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HomeMy WebLinkAbout2008-05-06; City Council; 19433; Traffic Impact fee updateCITY OF CARLSBAD - AGENDA BILL 11 x^^/ AB# 19,433 MTG. 5/06/08 DEPT. CA TRAFFIC IMPACT FEE UPDATE DEPT. HEAD Sty? CITY ATTY. S&& CITY MGR. (JJ RECOMMENDED ACTION: IntroduceOrdinance No.NS-890 amending Title 18, Chapter 18.42 of the Carlsbad Municipal Code revising the Traffic Impact Fee in accordance with the City Council's direction at its meeting of .April 22, 2008. ITEM EXPLANATION: Ordinance No. NS-885 was adopted by the City Council (3-2 Kulchin, Hall) at its meeting of April 22, 2008. At that same meeting, the Council directed staff to return with an Ordinance that would reduce the Traffic Impact Fees for a one-year period effective June 30, 2008 and provide a grandfathering provision that would keep the fee at the current rate of $46/ADT for commercial and industrial projects that applied for a building permit prior to April 8, 2008 and obtain a building permit prior to September 30, 2008. Attached to this Agenda Bill is the recommended Ordinance implementing the Council's direction. The Council further indicated that it would appoint an ad-hoc sub-committee to study future road improvements to be included or removed from the program and to give its report to the full Council within this one-year period. FISCAL IMPACT: The one-year reduction in Traffic Impact Fees will result in a reduction of revenue to the program in an amount dependent on the number of building permits issued for residential, commercial, and industrial development during that time period. It is estimated that the implementation of the grandfathering provision as described above would result in a reduction of up to $1.6 million in Traffic Impact Fee revenues when compared to the fees adopted on April 22, 2008 or $800,000 when compared to the reduced fees as incorporated in the attached ordinance. If the Council were to implement an alternative grandfathering provision based on projects having applied for a grading permit rather than a building permit by April 8, 2008, staff estimates that the additional reduction in revenues would be on the order of $200,000 to $400,000 when compared to the fee adopted on April 22, 2008 or $100,000 to $200,000 when compared to the reduced fees as incorporated in the attached ordinance. FOR CITY CLERKS USE ONL Y. COUNCIL ACTION: APPROVED J* DENIED 'D CONTINUED D WITHDRAWN D, AMENDED tR CONTINUED TO DATE SPECIFIC CONTINUED TO DATE UNKNOWN RETURNED TO STAFF OTHER -SEE MINUTES APPROVED AS AMENDED D D D D DEPARTMENT CONTACTS:Ron Ball, 760-434-2801, rball@ci.carlsbad.ca.us Marshall Plantz, 760-602-2766, mplan@ci.carlsbad.ca.us Page 2 ENVIRONMENTAL IMPACT: The Planning Director has determined that the 2008 Traffic Impact Fee program update and the fee increase does not constitute a "project" and, therefore, is not subject to review under the California Environmental Quality Act. The temporary reduction in fees represented by this Ordinance is similarly not a "project". The roadways included in the program are part of the roadway network and included in the Circulation Element of the Carlsbad General Plan and will be subject to environmental review and approval pursuant to CEQA and/or the National Environmental Policy Act, as appropriate. EXHIBITS: 1. Ordinance No. NS-890 amending Title 18, Chapter 18.42 of the Carlsbad Municipal Code revising the Traffic Impact Fee in accordance with the City Council's direction at its meeting of April 22, 2008. 2. Redline/strikeout version of Ordinance No. NS-890 amending Title 18, Chapter 18.42 of the Carlsbad Municipal Code revising the Traffic Impact Fee in accordance with the City Council's direction at its meeting of April 22, 2008. 1 ORDINANCE NO. NS-890 2 " 3 4 5 6 7 by the amendment of Section 18.42.050(a) to read as follows: •18.42.050 Fee. (a) The traffic impact fee of three hundred fifty-three dollars ($353) for each average 9 daily trip generated by a residential project and a traffic impact fee of one hundred forty-two dollars 10 ($142) for each average daily trip generated by a commercial or industrial project, pursuant to Section 18.42.020(e), and adopted by Ordinance No. NS-885 adopted April 22, 2008 and effective xb/felf I AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF CARLSBAD, CALIFORNIA, AMENDING TITLE 18, CHAPTER 18.42, OF THE CARLSBAD MUNICIPAL CODE REDUCING THE TRAFFIC IMPACT FEE FOR A PERIOD OF ONE YEAR. The City Council of the City of Carlsbad, California, hereby ordains as follows: SECTION 1: That Title 18, Chapter 18.42 of the Carlsbad Municipal Code is amended June 30, 2008, shall be reduced for a one-year period from July 1, 2008 to June 30, 2009, to two hundred forty dollars ($240) for each average daily trip generated by a single-family residential project, two hundred ninety dollars ($290) for each average daily trip generated by a condominium residential project, three hundred seventy-three dollars and thirty-four cents ($373.34) for each 12 13 14 15 n average daily trip generated by a apartment residential project and ninety-six dollars ($96) for each16 average daily trip generated by a commercial or industrial project. Thereafter, the fees shall 17 automatically revert to those amounts set forth at the beginning of this paragraph (a). The fees 18 shall be paid by the owner or developer prior to the issuance of any building permit or occupancy 19 permit for the project. The traffic impact fee shall be adjusted annually as part of the Capital Improvement Program budget process, by two percent or the annual percentage change in the Caltrans Construction Cost Index (12-month index), which ever is higher. SECTION 2: That Title 18, Chapter 18.42 of the Carlsbad Municipal Code is amended by the addition of Section 18.42.050(d) to read as follows: 20 21 22 23 ii (d) Commercial or industrial projects that have a grading permit application on file prior24 to April 8, 2008 and have obtained a building permit prior to September 30, 2008 shall pay a traffic 25 impact fee of forty-six dollars ($46) for each average daily trip generated by a commercial or 26 industrial project. 