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City of Rancho Cucamonga Development Impact Fee Study Report Final Report: April 22, 2014 Presented to the City Council: June 4, 2014 Submitted by: Colgan Consulting Corporation 3323 Watt Avenue # 131 Sacramento, CA 95821

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City of Rancho Cucamonga

Development ImpactFee Study Report

Final Report: April 22, 2014

Presented to the City Council: June 4, 2014

Submitted by:

Colgan Consulting Corporation3323 Watt Avenue # 131

Sacramento, CA 95821

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Revision Notes

These revision notes are provided for the convenience of anyone who has reviewedearlier drafts of this report.

December 19, 2013 RevisionsExecutive Summary (previous version November 29, 2013)Chapter 2 (previous version November 29, 2013)Chapter 4 (previous version November 29, 2013)

April 22, 2014 RevisionsExecutive Summary (previous version December 19, 2013)Chapter 3 (previous version November 29, 2013)Chapter 4 (previous version December 19, 2013)Chapter 5 (previous version November 29, 2013)Chapter 6 (previous version November 29, 2013)Chapter 7 (previous version November 29, 2013)

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City of Rancho Cucamonga – Development Impact Fee Study Table of Contents

April 22, 2014 Colgan Consulting Corporation Page i

Organization of the Report S-1 Future Development S-1 Impact Fee Analysis S-1 Impact Fee Summary S-3 Implementation S-4 Recovery of Study Cost S-4

Purpose 1-1 Legal Framework 1-1 Impact Fee Calculation Methodology 1-5 Facilities Addressed in this Study 1-6

Study Area and Time Frame 2-1 Development Types 2-1 Units of Development 2-2 Demand Variables 2-3 Development Data 2-5

Types of Park Fees 3-1 Service Area 3-2 Demand Variable 3-2 Level of Service 3-2 Methodology 3-4 Facility Needs 3-4 Cost per Capita 3-5 In-Lieu Fees and Impact Fees per Unit 3-5 Projected Revenue 3-7

Service Area 4-1 Demand Variable 4-1 Level of Service 4-1 Methodology 4-2 Facility Needs 4-2 Per-Capita Cost 4-2 Impact Fees per Unit 4-3 Projected Revenue 4-3

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City of Rancho Cucamonga – Development Impact Fee Study Table of Contents

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Table of Contents (cont’d)

Service Area 5-1 Demand Variable 5-1 Level of Service 5-1 Methodology 5-2 Facility Needs 5-3 Per Capital Cost 5-3 Impact Fees per Unit 5-3 Projected Revenue 5-4

Service Area 6-1 Level of Service 6-1 Demand Variable 6-1 Methodology 6-2 Facility Needs 6-2 Per Capita Cost 6-2 Impact Fee per Unit 6-2 Projected Revenue 6-3

Service Area 7-1 Demand Variable 7-1 Level of Service 7-2 Methodology 7-3 Facility Needs 7-4 Cost per Call for Service 7-4 Impact Fees per Unit 7-4 Projected Revenue 7-5

Background 8-1 Considerations in Establishing a Public Art Fee Program 8-1 Steps in Establishing a Public Art Fee Program 8-3

Adoption 9-1 Administration 9-2 Training and Public Information 9-6 Recovery of Study Cost 9-7

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City of Rancho Cucamonga – Development Impact Fee Study Executive Summary

April 22, 2014 Colgan Consulting Corporation Page S-1

The City of Rancho Cucamonga has retained Colgan Consulting Corporation to prepare this impact fee study to analyze the impact of development on certain capital facilities and to cal­culate impact fees based on that analysis. The methods used to calculate impact fees in this study are intended to satisfy all legal requirements of the U. S. Constitution, the California Constitution, the California Mitigation Fee Act (Government Code Sections 66000 et seq.) , and where applicable, the Quimby Act (Government Code Section 66477) .

Chapter 1 of this report provides an overview of impact fees. It discusses legal requirements for establishing and imposing such fees, as well as methods used in this study to calculate the fees.

Chapter 2 contains information on existing and future development in the City, and organizes that data in a form that can be used in the impact fee analysis. Projections of future devel­opment shown in Chapter 2 are based on the 2010 Rancho Cucamonga General Plan.

Chapters 3 through 7 analyze the impacts of development on specific types of public facilities and calculate impact fees for those facilities, as follows:

Chapter 3. Parks Chapter 4. Community and Recreation Centers Chapter 5. Libraries Chapter 6. Animal Center Chapter 7. Police Facilities and Equipment

Each of the chapters listed above identifies costs eligible for impact fee funding and calcu­lates the maximum impact fees that can be justified by the data used in this study.

Chapter 8 outlines options for a Public Art Program and Public Art Fee

Chapter 9 discusses implementation of the impact fee program including legal requirements for implementing the impact fee program under California law.

Forecasts of future development for this study are intended to represent potential develop­ment in the City, based on the 2010 General Plan. Data presented in Chapter 2 of this report indicate that future residential development would increase the City’s population by about 8%. By contrast, demand for police services could increase by 47% to buildout. The difference reflects the fact that the City has much more potential for commercial and industrial devel­opment than for residential development.

Each type of facility addressed in this report is analyzed individually. In each case, the rela­tionship between development and the need for facilities is quantified in a formula that al­lows the impact of development on facility needs to be reflected in the calculation of impact

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fees. Impact fees calculated in this report are based on the capital cost of facilities needed to serve additional development. Those fees are summarized in Table S.1, on page S­3. The fol­lowing paragraphs briefly discuss factors considered in the calculation of each type of impact fee calculated in this report.

Park In­Lieu Fees and Park Impact Fees. This chapter calculates two broad types of devel­opment fees for parks: fees for park land acquisition, and fees for park improvements. Fees for park land acquisition are subdivided into two types: fees for park land acquisition charged to residential development in subdivisions are governed by the Quimby Act. Fees for park land acquisition in projects that don’t involve a subdivision are impact fees. Fees for park im­provements are impact fees regardless of whether the project involves a subdivision. The relationship among different types of park fees in this report is shown in this outline:

1. Fees for park land acquisition are either:

a. Quimby Act fees in lieu of park land dedication (subdivisions), or

b. Impact fees for park land acquisition (projects with no subdivision)

2. Impact fees for park improvements (all residential development)

Quimby Act In­lieu fees are subject to different rules than impact fees. The most important difference for purposes of fee calculation has to do with the level of service standard used to set the fees. “Quimby” in­lieu fees in this report are based on a ratio of 3.0 acres per thou­sand residents. Impact fees are based on existing ratios of park acreage to population, which are somewhat lower. Park in­lieu fees and park impact fees calculated in this report are in­tended to replace the City’s existing park development fees. They would apply only to resi­dential development.

Land costs used to calculate park fees are based on the best available estimates of costs for low density residential land in the City. Improvement costs are estimated average costs for neighborhood and community park improvements. See Table S.1 below for a summary of the park in­lieu and impact fees calculated in this report.

Community and Recreation Center Impact Fees. This study calculates a new type of impact fee for community and recreation centers. Currently, the cost of those facilities is reflected in park impact fees for non­subdivision development only. The level of service used as the basis for the fee calculations is the ratio of existing replacement cost to existing population.

Impact fees based on that standard should provide enough revenue to cover the cost of maintaining the existing level of service as the City grows. Because these impact fees are based on population growth, they apply only to residential development. See Table S.1 for a summary of the Community and Recreation Center impact fees calculated in this report.

Library Impact Fees. This study calculates a new type of impact fee for library facilities and materials. The level of service used as the basis for the fee calculations is the ratio of existing replacement cost to existing population.

Impact fees based on that standard should provide enough revenue to cover the cost of maintaining the existing level of service as the City grows. Because these impact fees are

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City of Rancho Cucamonga – Development Impact Fee Study Executive Summary

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based on population growth, they apply only to residential development. See Table S.1 for a summary of the Library impact fees calculated in this report

Animal Center Impact Fees. This study calculates a new type of impact fee for the Animal Center. The level of service used as the basis for the fee calculations is the ratio of existing facility replacement cost to existing population. Impact fees based on that standard should provide enough revenue to cover the cost of maintaining the existing level of service as the City grows. Because these impact fees are based on population growth, they apply only to residential development. See Table S.1 for a summary of the Animal Center impact fees cal­culated in this report.

Police Impact Fees. This study calculates a new type of impact fee for Police facilities and equipment. The level of service used as the basis for the impact fee calculations is the ratio of existing asset replacement cost to existing calls for service. This impact fee applies to both residential and non­residential development in the City.

As part of this study, Colgan Consulting and the Rancho Cucamonga Planning Department analyzed a random sample of 2012 Police Department calls for service to determine the dis­tribution of calls among various types of development, or in other words, the percentage of all calls generated by each type of development used in the impact fee calculations. Those percentages were applied to the total number of 2012 calls for service to determine the number of calls originating with each type of development. Then the number of calls associ­ated with each type of development was divided by the number of existing units to arrive at a factor representing the number of calls per unit per year.

Meanwhile the total replacement cost of existing city­owned Police facilities was divided by the total number of 2012 calls for service to determine the average replacement cost of the existing capital facilities supporting each call. Then the impact fee per unit of development for each type of development was calculated as the number of calls per year multiplied by the average cost per call. See Table S.1 for a summary of the Police impact fees calculated in this report.

Table S.1 on the next page summarizes the impact fees calculated in this report. Impact fees shown in Table S.1 are fees per unit of development by development type.

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Chapter 9 of this report discusses the requirements of the California Mitigation Fee Act and the Quimby Act for adoption and administration of impact fees, including findings required by the Mitigation Fee Act for adoption of the impact fees.

As discussed in Chapter 9, Colgan Consulting recommends that the City add an administrative charge to the fees calculated in this report to cover the cost of periodic fee updates and pro­gram administration. The amount of that fee should be determined by the City, based on its costs.

Table S.1: Summary of Development Impact Fees per Unit Calculated in This Study (Rounded to Nearest Dollar)

Development Parks w/ Parks w/o Comm/Rec Animal Total w/ Total w/o

Type Units 1 Subdiv 2 Subdiv 3 Centers Libraries Center Police Subdiv Subdiv

Residential, Single Family (Det) DU $7,773 $6,876 $1,737 $577 $124 $172 $10,384 $9,487

Residential, Multi­Family (Att) DU $5,295 $4,684 $1,183 $393 $85 $195 $7,151 $6,540

Assisted Living Facilities DU N/A $2,192 $554 $184 N/A $41 N/A $2,972

Commercial/Retail KSF $531 $531 $531

Office KSF $122 $122 $122

Industrial KSF $46 $46 $46

Hotel/Motel Room $65 $65 $65

1 DU = dwelling unit; KSF = 1,000 gross square feet of building area; Room = guest room or suite2 Includes impact fee for park improvements and in­lieu fee for land acquisition under the Quimby Act (see Chapter 3)3 Includes impact fees for park improvements and land acquisition (see Chapter 3)

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City of Rancho Cucamonga – Development Impact Fee Study Introduction

April 22, 2014 Colgan Consulting Corporation Page 1-1

The City of Rancho Cucamonga has retained Colgan Consulting Corporation to prepare this study to analyze the impacts of development on certain public facilities and to calculate de­velopment impact fees based on that analysis. This study also discusses the establishment of a public art fee program.

The methods used to calculate impact fees in this study are intended to satisfy all legal re­quirements governing such fees, including provisions of the U. S. Constitution, the California Constitution, the California Mitigation Fee Act (Government Code Sections 66000 et seq.), and, where applicable, the Quimby Act (Government Code Section 66477).

This brief summary of the legal framework for development impact fees is intended as a general overview. It was not prepared by an attorney, and should not be treated as a legal opinion.

U. S. Constitution. Like all land use regulations, development exactions, including impact fees, are subject to the Fifth Amendment prohibition on taking of private property for public use without just compensation. Both state and federal courts have recognized the imposi­tion of impact fees on development as a legitimate form of land use regulation, provided the fees meet standards intended to protect against “regulatory takings.” A regulatory taking occurs when regulations unreasonably deprive landowners of property rights protected by the Constitution.

To comply with the Fifth Amendment, development regulations must be shown to substan­tially advance a legitimate governmental interest, and must not deprive the owner of all eco­nomically viable use of the property. In the case of impact fees, the government’s interest is in protecting public health, safety and welfare by ensuring that development is not detri­mental to the quality and availability of essential public services provided to the community at large.

Impact fees that apply to all development in a jurisdiction are not subject to the same level of judicial scrutiny as exactions involving the dedication of land or an interest in land, or a fee imposed as a condition of approval on a single development project. In those cases, height­ened scrutiny applies, and a higher standard must be met. The U. S. Supreme Court has found that a government agency must demonstrate an "essential nexus" between such ex­actions and the interest being protected (See Nollan v. California Coastal Commission, 1987). The agency must also demonstrate that the exaction imposed is "roughly proportional" to the burden created by development. (See Dolan v. City of Tigard, 1994).

