HomeMy WebLinkAboutOrd 1283 and Res 2015-27 - Affordable Housing Impact Feeordinance No. 1283
Resolution No. 2015-27
CITY OF PALM DESERT
DEPARTMENT OF COMMUNITY DEVELOPMENT
STAFF REPORT
REQUEST: ADDITION OF CHAPTER 3.47 "AFFORDABLE HOUSING IMPACT
FEE" TO THE PALM DESERT MUNICIPAL CODE TO ESTABLISH
AN AFFORDABLE HOUSING FEE FOR NEW RESIDENTIAL
DEVELOPMENT WITHIN THE CITY OF PALM DESERT
SUBMITTED BY: Lauri Aylaian, Director of Community Development
APPLICANT: City of Palm Desert
73-510 Fred Waring Drive
Palm Desert, CA 92260
DATE: May 28, 2015
CONTENTS: 1. Ordinance No. 1283 (revised)
2. Resolution No. 2015 - 27 (revised)
3. Revised Computation of Potential Fee Revenue, dated May 28,
2015
4. May 12, 2015, Letter from Gretchen Gutierrez, DVBA CEO
5. April 23, 2015, Letter from Walter P. McNeill, McNeill Law Offices
6. April 23, 2015, Letter from Nathan Miller, BIA Director of
Government Affairs
7. Memorandum to Mr. Bill Blankenship from David P. Lanferman,
Rutan & Tucker LLP, dated April 22, 2015
8. Letter from Darrin Smith, Economic & Planning Systems, dated
May 14, 2015
9. Memorandum from Assistant City Attorney Robert Hargreaves to
City Council Members dated May 19, 2015
10. May 18, 2015 email message from Anthony Gonsalves regarding
AB 2 (Alejo), AB 1335 (Atkins), and SB 628 (Beall)
Recommendation
By Minute Motion:
1. Approve and file the Nexus -Based Affordable Housing Fee Analysis
for Rental Housing and the Nexus -Based Affordable Housing Fee
Analysis for For -Sale Housing, both dated April 2, 2015, and by
Economic & Planning Systems, Inc., and together the "Nexus Study."
Staff Report
Affordable Housing Impact Fee
Page 2 of 7
May 28, 2015
Waive further reading and:
Ordinance No. 1283
Resolution No. 2015-27
2. Pass Ordinance No. 1283 to second reading approving the
addition of Chapter 3.47 "Affordable Housing Impact Fee" to the Palm
Desert Municipal Code.
3. Adopt Resolution No. 2015- 27 establishing a fee of $2.00 per
square foot of livable space as the Affordable Housing Impact Fee for
new residential development in the City of Palm Desert.
Executive Summary
A proposed affordable housing fee ordinance was considered by the City Council on
April 23, 2015, at which time staff was directed to investigate alternative methods of
providing affordable housing and to try to find a way of mitigating the impact of market
rate housing on the need for affordable housing that would be mutually supported by
staff, the Building Industry Authority and the Desert Valleys Builders Association. This
report informs the City Council as to the outcome of the efforts to devise an approach
that would garner the support of all interested parties.
Approval of the staff recommendation presented herein would implement a fee of $2.00
per square foot of living space on new home construction and additions. The fee would
remain in place until or unless alternative funding mechanisms are made available, at
which time the matter would be revisited.
Background
On April 23, 2015, the City Council had a study session, then conducted a public
hearing on the concept of adopting a fee on new market -rate residential development to
help offset the cost to the community of the affordable housing demand created directly
by that new market -rate residential development. At the public hearing, several
representatives of the single-family residential development community spoke in
opposition to the proposed fee, and the City Council continued the matter to allow staff
the chance to work further with these interested parties to try to develop a
recommendation that would be supported by all who addressed the matter.
Since the matter was first heard by the City Council, staff has continued to speak,
correspond, and meet with single-family residential developers and representatives
from the Building Industry Association (BIA) and the Desert Valleys Builders
Association (DVBA). Discussions have been wide-ranging and informative, but
ultimately no consensus was reached. Therefore, staff has returned to the City Council
with answers to questions posed by councilmembers and with a modified fee ordinance,
but without the support of the BIA and the DVBA, who continue to request that no fee,
regardless of the amount, be imposed. Letters from these organizations, as well as their
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Staff Report
Affordable Housing Impact Fee
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Ordinance No. 1283
Resolution No. 2015-27
legal advisors, are attached to this staff report. The responses to these letters, provided
by the Assistant City Attorney and the consultant who prepared the Nexus Study, are
also appended.
