c) The proposed special district is capable for providing economical and sufficient service to the area within its boundaries. Staff Comment: The service plans have not demonstrated that they can provide economical and sufficient service. Potential future residents of the development will pay additional property taxes, HOA dues, user fees for the services and facilities, and will be subject to a facilities fee in the amount of 1% of the sales price of the unit. This is highly speculative given that the proposed development is not currently approved, and the future density of the development is unknown. The service plans have not adequately demonstrated that they are capable of providing economical and sufficient service to the area. (d) The area to be included in the proposed special district has, or will have, the financial ability to discharge the proposed indebtedness on a reasonable basis. Staff Comment: Given the highly speculative nature of the “proposed” development it has not been demonstrated that the proposed special districts will have the financial ability to discharge the proposed indebtedness on a reasonable basis. (2.5) The board of county commissioners may disapprove the service plan if evidence satisfactory to the board of any of the following, at the discretion of the board, is not presented; (a) Adequate service is not, or will not be, available to the area through the county or other existing municipal or quasi-municipal corporations, including existing special districts, within a reasonable time and on a comparable basis. Staff Comment: The applicant has not provided sufficient evidence regarding this issue, particularly since the current districts appear to be capable of providing adequate service given that there is no “development” approval for the site other than ±1 acre of commercial and one single-family home. To assume any level of future development on the site is highly speculative. Rivers Edge Service Plans Planning Commission July 28, 2010 16 (b) The facility and service standards of the proposed special district are compatible with the facility and service standards of each county within which the proposed special district is to be located and each municipality which is an interested party under 32-1-201 (1). Staff Comment: The service plans do not discuss nor provide information sufficient to make this determination. (c) The proposal is in substantial compliance with a master plan adopted pursuant to section 30-28-106, C.R.S. Staff Comment: The Comprehensive Plan does indicate that High Density Residential uses (0 to less than 2 acres per dwelling unit) may be appropriate in this area (as indicated by the existing suburban zoning which complies with this designation), however the proposed density of .2 acres per dwelling unit is speculative. The objective, policies and goals of the Comprehensive Plan does not support the provision of redundant services. (d) The proposal is in compliance with any duly adopted county, regional or state long-range water quality management plan for the area. Staff Comment: This area is not subject to a 208 Plan. (e) The creation of the proposed special district will be in the best interest of the proposed area to be served. Staff Comment: The area to be served is currently vacant land with no human inhabitants, no development approval. Inadequate information has been submitted to demonstrate that the creation of districts, to provide service to a non-existent population, is the best interest of the area proposed to be served. VIII. STAFF RECOMMENDATION Disapproval of the service plans is required if the Board is not provided satisfactory evidence on any one of the following: that there is sufficient existing and projected need for organized service; that existing service is inadequate for present and projected needs; district is capable for providing economical and sufficient service; the proposed special district has, or will have, the financial ability to discharge the proposed indebtedness. Disapproval of the service plans is discretionary with regard to issues related to non-compliance with the Comprehensive Plan; that adequate service is not, or will not be, available to the area through the county other existing municipal or quasi-municipal corporations, including existing special districts; that the facility and service standards are compatible with the facilities and standards of the county and any ‘interested party’ municipality; compliance with water quality plans; that the formation of the districts is in the best interest of the area to be served. PUD Rivers Edge Service Plans Planning Commission July 28, 2010 17 Staff recommends that the Planning Commission recommends disapproval of the RE South Service Plan, the RE North Service Plan and the RE East Service Plan as required by 32-1-203 (2) (a) and (b) and 32-1- 203 (2.5) (a), (b), (c), and (e) with specific findings below and the chart on page 18: 1. 32-1-203 (2) (a) There is sufficient existing and projected need for organized service in the area to be serviced by the proposed special district. The petitioner has not demonstrated that that there is existing or projected need for any of the listed proposed services. The proposed district boundaries have entitlements for ±1-acre of commercial use and the ability to construct one single-family home. The projected need, the proposed development of 1,200 dwelling units and up to 70,000 square feet of commercial area, cannot be determined prior to submittal of numerous development plans for County review, plans which may or may not be approved. 2. 32-1-203 (2) (b) The existing service in the area to be served by the proposed special district is inadequate for present and projected needs. The service area for the Roaring Fork Water & Sanitation District, and the district boundaries of the Carbondale and Rural Fire Protection District overlap the proposed metropolitan district boundaries. The petitioner has not adequately demonstrated the need for additional organized service in the area. Approval of the service plans would result in overlap of district boundaries and/or redundancy of certain services. 3. 32-1-203 (2.5) (a) Adequate service is not, or will not be, available to the area through the county or other existing municipal or quasi-municipal corporations, including existing special districts, within a reasonable time and on a comparable basis. The petitioner has not demonstrated that adequate service is not, or will not be, available within a reasonable time and on a comparable basis. The existing fire protection and water/sanitation service is currently adequate to serve the area within their boundaries and service plan areas. 4. 32-1-203 (2.5) (b) The facility and service standards of the proposed special district are compatible with the facility and service standards of each county within which the proposed special district is to be located and each municipality which is an interested party under 32-1- 201 (1). The petitioner has not demonstrated that the proposed facility and service standards are compatible with other special districts, the County or interested party municipalities. 5. 32-1-203 (2.5) (c) The proposal is in substantial compliance with a master plan adopted pursuant to section 30-28-106, C.R.S. The service plans do not include an analysis of compliance with the Comprehensive Plan therefore they have not demonstrated that the proposal is in substantial compliance. Rivers Edge Service Plans Planning Commission July 28, 2010 18 6. 32-1-203 (2.5) (e) The creation of the proposed special district will be in the best interest of the proposed area to be served. The proposed district boundary contains vacant land with no entitlements other than for one single family home and approximately 1-acre of commercial development. The County has not review, nor even received, an application proposing the “development” that the districts propose to serve. That “development” is speculative and therefore the County cannot determine the need for the services at this time.