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A local legislative body is accorded considerable discretion by the courts when enacting im­pact fees that apply broadly to development projects within its jurisdiction. However, even where heightened scrutiny does not apply, an agency enacting impact fees should take care to demonstrate a nexus and ensure proportionality in the calculation of its fees.

California Constitution. The California Constitution grants broad police power to local gov­ernments, including the authority to regulate land use and development. That police power is the source of authority for local governments in California to impose impact fees on devel­opment. Some impact fees have been challenged on grounds that they are special taxes im­posed without voter approval in violation of Article XIIIA. However, that objection is valid only if the fees exceed the cost of providing capital facilities needed to serve new develop­ment. If that were the case, then the fees would also run afoul of the U. S. Constitution and the Mitigation Fee Act. Articles XIIIC and XIIID, added by Proposition 218 in 1996, require voter approval for some “property­related fees,” but exempt “the imposition of fees or charges as a condition of property development.”

The Mitigation Fee Act. California’s impact fee statute originated in Assembly Bill 1600 dur­ing the 1987 session of the Legislature, and took effect in January, 1989. AB 1600 added sev­eral sections to the Government Code, beginning with Section 66000. Since that time the impact fee statute has been amended from time to time, and in 1997 was officially titled the “Mitigation Fee Act.” Unless otherwise noted, code sections referenced in this report are from the Government Code.

The Mitigation Fee Act does not limit the types of capital improvements for which impact fees may be charged. It defines public facilities very broadly to include "public improve­ments, public services and community amenities." Although the issue is not specifically ad­dressed in the Mitigation Fee Act, other provisions of the Government Code (see Section 65913.8) prohibit the use of impact fees for maintenance or operating costs. Consequently, the fees calculated in this report are based on capital costs only.

The Mitigation Fee Act does not use the term “mitigation fee” except in its official title. Nor does it use the more common term “impact fee.” The Act simply uses the word “fee,” which is defined as “a monetary exaction, other than a tax or special assessment…that is charged by a local agency to the applicant in connection with approval of a development project for the purpose of defraying all or a portion of the cost of public facilities related to the devel­opment project ….”

To avoid confusion with other types of fees, this report uses the widely­accepted terms “im­pact fee” and “development impact fee” which should both be understood to mean “fee” as defined in the Mitigation Fee Act.

The Mitigation Fee Act contains requirements for establishing, increasing and imposing im­pact fees. They are summarized below. It also contains provisions that govern the collection and expenditure of fees and require annual reports and periodic re­evaluation of impact fee programs. Those administrative requirements are discussed in Chapter 9 of this report.

Required Findings. Section 66001 requires that an agency establishing, increasing or impos­ing impact fees, must make findings to:

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1. Identify the purpose of the fee;

2. Identify the use of the fee; and,

3. Determine that there is a reasonable relationship between:

a. The use of the fee and the development type on which it is imposed;

b. The need for the facility and the type of development on which the fee is im­posed; and

c. The amount of the fee and the facility cost attributable to the development project. (Applies when fees are imposed on a specific project.)

Each of those requirements is discussed in more detail below.

Identifying the Purpose of the Fees. The broad purpose of impact fees is to protect public health, safety and general welfare by providing for adequate public facilities. The specific purpose of the fees calculated in this study is to fund construction of certain capital im­provements identified in this report. Those improvements will be needed to mitigate the impacts of planned new development on City facilities, and to maintain an acceptable level of public services as the City grows. Findings with respect to the purpose of a fee should define the purpose broadly as providing for the funding of adequate public facilities to serve addi­tional development.

Identifying the Use of the Fees. According to Section 66001, if a fee is used to finance public facilities, those facilities must be identified. A capital improvement plan may be used for that purpose, but is not mandatory if the facilities are identified in a General Plan, a Specific Plan, or in other public documents. In this case, we recommend that the City Council adopt this report as the document that identifies the facilities to be funded by the fees.

Reasonable Relationship Requirement. As discussed above, Section 66001 requires that, for fees subject to its provisions, a "reasonable relationship" must be demonstrated between:

1. the use of the fee and the type of development on which it is imposed;

2. the need for a public facility and the type of development on which a fee is im­posed; and,

3. the amount of the fee and the facility cost attributable to the development on which the fee is imposed.

These three reasonable relationship requirements as defined in the statute mirror the nexus and proportionality requirements widely considered to be the standard for defensible impact fees. The term “dual rational nexus” is often used to characterize the standard used by courts in evaluating the legitimacy of impact fees. The “duality” of the nexus refers to (1) an impact or need created by a development project subject to impact fees, and (2) a benefit to the project from the expenditure of the fees. Although proportionality is reasonably implied in the dual rational nexus formulation, it was explicitly required by the Supreme Court in the Dolan case, and we prefer to list it as the third element of a complete nexus.

Demonstrating an Impact. All new development in a community creates additional demands on some, or all, public facilities provided by local government. If the supply of facilities is not

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increased to satisfy the additional demand, the quality or availability of public services for the entire community will deteriorate. Impact fees may be used to recover the cost of develop­ment­related facilities, but only to the extent that the need for facilities is occasioned by the development project subject to the fees. The Nollan decision reinforced the principle that development exactions may be used only to mitigate impacts created by the development projects upon which they are imposed. In this study, the impact of development on facility needs is analyzed in terms of quantifiable relationships between various types of develop­ment and the demand for public facilities, based on applicable level­of­service standards. This report contains all of the information needed to demonstrate this element of the nexus.

Demonstrating a Benefit. A sufficient benefit relationship requires that impact fee revenues be segregated from other funds and expended only on the facilities for which the fees were charged. Fees must be spent in a timely manner and facilities funded by the fees must serve the development projects paying the fees. Nothing in the U.S. Constitution or California law requires that facilities paid for with impact fee revenues be available exclusively to develop­ments paying the fees. Procedures for earmarking and expenditure of fee revenues are mandated by the Mitigation Fee Act, as are procedures to ensure that the fees are expended expeditiously or refunded. Those requirements are intended to ensure that developments benefit from the impact fees they are required to pay. Thus, an adequate showing of benefit must address procedural as well as substantive issues.

Demonstrating Proportionality. Proportionality in impact fees depends on properly identify­ing development­related facility costs and calculating the fees in such a way that the impact of development is reflected in the allocation of those costs. In calculating impact fees, costs for development­related facilities must be allocated in proportion to the facility needs creat­ed by different types and amounts of development. The section on impact fee methodology, below, describes methods used to allocate facility costs and calculate impact fees that meet the proportionality standard.

Impact Fees for Existing Facilities. It is important to note that impact fees may be used to cover some or all of the cost of existing facilities, provided those facilities are needed to serve additional development and have the capacity to do so. In other words, it must be possible to show that the fees meet the need and benefit elements of the nexus.

Development Agreements and Reimbursement Agreements. The requirements of the Miti­gation Fee Act do not apply to fees collected under development agreements (see Govt. Code Section 66000) or reimbursement agreements (see Govt. Code Section 66003). The same is true of fees in lieu of park land dedication imposed under the Quimby Act (see Govt. Code Section 66477).

Existing Deficiencies. In 2006, Section 66001(g) was added to the Mitigation Fee Act (by AB 2751) to prohibit impact fees from including costs attributable to existing deficiencies in pub­lic facilities. The legislature’s intent in adopting this amendment, as stated in the bill, was to codify the Holdings of Bixel v. City of Los Angeles (1989), Rohn v. City of Visalia (1989), and Shapell Industries Inc. v. Governing Board (1991). That amendment does not appear to be a substantive change. It is widely understood that other provisions of law make it improper for impact fees to include costs for correcting existing deficiencies.

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Any one of several legitimate methods may be used to calculate impact fees. The choice of a particular method depends primarily on the service characteristics and planning require­ments for the facility type being addressed. Each method has advantages and disadvantages in a particular situation. To some extent they are interchangeable, because they all allocate facility costs in proportion to the needs created by development.

Reduced to its simplest terms, the process of calculating impact fees involves two steps: de­termining the cost of development­related capital improvements, and allocating those costs equitably to various types of development. In practice, though, the calculation of impact fees can become quite complicated because of the many factors involved in defining the re­lationship between development and the need for facilities.

Allocating facility costs to various types and amounts of development is central to all meth­ods of impact fee calculation. Costs are allocated by means of formulas that quantify the re­lationship between development and the need for facilities. In a cost allocation formula, the impact of development is measured by a “demand variable,” which is an attribute of devel­opment that reasonably represents the facility needs created by different types and amounts of development. Different variables are used in analyzing different types of facilities. Specif­ic demand variables used in this study are discussed in more detail in subsequent chapters.

The following paragraphs discuss three general approaches to calculating impact fees and how they can be applied.

Plan­Based or Improvements­Driven Method. Plan­based impact fee calculations are based on the relationship between a specified set of improvements and a specified increment of development. The improvements are typically identified by a facility plan, while the devel­opment is identified by a land use plan that identifies potential development by type and quantity. Facility costs are allocated to various categories of development in proportion to the amount of development and the relative intensity of demand created by each category. To calculate impact fees using this approach, it is necessary to define an end point or “buildout” condition for development, and to determine what facilities will be needed to serve the additional development that occurs from the time of the analysis to buildout. Buildout is a hypothetical condition in which undeveloped land encompassed by the study has been developed to its expected intensity.

Under this approach, the total cost of eligible facilities is divided by the total units of addi­tional demand (based on the demand variable) to calculate a cost per unit of demand. Then, the cost per unit of demand is multiplied by the units of demand per unit of development (e.g. dwelling units or square feet of building area) in each category to arrive at a cost per unit of development. This method is somewhat inflexible in that it is based on the relation­ship between a particular facility plan and a particular land use plan. If either plan changes significantly, the fees may have to be recalculated.

Capacity­Based or Consumption­Driven Method. This method calculates a cost per unit of capacity based on the relationship between total cost and total capacity of a system. It can be applied to any type of development, provided the capacity required to serve each incre­ment of development can be estimated and the facility has adequate capacity available to

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serve the development. Since the cost per unit of demand does not depend on the type or quantity of development to be served, this method is flexible with respect to changing de­velopment plans.

Under this method, the cost of unused capacity is not allocated to development. Capacity­based fees are most commonly used for water and wastewater systems, where the cost of a system component is divided by the capacity of that component to derive a unit cost. How­ever, this method can be applied to other types of facilities. To produce a schedule of impact fees based on standardized units of development (e.g. dwelling units or square feet of non­residential building area), the cost per unit of capacity is multiplied by the amount of capacity required to serve a typical unit of development in each of several land use categories.

Standard­based Method. Standard­based fees are calculated using a specified relationship or standard that determines the number of service units to be provided for each unit of devel­opment. The standard can be established as a matter of policy or it can be based on the level of service being provided to existing development in the study area. Using the standard­based method, costs are defined on a generic unit­cost basis and then applied to develop­ment according to a standard that sets the amount of service or capacity to be provided for each unit of development. The standard­based method is useful where facility needs are de­fined directly by a service standard, and where unit costs can be determined without refer­ence to the total size or capacity of a facility or system. Parks fit that description. It is com­mon for cities or counties to establish a service standard for parks in terms of acres per thou­sand residents. In addition, the cost per acre for parks can usually be estimated without knowing the exact size or location of a particular park, or the total acreage of parks in the system.

This approach is also useful for facilities such as libraries, where it is possible to estimate a generic cost per square foot before a building is actually designed. One advantage of the standard­based method is that a fee can be established without committing to a particular size of facility, and facility size can be adjusted based on the amount of development that actually occurs.

Impact fees for the following types of facilities are addressed in this report:

• Park Land and Improvements (Chapter 3) • Community and Recreation Facilities (Chapter 4) • Libraries (Chapter 5) • Animal Center (Chapter 6) • Police (Chapter 7)

In addition Chapter 8 discusses the establishment of a public art fee program.

The impact fee analysis for each facility type is presented in a separate chapter of this report, beginning with Chapter 3. The next chapter, Chapter 2, contains data on land use and devel­opment in the City.

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This chapter of the report organizes and correlates data on existing development and planned future development to provide a framework for the impact fee analysis contained in subsequent chapters of the report.

The information in this chapter forms a basis for establishing levels of service, analyzing facil­ity needs, and allocating the cost of capital facilities between existing and new development, where appropriate, and among various types of new development.

Data on existing and planned development shown in this report were compiled from the City of Rancho Cucamonga 2010 General Plan, the General Plan EIR for that update, and addition­al information provided by the City of Rancho Cucamonga Planning Department.

The study area for the impact fee analysis is the area covered by the 2010 General Plan. The timeframe for this study extends from the present to buildout of land designated for devel­opment within the study area. The term “buildout” is used to describe a hypothetical condi­tion in which currently undeveloped land in the study area has been developed as designated in the General Plan.

The time required for buildout will depend on the rate at which development occurs. The timing of development does not enter into the impact fee calculations, so this report does not project the rate of growth or anticipated buildout date.