Answers to the Questions of Councilmembers
During the study session and subsequent public hearing, several members of the City
Council asked for more information concerning the follwing: how other cities are
providing affordable housing now that redevelopment funds are no longer available;
how Palm Desert stacks up against other Coachella Valley cities regarding Regional
Housing Needs Allocation (RHNA) numbers and the amount of affordable housing units
available; and new or proposed legislation that would assist with the production of
affordable housing.
Affordable Housing Development in Other California Cities: At the April 23, 2015, public
hearing on the proposed affordable housing fee, Councilmembers wanted to know of
programs or mechanisms through which other California cities are meeting their
affordable housing obligations. Staff investigated the matter by consulting with
developers of affordable housing and with staff from other cities in the Coachella Valley
that have produced affordable housing units since redevelopment agencies were
dismantled in 2011. Staff also searched technical literature and journals on
development and affordable housing to find what funding mechanisms were employed
on featured projects. The findings were consistent everywhere: the only way that
affordable housing projects have been built in California since the loss of
redevelopment is with tax credit financing. Tax credit financing is awarded on a
competitive basis to projects that meet specific requirements for proximity to jobs and
transportation, energy conservation and sustainability, density and land use, and that
have a significant amount of soft debt in the project. To win tax credits for financing
affordable housing in Riverside and San Bernardino Counties, a developer will need to
provide 40 to 50 percent of his financing in the form of free land, reduced or waived
fees, matching grants, or cash contributions. Since Palm Desert's development fees
account for a small portion of total development costs, even a complete waiver of them
will not make affordable housing development feasible. Money, such as that collected in
the form of the proposed fee, can be used to buy land, pay for offsite infrastructure, or
otherwise contribute to project as needed to secure the tax credit financing.
Affordable Housing Units and RHNA Numbers in the Coachella Valley: It can be useful
to view Palm Desert's affordable housing program in context with neighboring
Coachella Valley cities. The following information was compiled to show where Palm
Desert falls relative to other Valley cities with regard to the amount of affordable
housing provided, and the Regional Housing Needs Allocation requirements imposed of
or the near future (2014-2021). The RHNA numbers include only the low-income and
very -low income units, since in the Coachella Valley the open market generally fulfills
the RHNA need for moderate -income housing. Additionally, the numbers have been
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Staff Report
Affordable Housing Impact Fee
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Ordinance No. 1283
Resolution No. 2015-27
adjusted to per dwelling unit figures, since it would not be meaningful to compare Palm
Desert's numbers with those of a city whose population is, for example, 65% larger
(Indio) or 90% smaller (Indian Wells).
City
RHNA Low and
Very Low
Income Unit
Allocation for
2014 - 2021
Coachella
4,458
Desert Hot Springs
1,607
Indio
1,201
Cathedral City
236
Palm Desert
165
La Quinta
152
Palm Springs
106
Indian Wells
67
Rancho Mirage
38
City
% subsidized
units
Coachella
10
Cathedral City
7.4
Indio
5.4
Palm Desert
5
Palm Springs
5
La Quinta
4.9
Indian Wells
4.2
Rancho Mirage
4.1
Desert Hot Springs
Not available
RHNA
Allocation per
City
100 Dwelling
Units
Coachella
45.00
Desert Hot
14.74
Springs
Indio
4.15
Indian Wells
1.3
Cathedral City
1.12
La Quinta
0.65
Palm Desert
0.45
Palm Springs
0.3
Rancho Mirage
0.27
City
Subsidized
Units
Palm Desert
1,867
Palm Springs
1,732
Indio
1,576*
Cathedral City
1,548
La Quinta
1,145
Coachella
995
Rancho Mirage
591
Indian Wells
218
Desert Hot Springs
Not available
* Includes homeless shelter beds
Recent and Proposed Legislation: Two bills that would provide funding for affordable
housing have been introduced into the legislature, AB 2 (Alejo and Garcia) and AB
1335 (Atkins). The former would establish an RDA -like program that would receive tax
increment and issue debt for communities with crime rates 5% above and
unemployment 3% above statewide averages; Palm Desert would not likely be eligible.
