Agenda 03/23/2010 Item #10B
Agenda Item No. 10B
March 23, 2010
Page 1 of 10
EXECUTIVE SUMMARY
Recommendation to accept the first annual report on the "Impact Fee Program for
Existing Commercial Redevelopment" and to consider two proposed changes to the
Consolidated Impact Fee Ordinance which would (1) extend to Redevelopment
Program for all buildings which are five years and older on a continuing basis, and
(2) eliminate the expiration date of impact fee credits so that they run with the land
until used or transferred.
OBJECTIVE: That the Board of County Commissioners (Board) accepts the first annual
report on the "Impact Fee Program for Existing Commercial Redevelopment."
CONSIDERATIONS: On December 3,2008, during the regular meeting of the Board
of County Commissioners, the Board directed staff to develop an option, for
consideration by the Board, for a change in the current requirements for the assessment of
impact fees for changes of use within existing buildings. The current regulations are set
forth in Section 74-201 (c) of the Collier County Code of Laws and Ordinances (Code),
which is the Collier County Consolidated Impact Fee Ordinance, which states:
(c) Change of size or use. 1mpactfees shall be imposed and calculatedfor net
increase, alteration, expansion, or replacement of a use or a building, or
part of a building (including dwelling unit), and each accessory or non-
accessory building, provided such net increase, alteration, expansion or
replacement of the use, building, or part thereof or therein, by applying
this chapter results in " (1) a net increase in the number of dwelling units;
(2) a net increase in the size or square footage of a building; (3) a net
increase in the size of the use; or (4) intensification of the use as to
constitute an expansion of the same use category or result in a change to a
higher impact fee land use category; or (5) otherwise create additional
demand or additional impacts on any of the public facilities.
Staff reviews and assesses impact fees for changes of use via the review of all
applications for Zoning Certificates/Business Tax Receipts and Development Orders
(Building Permits, Site Plans, Site Plan Amendments, etc.) In order to assess impact fees
for a change of use, first the lawfully existing land use must be determined. Staff
researches information provided by applicant, site plans, building permits, Property
Appraiser's records, etc., in order to make this determination. The impact fees are then
calculated for the existing use based on current rates.
The impact fees are then calculated for the proposed new use. If the development
contemplates a land use that is of a higher intensity use and therefore creates additional
impacts on public facilities, impact fees are required to be assessed for the net increase in
demand. Therefore, the impact fees are assessed by applying the impact fees that are
calculated for the existing use against the impact fees that are calculated for the new use.
Agenda Item NO.1 OB
March 23, 2010
Page 2 of 10
Based on the direction of the Board, staff and the County Attorney developed the
following Program for the Board's consideration. The scope of the Program is limited to
commercial uses and the requirements for assessment for "intensification of the use" or
changes that "otherwise create additional demand or additional impacts on any of the
public facilities. "
Prol!ram:
Elil!ibilitv:
Limitations:
Applicable
Tvpes of Impact
Fees:
Lenl!th of Prol!ram:
"Impact Fee Program for Existing Commercial
Redevelopment" which provides applicants meeting the
requirements below an exemption from assessments for
"intensification of the use" or changes that "otherwise
create additional demand or additional impacts on any of
the public facilities. "
Commercial buildings that have had a Certificate of
Occupancy for a minimum of five (5) years. The building
must have been permitted and paid the then applicable
impact fees.
Program is limited to changes within existing commercial
buildings, for example tenant build-outs, tenant
improvements, etc. Additions to existing buildings and
demolition/replacement of buildings will not be eligible for
this Pro!,'l'am.
Applicable to all impact fees (excluding water-sewer)
assessed for commercial changes of use, based on land use.
This typically consists of Transportation, EMS,
Government Buildings, Law Enforcement and Jail. These
provisions will not apply to assessments for Water and
Sewer Impact Fees.
Initial term of Program two (2) years from adoption date,
with a report to the Board on the usage of the Program after
one year and again prior to the sunset date. The Board
could then elect to extend the Program or allow it to sunset.
On February 24, 2009, during the discussion of item lOA, the Board directed the County
Manager, or his designee, and the County Attorney to implement the Program as detailed
above. In addition the Board directed that a status report be presented to the Board in one
Agenda Item NO.1 08
March 23, 2010
Page 3 of 10
year, including detailed information on the participation in the Program and the fiscal
impact on each of the affected impact fee trust funds.