27" 28 SECTION 3: That Title 18, Chapter 18.42 of the Carlsbad Municipal Code is amended by the amendment of Section 18.42.070 to read as follows: 3 "18.42.070 Use of Fees. (a) All of the fees collected for a commercial or industrial project shall be allocated to a4 circulation improvement account and shall be expended only to build or finance circulation 5 improvements serving the city. (b) All of the fees collected for each newly constructed residential unit, excepting the portion defined in paragraph (c), shall be allocated to a circulation improvement account and shall 8 10 16 17 18 be expended only to build or finance circulation improvements serving the city. (c) A portion of the fees collected for newly constructed residential housing units, excepting the fees collected for newly constructed housing units constructed for extremely low, very-low, low and moderate income households as defined in California Health and Safety Code11 Sections 50105, 50106, 50079.5 and 50093, during the forty year period starting July 1, 2008 shall 12 be allocated to a separate circulation improvement sub account and shall be used to build or 13 finance circulation improvements to the Regional Arterial System as adopted by the Board of the 14 San Diego Association of Governments. For the year from July 1, 2008 to June 30, 2009, said 15 portion shall equal two thousand dollars per residential housing unit. Said portion shall be adjusted annually as part of the City's Capital Improvement Program budget process, by two percent or the annual percentage change in the Caltrans Construction Costs Index, (12-Month Index), whichever is higher." EFFECTIVE DATE: The Ordinance NS-885 was adopted at a noticed public hearing at which time the City Council of the City of Carlsbad also considered the Traffic Impact Fee Update Study which study and associated information was available to the general public for a period of at 21 least fourteen (14) days prior to the public meeting. The fee established by that ordinance applies 22 to the issuance of any building permit, for any residential, commercial or industrial development. 23 This ordinance temporarily reduces the fee established by Ordinance No. NS-885 for a one-year 24 period and shall become effective on June 30, 2008. 25 26 27 28 3 4 5 6 7 8 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 INTRODUCED AND FIRST READ at a Regular Meeting of the Carlsbad City Council on the 6th day of May. 2008, and thereafter. PASSED AND ADOPTED at a Regular Meeting of the City Council of the City of Carlsbad, California, on the day of , 2008, by the following vote, to wit: AYES: NOES: ABSENT: APPROVED AS TO FORM AND LEGALITY: RONALD R. BALL, City Attorney CLAUDE A. LEWIS, Mayor ATTEST: LORRAINE M. WOOD, City Clerk (SEAL) YN 1 2 AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF CARLSBAD, CALIFORNIA, AMENDING TITLE 18, CHAPTER 3 18.42, OF THE CARLSBAD MUNICIPAL CODE REDUCING THE TRAFFIC IMPACT FEE FOR A PERIOD OF ONE YEAR. 4 The City Council of the City of Carlsbad, California, hereby ordains as follows: 5 SECTION 1: That Title 18, Chapter 18.42 of the Carlsbad Municipal Code is amended c by the amendment of Section 18.42.050(a) to read as follows: 7 "18.42.050 Fee. 8 16 17 18 ORDINANCE NO. NS-890 (a) The traffic impact fee of three hundred fifty-three dollars ($353) for each average daily trip generated by a residential project and a traffic impact fee of one hundred forty-two dollars 10 ($142) for each average daily trip generated by a commercial or industrial project, pursuant to Section 18.42.020(e), and adopted by Ordinance No. NS-885 adopted April 22, 2008 and effective June 30, 2008, shall be reduced for a one-year period from July 1, 2008 to June 30, 2009, to two hundred forty dollars ($240) for each average daily trip generated by a single-family residential 13 project, two hundred ninety dollars ($290) for each average daily trip generated by a condominium 14 residential project, three hundred seventy-three dollars and thirty-four cents ($373.34) for each 15 average daily trip generated by a apartment residential project and ninety-six dollars ($96) for each average daily trip generated by a commercial or industrial project. Thereafter, the fees shall automatically revert to those amounts set forth at the beginning of this paragraph (a). The fees shall be paid by the owner or developer prior to the issuance of any building permit or occupancy permit for a-the project. The T traffic impact fees shall be adjusted annually as part of the Capitaln y Improvement Program budget process, by two percent or the annual percentage change in the 20 Caltrans Construction Cost Index (12-month index), which ever is higher. 21 SECTION 2: That Title 18, Chapter 18.42 of the Carlsbad Municipal Code is amended 22 by the addition of Section 18.42.050(d) to read as follows: 23" 24 25 26 27 28 (b) Commercial or industrial projects that have a building permit application on file prior to April 8, 2008 and have obtained a building permit prior to September 30, 2008 shall pay a traffic impact fee of forty-six dollars ($46) for each average daily trip generated by a commercial or industrial project. 1 2 3 "18.42.070 Use of Fees. (a) All of the fees collected for a commercial or industrial project shall be allocated to a 4 circulation improvement account and shall be expended only to build or finance circulation 5 improvements serving the city. c (b) All of the fees collected for each newly constructed residential unit, excepting the 7" 8 9 10 16 17 18 25 26 27 28 SECTION 3: That Title 18, Chapter 18.42 of the Carlsbad Municipal Code is amended by the amendment of Section 18.42.070 to read as follows: portion defined in paragraph (c), shall be allocated to a circulation improvement account and shall be expended only to build or finance circulation improvements serving the city. (c) A portion of the fees collected for newly constructed residential housing units, excepting the fees collected for newly constructed housing units constructed for extremely low, very-low, low and moderate income households as defined in California Health and Safety Code Sections 50105, 50106, 50079.5 and 50093, during the forty year period starting July 1, 2008 shall 12 be allocated to a separate circulation improvement sub account and shall be used to build or 13 finance circulation improvements to the Regional Arterial System as adopted by the Board of the 14 San Diego Association of Governments. For the year from July 1, 2008 to June 30, 2009, said 15"portion shall equal two thousand dollars per residential housing unit. Said portion shall be adjusted annually as part of the City's Capital Improvement Program budget process, by two percent or the annual percentage change in the Caltrans Construction Costs Index, (12-Month Index), whichever is higher." EFFECTIVE DATE: The Ordinance NS-885 was adopted at a noticed public hearing ati y which time the City Council of the City of Carlsbad also considered the Traffic Impact Fee Update20 Study which study and associated information was available to the general public for a period of at 21 least fourteen (14) days prior to the public meeting. The fee established by that ordinance applies 22 to the issuance of any building permit, for any residential, commercial or industrial development. 