Loading...
HomeMy WebLinkAboutIPFNA_Ord Issues Memo_Mar_06 MEMORANDUM TO: Chris Yuen, County of HawaiÓi Planning Department FROM: Clancy Mullen, Duncan Associates DATE: March 1, 2006 RE: Infrastructure and Public Facility Needs Assessment Study Ï Ordi The purpose of this memorandum is to present th e consultant teamÔs recommendations on major policy issues that will be involved in implementing an impact fee ordinance for HawaiÓi County. A glossary of impact fee terms is also attached as an appendix. Impact fees are subject to specific re quirements that do not apply to ot her types of fees or taxes. The courts have developed guidelines for constitutionally valid impact fees, based on a Ñrational nexusÒ that must exist between the regulatory fee or exaction and the activi I. SUMMARY OF RECOMMENDATIONS A. Types of Fees. The proposed impact fees are for roads, parks, fire, police, s wastewater facilities. B. Treatment of Existing Lots. Instead of making a recommendation, we have laid out a number of alternatives in the following discussion, which are briefly s Option 1: Existing lots of record can build one dwelling unit without pay Option 2: The County pays the fees for existing lots of record to build o Option 3: Owners of existing lots of record ha ve 2-5 years after ordinance adoption during which they could apply for a building permit for one dwelling unit without paying impact fees. Option 4: Exclude the Puna and KaÓ u Districts, where most of the existing lots are located, from the impact fee system, which means no impact fees would be impact fee money would be spent there. C. Time of Assessment/Collection. It is our recommendation that the impact fees should be collected at the time the building permit is issue d. Impact fees could be assessed (meaning that applicants for development approvals are given notice of the obligation to pay impact fees) at an earlier time (e.g., subdivision approval). D. Pre-Ordinance Credits. If developers have paid fair share assessments or made in-kind contributions for projects that have not been comp leted, impact fees should be reduced or eliminated for any remaining development in those projects. 13276 research blvd , ste 208 austin tx 78750 phone 512 258 7347 fax 512 258 9994 email clancy@duncanplan.com # # # # Infrastructure and Public Facility Needs Assessment St udy – Ordinance Issues Memorandum, March 1, 2006, page 2 E. Post-Ordinance Reimbursements. If developers are required or agree to dedicate land or make eligible improvements for impact fee facilities after the effective date of the ordinance, they should be reimbursed from impact fees for the value of those improvements. F. Assessment Districts. All fees should be calculated county-wide and assessed with a county-wide fee schedule. G. Benefit Districts. Fees should be earmarked to be spent on the side of the island which they were collected (see Figure 1). Park fees should have H. Affordable Housing Projects. Rather than waive fees for a ffordable housing projects, the County intends to appropriate other funding to pay the impact fee for s I. Progressive Residential Fees. Single-family fees should vary by the size of the dwelling uni reduce fees for smaller units. J. Cost Recovery. The impact fee study will calculate maximum f ees that can be charged. Preliminary analysis indicates that the total maximum impact fees will exceed the current total fair share assessments. The County will be able to adopt impact fees at any percentage up to 100 per cent of the maximum fees. K. Phase-in Period. The recommended effective date of the impact fee ordinance is one year after the adoption date. During the one-year phase-in peri od, the fair share assessments would continue to be in effect. Following this initial phase-in period , the fees could be gradually increased up to the ultimate desired Ñcost recoveryÒ level over a year or more. 13276 research blvd , ste 208 austin tx 78750 phone 512 258 7347 fax 512 258 9994 email clancy@duncanplan.com # # # # Infrastructure and Public Facility Needs Assessment St udy – Ordinance Issues Memorandum, March 1, 2006, page 3 II. DETAILED DISCUSSION A. TYPES OF FEES The proposed impact fees would replace the current fair share assessments for roads, parks, fire, police and solid waste facilities. An additional fee is proposed for w service is available. B. TREATMENT OF EXISTING LOTS The most critical issue is how to tr eat existing lots of record. In most jurisdictions that have adopted impact fees, how to treat existing lots is a minor i ssue. Generally, the supply of such lots is limited, and if they are grandfathered or otherwise exempted from impact fees the overall effect on impact fee revenues is short-lived and relatively minor. However , this is not the case in HawaiÓi County. A recent analysis indicates that there are about 64,000 undeve loped residential lots in the county. This exceeds the total number of housing units on the island at the time of the 2000 census (62,674). Of the roughly 2,000 permits of single-family detached units issued by the County annually, it has been estimated that about one-third of these new homes are being built on lots that The perception exists that many of these lots are owned by local residents