The development types used in this report correlate with General Plan land use designations, or groups of land use designations. Impact fees calculated in this report are intended to be applied based on actual land uses rather than zoning or general plan land use designations.

Residential Development. Residential development types used in this study are:

� Residential, Single­Family (Detached)

� Residential, Multi­Family (Attached)

The Residential, Single­Family (Detached) category, above, corresponds to residential devel­opment at or below the Low­Medium Density (LMD) designation in the General Plan.

The Residential, Multi­Family (Attached) category, above, corresponds to residential devel­opment at densities above the Low­Medium Density (LMD) designation in the General Plan, including residential development in Mixed Use projects.

Non­Residential Development. Non­residential development types used in this study are:

� Commercial/Retail

� Office

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� Industrial

� Hotel/Motel

The Commercial/Retail category corresponds to development covered by the Neighborhood Commercial, Community Commercial, and General Commercial designations in the General Plan and also assumes that Mixed Use development is 80% Commercial/Retail and 20% High Density residential.

The Office category corresponds to development covered by Office and Haven Office Over­lay designations in the General Plan as well as 40% of the land designated Industrial Park.

The Industrial category corresponds to the General Industrial and Heavy Industrial designa­tions in the General Plan, as well as 60% of the land designated Industrial Park.

The Hotel/Motel category breaks out hotel and motel uses from the broader Commercial/ Retail category.

Note on Assisted Living Facilities. Although Assisted Living Facilities are not identified as a separate development type in this study, some of the impact fees calculated in this report show impact fees specifically for that type of project.

Assisted Living Facilities are allowed in some higher­density residential zoning districts with a conditional use permit, but their impacts are quite different from the uses typically expected in those districts. It would be possible to calculate customized impact fees for such projects when they are being approved, but having those fees calculated in advance is a convenience for City staff.

Similar situations can arise with other types of development where the fees calculated for a broad category of development do not reflect the specific characteristics of an individual pro­ject that falls within that broad category. The fee calculations for Assisted Living Facilities in later chapters of this report can be viewed as an example of the approach that can be used to customize fees for such uses.

However, to qualify for special treatment, a development project must be designed for, and permanently committed to, a use whose impacts are significantly greater or less than the impact of the general development type into which that use would otherwise fall.

In this study, quantities of existing and potential development are measured in terms of cer­tain units of development. Those units are discussed below.

Dwelling Units. The dwelling unit (DU) is the most commonly used measure of residential development, and is the standard unit for residential development in this study.

Building Area. Gross building area in thousands of square feet (KSF) is used as the standard unit of development for non­residential development, except for the Hotel/Motel category.

Rooms. The standard unit of development for hotel and motel uses is a single guest accom­modation, i.e., a guest room or suite.

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In calculating impact fees, the relationship between facility needs and development must be quantified in cost allocation formulas. Certain measurable attributes of development (e.g., population) are used in those formulas to reflect the impact of different types and amounts of development on the demand for specific public services and the facilities that support those services. Those attributes are referred to in this study as “demand variables.”

Demand variables are selected either because they directly measure service demand created by various types of development, or because they are reasonably correlated with that de­mand. For example the need for parks in a community is almost universally assessed based on the population of the community, so added population is an appropriate demand variable to measure the impact of new development on the need for additional parks.

Specific demand variables used in this study are discussed below. The value of a demand var­iable for each type of development is called a demand factor. Demand factors used in this study are shown in Table 2.1, later in this chapter.

Population. Population is used as a demand variable to measure the impact of development on several types of facilities in this study. Because population growth is a function of resi­dential development, the value of this variable is zero for all non­residential development types.

Existing and potential population figures used in this study are intended to represent a “zero­vacancy” population, calculated as the number or existing or potential dwelling units in a category multiplied by the average population per unit (see Table 2.1, below).

Colgan Consulting uses this approach because fluctuating vacancy rates can obscure the po­tential demand for public service represented by existing or potential dwelling units, once they are constructed. A zero­vacancy population reflects the total demand the City is com­mitted to serve.

Persons­per­dwelling unit factors used in this study are based on an analysis of data from 5­year estimates in the 2007­2011 U. S. Census Bureau American Community Survey.

Police Calls for Service. In this study, police calls for service per­unit per­year are used to represent the demand for police services by different types of development. The calls per­unit per­year factors shown in Table 2.1 were derived from analysis of a random sample of all calls for service for calendar year 2012.

The total number of calls for service logged by the Rancho Cucamonga Police Department for 2012 was 139,696. From those calls for service, Colgan Consulting extracted a random sample consisting of 699 calls or 1 of every 200 calls. Then the Rancho Cucamonga Planning Department classified the sampled call locations by development type to establish a distribu­tion of those calls by development type.

Of the 699 sample calls, 91 (13.0%) were excluded from the analysis because the location was unknown or the development type could not be determined. Of the remaining 608 calls, 79 were for traffic stops and 45 were information calls. Colgan Consulting ultimately decided to exclude traffic stops and information calls from the distribution analysis.

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After excluding those calls, 484 calls remained. Those calls were used to analyze the distribu­tion of calls for service by development type. Table 7.1 in Chapter 7 shows that distribution. The sample size used in the distribution analysis results in a 4% margin of error at the 95% con­fidence level. In other words, statistically, we can be 95% sure that the results of the sample analysis are within 4% of the results we would have obtained if we had analyzed all 139,696 2012 calls for service.

Finally, to calculate the demand factors for each type of development in terms of calls for service per unit per year, the percentage of calls attributed to each development type in the analysis of the random sample, was applied to the total number of 2012 calls for service to determine the number of calls per year associated with each development type. That num­ber was then divided by the number of existing units in each development type to arrive at the average calls for service per unit per year factors. Those factors are shown in Tables 2.1 and 7.1.

It should also be noted that of the 484 calls used in the final distribution analysis, 12.8% were attributed to public facilities, such as schools, parks and public buildings. The demand repre­sented by those calls was not used in the impact fee analysis, so the impact fees calculated for private development will not include the cost of facilities needed to support that share of total demand.

Table 2.1 presents some of the basic demand factors used in this study. Other demand fac­tors are presented in connection with fee calculations for individual facility types.

Table 2.1: Demand Factors Used in This Study

Development Dev Population PD Calls

Type Units 1 per Unit 2 per Unit 3

Residential, Single­Family (Detached) DU 3.45 1.25

Residential, Multi­Family (Attached) DU 2.35 1.41

Commercial/Retail KSF 3.85

Office KSF 0.89

Industrial KSF 0.33

Hotel/Motel Rooms 0.47

1 Units of development: DU = dwelling unit; Occ = Occupant; KSF = 1,000 gross

square feet of building area; Room = hotel/motel room or suite2 Estimated average population per unit based on data from 5­year estimates in

the U. S. Census Bureau 2007­2011 American Community Survey3 Estimated average Police Department calls for service per unit per year based

on analysis of a random sample of calls for the 2012 calendar year by Colgan

Consulting and the Rancho Cucamonga Planning Department (see explanation

in the text above)

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Tables 2.2 through 2.4 present data on existing and future development in the City of Rancho Cucamonga that will be used throughout this report. Table 2.2 shows data for existing de­velopment as of October 1, 2013.

Table 2.3 presents a forecast of planned future development in the City, based on data from the 2010 General Plan Environmental Impact Report (EIR).

Table 2.2: Existing Development ­ October 1, 2013

Development Dev Estimated Estimated Estimated

Types Units 1

Units 2

Population 3

PD Calls 4

Residential, Single­Family (Detached) DUs 35,610 122,855 44,449

Residential, Multi­Family (Attached) DUs 21,833 51,308 30,883

Commercial/Retail KSF 7,870 30,306

Office KSF 3,900 3,464

Industrial KSF 37,100 12,411

Hotel/Motel Rooms 944 446

Total 174,163 121,958

1 Units of development: DU = dwelling unit; KSF = 1,000 gross square feet of building area;

Room = hotel/motel room or suite2 Existing units based on City of Rancho Cucamonga Planning Dept. 2013 demo­

graphic overview; commercial/retail square footage has been adjusted to

reflect the inclusion of hotel/motel development as a separate category3 Estimated existing population = residential units X population per unit from

Table 2.1; estimate assumes zero vacancy rate4 Estimated police calls for service per year based on analysis of a random sample

of police calls for service for calendar year 2012; calls associated with public facilities

are not included in the total; see discussion in the text of this chapter

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Table 2.4 represents total development in the City at buildout of undeveloped land covered by the 2010 General Plan.

The forecasted buildout population in Table 2.4 is lower than the total projected in the Gen­eral Plan EIR, because this study used estimated current persons per dwelling unit factors rather than the higher population per unit factors from the EIR.

Table 2.3: Forecasted Future Development

Development Dev Added Added Added

Types Units 1 Units 2 Population 3 PD Calls 4

Residential, Single­Family (Detached) DUs 3,305 11,402 4,125

Residential, Multi­Family (Attached) DUs 1,109 2,606 1,569

Commercial/Retail KSF 11,341 43,674

Office KSF 5,238 4,652

Industrial KSF 27,259 9,119

Hotel/Motel Rooms 320 151

Total 14,008 57,596

1 Units of development: DU = dwelling unit; KSF = 1,000 gross square feet of building area;

Room = hotel/motel room or suite2 Forecasted new development units = the difference between buildout units

in Table 2.4 and existing units in Table 2.23 Added population = added residential units X population per unit from Table 2.14 Added police calls = added units X calls per unit from Table 2.1

Table 2.4: Forecasted Total Development at General Plan Buildout

Development Dev Buildout Buildout Buildout

Types Units 1

Units 2

Population 3

PD Calls 4

Residential, Single­Family (Detached) DU 38,915 134,257 48,574

Residential, Multi­Family (Attached) DU 22,942 53,914 32,452

Commercial/Retail KSF 19,210 73,980

Office KSF 9,138 8,116

Industrial KSF 64,359 21,530

Hotel/Motel Rooms 1,264 597

Total 188,171 179,554

1 Units of development: DU = dwelling unit; KSF = 1,000 gross square feet of building area;

Room = hotel/motel room or suite2 Buildout development units based on 2010 General Plan EIR

3 Buildout population = buildout residential units X population per unit from Table 2.1

4 Buildout police calls = buildout units X calls per unit from Table 2.1

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The potential development shown in Table 2.3 represents approximately an 8% increase in population, and a 50% increase in the number police calls for service per year compared with existing levels.

The larger increase in demand for police services reflects the relatively greater potential for commercial, office and industrial development in the City, compared with residential devel­opment. These figures give a general picture of the potential impacts of future development on public facilities in Rancho Cucamonga. The fees calculated in subsequent chapters are intended to pay for the capital facilities needed to serve that additional demand.

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This chapter calculates two broad types of development fees for parks: fees for park land acquisition, and fees for park improvements. Fees for park land acquisition are subdivided into two types: fees in lieu of park land dedication under the Quimby Act, which apply to res­idential subdivisions, and impact fees for park land acquisition which apply to residential de­velopment not involving a subdivision. The relationship among different types of park fees is more easily seen in outline form:

1. Fees for park land acquisition are either:

a. Quimby Act fees in lieu of park land dedication (subdivisions), or

b. Impact fees for park land acquisition (projects with no subdivision)

2. Impact fees for park improvements (all residential development)

Park land dedication requirements and fees in­lieu of dedication for subdivisions are imposed under the authority of the Quimby Act (Govt. Code Section 66477), which is part of the Sub­division Map Act. Park impact fees for both land acquisition and park improvements are governed by the Mitigation Fee Act (Govt. Code Sections 66000 et seq.) As detailed below, the in­lieu (“Quimby”) fees are subject to different requirements and limitations than park impact fees.

Fees In Lieu of Park Land Dedication. Under the Quimby Act, the City may, by ordinance, “require the dedication of land or impose a requirement for the payment of fees in lieu thereof, or a combination of both, for park or recreational purposes as a condition of ap­proval of a tentative map or parcel map….” This provision of the statute applies only to resi­dential subdivisions. An ordinance imposing dedication and fee requirements under the Quimby Act must contain “definite standards for determining the proportion of a subdivision to be dedicated and the amount of any fee to be paid in lieu thereof.”

Before imposing these requirements, the City must have adopted a general plan or specific plan containing policies and standards for parks and recreation facilities. The dedicated land and/or in­lieu fees “are to be used only for the purpose of developing new or rehabilitating existing neighborhood or community parks or recreational facilities to serve the subdivision (paying the fees).” The Quimby Act provides that only in­lieu fees, not land dedication, may be required for subdivisions of less than 50 parcels. Otherwise, the City may choose to re­quire either land dedication or payment of in­lieu fees.

Park Impact Fees. Because the provisions of the Quimby Act apply only to land acquisition, and only in residential subdivisions, this study calculates separate park impact fees for park land acquisition in non­subdivision projects and for park improvements.

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All park fees are calculated for a single service area encompassing the entire City.