23 Ordinance No. NS-890 temporarily reduces the fee established by Ordinance No. NS-885 for a 24 one-year period and shall become effective on June 30, 2008. The City Clerk shall certify to the adoption of this Ordinance and cause it to be published at least once in a publication of general circulation within fifteen days after its adoption. 1 INTRODUCED AND FIRST READ at a Regular Meeting of the Carlsbad City Council on 2 the day of , 2008, and thereafter. 3 PASSED AND ADOPTED at a Regular Meeting of the City Council of the City of Carlsbad, California, on the day of , 2008, by the following vote, to wit:o AYES: 6 NOES: ABSENT: 8 9 APPROVED AS TO FORM AND LEGALITY: 10 11 RONALD R. BALL, City Attorney 12 13 CLAUDE A. LEWIS, Mayor14 15 ATTEST: 16 17 LORRAINE M. WOOD, City Clerk 18 (SEAL) 19 20 21 22 23 24 25 26 27 28 05/06/2008 16:11 FAX NftllUNflL 5'6/2008 Mayor Bud Lewis and Members of the City Council City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92008 AGENDA ITEM #__ c: Mayor City Council City Manager City Attorney City Clerk Subject: Continuance of Commercial/Industrial Traffic Impact Fees - Ordinance No. NS-885 D>?ar Mayor Lewis and Members of the City Council: Ch April 22, your City Council modified an earlier decision to implement traffic fee increases of more than 200% on both residential and commercial/industrial development. Because of SANDAG requirements for the City to implement new traffic fees on residential development, this very complex issue has been rushed through Council hearings with little opportunity for input from the impacted development community. Bocause of (he very limited time that the staff reports have been available and the complexity of those studies, we have not had the opportunity to fully analyze the impacts of such a significant fee increase on our plans for our second phase of Ventana Real, a project that has an approved PIP and future development. It is our understanding that the most recent action by the City Council would implement the fee increase on residential development required for SANDAG Transnet funding. The revised ordinance would also implement an equivalent percentage increase in traffic impact fees for commercial/industrial development for a one year period at which time the fees would revert to the higher level originally recommended by staff. While this approach may appear to be a good solution on the surface, we would urge the Council to delay a decision on the level of the commercial/industrial fee to allow more time to fully analyze the Impacts of this fee, to conduct further study of the projects and project costs that are funded by this fee, and have proper nexus to legally impose these fees. Since there is no timing requirement to adjust traffic impact fees for commercial/industrial development that would impact project funding from SANDAG, the City Council could move forward only with the proposed increase for residential development with the appropriate grandfather provisions requested by the Building Inoustry Association. This would provide an opportunity for commercial and industrial property owners and your staff to more fully study the proposed increase and make recommendations for an appropriate adjustment that balances project funding needs with potential economic impacts to the city. Thank you for your consideration of this request. 1525 Faraday AVL-., Suite 100 • Carlsbad, California 92008 • (760) 607-42R2 • I'ax (760) 607-4286 • www.newportnational.bi/ April 29, 2008 TO: CITY ATTORNEY CITY CLERK FROM: Assistant City Clerk CALENDAR OF EVENTS REGARDING NOTICING OF PUBLIC HEARING FOR 2008 TRAFFIC IMPACT FEE PROGRAM - AB #19,392 Thank you for meeting with the City Clerk and me today to discuss this matter. As you requested, we have compiled a chronology of the events regarding the noticing for this matter. The notice of public hearing was published in the newspaper well in advance of the required minimum notice, and was also put on, and remained on, the City's website for fourteen days prior to the hearing. In addition, the matter appeared on the agendas for three different City Council Meetings, and was also posted and placed on the City website prior to each meeting. The posting was done at City Hall 72 hours in advance of each meeting as required by the Brown Act. The calendar of events for the noticing process is as follows: March 21, 2008 March 25, 2008 April 4, 2008 April 11, 2008 April 18, 2008 Notice of public hearing submitted to NC Times for publication on March 25, 2008 Notice of April 8 hearing published and placed on City website Agenda for April 8 Council Meeting posted and placed on City website Agenda for April 15 Council Meeting posted and placed on City website Agenda for April 22 Council Meeting posted and placed on City website Please note that we did not have any written "Requests for Notice" regarding this matter on file in our office at the time the matter was noticed. For this reason, mailing of notices was not required. We also have compiled a list of persons that attended the City Council Meetings to speak on this matter. There were a total of ten speakers at the three meetings. A copy of the list is attached to this memo for information. Also, as a result of discussions with Senior Civil Engineer Plantz, we learned that he had provided information to parties interested in this matter. Mr. Plantz indicated that he had, on March 20, 2008, sent a letter (copy attached) and a copy of the Study to the BIA to alert them that it was anticipated that the matter would be scheduled for public hearing on April 8, 2008, which included a copy of the Traffic Impact Fee Update Study. In addition, Mr. Plantz indicated that he had spoken to Scott Molloy of the BIA prior to the hearing and had provided additional information, including an electronic version of the study, to him via email. Mr. Plantz also indicated that he had also spoken with representatives of Brookfield Homes and Planning Systems prior to the April 8, 2008 hearing, and had provided paper copies of the study to them. As a result of these discussions, we believe that the noticing for the public hearing referenced above was done in substantial compliance with the requirements of the Government Code. EN KUNDTZ, CMC Assistant City Clerk C: Interim City Manager Public Works Director Sr. Civil Eng. Plantz Attachment (1 - List of Speakers) (2 - Letter to BIA from M. Plantz) CITY COUNCIL MEETING SPEAKERS REGARDING THE TRAFFIC IMPACT FEE PROGRAM UPDATE APRIL 8. 