who intend to build a h for themselves in these older subdivisions. While this is undoubtedly true to some extent, it is far from the typical case. An analysis of property tax reco rds indicates that only about 14 percent of existing vacant residential lots are owned solely by Big Island residents, and two-thirds are under the exc ownership of non-Big Island residents (see Table 1) . The remaining 17 percen t are owned by multiple owners with some Big Island resident participation, but it is likely that most of these lots are being held as an investment, rather than as a future home si te. The investment motive probably holds for a good number of the Big Island owners as well. So the number owned by build a home on them is probably considerably less than 9,000 lots. To put that number in perspective, it represents less than five years of single-family building permit activity in HawaiÓi County at current development rates. Table 1 OWNERSHIP OF VACANT RESIDENTIAL LOTS Ownership# of LotsPercent Big Island-Single Owner9,12314.20% Big Island-Multiple Owners1750.30% Mixed Big Island/Oth er Owners10,74716.70% No Big Island Owners44,17568.80% Total Vacant Residential Lots64,220100.00% Source: HawaiÓi County Real Property Tax Administrator, January 7, 2006 (data base excludes lots that are (1 ) over 20 acres, (2) already improved with $10,000 or more worth of yard or outbuilding improvements, or (3) commercial, industrial or resort hotel tax classifications or zo roadway, governmental and utility parcels. 13276 research blvd , ste 208 austin tx 78750 phone 512 258 7347 fax 512 258 9994 email clancy@duncanplan.com # # # # Infrastructure and Public Facility Needs Assessment St udy – Ordinance Issues Memorandum, March 1, 2006, page 4 There are several alternative for dealing with this issue. Four Option 1. One of the options that is under considerati on is to allow any existing lot of record to be developed with one dwelling unit without paying an impact fee. Any additional dwelling units or any nonresidential development on the lot would be require d to pay an impact fee. A concern here is that if the amount of development not paying the fee is large, the impact fees will not be sufficient provide the level of service that the fees are intended to provi Option 2. Instead of waiving fees for the first dwelling unit on existing lots of record, an alternative would be for the County to use other funding sources to pay the impact fees for a single-family dwelling unit on existing lots. This approach ensures that the funding in the impact fee account is sufficient to maintain the level of service on which the impact f ees are based. The County would not need to pay fees for existing lots for which fair share assessmen ts had been paid, since the credit for such payments would likely offset any impact fees assessed. Assuming total impact fees of $10,000 per unit and that 1,000 of the 2,000 si ngle-family houses being built each year are on existing lots of record for wh ich fair share assessments had not been paid, a $10 million annual appropriation would be required. Since the likely source of the appropriation would be property taxes, and since new development paying th e fee would be generating some of those property tax revenues, the fees would need to be reduced by a credit that takes this into account to avoid double- charging (new development paying the fee should not ha ve to pay the full share of their costs, while also having to pay for part of the costs attributable to new development that is having their fee paid by the County). Option 3. An alternative to a permanen t waiver of fees for the first dwelling unit is to make it a temporary transition provision. Fo r example, the state impact fee enabling act in Texas allows own of lots that were subdivided prior to the impact fee ordinance to pull a building permit within one year following adoption of the ordinance without being requi red to pay the fee. A longer time period than one year could be considered, but it should probabl y not exceed five years. The transition exemption could be a blanket one that applies to all building perm its for all existing lots, or a more limited one such as the one-unit-per lot approach described above. If structured as a transition provision, the effects of the exemption would be minimal when viewed from a long-term perspective. For example, assume that a park impact fee includes a three-year Ñgrace peri odÒ during which fees are not charged on one unit per lot. In the first year, none of the 2,000 single-f amily permits is assessed a fee, while virtually all 3,000 multi-family units pay. In the next two years, th e number of units exempted would likely drop as the supply of newly-created lots declines, so perhaps a to tal of 4,000 single-family units would be exempted. Over the first ten years of the program, about 50,000 units would be built, of which less than 10 percent would be exempted due to the transition provision. The percentage would be even less for road, fire and police impact fees, which also apply to nonresidential devel Option 4. A fourth alternative would be to exclude the area where most of the existing lots are located (i.e., Puna and KaÓ u Districts) from the impact fee system. Exclusion means that no impact fees would be collected in this area, and no impact fees would be spent there. Exclusion would not have to be permanent. For example, for Kansas City, Missour i, we first developed arter ial street impact fees for the area north of the Missouri River, before preparin g impact fees for the southern part of the city. In each area, the older part of the city that was anne xed prior to 1950 was excluded from the impact fee system. 