A “demand variable” is some quantifiable attribute of development that can be used in fee

calculation formulas to represent the impact of development on a particular type of public

facility. The demand variable used to calculate park in­lieu fees and impact fees is added

population.

The value of a demand variable can differ by development type, so each type of development

has its own “demand factor.” Since population is a function of residential development, the

fees calculated in this chapter apply only to residential development. The demand factor for

each type of residential development is the average population per unit for that type.

Population is used as the demand variable for these fees because the need for parks in a

community is almost always based on population, and the Quimby Act specifies that park land dedication/in­lieu fee standards must be based on the relationship between park acre­

age and population.

Also, as discussed in the next section, the City’s adopted level­of­service standard for parks is

stated in terms of the relationship between acreage and population.

The level of service standard for parks, as adopted in the Community Services Element of the

2010 General Plan, is 5.0 acres per thousand residents. However, the General Plan recognizes

that the 5.0 acre standard is a goal, and is not necessarily applicable to development fees.

This study will use the relevant Quimby Act standard for fees in­lieu of park land dedication,

and the existing level of service for other park fees. Both are lower than the adopted 5.0

acre standard. Those levels are discussed below.

Table 3.1 on the next page lists the City’s existing parks and shows both total acres and im­

proved acres of park land. Total acreage of city­owned park land will be used to determine

the existing level of service for purposes of calculating impact fees for park land acquisition.

Improved park acreage will be used to determine the existing level of service for the calcula­

tion of impact fees for park improvements.

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Table 3.2 on the next page calculates the existing level of service in terms of acres per thou­sand residents for total City­owned park land and improved park land.

Table 3.1: Existing Parks

Park Total Improved

Name Acres 1 Acres 4

Community Parks

Central Park 103.0 30.0 Etiwanda Creek Park 33.5 12.0

Heritage Community Park 40.0 40.0 Red Hill Community Park 44.0 44.0

Epicenter Sports Complex 42.0 42.0 Subtotal Community Parks 262.5 168.0

Neighborhood ParksBear Gulch Park 5.0 5.0

Beryl Park East 10.0 10.0 Beryl Park West 10.0 10.0

Church Street Park 6.5 6.5 Coyote Canyon Park 5.0 5.0

Day Creek Park 11.0 11.0 Ellena Park 6.5 6.5

Garcia Park 5.5 5.5 Golden Oak Park 5.0 5.0

Hermosa Park 10.0 10.0 Kenyon Park 6.5 6.5 Legacy Park 3.7 3.7

Lions Park 1.5 1.5 Milliken Park 10.0 10.0

Mountain View Park 5.0 5.0 Old Town Park 5.0 5.0

Olive Grove Park 7.9 7.9 Ralph M. Lewis Park 9.5 9.5

Rancho Summit Park 6.6 6.6 Spruce Avenue Park 5.0 5.0

Victoria Arbors Park 9.1 9.1 Victoria Grove Park 6.5 6.5

Vintage Park 6.5 6.5 West Greenway Park 5.0 5.0

Windrows Park 8.0 8.0 Subtotal Neighborhood Parks 170.3 170.3

Total 432.80 338.30

1 Source: City of Rancho Cucamonga Community Services

Department

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Level­of­Service Standard for Park Land Acquisition In­Lieu Fees (In Subdivisions). The Quimby Act provides that park land dedication and in­lieu fee requirements may be based on a minimum ratio of 3.0 acres per thousand residents.

In this case, as shown in Table 3.2, the current ratio of City­owned park land to population is less than 3.0 acres per thousand, so the standard used to calculate park land acquisition in­lieu fees in this study is 3.0 acres per 1,000 residents.

Level­of­Service Standard for Park Land Acquisition Impact Fees (No Subdivision). The standard used to calculate park land acquisition impact fees in this study is the existing ratio of total park land to population in acres per 1,000 residents, as shown in Table 3.2.

Level­of­Service Standard for Park Improvement Impact Fees (All Development). The standard used to calculate park improvement impact fees in this study is the existing ratio of improved park land to population in acres per 1,000 residents, as shown in Table 3.2.

This chapter calculates impact fees using the standard­based method discussed in Chapter 1. Standard­based fees are calculated using a specified relationship or standard that determines the number of service units to be provided for each unit of development.

Both in­lieu and impact fees are calculated using ratios of park acreage to population, as dis­cussed in the previous section on level­of­service standards.

Because the method used to calculate impact fees in this section is standard­based rather than plan­based, those calculations are not dependent on a list of specific park projects. However, the Community Services element of the General Plan does identify sites for some future parks.

Both in­lieu fees and impact fees must expended for parks that adequately serve the devel­opment projects from which the fees are collected. Within the constraints of land availability for future parks, the City should consider that requirement when expending revenue from in­lieu and impact fees.

Table 3.2: Existing Level of Service ­ Park Land/Improved Park Land

Existing Existing Acres per Acres per

Component Acres 1

Population 2

Capita 3

1,000 4

Total Park Land 432.80 174,163 0.00249 2.49Improved Park Land 338.30 174,163 0.00194 1.94

1 See Table 3.1

2 See Table 2.2

3 Acres per capita = existing acres / existing population

4 Acres per 1,000 residents = acres per capita X 1,000

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The impact fees calculated in this chapter are based on the cost of maintaining the existing level of service for parks as additional development occurs.

Revenue from in­lieu fees and impact fees calculated in this chapter may be used for, but shall not be limited to the following: land acquisition and site improvements (landscape, hardscape, parking areas, perimeter street), picnic amenities, minor sports amenities, major sports amenities, playground equipment, amphitheaters, shelters, equestrian amenities, ca­nine amenities, and building/structural exterior and interior improvements necessary to sup­port the aforementioned items.

Table 3.3 shows the per­capita cost for each type of fee calculated in this chapter. Because different standards are used for land acquisition in­lieu fees and land acquisition impact fees, per capita cost is calculated separately for those cost components. Cost­per­acre for acquisi­tion of residential land is based on estimates used in updating the Housing Element of the General Plan in 2010. Estimated cost for park improvements is based on the most recent data available for park improvements in the City.

In the next section, the per­capita costs from Table 3.3 are used to calculate in­lieu fees and impact fees per unit of development.

Park Land Acquisition In­Lieu Fees (In Subdivisions). Table 3.4 shows the calculation of park land acquisition in­lieu fees per unit of development by development type. Those fees are calculated using per­capita costs from Table 3.3 and average population per dwelling unit from Table 2.1.

Table 3.3: Cost per Capita ­ Park In­Lieu and Impact Fees

Cost Acres per Acres per Cost per Cost per

Component 1,000 1

Capita 2

Acre 3

Capita 4

Park Land Acquisition (In Subdivisions) 3.00 0.00300 505,000$ 1,515.00$

Park Land Acquisition (No Subdivision) 2.49 0.00249 505,000$ 1,254.94$

Park Improvements (All Development) 1.94 0.00194 380,000$ 738.12$

1 See Table 3.2; in­lieu fees for park land acquisition under the Quimby Act may be based

on a minimum of 3.0 acres per 1,000 residents2 Acres per capita = acres per 1,000 / 1,000

3 Cost per acre for land based on estimates developed for the 2010 General Plan Housing

Element; cost per acre for park improvements represents average cost for community

and neighborhood parks4 Cost per Capita = acres per per capita X cost per acre

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Note on Fees for Assisted Living Facilities. The impact fees shown in the tables below in­clude fees for assisted living facilities. Assisted living is not one of the basic development types used in this report. However, assisted living facilities are allowed in some residential zoning districts with a conditional use permit, and residents of those facilities do make use of City parks. Impact fees for this type of development are based on a population­per­dwelling­unit factor specific to such facilities. That factor was estimated using data from a telephone survey of existing assisted living facilities in the City conducted by Colgan Consulting. Impact fees for other specialized development types could be calculated in the same way if the need arises.

Park Land Acquisition Impact Fees (No Subdivision). Table 3.5 shows the calculation of park land acquisition impact fees per unit of development by development type. Those fees are calculated using per­capita costs from Table 3.3 and average population per dwelling unit.

Park Land Improvement Impact Fees (All Development). Table 3.6 shows the calculation of park improvement impact fees per unit of development by development type. Those fees are calculated using per­capita costs from Table 3.3 and average population per dwelling unit.

Table 3.4: Park Land Acquisition In­Lieu Fee per Unit (In Subdivisions)

Development Population Cost per In­Lieu Fee

Type Units 1 per Unit 2 Capita 3 per Unit 4

Residential, Single­Family (Detached) DU 3.45 1,515.00$ 5,226.75$

Residential, Multi­Family (Attached) DU 2.35 1,515.00$ 3,560.25$

1 Units of development; DU = dwelling unit2 See Table 2.13 Cost per capita; see Table 3.34 In­lieu fee per unit = population per unit X cost per capita

Table 3.5: Park Land Acquisition Impact Fee per Unit (No Subdivision)

Development Population Cost per Impact Fee

Type Units 1 per Unit 2 Capita 3 per Unit 4

Residential, Single­Family (Detached) DU 3.45 1,254.94$ 4,329.54$

Residential, Multi­Family (Attached) DU 2.35 1,254.94$ 2,949.11$

Assisted Living Facility DU 1.10 1,254.94$ 1,380.43$

1 Units of development; DU = dwelling unit2 See Table 2.1; factor for Assisted Living Facilities based on a survey of existing facilities3 Cost per capita; see Table 3.34 Impact fee per unit = population per unit X cost per capita

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Estimating potential revenue from the park land acquisition and improvement fees is compli­cated by the fact that there is no way of accurately projecting how much future residential development will involve subdivisions. Since the fees differ for subdivisions and non­subdivision projects, the ultimate mix will affect fee revenue.

The revenue to buildout projected in Table 3.7 assumes that 60% of future residential devel­opment will occur in subdivisions, and that future development will occur as anticipated in the City’s current General Plan. No revenue is projected for Assisted Living Facilities because that type of development would displace other development in the Residential, Multi­Family (Attached) category.

The fees calculated in this chapter are based on estimated current land and improvement costs. This study assumes that the projects covered by park in­lieu fees and park impact fees will be funded on a pay­as­you­go basis, so no financing costs are included. To maintain pari­ty between impact fees and land and improvement costs, the impact fees must be adjusted periodically to reflect changes in price levels.

Table 3.6: Park Improvement Impact Fee per Unit (All Residential Development)

Development Population Cost per Impact Fee

Type Units 1 per Unit 2 Capita 3 per Unit 4

Residential, Single­Family (Detached) DU 3.45 738.12$ 2,546.53$

Residential, Multi­Family (Attached) DU 2.35 738.12$ 1,734.59$

Assisted Living Facility DU 1.10 738.12$ 811.94$

1 Units of development; DU = dwelling unit2 See Table 2.1; factor for Assisted Living Facilities based on a survey of existing facilities3 Cost per capita; see Table 3.34 Impact fee per unit = population per unit X cost per capita

Table 3.7: Projected Revenue ­ Park In­Lieu Fees and Park Impact Fees

Development Dev Avg Fee Future Projected

Type Units 1 per Unit 2 Units 3 Revenue 4

Residential, Single­Family (Detached) DU 7,414.40$ 3,305 24,504,580$

Residential, Multi­Family (Attached) DU 5,050.39$ 1,109 5,600,878$ Total 30,105,458$

1 Units of development; DU = dwelling unit2 Average fee per unit of development assumes that 60% of future residential

development will occur in subdivisions 3 See Table 2.34 Projected revenue = average fee per unit X future units

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City of Rancho Cucamonga – Development Impact Fee Study Parks

April 22, 2014 Colgan Consulting Corporation Page 3-8

A common practice is to adjust impact fees annually. Improvement costs can be adjusted using an index such as the Engineering News Record Building Cost Index. Adjustments to land costs should be based on local cost data. See the Implementation Chapter for more on in­dexing of fees.

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City of Rancho Cucamonga – Development Impact Fee Study Community and Recreation Centers

April 22, 2014 Colgan Consulting Corporation Page 4-1

This chapter calculates impact fees for community and recreation centers needed to serve

future development in the City.

The City of Rancho Cucamonga has a number of existing community and recreation centers,

as well as the Victoria Gardens Cultural Center, which is included in this analysis. Libraries,

including the Paul A. Biane Library which is a part of the Victoria Gardens Cultural Center, are

addressed separately in Chapter 5 of this report.

The community and recreation center impact fees calculated in this chapter are based on the

relationship between the City’s existing population and the replacement cost of existing

community center, recreation center, and cultural center facilities.

Rancho Cucamonga’s community and recreation centers serve the entire City, so the com­

munity and recreation center impact fees are calculated for a single service area encompass­

ing the entire City.

A “demand variable” is some quantifiable attribute of development that can be used in fee

calculation formulas to represent the impact of development on a particular type of public

facility. The demand variable used to calculate impact fees for community and recreation

centers is added population.