2008 CITY COUNCIL MEETING - PUBLIC HEARING • Scott Molloy, Public Policy Advocate for the Building Industry Association (BIA) APRIL 15. 2008 CITY COUNCIL MEETING - ORDINANCE FOR ADOPTION • No speakers. Item continued to meeting of April 22, 2008 APRIL 22. 2008 CITY COUNCIL MEETING - ORDINANCE FOR ADOPTION Michael Babawal, Director of Government Affairs, Carlsbad Chamber of Commerce Jeff Williams, LNR Partners Scott Molloy, Public Policy Advocate for the Building Industry Association (BIA) David DiRienzo, President of Urban West Mike Howes of Howes, Weiler and Associates Pat O'Day, President of O'Day Consultants Bob Ladwig, President of Ladwig Design Group, Inc. Brenda Tworoger, La Costa Town Center Project Fred Arbuckle, President of Morrow Development C'tv of Carlsbad Public Works Engineering March 20, 2008 Ann Ellis BUILDING INDUSTRY ASSOCIATION 9201 Spectrum Center Boulevard, Suite 110 San Diego, CA 92123 TRAFFIC IMPACT FEE UPDATE The purpose of this letter is to inform your organization that the City of Carlsbad is considering updating the existing Traffic Impact Fee (TIP) program which was established in 1991 The recommended update will revise the project list, project costs, trip volume projections, and ultimately the fee. The update also includes the amendments necessary to satisfy the requirements of the Regional Traffic Congestion Improvement Program (RTCIP) section of the TransNet Extension Ordinance. In support of these revisions, we have prepared the attached Traffic Impact Fee Update Study. The Study includes sections which generally describe the authority, justification, and purpose of the TIP program. In addition, the Study summarizes the results of the analysis of the roadway/circulation system which are then used to calculate project costs. These costs are then used in conjunction with future trip generation projections to calculate the fees needed to generate the funding for the projects. The recommended fees are summarized on page 1 1 of the Study. The Study also describes how a portion of the fees will be programmed for improvements on the Regional Arterial System (RAS) in conformance with the RTCIP. In general terms, the RTCIP requires member agencies to collect $2,000 per newly-constructed residential unit for the purpose of constructing/improving RAS roadways. By incorporating the necessary provisions into the TIP update, the City will be able to utilize an existing fee program to satisfy the requirements of the RTCIP. At this time, we anticipate that the item will be considered by the City Council at their April 8th meeting. Once the actual date is set, the City Clerk's office will provide a public notification of the associated public hearing and the agenda bill will be posted on the City's website. The updated fee would become effective 60 days after the adoption of the associated ordinance which amends Chapter 18 42 of the Carlsbad Municipal Code. If you have any questions regarding this subject, please contact me at (760) 602-2766. Sincerely, ^•-. -.-: .-•• .-,-rrr^- MARSHALL PLANTZ Senior Civil Engineer Attachment: Traffic Impact Fee Update Study c; City Engineer Deputy City Engineer, Planning and Programs Division Finance Director 1 635 Faraday Avenue * Carlsbad, CA 9200S-7314 • (760) 6O2-272Q - FAX (760) 302-3582 PROOF OF PUBLICATION (2010 & 2011 C.C.P.) This space is for the County Clerk's Filing Stamp STATE OF CALIFORNIA County of San Diego I am a citizen of the United States and a resident of the County aforesaid: I am over the age of eighteen years and not a party to or interested in the above- entitled matter. I am the principal clerk of the printer of North County Times Formerly known as the Blade-Citizen and The Times- Advocate and which newspapers have been adjudicated newspapers of general circulation by the Superior Court of the County of San Diego, State of California, for the City of Oceanside and the City of Escondido, Court Decree number 171349, for the County of San Diego, that the notice of which the annexed is a printed copy (set in type not smaller than nonpariel), has been published in each regular and entire issue of said newspaper and not in any supplement thereof on the following dates, to-wit: March 25th, 2008 Proof of Publication of NOTICE Of PUBUC HEARIMQ :ISt III O. A18.42 < », 1200 Carlsbad, at 6;00 p.m.onI Title merit* to beconsider revising meChapter 18.42 oHheling trie IB circulation Improve-Traffic Impact Fee; toimpact fee Imposed by1 Municipal Code; and tfl„. jgalnst the traffic impact18.42 of the CarlsbadT*J-^ _„_ B within the boundaries andto taxation Tjy Community Facilities District ^are ontapai- the Cfty-Wkte TrafficIf youLiSt of Prajocft to be funded in court,Ited to raising only • - -someone else at thiwritten Ited to raising only those issues nit the Isbsd, City Clerk's Office, 1200 Carlsbade, Carlsbad. 