The latter is almost identical to two previous bills, SB 391 and SB 1220, both of which
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Affordable Housing Impact Fee
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Ordinance No. 1283
Resolution NO. 2015-27
would have imposed a $75 transaction fee on all home sales, with the proceeds going
to the State for allocation to affordable housing in various local jurisdictions. Both
previous bills failed before making it out of the legislature, and the current bill, which
requires a 2/3 majority approval to pass, is not likely to be more successful than its
predecessors.
On a positive note, enactment of SB 628 last year allows cities to establish enhanced
infrastructure financing districts, which can be used to acquire, construct, or rehabilitate
affordable housing projects. These financing districts would function much the same as
redevelopment project areas dis, selling bonds which would be repaid using tax
increment monies. Two shortcomings of relying on an enhanced infrastructure financing
district are that a 55% vote of property owners is required to approve a district, so
district formation is not assured, and the time required for formation is probably several
years —a public financing authority must be established, district needs, boundaries, and
goals defined, agreements negotiated with all taxing entities and adopted by each of
their governing boards, a financing plan prepared and adopted, and special elections
held. For these reasons, staff believes that an enhanced infrastructure financing district
holds potential for helping the City address affordable housing needs, but that it cannot
be counted on. Instead, staff recommends that an affordable housing fee be
established for residential development, and if/when a financing district is established,
the fee be reduced or eliminated at that time.
Attached to this report is Anthony Gonsalves' summary of each of these three pieces of
legislation, and his opinion as to likelihood of passage. Further details and legislative
analyses of these bills, as well as the chaptered language of the Enhanced
Infrastructure Financing District act, is available upon request.
Modified Fee Ordinance
Despite the fact no consensus was reached with the representatives of the BIA and the
DVBA, staff has revised the ordinance in response to a suggestion made by several
developers interested market -rate residential projects in the city. They requested that
the fee be based upon net livable square footage of the market -rate homes, rather than
on gross square footage. This change essentially means that garage space will not be
included in the computation of fees, which is consistent with the manner in which other
fees are handled, and that the fee revenue generated during build out of the city will be
reduced by $2.7 to $3.6 million. Clearly, the fee per square foot could simply be
increased to offset the reduction in average home size by 400 square feet, leading to
the same potential fee generation as was originally proposed. However, in
consideration of the partnership historically forged between Palm Desert and the
developers who build our residential neighborhoods, staff recommends that the fee be
adopted at the $2.00 per square foot rate supported in the original recommendation.
The ordinance, resolution, and Computation of Potential Fee Revenue have been
revised to reflect this change, and are appended to this staff report.
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Staff Report
Affordable Housing Impact Fee
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Ordinance No. 1283
Resolution NO. 2015-27
Additionally, if the City Council adopts the proposed fee, staff recommends that the
Council reconsider the issue when and if conditions impacting affordable housing
development change. For instance, if an infrastructure financing district is established in
Palm Desert, or if new sources of federal or state funding become available for
affordable housing, or if a regional approach to funding is adopted, the Council should
review the necessity (or lack thereof), appropriateness, and amount of the fee and
adjust or eliminate it accordingly.
Conclusion and Recommendation
Support for the proposed affordable housing fee is not unanimous. Representatives
from the BIA and the DVBA have asked that no fee be imposed, and several individual
residential developers who have met with City staff have suggested that a lesser fee be
imposed. However, staff believes that provision of a modest revenue stream to mitigate,
at least in part, the need for affordable housing caused by the development of market
rate housing is an important part of the community fabric of Palm Desert.
Alternative sources of funding for affordable housing have been investigated, and none
have proven to be available in the near term. Adoption of the proposed ordinance does
not preclude use of alternative funding mechanisms when and if they become available.
If such other opportunities are implemented, the proposed fee can be revised or
eliminated, as would be determined to be appropriate at that time.