The value of a demand variable can differ by development type, so each type of development

has its own “demand factor.” Since population is a function of residential development, the

fees calculated in this chapter apply only to residential development, and the demand factor

for each type of residential development is the average population per unit for that type.

Population is used as the demand variable for these fees because the need for community

and recreation centers is normally defined in terms of population. Although these facilities

may be used by non­residents or businesses located in the City, such use is considered inci­

dental. Since planning for these facilities is based on the needs of the resident population,

added population is used in this chapter to measure the impact of development on the need

for community and recreation center facilities.

The City has not adopted a formal level of service standard for community and recreation

centers. Since some facilities such as the Family Sports Center and the Lewis Family Play­

house at the Victoria Gardens Cultural Center are one­of­a­kind, a ratio of facility square foot­

age to population would not reflect differences in cost for individual facilities. Consequently,

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City of Rancho Cucamonga – Development Impact Fee Study Community and Recreation Centers

April 22, 2014 Colgan Consulting Corporation Page 4-2

the level of service standard used to calculate impact fees in this chapter is the existing ratio of facility replacement cost to population.

Table 4.1 lists the City’s existing community and recreation centers and their estimated re­placement cost.

This chapter calculates impact fees using the standard­based method discussed in Chapter 1. Standard­based fees are calculated using a specified relationship or standard that determines the number of service units to be provided for each unit of development.

In this case, the standard is the average facility replacement cost per capita, which is calcu­lated in Table 4.2, below. That cost per capita will be applied to future population to com­pute impact fees per unit. This approach is used so that the community and recreation cen­ter impact fees paid by new development are based on the same level of service currently provided to the existing residents of the City.

Because the method used to calculate impact fees in this section is standard­based rather than plan­based, those calculations are not dependent on a list of specific future improve­ments. The impact fees calculated in this chapter are based on the cost of maintaining the existing level of service for community and recreation center facilities as additional develop­ment occurs.

Revenue from those impact fees may be used for but shall not be limited to the following: land acquisition and site improvements (landscape, hardscape, parking areas, perimeter street), building construction/expansion, interior building improvements, furniture, fixtures and equipment (including but not limited to carpet, desk, blinds, tables, chairs, shelving, cab­inets, communication systems, electronic equipment) exercise, sports and play equipment, special needs equipment, technical centers, aquatic facilities, and transportation facilities).

Table 4.1: Existing Community and Recreation Centers Replacement Cost

Facility Site Land Site Building Bldg Cost Building Facility

Name Acres Value/Ac 1

Value 2

Sq. Feet 3

per Sq Ft 4

Repl Cost 5

Repl Cost 6

Lion's Center West 0.24 505,000$ 121,200$ 11,400 371.00$ 4,229,400$ 4,350,600$

Lion's Center East 0.37 505,000$ 186,850$ 11,384 371.00$ 4,223,464$ 4,410,314$

RC Family Sports Center 1.47 505,000$ 742,350$ 32,000 371.00$ 11,872,000$ 12,614,350$

Lewis/Brulte Community/Sr. Ctr. Located in Central Park 57,000 371.00$ 21,147,000$ 21,147,000$

Heritage Park Equestrian Center 10.00 505,000$ 5,050,000$ 3,045 371.00$ 1,129,695$ 6,179,695$

Victoria Gardens Cultural Center 9.50 505,000$ 4,797,500$ 67,584 506.00$ 34,197,504$ 38,995,004$

Total 10,897,900$ 182,413 76,799,063$ 87,696,963$

1 Estimated land value per acre based on 2010 residential land cost estimates for the Housing Element of the General Plan

2 Existing site value = site acres X land value per acre

3 Building square footage provided by the City of Rancho Cucamonga Community Services Department

4 Building replacement cost per square foot estimated by the City of Rancho Cucamonga Community Services Department 5 Building replacement cost = building square feet X building cost per square foot6 Facility replacement cost = site value + building replacement cost

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City of Rancho Cucamonga – Development Impact Fee Study Community and Recreation Centers

April 22, 2014 Colgan Consulting Corporation Page 4-3

Table 4.2 calculates the replacement cost per capita for community and recreation center facilities. The per­capita cost is calculated using the replacement costs from Table 4.1 and the existing population of the City from Table 2.2.

In the next section, the replacement cost per­capita from Table 4.2 is used to calculate com­munity and recreation center impact fees per unit of development by development type.

Table 4.3 shows the calculation of community and recreation center impact fees per unit of development by development type. Those fees are calculated using the facility replacement cost per capita from Table 4.2 and average population per dwelling unit from Table 2.1.

Note on Fees for Assisted Living Facilities. The impact fees shown in Table 4.3 include fees for assisted living facilities. Assisted living is not one of the basic development types used in this report. However, assisted living facilities are allowed in some residential zoning districts with a conditional use permit, and residents of those facilities do make use of community and recreation facilities. Impact fees for this type of development are based on a population­per­dwelling­unit factor specific to such facilities. That factor was estimated using data from a telephone survey of existing assisted living facilities in the City conducted by Colgan Consult­ing. Impact fees for other specialized development types could be calculated in the same way if the need arises.

Table 4.2: Community/Recreation Centers ­ Replacement Cost per Capita

Facility Current Existing Repl Cost

Type Repl Cost 1 Population 2 per Capita 3

Community/Rec Centers $87,696,963 174,163 $503.53

1 See Table 4.12 See Table 2.23 Replacement cost per capita = existing replacement cost / existing population

Table 4.3: Community and Recreation Centers ­ Impact Fees per Unit

Development Population Cost per Impact Fee

Type Units 1 per Unit 2 Capita 3 per Unit 4

Residential, Single­Family (Detached) DU 3.45 $503.53 1,737.19$

Residential, Multi­Family (Attached) DU 2.35 $503.53 1,183.30$

Assisted Living Facility DU 1.10 $503.53 553.89$

1 Units of development; DU = dwelling unit2 See Table 2.13 Cost per capita; see Table 4.24 Impact fee per unit = population per unit X cost per capita

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City of Rancho Cucamonga – Development Impact Fee Study Community and Recreation Centers

April 22, 2014 Colgan Consulting Corporation Page 4-4

Potential revenue from the community and recreation center impact fees can be estimated by applying the fees per unit from Table 4.3 to forecasted future units from Table 2.3. Be­cause population is used as the demand variable in calculating these impact fees, and popula­tion is a function of residential development, the fees apply only to residential development.

Table 4.4 shows the projected revenue to buildout from the community and recreation cen­ter impact fees calculated in this chapter. This projection assumes that future development occurs as anticipated in the City’s current General Plan. No revenue is projected for Assisted Living Facilities because that type of development would displace other development in the Residential, Multi­Family (Attached) category.

The fees calculated in this chapter are based on estimated current replacement costs for ex­isting community and recreation center facilities. This study assumes that the projects cov­ered by the community and recreation center impact fees will be funded on a pay­as­you­go basis, so no financing costs are included. To maintain parity between impact fees and asset replacement costs, the impact fees should be adjusted periodically to reflect changes in price levels.

A common practice is to adjust impact fees annually. Improvement costs can be adjusted using an index such as the Engineering News Record Building Cost Index. Adjustments to land costs should be based on local cost data. See the Implementation Chapter for more on in­dexing of fees.

Table 4.4: Projected Revenue ­ Community/ Recreation Center Impact Fees

Development Dev Impact Fee Future Projected

Type Units 1 per Unit 2 Units 3 Revenue 4

Residential, Single­Family (Detached) DU 1,737.19$ 3,305 5,741,419$

Residential, Multi­Family (Attached) DU 1,183.30$ 1,109 1,312,285$

Total 7,053,703$

1 Units of development; DU = dwelling unit2 Impact fee per unit of development; see Table 4.3 3 Future units; see Table 2.34 Projected revenue = impact fee per unit X future units

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City of Rancho Cucamonga – Development Impact Fee Study Libraries

April 22, 2014 Colgan Consulting Corporation Page 5-1

This chapter calculates impact fees for library facilities and materials needed to serve future

development in the City.

The City of Rancho Cucamonga has two existing libraries, the Archibald Library and the Paul

A. Biane Library which is part of the Victoria Gardens Cultural Center. The Paul A. Biane Li­

brary includes space for future expansion, and the City will assess the need for a third library

in the future.

The library impact fees calculated in this chapter are based on the relationship between the

City’s existing population and the replacement cost of existing library facilities and materials.

Rancho Cucamonga’s public libraries comprise a system that serves the entire City, so the

library impact fees are calculated for a single service area encompassing the entire City.

A “demand variable” is some quantifiable attribute of development that can be used in fee

calculation formulas to represent the impact of development on a particular type of public

facility. The demand variable used to calculate impact fees for libraries is added population.

The value of a demand variable can differ by development type, so each type of development

has its own “demand factor.” Since population is a function of residential development, the

fees calculated in this chapter apply only to residential development, and the demand factor

for each type of residential development is the average population per unit for that type.

Population is used as the demand variable for these fees because the need for libraries is

normally defined in terms of population. Although these facilities may be used by non­

residents or businesses located in the City, such use is considered incidental. Since planning

for these facilities is based on the needs of the resident population, added population is used

in this chapter to measure the impact of development on the need for libraries

It common practice to calculate library impact fees using a square feet­per­capita standard

for library facilities and an items­per­capita standard for library materials. That approach is

not used here because the City’s Paul A. Biane Library includes a large area of unfinished ex­

pansion space. That shell space is an existing library asset, but if it were included in a square

footage standard, it would overstate the City’s currently usable library space. And if it were

excluded, it would understate the City’s existing investment in library facilities.

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City of Rancho Cucamonga – Development Impact Fee Study Libraries

April 22, 2014 Colgan Consulting Corporation Page 5-2

To resolve that issue, this study uses replacement cost instead of square footage to deter­mine the existing level of service used to calculate impact fees for library facilities. The same approach is used for library materials.

Table 5.1 lists the City’s existing libraries and their estimated replacement cost, including the unfinished space in the Paul A. Biane Library.

Table 5.2 shows the number of items in the Rancho Cucamonga Public Library collection, the average replacement cost per item, and the total replacement cost for the entire collection.

This chapter calculates impact fees using the standard­based method discussed in Chapter 1. Standard­based fees are calculated using a specified relationship or standard that determines the number of service units to be provided for each unit of development.

In this case, the standard is the average replacement cost per capita from Table 5.3. That cost per capita will be applied to future population to compute impact fees per unit. This approach is used so that the library impact fees paid by new development are based on the same level of service currently provided to the existing residents of the City.

Table 5.1: Existing Library Facilities

Library Site Site Building Bldg Cost Building Facility

Name Acres Value 1 Sq. Feet 2 per Sq Ft 3 Repl Cost 4 Repl Cost 5

Paul A. Biane Library 1.35 387,750$ 26,813 430.37$ 11,539,462$ 11,927,212$ Paul A. Biane Library (shell space) 0.00 0$ 15,500 200.00$ 3,100,000$ 3,100,000$ Archibald Library 1.67 843,350$ 22,500 350.00$ 7,875,000$ 8,718,350$

Total 64,813 23,745,562$

1 Site value for the Paul A. Biane Library site from the original development program; site value for the Archibald Library based on $505,000 per acre estimate from the 2010 General Plan Housing Element2 Building square footage provided by the City of Rancho Cucamonga Library Services Department3 Building cost per square foot for Paul A. Biane Library is actual cost; cost per square foot for other

facilities estimated by the City of Rancho Cucamonga Library Services Department4 Building replacement cost = building square feet X building cost per square foot

5 Facility replacement cost = site value + building replacement cost

Table 5.2: Existing Library Materials

Number Avg Repl Cost Repl Cost of

of Items 1 per Item 2 Existing Items 3

298,985 $18.00 $5,381,730.00

1 From Rancho Cucamonga Public Library 2012­2013 Collection Inventory2 Estimated by the Rancho Cucamonga Library Services Department3 Replacement cost of existing library materials = number of items X

average cost per item

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City of Rancho Cucamonga – Development Impact Fee Study Libraries

April 22, 2014 Colgan Consulting Corporation Page 5-3

Because the method used to calculate impact fees in this section is standard­based rather than plan­based, those calculations are not dependent on a list of specific future improve­ments. The most likely use of the library impact fees collected by the City will be to build out the unfinished expansion area that exists in the Paul A. Biane Library.

The impact fees calculated in this chapter are based on the cost of maintaining the existing level of service for libraries as additional development occurs.

Revenue from those impact fees may be used for but shall not be limited to the following: land acquisition and site improvements (landscape, hardscape, parking areas, perimeter street), building construction/expansion, interior building improvements, furniture fixtures and equipment (including but not limited to carpet, desks, blinds, tables, chairs, shelving, cabinets, communication systems, electronic equipment), library materials, (including but not limited to books, magazines, audio and video materials) theater facilities, special needs equipment/facilities, technical centers, and special activities facilities.

Table 5.3 shows the replacement cost per capita for library facilities and library materials. The per­capita costs are calculated using the replacement costs from Tables 5.1 and 5.2, and the existing population of the City from Table 2.2.