92008, at or prior to the pub- APPLICANT: NCT2137348 PUB: 03/2512006 I certify (or declare) under penalty of perjury that the foregoing is true and correct. Dated at SAN MARCOS California This 25th, day of March, 2008 Jane Allshouse NORTH COUNTY TIMES Legal Advertising Allen Matkins Leek Gamble Mallory & Natsis LLP TV It 4.1 * Attorneys at Law jyi3.tKlIlS 50> West Broadway, 15" Floor | San Diego, CA 92101-3541 Telephone: 619.233.1155 | Facsimile: 619.233.1158 www.allenmatkins.com Robin M. Munro E-mail: nnunro@alleninatkiiis.com Direct Dial: 619.235.1531 File Number: W8809-OOI/SD696682.05 Gerald C. Livingston E-mail: jlivingston@allenmatkins.com Direct Dial: 619.235.1510 Via Email/US Postal May 6, 2008 Mayor Bud Lewis and Members of the City Council City of Carlsbad 1200 Carlsbad Village Dr. Carlsbad, CA 92108 Re: Proposed Traffic Impact Fee - Hearing Date May 6,2008 - Item 11 Dear Mayor Lewis and Members of the City Council: We represent several owners of commercial and industrial property in the City of Carlsbad ("City"). The City has managed growth in the community with a management plan that balances new development with needed infrastructure. A key part of this growth management plan has been the provision of new roads and traffic facilities funded by traffic impact fees. Maintaining a balance between fee levels, the impacts of those fees on the economy and ensuring that new development pays its fair share toward the costs of public improvements, should be key considerations for the City Council when evaluating fee adjustments. It has recently come to our attention that the City adopted Ordinance No. NS-885 at its April 8, 2008 meeting to increase traffic impact fees on commercial and industrial development by 309%, and to increase traffic impact fees on residential development by 307% ("Fee Ordinance"). We also understand that when the Fee Ordinance was returned for a second reading on April 22, 2008, the Council directed staff to return with a revised ordinance that would delay the fee increase for commercial and industrial development for a one-year period ("Revised Fee Ordinance"). We were informed last Friday, May 2, 2008, that the Revised Fee Ordinance will be heard by the City Council today, May 6, 2008. Because of Transnet requirements that the City implement new traffic fees on residential development by June 30, 2008 as a condition precedent to receive Transnet funding through SANDAG, this very complex proposal has been rushed through City Council hearings with little opportunity for input from the impacted development community. It is our understanding that the City Council could implement the fee increase on residential development required to receive Los Angeles | Orange County | San Diego | Century City | San Francisco | Del Mar Heights | Walnut Creek Allen Matkins Leek Gamble Mallory & Natsis LLP Attorneys at Law Mayor Bud Lewis and Members of the City Council May 6, 2008 Page 2 Transnet funding from SANDAG, without adjusting the commercial/industrial fees. Therefore, we urge the Council to delay any decision on the commercial/industrial fees to allow more time to fully analyze the impacts of this fee on revenue producing development (sales taxes) in the City. Additional time is also necessary to study the projects funded by this fee and analyze the relationship and proportionality to the development projects which will have to pay the fee. We note that review of the Traffic Impact Fee Update prepared by the City appears to indicate that the fee increase is intended to fund post-deficiency between previously required infrastructure and past fees, and that the fee assumes a level of infrastructure beyond that required for future development. Moreover, although we support formation of an ad-hoc committee to review the proposed commercial/industrial fee increases, that committee should include representatives of the commercial and industrial property owners to ensure their interests are represented. In addition, we believe that the original public notice for the April 8, 2008 hearing was defective. Pursuant to the Mitigation Fee Act1, Section 66018 provides: Prior to adopting an ordinance, resolution, or other legislative enactment adopting a new fee or approving an increase in an existing fee to which this section applies, a local agency shall hold a public hearing, at which oral or written presentations can be made, as part of a regularly scheduled meeting. Notice of the time and place of the meeting, including a general explanation of the matter to be considered, shall be in accordance with Section 6062a. Cal. Gov. Section 6062a provides: Publication of notice pursuant to this section shall be for 10 days in a newspaper regularly published once a week or oftener. Two publications with at least five days intervening between the dates of the first and last publication not counting such publication dates, are sufficient. The period of notice commences upon the first day of publication and terminates at the end of the tenth day, including therein the first day. (Emphasis added). According to the City Clerk, notice of the April 8, 2008 hearing was published only once on March 25, 2008 in the North County Times. However, Section 6062a, cited above, clearly requires that the notice be published at least twice within the ten day period in order to be sufficient. When we brought this to the attention of the City Attorney, Mr. Ron Ball, he acknowledged that the notice was only published once. Cal. Gov Code sections 66000-66025. Allen Matkins Leek Gamble Mallory & Natsis LLP Attorneys at Law Mayor Bud Lewis and Members of the City Council May 6, 2008 Page 3 Mr. Ball also suggested that we consider Cal. Gov. Code Section 65945.7 with respect to the defective notice, which states: No action, inaction, or recommendation regarding any ordinance, rule or regulation subject to this Section 65945, 65945.3, or 65945.5 by any legislative body, administrative body, or the officials of any state or local agency shall be held void or invalid or be set aside by any court on the ground of any error, irregularity, informality, neglect or omission (hereinafter called "error") as to any matter pertaining to notices, records, determinations, publications or any matters of procedure whatever, unless after an examination of the entire case, including evidence, the court shall be of the opinion that the error complained of was prejudicial, and that by reason of such error the party complaining or appealing sustained and suffered substantial injury, and that a different result would have been probable if such error had not occurred or existed. There shall be no presumption that error is prejudicial or that injury was done if error is shown. While we appreciate the acknowledgment that the notice may be defective, we do not believe Cal. Gov. Code Section 65945.7 applies here. The cited Sections 65945, 65945.3 and 65945.5, relate to an applicant's general right to request notice from a city, county, local agency or state agency of a proposal to amend plans, zoning ordinances, and/or regulations. The City's