13276 research blvd , ste 208 austin tx 78750 phone 512 258 7347 fax 512 258 9994 email clancy@duncanplan.com # # # # Infrastructure and Public Facility Needs Assessment St udy – Ordinance Issues Memorandum, March 1, 2006, page 5 C. TIME OF COLLECTION/ASSESSMENT The current fair share assessments are imposed duri ng the rezoning process, and are collected prior to final subdivision approval for single-family lots and prior to site plan approv al for multi-family and hotel/motel development. Collection at time of subdivision woul recommendation that single-family homes be assessed on the basis of dwelling unit size, since the square footage of the home is not known at that time. While there is no i nherent reason why multi-family and nonresidential fees could not be coll ected at time of site plan approval, site plan approval is not required for single-family units, an d it would seem to be simpler and more administratively efficien all impact fees at the same point in the developm ent process. For these reasons, we recommend that the impact fees be collected at the time of building permit for While the fees should be collected at building pe rmit, they could be assessed at an earlier time. Assessment can mean several things. It can simply be notice tha building permit, based on the fee schedules that are in place when the building permit is applied for. Or it can mean that the fee schedule in place at th e time of assessment is the one that will apply to the property. Assessment of fees at subdivision would e ssentially be the same as waiving impact fees for any existing lot that was already subdivided at the time of ordinance adoption or that could be developed without subdivision. D. PRE-ORDINANCE CREDITS Some building permits will be issued in projects for which developers have already paid fair share assessments. To prevent double-charging, it will be necessary to either reimburse the developer, or to reduce or eliminate the impact fees that are charged for those b passed along the cost of the fair share assessment to the extent possible in the sale of the lots, reimbursing the developers would have the effect of handing them windfall prof its. A better alternative might be to reduce or eliminate the impact fees due to be paid a We recommend the following approach. Prior to th e effective date of the or dinance, County planning staff would need to identify all parcels or subdivisi ons for which fair share assessments have been paid, and the amounts paid for each type of facility. If the project is bu ilt-out, no credits would be needed. If no development has yet occurred, the credit would be the amount paid, adjusted for inflation since the time of payment. If building permits have al ready been issued for a particular subdivision, but some development potential remains. the credit would be the amount paid, adjusted for inflation, less wh the subdivision would have generated in impact fees had the fee schedule been in place. The resulting credit amounts would be available to offset impact fees otherwise due for building permits issued for the applicable parcels or within the subdivisions on a first-come, first-served basis until the credits are exhausted. The amount of the credits would be annually adjusted that is used for the impact fees. A time limit, suc h as ten years, could be imposed on the use of the credits. Fair share assessments that were imposed as a condit ion of zoning approval, but have not yet been paid by the effective date of the impact fee ordinance (b ecause the property has not been subdivided or site- planned) would be replaced by the obligation to pay impact fees Another issue that must be addressed is cred its for developers who made impact fee-eligible contributions prior to the impact fee ordinance, bu t who did not receive credit against fair share 13276 research blvd , ste 208 austin tx 78750 phone 512 258 7347 fax 512 258 9994 email clancy@duncanplan.com # # # # Infrastructure and Public Facility Needs Assessment St udy – Ordinance Issues Memorandum, March 1, 2006, page 6 assessments for the value of those contributions. We recommend types of improvements in much the same way as credits for fair s E. POST-ORDINANCE REIMBURSEMENTS For fair share assessments and pre-ordinance contri butions, we have recommended credits that run with the land rather than developer reimbursements. So it may make sense to use the same approach when dealing with new developer exactions that occur after the impact fee ordinance is in place. However, an alternative approach is at least worthy of cons ideration, since the fair share credits affect a limited number of parcels and will expire in a certain number of years. The alternative approach is to reimburse developers who make eligible