Palm Desert has a history of being a leader in the Coachella Valley, and such
leadership does not always enjoy unanimous support at the outset. The fact that other
Valley cities have not established an affordable housing fee does not mean that it
should not be done. Palm Desert will remain a premier city in which to live, build, and
do business, attracting investors, residents, and tourists alike, at least in part due to its
commitment to making sound long-range decisions that enhance the quality of life for
all who reside here. Staff believes that adoption of the proposed ordinance is one
example of the way in which Palm Desert weighs the thoughts and opinions of all
concerned, and decides in favor of a well-grounded, reasonable step forward.
Environmental Review
The establishment of an affordable housing impact fee constitutes the creation of a
government funding mechanism that involves no commitment to a specific project,
therefore, is a non -project in terms of CEQA.
Fiscal Analysis
The estimate of potential revenue for an affordable housing impact fee of $2.00 per
square foot of livable area (excludes garages) applied to residential development through
build -out of the City, assumed to be in 20 years, is $11.3 to $20.7 million, depending on
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Affordable Housing Impact Fee
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Ordinance No. 1283
Resolution No. 2015-27
the densities of future development and the sizes of dwelling units constructed. (This
number has been reduced from the $14.0 to $24.5 million in revenue that was projected
based upon gross home size.)
As discussed in the April 23, 2015 staff report, the revenue from this fee could be used
most effectively to provide affordable housing through a variety of programs, such as
those identified in the current Housing Element. These programs include purchasing and
renovating existing, blighted housing units; purchasing extensions for affordability
covenants that are set to expire in the near future; providing financial assistance to private
developers for constructing and operating new multi -family dwelling units; etc. A detailed
calculation of this potential revenue is attached to this report.
Submitted By:
auri Aylaian, Director of Community beveleMent
Review
Paul S. Gibson, Director of Finance
proval:
in M. Wohlmuth, City Manager
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ORDINANCE NO. 1283
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF PALM
DESERT, CALIFORNIA, ADDING A CHAPTER TO THE CITY OF PALM
DESERT MUNICIPAL CODE TO ESTABLISH AN AFFORDABLE
HOUSING FEE FOR ALL NEW RESIDENTIAL DEVELOPMENT WITHIN
THE CITY OF PALM DESERT
THE CITY COUNCIL OF THE CITY OF PALM DESERT, CALIFORNIA, DOES
ORDAIN AS FOLLOWS:
WHEREAS, the City Council of the City of Palm Desert, California, held a duly
noticed public hearing on the 23d day of April 2015, continued to the 28th day of May 2015,
to consider an affordable housing impact mitigation fee to be assessed against all new
market rate residential development within the City; and
WHEREAS, that at said public hearing, upon hearing and considering all testimony
and arguments, if any, of all interested persons desiring to be heard, and after considering
the staff report and its exhibits, the City Council found the following facts to justify their
actions as described below:
There exists a shortage of very low, low, and moderate income housing within
the city of Palm Desert and surrounding communities.
2. As the city is built out over the next twenty (20) years, the residents who move
into the new market rate housing development will require goods and services
that are produced, provided, and/or sold by persons who have service industry
jobs, which are typically lower -paying jobs that do not compensate their
employees highly enough that they can afford to live in market -rate housing in
the city of Palm Desert.
3. The city of Palm Desert stands to benefit when there is a balance between jobs
offered in the city and the housing provided therein: traffic is lessened when
fewer workers need to commute in from other cities; parents work near to where
their children attend school and can more easily engage in school -related
activities; families can participate in more activities in their communities by virtue
of spending less time commuting to and from work; and residents and visitors
alike are serviced by people who are proud of Palm Desert, which is their home.
4. The City of Palm Desert understands the importance of continual planning for
affordable housing and intends to encourage, in accordance with the approved
Housing Element, the integration of affordable housing throughout the community
by requiring that market -rate residential development be complemented with
affordable dwelling units either within or adjacent to the market -rate units; the
City is also prepared to accept payment of a reasonable impact fee in lieu of
requiring that all market -rate developers simultaneously construct affordable
dwelling units, when such requirement is not consistent with the goals and
policies of the General Plan or is otherwise not feasible.
ORDINANCE NO. 1283
5. The former City of Palm Desert Redevelopment Agency, which was the primary
source of funding for Palm Desert's affordable housing program, was abolished
by the State of California in 2011, leaving only nominal funding available through
which the City can assist the private sector in the provision of subsidized
affordable housing.