On March 24,2009, the Board adopted Ordinance No. 2009-14 establishing the above
Program which became effective March 30, 2009, upon filing with the Florida Secretary
of State.
During the Program's fITst year, 40 applicants participated with 20 of the applicants being
new businesses. The majority of the applicants were referred to the Impact Fee
Administration Office through the Zoning Certificate process and were unaware of the
potential impact fee assessments related to changes of use. However, the applicants also
stated that they would be unable to move forward with the proposed business, at the
specified location, if the "Impact Fee Program for Existing Commercial Redevelopment"
was not available.
Of the 20 applicants that were existing businesses relocating to new space, none of the
applicants indicated that they were receiving a lower rent or lease rate due to the
Program. In fact, the majority of applicants in this category were also unaware of the
potential impact fee assessments related to changes of use and also stated that they would
be unable to move forward with the proposed business relocation if the Program was not
available.
Staff has fielded numerous inquiries during this one-year period related to newer
buildings participating in the Program. As stated above, the Program is limited to
commercial buildings that have had a Certificate of Occupancy for a minimum of five (5)
years. The building must have been permitted and paid the then applicable impact fees.
Included with this Executive Summary is a protest letter provided by the owner of a
newer building that did not meet the age requirements of the Program. The property
owner elected to pay impact fees related to a change of use for a tenant "under protest"
pending the Board's review of the Program. As indicated in the attached correspondence,
the property owner believes that the Program should also apply to newer construction.
The following chart provides a list of the types, and amounts by type, of changes of use
that are participating in this Program. The land uses indicated correspond to the closest
applicable land use for establishing the impact fee rates to be applied. These categories
do not dictate the land use classifications for zoning purposes.
Change of Use Number of Applicants in Program
Church to General Office I
General Light Industrial to Auto Sales I
General Light Industrial to Church 1
General Light Industrial to Gymnastics 3
Agenda Item No. 10B
March 23, 2010
Page 4 of 10
Change of Use (cont'd) Number of Applicants in Program
General Light Industrial to General Office 17
General Light Industrial to Retail 7
General Light Industrial to Tire Store 1
General Office to Medical Office 8
General Office to Day Care 1
The Program was initially established for a two-year period, with a report to the Board
after one year and again prior to the sunset.. At that time, the Board could then elect to
extend the program or allow it to sunset. If the Board accepts this first annual report,
staff will continue to track the qualifYing participants in the program and report back to
the Board in March of2011, which is prior to the sunset date for the Program.
FISCAL IMPACT: The following is a breakdown, by impact fee type, of the total
impact fees that were not assessed for the qualifYing changes of use.
Impact Fee Type Amount
Correctional Facilities (Jail) $26,174.52
Emergency Medical Services $11,398.70
Government Buildings $59,786.64
Law Enforcement $21,065.73
Road $1,147,851.95
Cumulative Total $1,266,277. 54
As stated in the Considerations Section (above), staff spoke directly with many of the
customers that qualified for the Program. The customers indicated that if the Program
was not in place, and they were required to pay additional impact fees in order to open or
relocate their business to a particular building, they would have elected not to move
forward with the proposed use. Another option for such customers would have been to
continue seeking out tenant spaces in which the impact fees had been paid for a use
similar to the type they were proposing, and therefore the payment of additional impact
fees would not be required. In either case, the County would not collect any additional
impact fees and in many cases businesses would be unable to open or relocate/expand.
Therefore, the benefits of the Proi,'1'am, which include encouraging new business within
Collier County, retention and expansion of existing businesses in Collier County and
Agenda Item NO.1 OB
March 23, 2010
Page 5 of 10
absorption of a portion of the supply of vacant commercial lease space, in older
buildings, minimize the implied fiscal impact on the respective impact fee trust funds.
GROWTH MANAGEMENT IMPACT: Impact Fees generate funds to be expended
for capital improvements to public facilities necessitated by growth which is consistent
with Policy 2 of the Capital Improvement Element (CIE) of the Collier County Growth
Management Plan (GMP), which states: "Future development will bear a proportionate
cost of facility improvements necessitated by growth."
