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Agenda 10/26/2010 Item #10GAgenda Item No. 10G October 26, 2010 Page 1 of 5 EXECUTIVE SUMMARY Recommendation to review the options related to the application of reduced impact fee rates to building permits that have not been issued and are currently in "Apply" or "Ready" status, prepared in accordance with direction provided by the Board of County Commissioners on October 12, 2010 OBJECTIVE: That the Board of County Commissioners (Board) review the options related to the application of reduced impact fee rates to building permits that have not been issued and are currently in "Apply" or "Ready" status, prepared in accordance with direction provided by the Board on October 12, 2010, and provide direction to the County Manager, or his designee, and the County Attorney as to any such changes that will be implemented. CONSIDERATIONS: On September 28, 2010 the Board adopted Ordinance No. 2010 -38, with and effective date of October 8, 2010, thereby providing a decrease in Road, Community Parks and Regional Parks Impact Fees for building permits applied for on or after the effective date. On October 12, 2010, the Board of County Commissioners accepted the recommendation by the District School Board of Collier County to reduce the current, adopted School Impact Fees by 50 %. This action was taken by way of the adoption of Ordinance No. 2010 -39, with a retroactive effective date of October 8, 2010. Additionally, on October 12, 2010, the Board considered a request by Mr. Bruce Anderson to allow the reduced impact fees to apply to building permits in process that have not been issued. The Board directed the County Manager, or his designee, to develop options, including cost, financial impact, processing requirements, sunset date, etc. and present the options to the Board, for review and consideration, at the next meeting. The Board also directed that the County Manager, or his designee, contact the District School Board to seek their input on this matter. The following is the background and analysis that has been utilized in developing several options: Background: Section 74 -108 of the Collier County Code of Laws and Ordinances (The Collier County Consolidated Impact Fee Ordinance) provides: "Impact fees are assessed using the rates in effect when the building permit application is submitted." In the past this rule provided the customer the ability to apply for a building permit and "lock -in" existing impact fees when fees were scheduled to increase. As of September 30, 2010, there are 42 commercial permits, totaling approximately 528,000 square feet, in apply or ready status (not issued) that may be subject to impact fee assessment. There are also 61 residential permits consisting of 126 units. Impact fees have not been paid for these permits, with the exception of the upfront portion of the Road Impact Fees. The impact of allowing the impact fees to be calculated at the new rates is the potential loss of revenue related to the difference in the rates. The estimated loss of revenue: Road = Agenda Item No. 10G October 26, 2010 Page 2 of 5 $1.9 million. School = $503,000. Parks = $44,086. The estimated loss of revenue reflects the "worst case scenario' and assumes that all permits above will commence construction based on the rate reduction. In consideration of the information above, the following options have been developed to mitigate this issue: 1) Allow applicant to request a re- calculation of the impact fees, pay a re- calculation fee of $50.00 for single - family homes or $250.00 for multi - family or commercial construction, based on staff time and administrative costs, for those permits that are in apply or ready status (not issued). Re- calculation could be completed within 5 business days of submittal of the request/payment of re- calculation fee. Allowing the re- calculation of the impact fees does not waive any requirements related to plan review, Building Code requirements, permit expiration, etc. This option would be available for permits currently in process (not issued) due to the extraordinary circumstances of two large scale impact fee reductions occurring simultaneously. In the event that another large reduction occurs, this option could be re- implemented. Customer Impact: This is a simplified process with a projected cost of $50 to $250.00, depending on the type of construction, and. minimal wait time for impact fees to be re- calculated. This would delay a project approximately 5 working days. County Impact: This will create a short term overtime demand on staff which would be offset by the proposed re- calculation fee. Financial exposure will depend on the number of applicants that take advantage of this process. 2) Utilize the structure of Option 1, customer requested re- calculation and associated fee, but amend the Code to reflect this procedure. Language similar to the following could be included: Section 74 -108. Definitions. Impact fees are assessed using the rates in effect when the building permit application is submitted. However, an applicant may request a re- calculation of the impact fees, based on revised impact fee schedules prior to the issuance of the building permit. In order to request a re- calculation the applicant must submit: 1) a written request to re- calculate the impact fees including permit number and 21 payment of a re- calculation fee of $50.00 for a single - family home or $250.00 for multi - family or commercial permits. Re- calculations will be completed within 5 business days of receipt of the required request and payment of re- calculation