improvements with impact fees collected from other developers who do not. This approach was pioneered by Raleigh, North Carolina when it established road and park impact fees in 1 987, and although it has not been widely emulated by other jurisdictions, we think it has much to recommend it. Rale agreement with each developer who makes an impact fee-eligible improvement. If the improvement is an expensive one, the reimbursement is scheduled to occur over a five-year period, subject to available funding. The City also categorizes each developer contribution as Priority I or Priority II. Priority I projects include dedication of land or right-of-w ay and projects in the CityÔs five-year capital improvements plan. Each year, the City sets aside a percentage of impact fees collected in each benefit zone (20 percent of park fees and 27 percent of road fees) into reimbursement accounts. If the reimbursement account has sufficient funds to pay all reimbursements owed for that year, all developers with outstanding reimbursements for that year receive full payme reimburse all developers, developers with Priority I im provements are reimbursed first. If funds are still insufficient, each Priority I developer receives a pro rata share of his reimbursement amount, with the unpaid amount rolled over to the next year. The reimbursement approach used by Raleigh is considerably simpl approach, and it also has the advantage that a predi ctable percentage of impact fee revenue is available to the local government to program for priority im provements. The first advantage would not be as pronounced for HawaiÓi County for the first few years , since staff would need to track fair share assessment credits for a number of years. However, those credit properties and would disappear after a few years. After that, the collection of fees at the building permit counter would be automatic for all permits, with no need to check to see if cred its are available to offset the fees. The second advantage would also be so mewhat attenuated in the first few years, since fair share credits would reduce the amount of fees collected, but the County would be guaranteed that subsequent developer contributions would not consume more than a impact fee revenues. Our recommendation is that the County consider using a reimbursement approach similar to RaleighÔs for post-ordinance developer contributions. F. ASSESSMENT DISTRICTS In an impact fee system, it is important to clearl y define the geographic areas within which impact fees will be collected and within which the fees collected will be spent. There are really two types of geographic areas that serve different functions in an impact fee system: assessment districts and benefit districts. Assessment districts, which may also be calle d service areas, define the area within which a set of common capital facilities provides service, and fo r which a fee schedule based on average costs within 13276 research blvd , ste 208 austin tx 78750 phone 512 258 7347 fax 512 258 9994 email clancy@duncanplan.com # # # # Infrastructure and Public Facility Needs Assessment St udy – Ordinance Issues Memorandum, March 1, 2006, page 7 that district is calculated. It is recommended that there be on In other words, all fees will be ca lculated on a county-wide basis. While there may be some geogra variations in land and construction costs, any addi tional accuracy in fee calculations would be offset by greater complexity and administrative difficulty. G. BENEFIT DISTRICTS Benefit districts represent an area within which the fees collec improvements funded with impact fees are constru cted within reasonable proximity of the fee-paying developments as a means of helping to ensure that Figure 1 developments benefit from the improvements. PROPOSED EAST/WEST DISTRICTS Concern has been expressed th at a broad-based impact fee should be restricted to internal subdivision improvements like roads and parks, because otherwise owners of individual lots would not feel they were g etting any benefit. However, It would not be practical to make every subdivision its own benefit district, as some of them will have little development. Most types of facilities serve a much larger area. Given the size of the is land, it may be necessary at a minimum to have East and West benefit districts for all types of facilities. Any benefit district boundaries should match judicial district boundaries to the extent practical. Suggested benefit district boundaries for roads, fire, police and solid waste facilities are illustrated in Figure 1. The proposed east/west benefit district boundaries conform with existing judicial district boundaries. In proposing the benefit district boundaries, the Consultant attempted to balance current population and projected population growth. Figure 2 Since parks tend to serve a smaller geographic areas than PROPOSED PARK DISTRICTS other facilities, it is recommended that the County create several benefit districts for park impact fees. The County currently restricts fair share assessments to the judicial district in which they were collected. There are nine judicial districts, and these were utilized in developing five proposed park development districts shown in Figure 