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Agenda 06/25/2019 Item #16F 2 (Suspend Chaper 74 of Collier County Code of Laws & Ords/chapter 10)06/25/2019 EXECUTIVE SUMMARY Recommendation to direct the County Manager and the County Attorney to suspend all provisions of Chapter 74 of the Collier County Code of Laws and Ordinances and Chapter 10 of the Collier County Land Development Code, pertaining to any payment of Impact Fees, which are in conflict with CS/HB 207, which specifies that impact fees may not be required to be collected any sooner than issuance of a building permit; the suspension will remain in effect until such time that the Collier County Code of Laws and Ordinance and the Collier County Land Development Code are amended to comply with the new requirements. OBJECTIVE: To obtain direction by the Board of County Commissioners (Board) to suspend applicable provisions of the Collier County Code of Laws and Ordinances (Code) and the Collier County Land Development Code (LDC) to comply with legislation that specifies that impact fees may not be required to be collected any sooner than issuance of a building permit, until such time that the Code and LDC are amended. CONSIDERATIONS: During the regular Florida Legislative Session, the Florida Senate and the Florida House of Representatives passed House Bill 207 relating to impact fees. The most significant impact of the legislation on Collier County is new language being added to Section 163.31801, Florida Statutes, which provides: (3)(e) The local government may not require payment of the impact fee before the issuance of the building permit for the property that is subject to the fee. Currently, in order to obtain a Certificate of Adequate Public Facilities (COA) for Transportation Concurrency, and move forward with development, 33% of the estimated Road Impact Fees for the proposed construction are required to be paid before the issuance of the Final Local Development Order (Site Plan, Plat, etc,). The balance of the Road Impact Fees and other applicable Collier County Impact Fees are paid prior to Certificate of Occupancy (CO). (Note: Independent Fire District Impact Fees as collected prior to issuance of building permit per the approved Interlocal Agreements). On June 18, 2019, the Governor signed CS/HB 207, which will become law on July 1, 2019, and Collier County will be required to change the timing of payment to meet the new statutory provisions. Therefore, all impact fees will be paid prior to CO, with the exception of Independent Fire. Applicants may still voluntarily pay impact fees at an earlier point in time by way of negotiated Developer Agreements or other similar instruments. Several amendments to Chapter 74 of the Code and Chapter 10 of the LDC will be required to implement these statutory requirements. The suspension of the Code and LDC provisions will remain in effect until all required updates are adopted. FISCAL IMPACT: Approximately 20% of annual Road Impact Fee collections are attributable to upfront payments. In FY 2018, that amount totaled approximately $5.9 million, countywide. This legislative change does not affect the final amount to be collected, but does modify the timing of payment, and therefore the County’s ability to deliver capital projects in advance of or concurrent with the demand being created by new development. GROWTH MANAGEMENT IMPACT: Impact fees provide financial resources for the construction and/or expansion of the County’s capital infrastructure, as necessary to accommodate 16.F.2 Packet Pg. 2455 06/25/2019 growth. Consistent with Objective 2 of the Capital Improvement Element (CIE) of the Collier County Growth Management Plan (GMP), development is required to contribute its fair share of the costs of providing public facilities necessitated by new development. While this legislation will have an impact on the County’s timing of capital construction, due to the delay in the collection of funds, the new statutory language preempts local ordinances, and the County is required to follow the new regulations. LEGAL CONSIDERATIONS: This item has been reviewed by the County Attorney, is approved as to form and legality, and requires majority vote for approval. Should this l egislation be implemented, the County Attorney, working with staff, will advertise and bring to the Board an Ordinance which strikes out the conflicting language. Since elimination of the conflicting provisions are essentially both mandatory and ministerial, there is no need to take it through the normal LDC hearing process. -JAK RECOMMENDATION: To direct the County Manager and the County Attorney to suspend all provisions of Chapter 74 of the Collier County Code of Laws and Ordinances and Chapter 10 of the Collier County Land Development Code, pertaining to any payment of Impact Fees in conflict with CS/HB 207, which specifies that impact fees may not be required to be collected any sooner than issuance of a building permit; the suspension will remain i n effect until such time that the Collier County Code of Laws and Ordinance and the Collier County Land Development Code are amended to comply with the new requirements. Prepared by: Amy Patterson, Director, Capital Project Planning, Impact Fees and Program Management ATTACHMENT(S) 1. HB 207ER (PDF) 16.F.2 Packet Pg. 2456 06/25/2019 COLLIER COUNTY Board of County Commissioners Item Number: 16.F.2 Doc ID: 9380 Item Summary: Recommendation to direct the County Manager and the County Attorney to suspend all provisions of Chapter 74 of the Collier County Code of Laws and Ordinances and Chapter 10 of the Collier County Land Development Code, pertaining to any payment of Impact Fees, which are in conflict with CS/HB 207, which specifies that impact fees may not be required to be collected any s ooner than issuance of a building permit; the suspension will remain in effect until such time that the Collier County Code of Laws and Ordinance and the Collier County Land Development Code are amended to comply with the new requirements. Meeting Date: 06/25/2019 Prepared by: Title: Senior Grants and Housing Coordinator – Capital Project Planning, Impact Fees, and Program Management Name: Gino Santabarbara 06/18/2019 12:27 PM Submitted by: Title: Division Director - IF, CPP & PM – Capital Project Planning, Impact Fees, and Program Management Name: Amy Patterson 