In the next section, the per­capita costs from Table 5.3 are used to calculate library impact fees per unit of development by development type.

Table 5.4 on the next page shows the calculation of library impact fees per unit of develop­ment by development type. Those fees are calculated using the per­capita costs for library facilities and materials from Table 5.3 and average population per dwelling unit from Table 2.1.

Table 5.3: Library Facilities and Materials ­ Replacement Cost per Capita

Current Existing Repl Cost Percent by

Component Repl Cost 1 Population 2 per Capita 3 Component 4

Library Facilities $23,745,562 174,163 136.34$ 81.52%

Library Materials $5,381,730 174,163 30.90$ 18.48%

$29,127,292 174,163 167.24$ 100.00%

1 See Table 3.12 See Table 2.23 Replacement cost per capita = current replacement cost / existing population4 Percentage of total replacement cost by component; this percentage should be

used to split fee revenue into separate accounts for tracking and expenditure

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City of Rancho Cucamonga – Development Impact Fee Study Libraries

April 22, 2014 Colgan Consulting Corporation Page 5-4

Note on Fees for Assisted Living Facilities. The impact fees shown in Table 5.4 include fees for assisted living facilities. Assisted living is not one of the basic development types used in this report. However, assisted living facilities are allowed in some residential zoning districts with a conditional use permit, and residents of those facilities do make use of community and recreation facilities. Impact fees for this type of development are based on a population­per­dwelling­unit factor specific to such facilities. That factor was estimated using data from a telephone survey of existing assisted living facilities in the City conducted by Colgan Consult­ing. Impact fees for other specialized development types could be calculated in the same way if the need arises.

Potential revenue from the library impact fees can be estimated by applying the fees per unit from Table 5.4 to forecasted future units from Table 2.3. Because population is used as the demand variable in calculating these impact fees, and population is a function of residential development, the fees apply only to residential development.

Table 5.5 on the next page shows the projected revenue to buildout from the library impact fees calculated in this chapter. This projection assumes that future development occurs as anticipated in the City’s current General Plan. No revenue is projected for Assisted Living Fa­cilities because that type of development would displace other development in the Residen­tial, Multi­Family (Attached) category.

Table 5.4: Library Impact Fees per Unit of Development

Development Dev Population Cost per Impact Fee

Type Units 1 per Unit 2 Capita 3 per Unit 4

Residential, Single­Family (Detached) DU 3.45 167.24$ 576.98$ Residential, Multi­Family (Attached) DU 2.35 167.24$ 393.02$ Assisted Living Facilities DU 1.10 167.24$ 183.97$

1 Units of development; DU = dwelling unit2 See Table 2.13 Cost per capita; see Table 5.34 Impact fee per unit = population per unit X cost per capita

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City of Rancho Cucamonga – Development Impact Fee Study Libraries

April 22, 2014 Colgan Consulting Corporation Page 5-5

The fees calculated in this chapter are based on estimated current replacement costs for ex­isting library facilities and materials. This study assumes that the projects covered by library impact fees will be funded on a pay­as­you­go basis, so no financing costs are included. To maintain parity between impact fees and asset replacement costs, the impact fees should be adjusted periodically to reflect changes in price levels.

A common practice is to adjust impact fees annually. Facility construction costs can be ad­justed using an index such as the Engineering News Record Building Cost Index. Adjustments to land costs should be based on local cost data. See the Implementation Chapter for more on indexing of fees.

Table 5.5: Projected Revenue ­ Library Impact Fees

Development Dev Impact Fee Future Projected

Type Units 1 per Unit 2 Units 3 Revenue 4

Residential, Single­Family (Detached) DU 576.98$ 3,305 1,906,930$ Residential, Multi­Family (Attached) DU 393.02$ 1,109 435,857$

Total 2,342,787$

1 Units of development; DU = dwelling unit; Occ = occupant2 Impact fee per unit of development; see Table 5.4 3 Future units; see Table 2.34 Projected revenue = impact fee per unit X future units

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City of Rancho Cucamonga – Development Impact Fee Study Animal Center

April 22, 2014 Colgan Consulting Corporation Page 6-1

This chapter calculates impact fees for additional animal center facilities needed to serve fu­ture development in the City. The City’s existing Animal Center is at capacity and additional space will be needed for the growing demand imposed by future development.

The Animal Center impact fees calculated in this chapter are based on the relationship be­tween the City’s existing population and the replacement cost of the existing Animal Center.

Rancho Cucamonga’s Animal Center serves the entire City, so the Animal Center impact fees are calculated for a single service area encompassing the entire City.

The need for Animal Center facilities cannot be related directly to development. However, it is reasonable to assume that the demand for Animal Center facilities depends on the number of pets owned by City residents, which is clearly related to population. Consequently, added population will be used to measure the impact of development on the need for additional Animal Center facilities.

It should be noted that because population is a function of residential development, the fees calculated in this chapter apply only to residential development

The City has not adopted a formal level of service standard for animal center facilities. Con­sequently, the level of service standard used to calculate impact fees in this chapter is the existing ratio of facility replacement cost to population.

Table 6.1 shows the estimated replacement cost for the City’s existing Animal Center.

Table 6.1: Existing Animal Shelter Replacement Cost

Site Land Site Building Bldg Cost Building Facility

Acres Value/Ac 1 Value 2 Sq. Feet 2 per Sq Ft 3 Repl Cost 4 Repl Cost 5

1.60 505,000$ 808,000$ 12,148 450.00$ 5,466,600$ 6,274,600$

1 Land value per acre based on estimates in the 2010 General Plan Housing Element2 Existing site value = site acres X land value per acre3 Building square footage provided by the City of Rancho Cucamonga Engineering Services Dept.4 Building cost per sq. ft. based on a similar facility built in the City of Moreno Valley in 20005 Building replacement cost = building square feet X building cost per square foot6 Facility replacement cost = site value + building replacement cost

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City of Rancho Cucamonga – Development Impact Fee Study Animal Center

April 22, 2014 Colgan Consulting Corporation Page 6-2

This chapter calculates impact fees using the standard­based method discussed in Chapter 1. Standard­based fees are calculated using a specified relationship or standard that determines the number of service units to be provided for each unit of development.

In this case, the standard is the average replacement cost per capita for the existing Animal Center, which is calculated in Table 6.2, below. That cost per capita will be applied to future population to compute impact fees per unit. This approach is used so that the Animal Center impact fees paid by new development are based on the same level of service currently pro­vided to the existing residents of the City.

Because the method used to calculate impact fees in this section is standard­based rather than plan­based, those calculations are not dependent on the details of specific future im­provements. The Animal Services department is in the early stages of planning for its future facility needs. It has not yet been determined whether additional Animal Center space will be provided by expanding the existing facility or by constructing a second facility in a different location.

The impact fees calculated in this chapter are based on the cost of maintaining the existing level of service for animal center facilities as additional development occurs.

Revenue from those impact fees may be used for but shall not be limited to the following: land acquisition and site improvements (landscape, hardscape, parking areas, perimeter street), building construction/expansion, interior building improvements, furniture fixtures and equipment (including but not limited to carpet, desks, blinds, tables, chairs, shelving, cabinets, counters, communication systems, electronic equipment), special needs equip­ment/facilities, veterinarian equipment/facilities, transportation facilities, kennel facilities, outdoor dog runs and play areas)

Table 6.2 shows the replacement cost per the existing Animal Center. The per­capita cost is calculated using the replacement cost from Table 6.1 and the existing population of the City from Table 2.2.

Table 6.2: Animal Shelter ­ Replacement Cost per Capita

Current Existing Repl Cost

Repl Cost 1 Population 2 per Capita 3

$6,274,600 174,163 $36.03

1 See Table 6.12 See Table 2.23 Replacement cost per capita = existing replacement cost /

existing population

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City of Rancho Cucamonga – Development Impact Fee Study Animal Center

April 22, 2014 Colgan Consulting Corporation Page 6-3

In the next section, the per­capita cost from Table 6.2 is used to calculate Animal Center im­pact fees per unit of development by development type.

Table 6.3 calculates Animal Center impact fees per unit of development by development type. Those fees are calculated using the per­capita cost of existing facilities from Table 6.2 and average population per dwelling unit from Table 2.1.

Potential revenue from the Animal Center impact fees can be estimated by applying the fees per unit from Table 6.3 to forecasted future units from Table 2.3. Because population is used as the demand variable in calculating these impact fees, and population is a function of resi­dential development, the fees apply only to residential development.

Table 6.4 shows the projected revenue to buildout from the Animal Center impact fees calcu­lated in this chapter. This projection assumes that future development occurs as anticipated in the City’s current General Plan.

Table 6.3: Animal Shelter ­ Impact Fees per Unit

Development Population Cost per Impact Fee

Type Units 1 per Unit 2 Capita 3 per Unit 4

Residential, Single­Family (Detached) DU 3.45 $36.03 124.29$

Residential, Multi­Family (Attached) DU 2.35 36.03$ 84.66$

1 Units of development; DU = dwelling unit2 See Table 2.13 Cost per capita; see Table 6.24 Impact fee per unit = population per unit X cost per capita

Table 6.4: Projected Revenue ­ Animal Shelter Impact Fees

Development Dev Impact Fee Future Projected

Type Units 1 per Unit 2 Units 3 Revenue 4

Residential, Single­Family (Detached) DU 124.29$ 3,305 410,791$ Residential, Multi­Family (Attached) DU 84.66$ 1,109 93,892$

Total 504,683$

1 Units of development; DU = dwelling unit2 Impact fee per unit of development; see Table 6.3 3 Future units; see Table 2.34 Projected revenue = impact fee per unit X future units

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City of Rancho Cucamonga – Development Impact Fee Study Animal Center

April 22, 2014 Colgan Consulting Corporation Page 6-4

The fees calculated in this chapter are based on estimated current replacement costs for the existing Animal Center. This study assumes that the projects covered by the animal shelter impact fees will be funded on a pay­as­you­go basis, so no financing costs are included. To maintain parity between impact fees and asset replacement costs, the impact fees should be adjusted periodically to reflect changes in price levels.

A common practice is to adjust impact fees annually. Facility construction costs can be ad­justed using an index such as the Engineering News Record Building Cost Index. Adjustments to land costs should be based on local cost data. See the Implementation Chapter for more on indexing of fees.

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City of Rancho Cucamonga – Development Impact Fee Study Police

April 22, 2014 Colgan Consulting Corporation Page 7-1

This chapter calculates impact fees for police facilities needed to serve future development in the City. The City’s existing police facility is at capacity and additional space will be needed to serve the growing demand imposed by future development.

The impact fees calculated in this chapter for police facilities are based on the existing rela­tionship between the Police Department calls for service per year generated by existing de­velopment and the replacement cost of the department’s existing facilities.

Rancho Cucamonga’s Police Department serves the entire City, so the police impact fees are calculated for a single service area encompassing the entire City.

A “demand variable” is some quantifiable attribute of development that can be used in fee calculation formulas to represent the impact of development on a particular type of public facility. The demand variable used to calculate impact fees for police facilities and equipment is added calls for service per year.

The value of a demand variable can differ by development type, so each type of development has its own “demand factor.” The demand factor for each type of development in this chap­ter is the average number of calls for service per unit per year for that type.

The best available measure of demand for police services in Rancho Cucamonga is the num­ber of calls for service logged by the Police Department each year. In 2012, the department logged 139,696 calls. As part of this study, Colgan Consulting and the Rancho Cucamonga Planning Department analyzed a random sample of 699 (1 of each 200) 2012 calls to establish the distribution of those calls by development type. Given the sheer volume of calls, it was not possible to analyze all of the calls received, but the sample used in the analysis provided a 4% margin of error at the 95% confidence level. (See additional discussion in Chapter 2.)

In the analysis, the Planning Department classified each sampled call location by develop­ment type. Then Colgan Consulting determined the percentage of sampled calls associated with each development type and applied those percentages to the total volume of calls for 2012 to estimate the number of annual calls generated by each type of development. Finally, the number of calls was divided by the number of existing units for each type of develop­ment to arrive at a factor representing the average number of calls per unit per year.

As discussed in Chapter 2, some sampled calls were excluded from the distribution analysis. The excluded calls were traffic stops, information calls, and any call for which a location could not be determined or a specific land use type could not be identified.

The calls­per­unit­per­year factors resulting from the distribution analysis are shown in Table 7.1. Table 7.1 also shows that 12.7% of the analyzed calls were associated with public facilities

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or other public uses. This study does not calculate impact fees for public facilities because those fees would not provide revenue to the City. However, it is important to point out that the method used to calculate impact fees in this chapter excludes costs associated with po­lice services provided to public facilities.