6. With sufficient funding, the City of Palm Desert can assist in providing affordable
housing by: acquiring blighted housing stock, renovating it, and establishing
affordability covenants on it; providing below -market rate interest loans to
developers of affordable housing; providing land at reduced or no cost to not -for -
profit affordable housing developers; purchasing extensions of affordability
covenants on existing affordable units when those covenants are scheduled to
expire; purchasing affordability on suitable existing market -rate dwelling units;
and other means that will stabilize or increase the inventory of affordable housing
stock in the city of Palm Desert.
WHEREAS, the City Council considered the "Nexus -Based Affordable Housing Fee
Analysis for Rental Housing" and the "Nexus -Based Affordable Housing Fee Analysis for
For -Sale Housing," both dated April 2, 2015, and prepared by Economic & Planning
Systems, Inc. of Oakland, California, and attached to the 23 April 2015 staff report as
Exhibits "A" and "B," respectively, and referred to collectively as the "Nexus Study," which
Nexus Study establishes the nexus between construction of new market rate housing and
the need for affordable housing in the community, and which Nexus Study also
demonstrates that affordable housing impact fees of $9.24 to $12.38 per square foot for for -
sale housing units and $13.50 to over $20.00 per square foot for rental housing units would
be needed to fully mitigate the impacts on the need for affordable housing of new market
rate units with sales prices between $200,000 and $1.2 million; and
WHEREAS, the nexus exists for all new residential construction, including any
residential remodel or addition that increases the number of bedrooms, thereby increasing
the capacity for residents, whether the new home or addition be a custom home or a tract of
homes, and whether the home(s) be single family or multi -family; and
WHEREAS, the City Council also considered the Memorandum regarding
Implementation Considerations for Palm Desert Affordable Housing Impact Fees dated
March 18, 2015, prepared by Economic & Planning Systems, Inc. of Oakland, California,
and appended to the 23 April 2015 staff report as Exhibit "C," which recommends that
affordable housing impact fees lower than the maximum permissible fees be adopted; and
WHEREAS, the City Council desires to adopt and implement affordable housing
impact fees for both residential rental development and residential ownership development,
including for residential remodel or addition projects that increase the number of bedrooms
in a residence, to mitigate the impact of this market rate development on the need for
affordable housing, while ensuring that those market rate developments remain
economically feasible; and
WHEREAS, the proposed affordable housing impact fee is reasonably related to the
impact resulting from the type of development upon which the fee will be imposed and the
fees generated and will not exceed the reasonable cost estimate of the housing program.
2
ORDINANCE NO. 1283
The fee rate is projected to generate approximately $11.3 to $20.7 million of the total $112.6
million required to facilitate implementation of the goals and programs described in the
currently adopted Housing Element of the City of Palm Desert Comprehensive General
Plan, which is only 10.0 to 18.4% of the total program mitigation costs.
NOW, THEREFORE, BE IT ORDAINED by the City Council of the City of Palm
Desert, California, does hereby determine that it is in the public interest that market rate
residential development in the City be supplemented by affordable residential development
to provide housing opportunities for the workers needed to fill jobs created to service the
residents in the new market rate development.
BE IT FURTHER ORDAINED AS FOLLOWS:
Section 1: Accounting and disbursement of fees: The affordable housing impact
fees collected shall be deposited into the City's affordable housing fund
to be used only for the provision of affordable housing in accordance
with policies and programs identified in the approved Housing Element
of the City of Palm Desert General Plan, and
Section 2: Chapter 3.47 is hereby added to the City of Palm Desert Municipal Code
to read as shown in attached Exhibit "A."
PASSED, APPROVED, AND ADOPTED by the City Council of the City of Palm
Desert, California, at its regular meeting held on the 28th day of May 2015, by the
following vote, to wit:
AYES:
NOES:
ABSENT:
ABSTAIN:
ATTEST:
RACHELLE D. KLASSEN, CITY CLERK
CITY OF PALM DESERT, CALIFORNIA
a:100 : IIN-11aC07ITS$V81A
DAVID J. ERWIN, CITY ATTORNEY
Susan Marie Weber, Mayor
3
ORDINANCE NO. 1283
EXHIBIT "A"
CHAPTER 3.47 AFFORDABLE HOUSING IMPACT FEE ON NEW MARKET RATE
RESIDENTIAL DEVELOPMENT
3.47.10.1 Purpose, Use, and Findings.
A. There exists shortageof very low, low, and moderate income housing within the
City of Palm Desert and surrounding communities.
