HomeMy WebLinkAboutItem 2 - Hopkins
Item 2
Rcvd. 10/11/2017
October 11, 2017
Planning Commission
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
RE:10-11-2017Planning Commission Agenda Item 2: AB 1600 Requirements Nexus Study Update
Dear Esteemed Members of the Planning Commission:
Thank you for allowing us the opportunity to provide public comment regarding staff’s report for the Planning
Commission’s Study Session on Item 2: AB 1600 Requirements Nexus Study Update. We would like to offer a few
recommendations for the Planning Commission’s consideration below.
1.Create an interactive fee calculator to implementthenew fee schedule.
Concern:Calculatingfees is often an onerous task for developers and city staff alike. Although fee schedules are
intended to be straightforwardmathematical calculations,in practice, there is often greatconfusion in this
process.This is not a transparency issue, but rather, the result of fee complexity. As a result, project participants
spendprecious time working to determine fee payments, whichstaff may later recalculate. Additionally, from a
developer’s point of view, fee changescan be problematic as banks and investors begin underwriting a project to
one amount, only to pay another.
Recommendation: While the city’s Master Fee Schedule is helpful, it is not complete, as it does not include impact
fees. One innovative way to address this discrepancy would be to create an interactive and comprehensive online
fee calculator that could be used by both the city and developers when determining fees.Such a toolcould be
posted on the City’s website and require developers to input all relevant information about a project, which would
bequick, consistent, and efficient. This resource would reduce the time and headaches spent by all participants in
this process.
2.Stagger fee implementation for projects in the pipeline.
Concern:As you are already aware, developers often invest significant time and resources into a project years
before ever applying for a building permit. Developers must create a tight budget that will incentivize investment
and lending in a particular development. Fee schedules are a criticalcomponent of this budget, as it is a sizable
portion of predevelopment expenses. Therefore, it is important for developers to be able to anticipate fees or
potential changes to fees. The December implementation date notedin the staff report would make it difficult for
pipeline projects to adjust to the city’s new fee schedule.While this is problematic for both private projects, it is
particularly challenging for affordable housing, asregulatory agencies and deed-restrictions capincome fromrent.
Furthermore, at such a late stage in development, an affordable housing developer would be unable to seek
additional funds to close thefinancialgapcreated by the new fee schedule. Such a project would either be
significantly delayed or stopped altogether.
Recommendation: We recommend for the Planning Commission to consider delaying the fee implementation
schedule for projects that have already applied forentitlements through the City.These projects would be most
_______________________________________________________________________________________________
3533 Empleo Street, San Luis Obispo, CA 93401
26 E. Victoria Street, Santa Barbara, CA 93101
(805) 781-3088 phone • (805) 544-1901 fax (805) 961-5152 phone • (805) 962-8152 fax
admin@pshhc.org • www.pshhc.org
admin@pshhc.org • www.pshhc.org
Federal Tax ID #95-2750154
Item 2
Rcvd. 10/11/2017