The level of service standards normally applied to police departments, such as sworn officers per thousand residents, are not useful in calculating impact fees. The level of service stand­ard used in this analysis is the existing relationship between service demand, as measured by calls for service per year, and the replacement value of facilities and equipment used by the Police Department to provide that service. Table 7.2 shows the estimated replacement cost for the City’s existing Public Safety Building. The cost estimate uses the actual cost of a re­cent 10,000 square foot third floor addition ($821.00 per sq. ft.) and the estimated replace­ment cost for the original 25,000 square foot building ($450.00 per sq. ft.).

Table 7.1: Distribution of Police Calls for Service by Development Type

Development % of 2012 2012 Calls Existing Calls per Unit

Type Calls 1 for Service 2 Units 3 per Year 4

Residential, Single­Family (Detached) 31.8% 44,449 35,610 1.25Residential, Multi­Family (Attached) 22.1% 30,883 21,833 1.41

Commercial/Retail 21.7% 30,306 7,870 3.85Office 2.5% 3,464 3,900 0.89Industrial 8.9% 12,411 37,100 0.33

Hotel/Motel 0.3% 446 944 0.47

Subtotal Private Development 87.3% 121,958 N/A N/A

Public Facilities 12.7% 17,738 N/A N/A

Total 100.0% 139,696

1 Distribution of 2012 calls for service as a percentage of total calls, based on analysis of

a random sample of those calls; see discussion in Chapter 22 2012 calls for service by development type = total 2012 calls for service X % of 2012 calls3 See Table 2.24 Calls per unit per year = 2012 calls for service / existing units

Table 7.2: Existing Police Facilities

Facility Building Est Repl Cost Building

Name Sq. Feet 1 per Sq Ft 2 Repl Cost 3

Existing Public Safety Building 35,000 $550.00 $19,250,000

1 Area of existing public safety building in gross square feet2 Estimated average replacement cost per square foot3 Estimated building replacement cost = building square feet X cost per square foot

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This chapter calculates impact fees using the standard­based method discussed in Chapter 1. Standard­based fees are calculated using a specified relationship or standard that determines the number of service units to be provided for each unit of development.

In this case, the standard is the average replacement cost per call for service per year, which is calculated in Table 7.4, on the next page. That cost per call, and the calls­per­unit­per­year factors from Table 7.1 are used to calculate impact fees for each type of development.

This approach is used so that the police impact fees paid by new development are based on the same level of service currently provided to the existing residents of the City.

The Rancho Cucamonga Police Department’s primary facility is the Public Safety Building lo­cated in the Civic Center Complex. A satellite station in the Victoria Gardens Mall is not treat­ed as an existing facility in this analysis because it is not owned by the City. However, as de­scribed in the Public Health and Safety Element of the General Plan, the City does intend to construct another police facility in the Northeastern portion of the City in the future.

The impact fees calculated in this chapter are based on the cost of maintaining the existing level of service for police facilities as additional development occurs.

Revenue from those impact fees may be used for, but shall not be limited to the following types of Police facility improvements: land acquisition and improvements (landscape, hard­scape, parking areas, perimeter street), building construction, furniture fixtures and equip­ment (including but not limited to carpet, desks, blinds, tables, chairs, shelving, cabinets, communication systems, electronic equipment, exercise equipment, special needs equip­ment), technical centers and transportation facilities .

Table 7.3 calculates the average cost per call for service per year using costs from Table 7.2 and total 2012 calls for service from Table 7.1.

In the next section, the per­capita cost from Table 7.3 is used to calculate police impact fees per unit of development by development type.

Table 7.3: Average Facility Cost per Call for Service per Year

Cost Estimated 2012 Calls Avg Cost per

Component Repl Cost 1 for Service 2 Call for Service 3

Existing Public Safety Bldg $19,250,000 139,696 $137.80

1 See Table 7.2 2 See Table 7.13 Average cost per call for service per year

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Table 7.4 shows the calculation of police impact fees per unit of development by develop­ment type. Those fees are calculated using the average cost per call for service from Table 7.3 and the calls­per­unit factors from Table 7.1.

Note on Fees for Assisted Living Facilities. The impact fees shown in Table 7.4 include fees for assisted living facilities. Assisted living is not one of the basic development types used in this report. However, assisted living facilities are allowed in some residential zoning districts with a conditional use permit, and those facilities do generate demand for police services. Impact fees for this type of development are based on a calls­per­unit factor specific to such facilities. That factor was estimated using location­specific data from the calls­for­service database. Impact fees for other specialized development types could be calculated in the same way if the need arises.

Potential revenue from the police impact fees can be estimated by applying the fees per unit from Table 7.4 to forecasted future units from Table 2.3.

Table 7.5 on the next page shows the projected revenue to buildout from the police impact fees calculated in this chapter. This projection assumes that future development occurs as anticipated in the City’s current General Plan. No revenue is projected for Assisted Living Fa­cilities because that type of development would displace other development in the Residen­tial, Multi­Family (Attached) category.

Table 7.4: Police Impact Fees per Unit of Development

Development Avg Cost per Avg Calls Impact Fee

Type Units 1 Call for Service 2 per Unit 3 per Unit 4

Residential, Single­Family (Detached) DU $137.80 1.25 172.00$

Residential, Multi­Family (Attached) DU $137.80 1.41 194.92$ Assisted Living Facilities DU $137.80 0.30 41.34$

Commercial/Retail KSF $137.80 3.85 530.67$ Office KSF $137.80 0.89 122.38$

Industrial KSF $137.80 0.33 46.10$ Hotel/Motel Room $137.80 0.47 65.10$

1 Units of development; DU = dwelling unit; KSF = 1,000 gross square feet of building area

Room = single guest room or suite 2 See Table 7.33 See Table 7.14 Impact fee per unit = average cost per call for service X average calls per unit

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The fees calculated in this chapter are based on estimated current replacement costs for ex­isting Police Department facilities and equipment. This study assumes that the projects cov­ered by the police impact fees will be funded on a pay­as­you­go basis, so no financing costs are included. To maintain parity between impact fees and asset replacement costs, the im­pact fees should be adjusted periodically to reflect changes in price levels.

A common practice is to adjust impact fees annually. Facility construction costs can be ad­justed using an index such as the Engineering News Record Building Cost Index. Adjustments to land and equipment costs should be based on local cost data. See the Implementation Chapter for more on indexing of fees.

Table 7.5: Projected Revenue ­ Police Impact Fees

Development Dev Impact Fee Future Projected

Type Units 1

per Unit 2

Units 3

Revenue 4

Residential, Single­Family (Detached) DU 172.00$ 3,305 568,467$ Residential, Multi­Family (Attached) DU 194.92$ 1,109 216,166$

Commercial/Retail KSF 530.67$ 11,341 6,018,187$ Office KSF 122.38$ 5,238 641,014$

Industrial KSF 46.10$ 27,259 1,256,579$ Hotel/Motel Room 65.10$ 320 20,833$

Total 8,721,247$

1 Units of development; DU = dwelling unit; KSF = 1,000 gross square feet of building area

Room = single guest room or suite 2 Impact fee per unit of development; see Table 7.4

3 Future units; see Table 2.3

4 Projected revenue = impact fee per unit X future units

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City of Rancho Cucamonga – Development Impact Fee Study Public Art

April 22, 2014 Colgan Consulting Corporation Page 8-1

As part of this study, Colgan Consulting was asked to assist the City in developing a public art program. Goal LU­14 of in the Rancho Cucamonga General Plan is to “support public art as an important amenity of a beautiful city.” General Plan Policy LU­14.3 addresses development of a public art ordinance in the Development Code

We don’t recommend treating developer fees for public art as impact fees because it is diffi­cult to structure public art fees in a way that can be justified as impact fees. Cities that charge fees for public art typically treat them as in­lieu fees. That is, the choice to pay a fee is offered an alternative way of satisfying a requirement to include public art in a development project.

Legally, a requirement to provide public art can established as a design standard, analogous to requiring a certain amount and quality of landscaping in a development project. As a prac­tical matter, the only way of defining the amount or quality of public art required of a devel­oper is by its monetary value.

Consequently, most public art programs define their requirements in terms of the cost of the art to be provided as a percentage of the valuation of the development project. Building permit valuation is most often used as the cost basis in such programs.

Should the City Contribute to the Program? Some cities choose to invest a percentage of the value of new public buildings in public art. The percentage is often 1% (e.g., Pasadena), but can be higher (e.g., 1.5% in Emeryville and 2% in Sacramento and San Diego).

What types of development should be subject to the fees? Many public art programs estab­lish a minimum size or value, below which development projects are exempt from the re­quirements of the program. Below are some examples of different ways those standards can be applied. For simplicity, some details have been omitted.

The City of Brea requires that all development projects valued between $1,500,000 and $3,999,999 pay a “sculpture allocation” equal to 1% of the project valuation into the public art fund. Projects valued at $4,000,000 or more must provide public sculpture on site. No public art requirement applies to projects valued at less than $1,500,000.

In Culver City, new residential development of 5 or more units, and most commercial, indus­trial and public building projects valued at $500,000 or more, are subject to a public art re­quirement equal to 1% of the project valuation. That requirement can be met either by providing approved art on site or by paying a public art fee.

Palm Springs and Palm Desert impose public art requirements equal to 0.25% of project valua­tion for residential development and 0.5% for non­residential development. For individual residential units, the first $100,000 of valuation is exempt.

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In San Diego, new commercial or industrial development exceeding $5,000,000 of valuation must EITHER provide on­site art works valued at 1% of the project value, OR contribute 0.5% of the project value in cash to the City’s public art fund. Residential development is exempt.

These examples show a range of possibilities that can be considered by the City of Rancho Cucamonga in designing its public art fee program.

Does the City want to encourage on­site provision of public art vs. payment of fees? The City could design a program that includes incentives either to include public art in a develop­ment project or to pay a public art fee. For example, the cost of complying with San Diego’s public art requirement is 0.5% if the development contributes to the public art fund com­pared with 1% if the developer includes public art in the development project. Presumably, that differential encourages developers to contribute cash that the City can spend for public art of its choosing.

To the extent that the program is geared toward collecting fees as opposed to requiring on­site public art within a development project, the City is faced with assuming responsibility for acquiring, owning, and maintaining public art. That is probably unavoidable in any case, un­less the program applies only to projects large enough to make on­site placement of art works feasible.

What works of art will the City approve for this program? If the program allows developers the option of acquiring and placing public art, as opposed to paying in­lieu fees, the City would need a procedure for approving the works of art, or at least the artist. The City of Brea’s Public Art Manual contains detailed guidelines for the types of art that are acceptable under that City’s program.

The manual addresses the size and type of art (three­dimensional sculpture, monumental in scale, constructed of durable, low­maintenance materials), as well as placement for visibility, safety and other considerations. It also establishes a process for reviewing the qualifications of a proposed artist.

Brea’s guidelines include detailed application forms for developers seeking approval of an art project, and standards to guide the review of those applications. Property owners must agree to be responsible for ongoing maintenance of public art placed on private property.

What costs may be included in the value of an art work? The Brea Public Art Manual details which costs related to the acquisition and installation of art works will be considered in de­termining the value of the piece.

How is a development project defined for purposes of the public art fee program? Since the requirement to provide public art in many cities is triggered by the number of units or the valuation of a development project, issues can arise when a project is submitted in phases or constructed in phases.

Whether intentional or not, breaking a project into phases could have the effect of avoiding the public art requirement, whether the project­size is defined in terms of units or valuation. That is more of an issue when the minimum project size subject to the public art requirement is fairly large, as is the case in San Diego. Standards for projects subject to the public art fee program should be defined with a view to the types of development expected in the City.

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Is the added cost imposed on development by the public art fee program at odds with other City priorities? The design of a public art program should consider potential conflicts with goals and policies such as housing affordability and economic development.

In developing a public art fee program, the City will need to make policy decisions in a num­ber of areas. Several relate to issues that were discussed in the previous sections. Below is a list of elements that should be addressed in designing a public art fee program for Rancho Cucamonga.

� Determine the type/size of development projects to be subject to the program re­quirements (e.g., Does it apply to both residential and non­residential development? Are there exemptions for some types of development such as non­profits or afforda­ble housing? What is the minimum project size or valuation subject to the program requirements?)

� Determine the amount of the fee or allocation as a percentage of project value (Does the allocation differ by project size or type?)

� Determine how the program requirements can be met (e.g., by including art works on site or by paying a fee, or by choosing between the two options)

� Determine what types of art are acceptable when a developer commissions or ac­quires art to meet the program requirements

� Establish a process for approving art to be commissioned or acquired by a developer

� Establish a process for collecting public art fees from developers, when applicable

� Provide for permanent ownership and long­term maintenance of public art on private property

� Prepare a program manual (The City of Brea Art in Public Places Policy Manual is an excellent example)

� Establish a Public Art review committee or assign responsibility to an existing board or committee.

� Define an appeal process

� Assign departmental responsibility for implementation of the program at the staff level

� Develop policies and procedures for acquisition and placement of art works by the City with money collected from public art fees

The list above is not necessarily exhaustive, but it outlines many of the decisions that must be made by the City in developing a public art program and ordinance. Unlike the establish­ment of an impact fee program which is governed by to a large extent by legal constraints, a public art program involves many discretionary elements that are subject to local prefer­ences.