2. Some of the judicial distri cts were combined since fewer benefit districts provide greater flexibility in the expenditure of fees collected. In developing the districts, the consultant looked at existing parks and development patterns and combined several districts to create five park and recreation impact fee benefit districts. Wastewater impact fees could be subject to either the east/west or the five benefit districts, but would need to be further restricted to be spent only to improve the system that the fee payer is physically connected to. Language in the ordinance would allow revenues collected 13276 research blvd , ste 208 austin tx 78750 phone 512 258 7347 fax 512 258 9994 email clancy@duncanplan.com # # # # Infrastructure and Public Facility Needs Assessment St udy – Ordinance Issues Memorandum, March 1, 2006, page 8 in any district to be spent on coun ty-wide facilities. For example, landfill improvements should be funded from solid waste fees from all benefit dist ricts, since the CountyÔs one functioning landfill serves the entire island. H. AFFORDABLE HOUSING PROJECTS The key characteristic of an impact fee is that th e amount of the fee is proportional to the impact on facilities. To waive fees for affordable housi ng projects or other policy goals may weaken the defensibility of the impact fee system, since opponents could ar but an illegal tax disguised as a fee. Consequently, any waiver of fees for affordable housing or other purposes should be paid by other funding sources. I. PROGRESSIVE RESIDENTIAL FEES Figure 3 One thing that can be done to mitigate the effect on RESIDENTS BY UNIT SIZE affordable housing is to reduce fees for the smaller and more affordable units to the extent that it can be demonstrated that smaller units have less of an impact on the need for facilities. We recommend that the CountyÔs impact fees in corporate progressive fees for single-family homes that vary by the size of the dwelling unit. For the most part, the variation in fees will reflect the average number of people residing in units of varying sizes. The relationship determined in the Growth Policy Memorandum is illustrated in Figure 3. The observed variation is not dramatic, since even very small units tend to have an average of almost three residents, and very large units tend to have less than four residents. Nevertheless, these data do justify some variati on in fees by dwelling size. The graphed relationship shows that the larger the dwelling unit As can be seen in Table 4, a single-family detached unit with less than 1,000 square feet has an average of 2.78 persons, while a unit with 4,000 square f eet averages 3.68 residents. Fees directly based on population, such as park fees, would vary propor tionately with average household size, and fees indirectly based on population, such as road impact fees, would dwelling size categories shown below are suggested for use in th 13276 research blvd , ste 208 austin tx 78750 phone 512 258 7347 fax 512 258 9994 email clancy@duncanplan.com # # # # Infrastructure and Public Facility Needs Assessment St udy – Ordinance Issues Memorandum, March 1, 2006, page 9 Table 2 SINGLE-FAMILY HOUSEHOLD SIZE BY SQUARE FEET Approximate Average midpoint Household (sq. ft.) Size Dwelling Size Category Less than 1,000 sq. ft.750 2.84 1,000 - 1,499 sq. ft.1,250 2.95 1,500 - 1,999 sq. ft.1,750 3.06 2,000 - 2,999 sq. ft.2,500 3.23 3,000 - 3,999 sq. ft.3,500 3.45 4,000 sq. ft. or more4,500 3.68 Source: Average household size is derived by substituting the midpoint solving for y in the equation illustrated in Figure 3. J. COST RECOVERY The impact fee study will calculate maximum fees that can be charged. Preliminary analysis indicates that the total maximum impact fees will exceed the curre nt total fair share assessments. The fair share assessments are compared with California and national average impact fees in Table 4. HawaiÓi CountyÔs assessments for roads and parks are significantly higher than the national average, although they are right in line with average fees charged in California. The total fair share assessment in HawaiÓi County par with what the average jurisdiction in Californi a charges in impact fees for the same facilities. Table 3 FAIR SHARE ASSESSMENTS PER SINGLE-FAMILY UNIT Facility HawaiÓi CA Avg.NatÔl Avg. Co. Roads$4,281 $3,922$2,037 Parks$4,818 $4,856$1,810 Fire$459 $584$329 Police$232 $843$302 Solid Waste$201 na$179 Total$9,991 $10,205$4,657 Source: HawaiÓi County fair share assessmen ts; California and national average fees from Duncan Associates survey, January 4, 2006 The maximum fees that will be calculated in the im pact fee study will represent the full cost to provide new development with the existing le vel of service of capital facilities. However, the County will to adopt impact fees at some percentage less than 100 percent of K. PHASE-IN PERIOD Following the adoption of the impact fee ordinance, th ere will need to be a period of time before the impact fees actually go into effect and being to be collected. Some delay is necessary in order to give development projects already well underway time to apply for bui projects. County staff will also need time to put the administrative processes in place to