06/18/2019 12:27 PM Approved By: Review: Growth Management Department Judy Puig Level 1 Reviewer Completed 06/18/2019 1:31 PM Capital Project Planning, Impact Fees, and Program Management Amy Patterson Additional Reviewer Completed 06/18/2019 1:37 PM Growth Management Department Gino Santabarbara Deputy Department Head Review Skipped 06/18/2019 12:27 PM Growth Management Department Thaddeus Cohen Department Head Review Completed 06/18/2019 3:32 PM Office of Management and Budget Valerie Fleming Level 3 OMB Gatekeeper Review Completed 06/18/2019 3:36 PM County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 06/18/2019 4:36 PM Office of Management and Budget Laura Zautcke Additional Reviewer Completed 06/18/2019 4:51 PM County Manager's Office Nick Casalanguida Level 4 County Manager Review Completed 06/19/2019 12:50 PM Board of County Commissioners MaryJo Brock Meeting Pending 06/25/2019 9:00 AM 16.F.2 Packet Pg. 2457 ENROLLED CS/HB 207 2019 Legislature CODING: Words stricken are deletions; words underlined are additions. hb0207-02-er Page 1 of 4 F L O R I D A H O U S E O F R E P R E S E N T A T I V E S 1 An act relating to impact fees; amending s. 163.31801, 2 F.S.; revising the minimum requirements for the 3 adoption of impact fees by specified local 4 governments; exempting water and sewer connection fees 5 from the Florida Impact Fee Act; providing an 6 effective date. 7 8 Be It Enacted by the Legislature of the State of Florida: 9 10 Section 1. Section 163.31801, Florida Statutes, is amended 11 to read: 12 163.31801 Impact fees; short title; intent; minimum 13 requirements; audits; challenges definitions; ordinances levying 14 impact fees.— 15 (1) This section may be cited as the "Florida Impact Fee 16 Act." 17 (2) The Legislature finds that impact fees are an 18 important source of revenue for a local government to use in 19 funding the infrastructure necessitated by new growth. The 20 Legislature further finds that impact fees are an outgrowth of 21 the home rule power of a local government to provide certain 22 services within its jurisdiction. Due to the growth of impact 23 fee collections and local governments' reliance on impact fees, 24 it is the intent of the Legislature to ensure that, when a 25 16.F.2.a Packet Pg. 2458 Attachment: HB 207ER (9380 : Impact Fee Legislative Adjustments) ENROLLED CS/HB 207 2019 Legislature CODING: Words stricken are deletions; words underlined are additions. hb0207-02-er Page 2 of 4 F L O R I D A H O U S E O F R E P R E S E N T A T I V E S county or municipality adopts an impact fee by ordinance or a 26 special district adopts an impact fee by resolution, the 27 governing authority complies with this section. 28 (3) At a minimum, an impact fee adopted by ordinance of a 29 county or municipality or by resolution of a special district 30 must satisfy all of the following conditions, at minimum: 31 (a) The local government must calculate Require that the 32 calculation of the impact fee be based on the most recent and 33 localized data. 34 (b) The local government must provide for accounting and 35 reporting of impact fee collections and expenditures. If a local 36 governmental entity imposes an impact fee to address its 37 infrastructure needs, the entity must shall account for the 38 revenues and expenditures of such impact fee in a separate 39 accounting fund. 40 (c) The local government must limit administrative charges 41 for the collection of impact fees to actual costs. 42 (d) The local government must provide Require that notice 43 be provided no less than 90 days before the effective date of an 44 ordinance or resolution imposing a new or increased impact fee. 45 A county or municipality is not required to wait 90 days to 46 decrease, suspend, or eliminate an impact fee. 47 (e) The local government may not require payment of the 48 impact fee before the date of issuance of the building permit 49 for the property that is subject to the fee. 50 16.F.2.a Packet Pg. 2459 Attachment: HB 207ER (9380 : Impact Fee Legislative Adjustments) ENROLLED CS/HB 207 2019 Legislature CODING: Words stricken are deletions; words underlined are additions. hb0207-02-er Page 3 of 4 F L O R I D A H O U S E O F R E P R E S E N T A T I V E S (f) The impact fee must be reasonably connected to, or 51 have a rational nexus with, the need for additional capital 52 facilities and the increased impact generated by the new 53 residential or commercial construction. 54 (g) The impact fee must be reasonably connected to, or 55 have a rational nexus with, the expenditures of the revenues 56 generated and the benefits accruing to the new residential or 57 commercial construction. 58 (h) The local government must specifically earmark 59 revenues generated by the impact fee to acquire, construct, or 60 improve capital facilities to benefit new users. 61 (i) The local government may not use revenues generated by 62 the impact fee to pay existing debt or for previously approved 63 projects unless the expenditure is reasonably connected to, or 64 has a rational nexus with, the increased impact generated by the 65 new residential or commercial construction. 66 (4) Audits of financial statements of local governmental 67 entities and district school boards which are performed by a 68 certified public accountant pursuant to s. 218.39 and submitted 69 to the Auditor General must include an affidavit signed by the 70 chief financial officer of the local governmental entity or 71 district school board stating that the local governmental entity 72 or district school board has complied with this section. 73 (5) In any action challenging an impact fee, the 74 government has the burden of proving by a preponderance of the 75 16.F.2.a Packet Pg. 2460 Attachment: HB 207ER (9380 : Impact Fee Legislative Adjustments) ENROLLED CS/HB 207 2019 Legislature CODING: Words stricken are deletions; words underlined are additions. hb0207-02-er Page 4 of 4 F L O R I D A H O U S E O F R E P R E S E N T A T I V E S evidence that the imposition or amount of the fee meets the 76 requirements of state legal precedent or this section. The court 77 may not use a deferential standard. 78 (6) This section does not apply to water and sewer 79 connection fees. 80 Section 2. This act shall take effect July 1, 2019. 81 16.F.2.a Packet Pg. 2461 Attachment: HB 207ER (9380 : Impact Fee Legislative Adjustments)