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This chapter of the report contains recommendations for adoption and administration of a development impact fee program based on this study, and for the interpretation and applica­tion of impact fees recommended herein.

Statutory requirements for the adoption and administration of fees imposed as a condition of development approval are found in the Mitigation Fee Act (Government Code Sections 66000 et seq.). For implementation of fees in lieu of park land dedication, see the Quimby Act (Government Code Section 66477).

The form in which development impact fees are enacted, whether by ordinance or resolu­tion, should be determined by the City Attorney. Ordinarily, it is desirable that specific fee amounts be set by resolution to facilitate periodic adjustments. Procedures for adoption of fees subject to the Mitigation Fee Act, including notice and public hearing requirements, are specified in Government Code Sections 66016 and 66018. It should be noted that Section 66018 refers to Government Code Section 6062a, which requires that the public hearing no­tice be published at least twice during the 10­day notice period. Government Code Section 66017 provides that fees subject to the Mitigation Fee Act do not become effective until 60 days after final action by the governing body.

Actions establishing or increasing fees subject to the Mitigation Act require certain findings, as set forth in Government Code Section 66001 and discussed below and in Chapter 1 of this report.

Establishment of Fees. Pursuant to the Mitigation Fee Act (Section 66001(a)), when the City establishes fees to be imposed as a condition of development approval, it must make find­ings to:

1. Identify the purpose of the fee;

2. Identify the use of the fee; and

3. Determine how there is a reasonable relationship between:

a. The use of the fee and the type of development project on which it is imposed;

b. The need for the facility and the type of development project on which the fee is imposed

Examples of findings that could be used for impact fees calculated in this study are shown below. The specific language of such findings should be reviewed and approved by the City Attorney.

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Finding: Purpose of the Fee. The City Council finds that the purpose of the impact fees hereby enacted is to prevent new development from reducing the quality and availability of public services provided to residents of the City by requiring new de­velopment to contribute to the cost of additional capital assets needed to serve addi­tional development.

Finding: Use of the Fee. The City Council finds that revenue from the impact fees hereby enacted will be used to construct public facilities and pay for other capital as­sets needed to serve new development. Those public facilities and other assets are identified in the 2013 Development Impact Fee Study prepared by Colgan Consulting Corporation. 1

Finding: Reasonable Relationship: Based on analysis presented in the 2013 Devel­opment Impact Fee Study prepared by Colgan Consulting Corporation, the City Coun­cil finds that there is a reasonable relationship between:

a. The use of the fees and the types of development projects on which they are imposed; and, b. The need for facilities and the types of development projects on which the fees are imposed.

The California Mitigation Fee Act (Government Code Sections 66000 et seq.) mandates pro­cedures for administration of impact fee programs, including collection and accounting, re­porting, and refunds. References to code sections in the following paragraphs pertain to the California Government Code.

Imposition of Fees. Pursuant to the Mitigation Fee Act (Section 66001(a)), when the City im­poses an impact fee upon a specific development project, it must make essentially the same findings adopted upon establishment of the fees to:

1. Identify the purpose of the fee;

2. Identify the use of the fee; and

3. Determine how there is a reasonable relationship between:

a. The use of the fee and the type of development project on which it is imposed;

b. The need for the facility and the type of development project on which the fee is imposed

1 According to Gov’t Code Section 66001 (a) (2), the use of the fee may be specified in a capital im­provement plan, the General Plan, or other public documents that identify the public facilities for which the fee is charged. The findings recommended here identify this impact fee study as the source of that information.

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Per Section 66001 (b), at the time when an impact fee is imposed on a specific development project, the City is also required to make a finding to determine how there is a reasonable relationship between: c. The amount of the fee and the facility cost attributable to the development project on which it is imposed.

In addition, Section 66006 (f) provides that a local agency, at the time it imposes a fee for public improvements on a specific development project, "... shall identify the public im­provement that the fee will be used to finance." In this case, the fees will be used to finance public facilities, infrastructure, and other development­related capital expenditures identified in the 2013 Development Impact Fee Study prepared by Colgan Consulting Corporation.

Section 66020 (d) (1) requires that the City, at the time it imposes an impact fee provide a written statement of the amount of the fee and written notice of a 90­day period during which the imposition of the fee can be protested. Failure to protest imposition of the fee during that period may deprive the fee payer of the right to subsequent legal challenge.

Section 66022 (a) provides a separate procedure for challenging the establishment of an im­pact fee. Such challenges must be filed within 120 days of enactment.

The City should develop procedures for imposing fees that satisfy those requirements for findings and notice.

Collection of Fees. Section 66007 (a), provides that a local agency shall not require payment of fees by developers of residential projects prior to the date of final inspection, or issuance of a certificate of occupancy, whichever occurs first. However, "utility service fees" (not de­fined) may be collected upon application for utility service. In a residential development pro­ject of more than one dwelling unit, Section 66007 (a) allows the agency to choose to collect fees either for individual units or for phases upon final inspection, or for the entire project upon final inspection of the first dwelling unit completed.

Section 66007 (b) provides two exceptions when the local agency may require the payment of fees from developers of residential projects at an earlier time: (1) when the local agency determines that the fees “will be collected for public improvements or facilities for which an account has been established and funds appropriated and for which the local agency has adopted a proposed construction schedule or plan prior to final inspection or issuance of the certificate of occupancy” or (2) the fees are “to reimburse the local agency for expenditures previously made.”

Statutory restrictions on the time at which fees may be collected do not apply to non­residential development.

In cases where the fees are not collected upon issuance of building permits, Sections 66007 (c) (1) and (2) provide that the city may require the property owner to execute a contract to pay the fee, and to record that contract as a lien against the property until the fees are paid.

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Earmarking and Expenditure of Fee Revenue. Section 66006 (a) mandates that fees be de­posited “with other fees for the improvement” in a separate capital facilities account or fund in a manner to avoid any commingling of the fees with other revenues and funds of the local agency, except for temporary investments and expend those fees solely for the purpose for which the fee was collected. Section 66006 (a) also requires that interest earned on the fee revenues be placed in the capital account and used for the same purpose.

The language of the law is not clear as to whether depositing fees "with other fees for the improvement" refers to a specific capital improvement or a class of improvements (e.g., street improvements). We are not aware of any city that has interpreted that language to mean that funds must be segregated by individual projects.

As a practical matter, that approach is unworkable because it would mean that no pay­as­you­go project could be constructed until all benefiting development had paid the fees. Common practice is to maintain separate funds or accounts for impact fee revenues by facili­ty category (i.e., streets, park improvements), but not for individual projects. We recom­mend that approach.

It is important that fee revenue be expended so as to provide a reasonable benefit to the development projects from which the fees are collected. Some fees in this report were cal­culated without knowing the specific locations of all facilities to be funded by the fees. The City should exercise caution in expending such fees to ensure that facilities are located in such as way as to serve the development projects from which the fees were collected.

Impact Fee Exemptions, Reductions, and Waivers. In the event that a development project is found to have no impact on facilities for which impact fees are charged, such project must be exempted from the fees.

If a project has characteristics that indicate its impacts on a particular public facility or infra­structure system will be significantly and permanently smaller than the average impact used to calculate impact fees in this study, the fees should be reduced accordingly. Per Section 66001 (b), there must be a reasonable relationship between the amount of the fee and the cost of the public facility attributable to the development on which the fee is imposed. The fee reduction is required if the fee is not proportional to the impact of the development on relevant public facilities.

In some cases, the City may desire to voluntarily waive or reduce impact fees that would oth­erwise apply to a project, as a way of promoting goals such as affordable housing or econom­ic development. Such a waiver or reduction may not result in increased costs to other devel­opment projects, and are allowable only if the City offsets the lost revenue from other fund sources.

Credit for Improvements Provided by Developers. If the City requires a developer, as a con­dition of project approval, to dedicate land or construct facilities or improvements for which impact fees are charged, the impact fee imposed on that development project for that type of facility must be adjusted to reflect a credit for such dedication or construction.

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In the event that a developer voluntarily offers to dedicate land, or construct facilities or im­provements in lieu of paying impact fees, the City may accept or reject such offers, and may negotiate the terms under which such an offer would be accepted.

Credit for Existing Development. If a project involves replacement, redevelopment or inten­sification of previously existing development, impact fees should be applied only to the por­tion of the project which represents a net increase in demand for relevant City facilities, ap­plying the measure of demand used in this study to calculate that particular impact fee.

Reporting. Section 66006 (b) (1) requires that once each year, within 180 days of the close of the fiscal year, the local agency must make available to the public the following information for each separate account established to receive impact fee revenues:

1. A brief description of the type of fee in the account or fund;

2. The amount of the fee;

3. The beginning and ending balance of the account or fund;

4. The amount of the fees collected and interest earned;

5. Identification of each public improvement on which fees were expended and the amount of the expenditures on each improvement, including the percentage of the cost of the public improvement that was funded with fees;

6. Identification of the approximate date by which the construction of a public im­provement will commence, if the City determines sufficient funds have been col­lected to complete financing of an incomplete public improvement;

7. A description of each inter­fund transfer or loan made from the account or fund, in­cluding interest rates, repayment dates, and a description of the improvement on which the transfer or loan will be expended;

8. The amount of any refunds or allocations made pursuant to Section 66001, para­graphs (e) and (f).

That information must be reviewed by the City Council at its next regularly scheduled public meeting, but not less than 15 days after the statements are made public, per Section 66006 (b) (2).

Refunds. Prior to 1996, a local agency collecting impact fees was required to expend or commit impact fee revenue within five years, or make findings to justify a continued need for the money. Otherwise, those funds had to be refunded. SB 1693, adopted in 1996 as an amendment to the Mitigation Fee Act, changed that requirement in material ways.

Now, Section 66001 (d) requires that, for the fifth fiscal year following the first deposit of any impact fee revenue into an account or fund as required by Section 66006 (b), and every five years thereafter, the local agency shall make all of the following findings for any fee revenue that remains unexpended, whether committed or uncommitted:

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1. Identify the purpose to which the fee will be put;

2. Demonstrate the reasonable relationship between the fee and the purpose for which it is charged;

3. Identify all sources and amounts of funding anticipated to complete financing of incomplete improvements for which impact fees are to be used;

4. Designate the approximate dates on which the funding necessary to complete financing of those improvements will be deposited into the appropriate account or fund.

Those findings are to be made in conjunction with the annual reports discussed above. If such findings are not made as required by Section 66001, the local agency could be required to refund the moneys in the account or fund, per Section 66001 (d).

Once the agency determines that sufficient funds have been collected to complete an in­complete improvement for which impact fee revenue is to be used, it must, within 180 days of that determination, identify an approximate date by which construction of the public im­provement will be commenced (Section 66001 (e)). If the agency fails to comply with that requirement, it must refund impact fee revenue in the account according to procedures spec­ified in Section 66001 (d).

Annual Update of the Capital Improvement Plan. Section 66002 (b) provides that if a local agency adopts a capital improvement plan to identify the use of impact fees, that plan must be adopted and annually updated by a resolution of the governing body at a noticed public hearing. The alternative, per Section 66001 (a) (2) is to identify improvements by applicable general or specific plans or in other public documents.

In most cases, the CIP identifies projects for a limited number of years and may not include all improvements needed to serve future development covered by the impact fee study. We recommend that this development impact fee study be identified by the City Council as the public document on which the use of the fees is based.

Indexing of Impact Fees. Development impact fees calculated in this report assume the facil­ities in question will be constructed on a pay­as­you­go basis. Those fees are based on cur­rent costs and should be adjusted at least annually to account for inflation. That adjustment is intended to account for future escalation in costs for land and construction. We recom­mend the Engineering News Record Building Cost Index as the basis for indexing construction costs. Where land costs make up a significant portion of the costs covered by a fee, land costs should be adjusted relative to changes in local land prices.

Effective administration of an impact fee program requires considerable preparation and training. It is important that those responsible for collecting the fees, and for explaining them to the public, understand both the details of the fee program and its supporting ra­tionale. Before fees are imposed, a staff training workshop is highly desirable if more than a handful of employees will be involved in collecting or accounting for fees.

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It is also useful to pay close attention to handouts that provide information to the public re­garding impact fees. Impact fees should be clearly distinguished from other fees, such as user fees for application processing, and the purpose and use of particular impact fees should be made clear.

Finally, anyone who is responsible for accounting, capital budgeting, or project management for projects involving impact fees must be fully aware of the restrictions placed on the ex­penditure of impact fee revenues. The fees recommended in this report are tied to specific improvements and cost estimates. Fees must be expended accordingly and the City must be able to show that funds have been properly expended.

Colgan Consulting recommends that the City add an administrative charge to the fees calcu­lated in this report to cover the cost of periodic fee updates and program administration. The amount of that fee should be determined by the City, based on its costs.