While many of the new and existing business noted that the program was a key factor in
their decision to proceed, it should also be noted that their corresponding increase in
impacts to public facilities, especially roads, were not addressed. Long term, this could
negatively impact the County's ability to address any potential transportation
infrastructure improvements necessitated by the changes in use.
Although the Program limits the additional impact fees that will be assessed for changes
of use, despite the intensification of use and demand on public facilities, this type of
program for redevelopment is consistent with Policy 3.12 of the Economic Element of the
GMP which states: "Collier County, in coordination with other appropriate entities, will
support the establishment and retention of small businesses throughout the County. "
Additionally, this Program does not in any way negate or waive existing zoning laws.
Any relocation of a new or existing business into an existing facility generates the need
for a Zoning Certificate from the Zoning Department and the subsequent issuing of a
Business Tax Receipt from the Collier County Tax Collector. Staff, through issuing the
Zoning Certificate, verifies that the new business location is properly zoned to allow for
the business to legally operate at a new location. Additionally, prior to issuing a Zoning
Certificate, staff reviews the proposed business location to ensure that the site provides
the required number of parking spaces and meets the minimum landscape code
requirements.
If the new business location is not located within a zoning district that permits the
proposed use, the Zoning Certificate is dcnied and the business owner is directed to
consider other areas within the County that are appropriately zoned for the proposed use.
In the alternative, the applicant is advised of the option to seek to rezone the property to a
zoning district that would allow the proposed commercial use. All rezoning applications
first have to be found consistent with the applicable elements of the Collier County
Growth Management Plan (GMP) as well as found to be compatible with the adjacent
land uses. If deemed inconsistent with the Comprehensive Plan, the applicant would have
to seek an amendment to the GMP.
LEGAL CONSIDERA nONS: In light of continuing issues caused by this
unprecedented economic slowdown, there are two proposed changes to the Consolidated
Impact Fee Ordinance that Ms. Patterson and I have been discussing for some time.
l. The first change we would like to propose is to the Redevelopment Program. As
currently written, the Program is limited to existing buildings which had an existing
certificate of occupancy for at least 5 years prior to the commencement of the Program.
Agenda Item NO.1 OB
March 23, 2010
Page 6 of 10
As time passes, more and more buildings will have certificates of occupancy in excess of
5 years but which will not qualify for the Program. Given the Program's success, it is
recommended that the Board extend this to all buildings with a certificates of occupancy
in excess of 5 years. The change to the Ordinance would read as follows:
"Development is proposed within a lawfully existing building which has had a
Certificate of Occupancy issued for at least 5 years. prior t8 the eomHlllHeem8Rt sf this
~
2. The second change we would like to propose is to amend the Consolidated Impact
Fee Ordinance to eliminate the sunsetting of impact fee credits. Section 73-203(f) of the
Consolidated Ordinance provides in relevant part as follows:
"The impact fee collected pursuant to this chapter (including all predecessor ordinances
that are hereby being consolidated into this chapter) shall be returned to the then current
owner of the property for which such fee was paid if which fees have not been expended
or encumbered prior to the end of the fiscal year immediately following the sixth
anniversary of the date when the respective impact fee was paid. Refunds shall be made
only in accordance with the following procedure:
(1) The then current owner shall petition the board for the refund prior to the end 0 f
the fiscal year immediately following the sixth anniversary of the date of the
payment of the respective impact fee."
The ordinance goes on to set forth the requirements of the petition, which we believe
need to be maintained to properly administer the request. The problem of course is that
if you do not petition the Board for a refund by the end of the sixth year, any right to a
refund expires, effectively creating a sunset provision on impact fee credits.
Impact fee credits are typically given by the County in lieu of cash payment for land or
construction projects which benefit the County. Given the economic slowdown, many
Developers who obtained Impact Fee Credits are presently unable to use them. We
believe that as a matter of fairness they should not lose the benefit of their bargain
through the expiration of these credits. The proposed change to the Ordinance would
read as follows:
"The impact fee collected pursuant to this chapter (including all predecessor ordinances
that are hereby being consolidated into this chapter) shall be returned to the then current
owner of the property for which such fee was paid if which fees have not been expended
or encumbered prior to the end of the fiscal year at any time iHlffieaiately following the
sixth anniversary of the date when the respective impact fee was paid. Refunds shall be
made only in accordance with the following procedure:
(1) The then current owner shall petition the board for the refund. prior to the ena of
tee fiseal yom- immeaiately followillg the si][th annivofGal')' of the Gate of the
payment sf the respeetive imflaet fee."