B. As the City of Palm Desert is built out over the next twenty years, the residents
who move into the new market rate housing development will require goods and services
that are produced, provided, and/or sold by persons who have service industry jobs, which
are typically lower -paying jobs that do not compensate their employees highly enough that
they can afford to live in market -rate housing in the city of Palm Desert.
C. The City of Palm Desert stands to benefit when there is a balance between jobs
offered in the city and the housing provided therein: traffic is lessened when fewer workers
need to commute in from other cities; parents work near to where their children attend
school and can more easily engage in school -related activities; families can participate in
more activities in their communities by virtue of spending less time commuting to and from
work; and residents and visitors alike are serviced by people who are proud of Palm Desert,
which is their home.
D. The City of Palm Desert understands the importance of continual planning for
affordable housing and intends to encourage, in accordance with the approved Housing
Element, the integration of affordable housing throughout the community by requiring that
market -rate residential development be complemented with affordable dwelling units either
within or adjacent to the market -rate units; the City is also prepared to accept payment of a
reasonable impact fee in lieu of requiring that all market -rate developers simultaneously
construct affordable dwelling units, when such requirement is not consistent with the goals
and policies of the General Plan or is otherwise not feasible.
E. The former City of Palm Desert Redevelopment Agency, which was the primary
source of funding for Palm Desert's affordable housing program, was abolished by the State
of California in 2011, leaving only nominal funding available through which the City can
assist the private sector in the provision of subsidized affordable housing.
F. With sufficient funding, the City of Palm Desert can acquire interest in real
properties that provide affordable housing by: acquiring blighted housing stock, renovating
it, and establishing affordability covenants on it; acquiring affordability covenants by
providing below -market rate interest loans to developers of affordable housing and/or
providing land at reduced or no cost to not -for -profit affordable housing developers;
purchasing extensions of affordability covenants on existing affordable units when those
covenants are scheduled to expire; purchasing affordability covenants on existing, suitable
market -rate dwelling units; and other means that will stabilize or increase the inventory of
affordable housing stock in the city of Palm Desert.
51
ORDINANCE NO. 1283
G. The City Council considered a nexus -based affordable housing fee analysis for
rental housing and a nexus -based affordable housing fee analysis for for -sale housing,
collectively referred to as the "Nexus Study," which Nexus Study establishes the nexus
between construction of new market rate housing and the need for affordable housing in the
community, and which Nexus Study also demonstrated that affordable housing impact fees
of $9.24 to $12.38 per square foot for for -sale housing units and $13.50 to over $20.00 per
square foot for rental housing units would be needed to fully mitigate the impacts on the
need for affordable housing of new market rate units with sales prices between $200,000
and $1.2 million.
H. The nexus exists for all new residential construction, including any residential
remodel or addition that increases the number of bedrooms, thereby increasing the capacity
for residents, whether the new home or addition is a custom home or a tract of homes, and
whether the home(s) be single family or multi -family.
I. The City Council also studied implementation considerations, including the
financial impact of such fees on potential development in the City, and concluded that it was
appropriate to adopt affordable housing impact fees lower than the maximum permissible
fees.
J. The City Council desires to adopt and implement affordable housing impact fees
for both residential rental development and residential ownership development, including for
residential remodel or addition projects that increase the number of bedrooms in a
residence, to mitigate the impact of this market rate development on the need for affordable
housing, while ensuring that those market rate developments remain economically feasible.
K. The City Council of the City of Palm Desert does hereby determine that it is in the
public interest that market rate residential development in the city be supplemented by
affordable residential development to provide housing opportunities for the workers needed
to fill jobs created to service the residents in the new market -rate development.
3.47.020 Accounting and Disbursement of Fees. The affordable housing impact
fees paid pursuant to this chapter shall be deposited into the City's affordable housing fund
to be used only for the provision of affordable housing in accordance with policies and
programs identified in the Housing Element of the City of Palm Desert General Plan which
is approved and adopted at the time of payment of fees.