public notice obligation of a proposed fee increase is more specifically addressed in the Mitigation Fee Act, specifically Sections 66018 which incorporates the notice provision in Section 6062a, both cited above. The Mitigation Fee Act does not contain a provision similar to Cal. Gov. Code Section 65945.7 regarding defective notice. However, even if Cal. Gov. Code Section 65945.7 did apply, our clients are most certainly prejudiced by the City's failure to properly notice this item. Because of the lack of notice, we have had very limited time to review the staff reports and the complex studies associated with the proposed fee increase. For that reason, our clients have not had the opportunity to analyze the impacts of such a significant fee increase on the viability of their development plans. As such, it is extremely speculative for the City to conclude that it would actually collect the fees contemplated by either the Fee Ordinance or Revised Fee Ordinance because both present significant obstacles to actual development for economic reasons. There is no timing requirement to adjust traffic impact fees for commercial/industrial development that would impact the City's ability to qualify for Transnet funding from SANDAG. For that reason, we would support a City Council action to move forward with the proposed increase for residential development only, and include the appropriate pre-payment provisions for residential development requested by the Building Industry Association. This would provide an Allen Matkins Leek Gamble Mallory & Natsis LLP Attorneys at Law Mayor Bud Lewis and Members of the City Council May 6, 2008 Page 4 opportunity for commercial and industrial property owners to work with City staff to more fully study the proposed increase in commercial/industrial fees and make recommendations for an appropriate adjustment that balances project funding needs, fairness and potential economic impacts to the City. This additional time could potentially attenuate the prejudicial error to our clients as a result of the defective public notice. Therefore, in the interest of due process and fundamental fairness, we urge you to delay any action which would increase traffic impact fees for commercial or industrial development until the public, specifically the owners of commercial and industrial properties, have had a meaningful opportunity to review the proposal and provide input. Thank you for your consideration of this request. RMM:sdw cc: Lisa Hildabrand, Interim City Manager Ron Ball, City Attorney Gerald C. Livingston Carlsbad Transportation Impact fee Building Industry Recommendations Establish a Pre-Payment Option for Entitled Projects Allow projects meeting the following criteria to pre-pay their traffic fees before October 1, 2008, based on the old fees (fees in effect prior to the April 8,2008, city council hearing). Provide council the discretion to extend the Oct. 1st window if deemed appropriate. CRITERIA: > Single family projects with a Final Map recorded prior to April 8,2008 > Multif amily projects with a Precise Development Plan approved prior to April 8,2008 > Commercial and industrial projects with a Site Plan or a Planned Industrial Permit approved prior to April 8,2008 > Tennant Improvement Plans submitted for plan check prior to April 8,2009 Projects meeting any of these criteria and pre-paving their fees before October 1,2008, would have until April 8,2009, to apply for a building permit ana not be subject to any additional traffic fees. Any building permit applied for on or after April 8,2009, will be subject to the fees in effect at the time of building permit application submittal with a credit for any fees previously paid. Changes to projects which result in an increase in density or square footage will subject the project to the fees in effective at building permit application with a credit for the total amount previously paid. NO! ^^i<c^>; CO; -P5>- Projects Which have TftnStnM^ 'TmTX>™f«"?lV^ fh^ wuiv» tinier for Hollnr crodit fnr »hn«P i toward the project's calculated TIP for the life of the project, even in the case where those improvements are fully completed today. Alternative Pre-Payment Option Allow projects meeting the following criteria to pre-pay the adjusted fees (fees in effective on July 1, 2008) before October 1,2008, and exempt these projects from any further traffic fee increases for the life of the project. Provide council the discretion to extend the Oct. 1st window if deemed appropriate. CRITERIA: > Single family projects with a Final Map recorded prior to April 8,2008 > Multifamily projects with a Precise Development Flan approved prior to April 8,2008 > Commercial and industrial projects with a Site Flan or a Planned Industrial Permit approved prior to April 8,2008 > Tennant Improvement Plans submitted for plan check prior to April 8,2009 Projects meeting any of these criteria and ore-paying adjusted fees (fees in effect on Tuly 1f2008) before October 1,2008,would be exempt from additional traffic fees tor the lif e ofthe project Changes to projects which result in an increase in density or square footage will subject the project to the fees in effective at building permit application with a credit for the total amount previously paid. Projects which have constructed improvements shall receive dollar for dollar credit fur those improvements— toward the project's calculated TIP for the life of the project, even in the case where those improvements are fully completed today. Convene a subcommittee to revise the Traffic Fee Study by October 1,2008 > Revise the traffic modeling assumptions based on the SANDAG Series 11 traffic model and the city's Growth Management Flan build out, including units held in reserve. > Revise the TIP Program Project List and Funding Approach: — Remove Cannon Road Reach 4 improvements. — Remove Intersections 5 and 6 which are being constructed by the Palomar/Forum project. - Remove El Carnino Real/Cannon Road intersection improvements which are being funded by Robertson Ranch, — Remove the Avenida Enemas improvements as these improvements should be funded by the water treatment facility. — Remove the Sidewalk and Transportation Management Program cost items and utilize TransNet sales tax funding for these improvements. — Remove the Carlsbad Village Drive widening improvements as these improvements may not be necessary