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Comments on Bill 304 Prepared by Co of HI Planning Department April 5, 2011 Below comments provided by Dave Freudenberger of Goodwin Consulting Group author of Kona CDP Financing Plan for Public Facilities and Backbone Infrastructure (Jan 2011): April 4, 2001 Margaret — I really need more time to do a complete review, but I'll pass along the comments I do have at this point. As I have mentioned to you, I believe without hesitation that the County needs an impact fee program, but I am troubled by some of the aspects of this bill. On the other hand, I've never spoken with anyone about the details of the bill, so maybe if I had that opportunity it would clear up some or all of my concerns. 1. Sections 36 -13 and 36 -14 should probably be removed. The formulas are too open to variables and interpretation, and include provisions that may not make sense. These sections also throw the whole impact fee program into a state of uncertainty because the impact fee administrator can decide that any application needs to be reviewed; to make matters worse, the review must be conducted at the applicant's expense. The land use types in the bill cover every possible land use scenario; in fact, the impact fee program would be easier to apply and administer if some of the more detailed land use types were removed from the bill. 2. With respect to the residential land use types and the possibility of more granularity (i.e., expanding single family and multi - family into categories based on home size), I am generally not in favor of it. First, how were the new amounts determined; is there a direct connection, or nexus, between the home size categories and proposed fees? It doesn't appear that there is. The nexus gets much more vague when you move into this level of detail. This granularity is more common for school fees (and sometimes fire fees), but much less common for other fees. Using this approach for school fees (impacts relate directly to kids, which correlate strongly to home size) and fire fees (fires involving bigger structures are more difficult to fight) is more clear. Also, this level of detail just becomes more challenging to administer. 3. My understanding is that the proposed fees represent 50% of the actual impacts calculated in 2006 as part of the Needs Assessment Study. I don't know why something less than 100% of the impacts are being integrated into the fee program. Some fairly detailed calculations we did as part of the Kona CDP Financing Plan suggest that, for residential (single family and multi - family) and resort/hotel land uses, levying fees based on 100% of the impacts would be comparable to the assessments currently required under the Fair Share approach. 4. The proposed fees are now at least five years out of date, if not more, given that the Needs Assessment Study was completed in 2006 and probably based on data that Page 6 of 7