implement the 13276 research blvd , ste 208 austin tx 78750 phone 512 258 7347 fax 512 258 9994 email clancy@duncanplan.com # # # # Infrastructure and Public Facility Needs Assessment St udy – Ordinance Issues Memorandum, March 1, 2006, page 10 ordinance. After discussions with staff, it is reco mmended that the impact fees go into effect one year from the date of ordinance adoption. The fair share assessments would continue to be in effect duri this period, but would be repealed on the effective date of the In addition, we often recommend that substantial n ew or increased impact fees be phased-in over 6-18 months. For example, the fees might go into effect initially at 50 percent, then go up to 75 percent after six months and 100 percent or wha tever the ultimate level is after a year. 13276 research blvd , ste 208 austin tx 78750 phone 512 258 7347 fax 512 258 9994 email clancy@duncanplan.com # # # # Infrastructure and Public Facility Needs Assessment St udy – Ordinance Issues Memorandum, March 1, 2006, page 1 APPENDIX A: IMPACT FEE GLOSSARY Assessment Districts refer to geographic areas subject to a uniform impact fee sched Benefit Districts refer to geographic areas in which impact fees collected are earmarked to be spent. Deficiencies, Existing refers to the cost to provide developm ent existing at the time of adoption of an impact fee ordinance with the higher-than-existi ng level of service on which the impact fees are based. Development, Residential refers to subdivision of land for or construction of single-fam or multi-family dwelling units. Development, New refers to development that is not in existence at the time of a fee ordinance. Development, Nonresidential refers to subdivision of land for or construction of buildings other than residential development. Fair Share Assessments refers to the CountyÔs informal policy of requiring applicants for residential and hotel rezoning to agree to pay f ees at time of platting, site plan or building permit to cover p off-site infrastructure costs relating to roads, park s, fire, police and solid waste facilities. The amount of the fees are based on a 1990 st udy, with annual inflation adjustments based on the Consumer Pri Index. Grace Period refers to a period of time following ordi nance adoption during which an owner of a lot of record in existence at the date of ordinance adoption may apply fo r a building permit without being required to pay a fee. Impact Fees are one-time charges assessed on new development to cover prima infrastructure costs as authorized by Chapter 46, Part VIII of HawaiÓi Revised Statutes. Level of Service is a measure of the service pr ovided by a certain type of ca pital facility. In impact fee analysis, level of service is typically expressed as a ratio of some characteristic of the facility type to the amount of development being served. For exampl e, a common level of service measure for parks is acres of parkland per 1,000 residents. Level of Service, Existing refers to the actual level of servi ce provided by the County at the time of adoption of an impact fee ordinance. Level of Service, Higher-than-Existing refers to the calculation of impact fees based on the cost of providing a better leve l of service than is being provided to existing development at t adoption of an impact fee ordinance. Lot of Record, Existing refers to a parcel of property in existence on the date of adoption of an impact fee ordinance on which a building or structu re could legally be constructed without going through the CountyÔs subdivision process. 13276 research blvd , ste 208 austin tx 78750 phone 512 258 7347 fax 512 258 9994 email clancy@duncanplan.com # # # # Infrastructure and Public Facility Needs Assessment St udy – Ordinance Issues Memorandum, March 1, 2006, page 2 Lots in Older Subdivisions refers to lots that were created in the early 1950s and 1960s a conform to present-day subdivision co de requirements. Many of thes e lots were created without County facilities and services: they have private roads, which are often unpaved, no County water system, no parks, police or fire substations in the vicinity, an d are on cesspool. A large number of these lots are in the Puna and KaÓ u Districts. Phase-In Period refers to the time between the date of or dinance adoption and the date the impact fees go into effect. Rational Nexus refers to the doctrine articulated by the courts for constitutionally-valid impact fees, based on a Ñrational nexusÒ that must exist between the regulatory fee or exaction and the activity that is being regulated. The standards set by court ca ses generally require that an impact fee or other developer exaction meet a two-part test: (1) the need for new fa development; and (2) the expenditure of impact fee revenues must provide benefit to the fee-paying development. State Enabling Act refers to Chapter 46, § 141 to148 of HawaiÓi Revised Statutes, which was passed by the Legislature in 1992 and authorizes counties to assess, impose, levy and collect impact fees upon conducting a facility needs assessment study and the adoption of an impact fee ordinance. 13276 research blvd , ste 208 austin tx 78750 phone 512 258 7347 fax 512 258 9994 email clancy@duncanplan.com # # # #