under the SANDAG Series 11 traffic modeling. — Consider revising projected construction costs if/when city becomes a charter city. — Consider utilizing a portion of TransNet sales tax revenue toward road improvements that are growth related. — Consider an optional offset to impact fees for retail projects which generate sales tax revenue to the city. - Codify provisions for TIP credits and reimbursement provisions for projects which construct road improvements. Revise the City Council Ordinance # NS-890 to remove the following language in Section 18.42.050, paragraph (a), lines 12 and 17: Line 12, remove the text: "...for a one year period from July I, 2008; to June 30, 2009..." Line 17, remove the statement: "Thereafter the fees shall automatically revert to those amounts set forth at the beginning of this paragraph (a)." This language in the proposed ordinance is not consistent with the city council direction to revise the traffic fee study to remove certain road projects which aluMiM no! h*» rnrhnVri (n g/ Oirmon Foarl F^arh 4), CJ-v NO > Summary of Building Industry Recommendations Establish a pre-payment window for entitled projects with the option to extend the window at the discretion of the city council. Convene a subcommittee to review and revise as necessary the Traffic Fee Study project list and funding sources. Make necessary modifications to ordinance #NS-890 such that the ordinance is consistent with council action CQ CO .E * •o ** l!o " Q. W re o $ .±5 LL £ _ +3 ? -acre CO _c_ 0) _j OT C Q. "C O J2 Mo) 2LL O) >' w "£ jBre <D a <D fc OCD 3 73LL o re <D E 2*S 0)•ji (0'x LU CO .22 LU O)cIXLU 5 co > d) CO |§8 Z -3 CN T3d>O3 1£ ^" "OCO C•c co W 00 3 OESg — . ^r- ^j r* ^^ CN W '™" R ^— J-^ ^^^^ "re <"co -^ d) -Q <D mE c CO .-g £ .0 >» W O f(j »^ V^Q- ^ \1 Q. co -n0)< w ^ .E ±i .-fci O 'x a> CD a>LU Q_ Q. 0£ __ 3 LL -2 o -i-» 00 ^5 (J^ f^ -3 CO CN 0)O3 T3 °^ •o0)o3T3 £ __ 3 LL o o"*- co *"~ 0) O) (SlcN 3 LL 3LL __ "3 LL •ac - CO <>»o> 3 o c-5 CN O (0 re o oo oo o cT oo oto o ^ offf% f/\- o o C O .0 !ffi i S *> .E oo -o«§ a a3 3 0)on O co 0) o oo oCM T- g 2 Im Q. Q. 2™ a a o < <I o "5 <D <D (I)d> 0) (01^ CO CO« 2 2 « c ca — .= E l- H- Q Q,g < < CO CD 0)i a a « « «o o a>Z u. LL T3 eoC i_gfsit « <D (O -Q0)(0reA 1 -o-tt ® 2 reis. fa ~re Ea> o «» c«- 3 ±i Ju .<S = -a X 3 «LU u_ a: I T3 O. 3 O)re c LU DO coc | Q. O Q. CO "O 2 2 CQ O Industrial and Commercial Development Approval Process Flowchart 18-24 months 6-12 months 8-18 months Master Tentative Map Engineering Plan Review A Mass Grading 3-12 months*3-8 months 2-4 months Site Plan Approval Engineering Plan Review A Finish Pad Grading * Assumes no EIR 3-4 months for PIP 6-12 months for SDP 2-3 months 2-4 months Shell Building Construction 1-2 months 2-3 months Tennant Imp. Construction -Grading Permit -Building Permit Residential Development Approval Process Flowchart 18-24 months Master Tentative Map 6-12 months 8-18 months Engineering Plan Review A Mass Grading 6-12 months 4-8 months 4-8 months Village Level Tentative Map Engineering Plan Review A Rough Pad Grading 3-6 months Site Plan Approval 3-8 months 2-4 months Engineering Plan Review A Finish Pad Grading 2-3 months 4-6 months Building Construction -Grading Permit -Building Permit Prepayment Pros • Money available sooner Cons • Time value of Money - (Construction Cost Inflation) • Ownership of prepayment value - w/individual or w/land • Multiple Development Agreements • Complicated record keeping and administrative tracking April 29, 2008 TO: CITY ATTORNEY CITY CLERK FROM: Assistant City Clerk CALENDAR OF EVENTS REGARDING NOTICING OF PUBLIC HEARING FOR 2008 TRAFFIC IMPACT FEE PROGRAM- AB #19,392 Thank you for meeting with the City Clerk and me today to discuss this matter. As you requested, we have compiled a chronology of the events regarding the noticing for this matter. The notice of public hearing was published in the newspaper well in advance of the required minimum notice, and was also put on, and remained on, the City's website for fourteen days prior to the hearing. In addition, the matter appeared on the agendas for three different City Council Meetings, and was also posted and placed on the City website prior to each meeting. The posting was done at City Hall 72 hours in advance of each meeting as required by the Brown Act. The calendar of events for the noticing process is as follows: March 21, 2008 March 25, 2008 April 4, 2008 April 11, 2008 April 18, 2008 Notice of public hearing submitted to NC Times for publication on March 25, 2008 Notice of April 8 hearing published and placed on City website Agenda for April 8 Council Meeting posted and placed on City website Agenda for April 15 Council Meeting posted and placed on City website Agenda for April 22 Council Meeting posted and placed on City website Please note that we did not have any written "Requests for Notice" regarding this matter on file in our office at the time the matter was noticed. For this reason, mailing of notices was not required. We also have compiled a list of persons that attended the City Council Meetings to speak on this matter. There were a total of ten speakers at the three meetings. A copy of the list is attached to this memo for information. Also, as a result of discussions with Senior Civil Engineer Plantz, we learned that he had provided information to parties interested in this matter. Mr. Plantz indicated that he had, on March 20, 2008, sent a letter (copy attached) and a copy of the Study to the BIA to alert them that it was anticipated that the matter would be scheduled for public hearing on April 8, 2008, which included a copy of the Traffic Impact Fee Update Study. In addition, Mr. Plantz indicated that he had spoken to Scott Molloy of the BIA prior to the hearing and had provided additional information, including an electronic version of the study, to him via email. Mr. Plantz also indicated that he had also spoken with representatives of Brookfield Homes and Planning Systems prior to the April 8, 2008 hearing, and had provided paper copies of the study to them. As a result of these discussions, we believe that the noticing for the public hearing referenced above was done in substantial compliance with the requirements of the Government Code. :N KUNDTZ, CMC Assistant City Clerk C: Interim City Manager Public Works Director Sr. Civil Eng. Plantz Attachment (1 - List of Speakers) (2 - Letter to BIA from M. Plantz) CITY COUNCIL MEETING SPEAKERS REGARDING THE TRAFFIC IMPACT FEE PROGRAM UPDATE APRIL 8. 