If approved, this change would effectively result in impact fee credits running in
perpetuity with the land until used or transferred. This concept could also be extended to
existing Developer Contribution Agreements, some of which have specific expiration
Agenda Item No. 10B
March 23, 2010
Page 7 of 10
dates to utilize the credits. Such changes to existing DCAs would come back to the
Board on a case-by-case basis as amendments to the Agreements. - JAK
RECOMMENDATION: That the Board of County Commissioners accepts the first
annual report on the "Impact Fee Program for Existing Commercial Redevelopment" and
the proposed changes to the Consolidated Impact Fee Ordinance.
Prepared by: Amy Patterson, Impact Fee and Economic Development Manager, CDES,
and Jeffrey A. Klatzkow, County Attorney
Item Number:
Item Summary:
Meeting Date:
Agenda Item No. 10B
March 23, 2010
Page 8 of 10
COLLIER COUNTY
BOARD OF COUNTY COMMISSIONERS
lOB
Recommendation to accept the first annual report on the Impact Fee Program for Existing
Commercial Redevelopment. (Amy Patterson, Manager Impact Fees & EDC, CDES)
3/23/2010 9:00:00 AM
Manager ~ Impact Fees & EDC
Date
Prepared By
Amy Patterson
Community Development &
Environmental Services
Business Management & Budget Office
2/25/2010 11 :34:42 AM
Approved By
Date
Judy Puig
Community Development &
Environmental Services
Operations Analyst
Community Development &
Environmental Services
2/26/2010 11 :05 AM
Nick Casalanguida
Director - Transportation Planning
Date
Approved By
Transportation Division
Transportation Planning
3/9/20103:19 PM
Approved By
OMS Coordinator
County Manager's Office
Date
Office of Management & Budget
3/10/20109:17 AM
County Attorney
Date
Approved By
Jeff Klatzkow
3/11/20109:57 AM
Approved By
Date
Susan Usher
Office of Management &
Budget
Management/Budget Analyst, Senior
Office of Management & Budget
3/11/20107:29 PM
Date
Approved By
James W. Delany
County Attorney
County Attorney
3/15/201010:20 AM
Date
Approved By
Dan E. Summers
Bureau of Emergency
SelVices and Emergency
Management
Director of Emergency Services
Bureau of Emergency Services and
Emergency Management
311S/2010 10:30 AM
Administrator M Public Services
Date
Approved By
Marla Ramsey
Public Services Division
Agenda Item No. 10B
March 23, 2010
Page 9 of 10
PubliC Services Division
3/16/20104:03 PM
Len Golden Price
Date
Approved By
Administrative Services
Division
Administrator ~ Administrative Services
Administrative Services Division
3/16/20104:15 PM
Leo E. Ochs, Jr.
Date
Approved By
County Managers Office
County Manager
County Managers Office
3/16/20104:20 PM
Agenda Item NO.1 OB
March 23, 2010
Page 10 of 10
February 2, 2010
Amy Patterson, Manager
Collier County Impact Fee & Economic Development
Horseshoe Drive
Naples, FL
Re: 5465 Jaegar Road, Unit 10
Dear Ms. Patterson:
Please accept my check in the amount of $/~ !j f J /{, as payment in full
for the impact fees due on the lease of Unit 10, 5465 Jaegar Road, to
Elizabeth and Jason Anderson. Please know that this payment is made
under protest and I expect to revisit the issue in the near future to obtain a
full refund of this amount. I believe there is no basis for this fee for several
reasons, one being that my neighbor's building, built more than five years
ago, is exempt from these fees by Collier County Board decree. Therefore,
I feel this is unjust and discriminatory.
Yours truly,
Arthur H. Brandt
26221 Mira Way
Bonita Springs, FL 34134
(' -0---- .- ---'- "...,
..... PI~~~~_5239) 221-733~
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MI_;t'~
Deliver acknowledgement
JMu
Date