fee Agenda Item No. 10G October 26, 2010 Page 3 of 5 3) Utilize the current process and allow the applicant to re -apply under the revised rates. Staff would work with applicants to minimize the time and expense related to this option. Building permits that are not active or those that require updated plans due to Building Code or Fire Code changes may incur a greater expense and new plan reviews. Customer Impact: Estimated costs for a cancellation and re- application are $110 per discipline ($440 max). This does not include any fees that may be assessed by outside agencies (Health, Fire, etc.). It could delay the project two to four weeks. Count pact: Limited. Process is already established. Financial exposure is related to the potential revenue loss of the difference between the rate based on application date and the new reduced rate. The financial impact is listed in the background narrative above. These options apply to building permit that are in process but have not been issued. Permits that have been issued, including those that have commenced construction, may elect to follow the current process to cancel a building permit, re -apply for a building permit and request a reimbursement of a portion of the impact fees previously paid. Staff has contacted representatives of the District School Board of Collier County to solicit their input on this matter and will provide the Board with that information during the discussion on this item. FISCAL IMPACT: As discussed above, there are 42 commercial permits, totaling approximately 528,000 square feet, in apply or ready status (not issued) that may be subject to impact fee assessment. There are also 61 residential permits consisting of 126 units. If each of the applicants elected to follow a process to have the impact fees re- calculated using the revised impact fee rates the fiscal impact is the loss of revenue between the rate in place at time of building permit application and the new revised rates. The estimated amount of this loss is $1.9 million for Road Impact Fees, $503,000 for School Impact Fees and $44,086 for Parks Impact Fees. This is the worst case scenario as it assumes that all of the above permits will be issued and commence construction. There are no cash reimbursements related to the above options. The building permits in question have not been issued and therefore have not paid impact fees. The financial impact on the customer is minimal and ranges between $50.00 and $440.00, depending on the option selected. This does not include any fees that may be assessed by outside agencies (Health, Fire, etc.). The reduction to Road Impact Fees for a mid -size Single - Family home is $3,387.00, the reduction to School Impact Fees, for the same size home, is $5,378.00 and the reduction to Parks Impact Fees is $349.00 (Total: $9,114). The re- calculation fee will be used to offset the staff hours related to re- calculation of the impact fees, administrative cost and hours related to ensuring that information contained in permit files and other records accurately reflect the basis for the change and revising procedures and generating audit reports to ensure that impact fees are correctly assessed and paid. The amounts are based on the staff time to be allocated to the entire re- calculation process, based on a fully Agenda Item No. 10G October 26, 2010 Page 4 of 5 weighted salary of $75.00 per hour. The City of Naples is assessing an administrative fee of $250.00 for their process related to this issue. 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." LEGAL CONSIDERATIONS: This item is legally sufficient for Board action. -JAK RECOMMENDATION: That the Board of County Commissioners selects Option One (1) and directs staff to implement the recalculation process and fee immediately for all projects in "apply & ready" status. Prepared by: Nick Casalanguida, Deputy Administrator, Growth Management Division — Planning and Regulation and Amy Patterson, Impact Fee and Economic Development Manager, Growth Management Division — Planning and Regulation Agenda Item No. 10G October 26, 2010 Page 5 of 5 COLLIER COUNTY BOARD OF COUNTY COMMISSIONERS Item Number. 10G Item Summary: Recommendation to review the options related to the application of reduced impact fee rates to building permits that have not been issued and are currently in Apply or Ready status, prepared in accordance with direction provided by the Board of County Commissioners on October 12, 2010 (Amy Patterson, Impact Fee and Economic Development Manager, Growth Management Division) Meeting Date: 10/26/2010 9:00:00 AM Prepared By Amy Patterson Manager - Impact Fees & EDC Date Community Development & Environmental Services Business Management & Budget Office 10/19/2010 10:34:08 AM Approved By Judy Puig Operations Analyst Date Community Development & Community Development & Environmental Services Environmental Services 10/19/2010 11:01 AM Approved By Nick Casalanguida Director - Transportation Planning Date Transportation Division Transportation Planning 10/19/2010 11:24 AM Approved By Jeff Klatzkow County Attorney Date 10/19/2010 12:53 PM Approved By Norm E. Feder, AICP Administrator- Transportation Date Transportation Division Transportation Administration 10/19/2010 1:02 PM Approved By OMB Coordinator Date County Manager's Office Office of Management & Budget 1011912010 1:47 PM Approved By Susan Usher Management/Budget Analyst, Senior Date Office of Management & Budget Office of Management & Budget 1 011 9/201 0 4:50 PM Approved By _ Leo E. Ochs, Jr. County Manager Date County Managers Office County Managers Office 10/20/2010 8:58 AM