2008 CITY COUNCIL MEETING - PUBLIC HEARING • Scott Molloy, Public Policy Advocate for the Building Industry Association (BIA) APRIL 15. 2008 CITY COUNCIL MEETING - ORDINANCE FOR ADOPTION • No speakers. Item continued to meeting of April 22, 2008 APRIL 22. 2008 CITY COUNCIL MEETING - ORDINANCE FOR ADOPTION Michael Babawal, Director of Government Affairs, Carlsbad Chamber of Commerce Jeff Williams, LNR Partners Scott Molloy, Public Policy Advocate for the Building Industry Association (BIA) David DiRienzo, President of Urban West Mike Howes of Howes, Weiter and Associates Pat O'Day, President of O'Day Consultants Bob Ladwig, President of Ladwig Design Group, Inc. Brenda Tworoger, La Costa Town Center Project Fred Arbuckle, President of Morrow Development City of Carlsbad Public Works Engineering March 20, 2008 Ann Ellis BUILDING INDUSTRY ASSOCIATION 9201 Spectrum Canter Boulevard/Suite 110 San Diego, CA 92123 TRAFFIC IMPACT FEE UPDATE The purpose of this letter Is to inform your organization that the City of Carlsbad is considering updating the existing Traffic Impact Fee (TIP) program which was established in 1991. The recommended update will revise the project list, project costs, trip volume projections, and ultimately the fee. The update also Includes the amendments necessary to satisfy the requirements of the Regional Traffic Congestion Improvement Program (RTCIP) section of the TransNet Extension Ordinance. In support of these revisions, we have prepared the attached Traffic Impact Fee Update Study. The Study includes sections which generally describe the authority, justification, and purpose of the TIF program. In addition, the Study summarizes the results of the analysis of the roadway/circulation system which are then used to calculate project costs. These costs are then used in conjunction with future trip generation projections to calculate the fees needed to generate the funding for the projects. The recommended fees are summarized on page 1 1 of the Study. The Study also describes how a portion of the fees will be programmed for Improvements on the Regional Arterial System (RAS) in conformance with the RTCIP. In general terms, the RTCIP requires member agencies to collect $2,000 per newly-constructed residential unit for the purpose, of constructing/improving RAS roadways. By incorporating the necessary provisions inje the TIF update, the City will be able to utilize an existing fee program to satisfy the requirements of the RTCIP. At this time, we anticipate that the Hem will be considered by the City Council at their April 8th meeting. Once the actual date is set, the City Clerk's office will provide a public notification of the associated public hearing and the agenda bill will be posted on the City's website. The updated fee would become effective 60 days after the adoption of the associated ordinance which amends Chapter 18 42 of the Carlsbad Municipal Code. If you have any questions regarding this subject, please contact me at (760) 602-2766. Sincerely, yt ,..-•,'. • .' ,' • .,..,. i.--/"""^ MARSHALL PLANTZ Senior Civil Engineer Attachment: Traffic Impact Fee Update Study c: City Engineer Deputy City Engineer, Planning and Programs Division Finance Director 1635 Faraday Avenue • Carlsbad, CA 92008-7314 - (760) 602-2720 - FAX (760) 302-3532 Traffic Impact FeeTraffic Impact Fee••Ordinance for IntroductionOrdinance for Introduction„„Fee Reduction Fee Reduction ••Residential adjusted to meet the RTCIP Residential adjusted to meet the RTCIP requirementsrequirements••Commercial and Industrial adjusted by the same Commercial and Industrial adjusted by the same percentage as residentialpercentage as residential„„Grandfathering provisionGrandfathering provision••Exclude projects from the change in the Traffic Exclude projects from the change in the Traffic Impact Fee based on the following criteriaImpact Fee based on the following criteria„„Building Permit application on file by April 8, Building Permit application on file by April 8, 20082008„„Building Permit issued by September 30, 2008Building Permit issued by September 30, 2008 Fee ReductionFee Reduction••Current Fee Current Fee „„Residential Residential ––$115/ADT$115/ADT„„Commercial/Industrial Commercial/Industrial --$46/ADT$46/ADT••Full Fee as adopted on 4/22/08 (207% increase)Full Fee as adopted on 4/22/08 (207% increase)„„Residential Residential --$353/ADT$353/ADT„„Commercial/Industrial Commercial/Industrial --$142/ADT$142/ADT••Reduced Fee per this Agenda Bill (109% increase)Reduced Fee per this Agenda Bill (109% increase)„„Residential Residential --$240/ADT*$240/ADT*„„Commercial/Industrial Commercial/Industrial --$96/ADT$96/ADT* Per Single Family Unit* Per Single Family Unit ““GrandfatheringGrandfathering””••Revise the Ordinance to exclude commercial Revise the Ordinance to exclude commercial and industrial projects from the effects of the and industrial projects from the effects of the TIF update. TIF update. „„Projects that had a Building Permit application on file Projects that had a Building Permit application on file prior to April 8, 2008.prior to April 8, 2008.andand„„Projects that obtain a Building Permit by September Projects that obtain a Building Permit by September 30, 2008.30, 2008.••Financial ImpactFinancial Impact„„$1,600,000 less revenue when compared to full fee$1,600,000 less revenue when compared to full fee„„$ 800,000 less revenue when compared to reduced $ 800,000 less revenue when compared to reduced feefee Traffic Impact FeeTraffic Impact Fee$54.6$34.1$23.69/30/086/30/096/30/08ResidentialComm/IndAllAll$1.6AllFull ReducedCurrentBuildout Calendar of eventsCalendar of events••Ordinance with full fee increase Ordinance with full fee increase „„Introduced on April 8, 2008Introduced on April 8, 2008„„Adoption on April 22, 2008Adoption on April 22, 2008„„Fee becomes effective June 30, 2008Fee becomes effective June 30, 2008••Ordinance with a fee reduction and a Ordinance with a fee reduction and a ““grandfatheringgrandfathering””provision.provision.„„Introduce Ordinance on May 6, 2008Introduce Ordinance on May 6, 2008„„Adopt new Ordinance on May 13, 2008Adopt new Ordinance on May 13, 2008„„Fee becomes effective June 30, 2008Fee becomes effective June 30, 2008 Conclusion of Presentation