3.47.030 Calculation and Payment of Fee.
A. The affordable housing impact fee paid pursuant to this chapter shall be applied
to new market rate residential development. For the purposes of this chapter, "new market -
rate residential development" is defined as the construction of any new dwelling unit,
including for -sale or rental homes, apartments, time-share units, and condominiums, or the
remodel of or addition to any such dwelling unit, which remodel or addition creates one or
more new bedrooms.
B. Calculation of fee shall be based upon the square footage of the livable building
area (including bedrooms, bathrooms, dining and living rooms, hallways, recreation rooms,
dens, libraries, casitas, and other conditioned space, but excluding garages, carports,
storage sheds, and the like) of the dwelling unit or, in the case of a remodel or addition
5
ORDINANCE NO. 1283
described in 3.47.030 A, upon the square feet of the living area of the new bedroom(s).
C. The fee enacted by this chapter shall be paid to the City of Palm Desert prior to
issuance of the building permit for the dwelling unit.
3.47.040 Exemptions. The affordable housing impact fee shall not apply to
mobile homes, to new dwelling units on which affordability covenants are recorded if those
covenants are for a period of thirty (30) years or longer, or to any new single family home
that is less than 1,250 square feet in size and situated on an infill lot.
RESOLUTION NO. 2015 - 27
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PALM
DESERT, CALIFORNIA, ESTABLISHING FEES PURSUANT TO CHAPTER
3.47 OF THE MUNICIPAL CODE OF THE CITY OF PALM DESERT
WHEREAS, it is determined that there is a need for affordable housing in Palm
Desert, and the State of California has mandated that local governments provide for
affordable housing through their zoning and development ordinances, Palm Desert has
chosen to use its police power land use planning authority to provide for affordable housing;
and
WHEREAS, applicable goals, policies and actions of the adopted 2004 City of Palm
Desert Comprehensive General Plan, including the Housing Element (as updated and
adopted in 2013), demonstrate the need for affordable hosusing in Palm Desert; and
WHEREAS, on May 28, 2015 the City Council approved an ordinance creating
Chapter 3.47 "Affordable Housing Impact Fee" of the Palm Desert Municipal Code that,
among other things, includes establishment of an Affordable Housing Impact Fee to be
adopted by the City Council and applicable only to development of new market -rate
residnetial for -sale and rental dwelling units, including additions and remodels to existing
units when those additions/remodels increase the number of bedrooms in existing dwelling
units, that shall be based upon the cost of mitigating the impact of market -rate units on the
need for affordable housing in the city, and
WHEREAS, the City Council has considered and adopted an ordinance to add
Chapter 3.47 to the Municipal Code to also implement goals, policies, and actions of the
2013 Housing Element update; and
WHEREAS, on April 23 and May 28, 2015, the City Council considered the "Nexus -
Based Affordable Housing Fee Analysis for Rental Housing" and the "Nexus -Based
Affordable Housing Fee Analysis for For -Sale Housing," both dated April 2, 2015, and
prepared by Economic & Planning Systems, Inc. of Oakland, California and referred to
collectively as the "Nexus Study," which Nexus Study demonstrates that affordable housing
impact fees of $9.24 to more than $20.00 per square foot of new market rate development
would be needed to fully mitigate the impacts of such development on the need for
affordable housing; and
WHEREAS, to ensure the economic feasibility of residential development, including
new market -rate units and the addition of new bedrooms to existing residential
development, the memorandum entitled Implementation Considerations for Palm Desert
Affordable Housing Impact Fees dated March 18, 2015, prepared by Economic & Planning
Systems, Inc., recommends that affordable housing impact fees lower than the maximum
permissible fees be adopted; and
WHEREAS, the City Council desires to adopt and implement affordable housing
impact fees for market -rate residential development while ensuring that that development
remain economically feasible; and
RESOLUTION NO. 2015- 27
WHEREAS, affordable housing impact fees collected shall be deposited into the
Affordable Housing Fund to be used only for acquiring interest in real properties that provide
affordable housing, consistent with the goals and programs identified in the currently
adopted Housing Element of the Palm Desert Comprehensive General Plan so as to
provide housing options to persons and families of very low, low, and moderate income; and
WHEREAS, at least 10 days prior to the date this resolution is to be considered,
data was made available to the public indicating the amount of cost, or estimated cost,
required to provide the service for which the fee or service charge is levied and the revenue
sources anticipated to provide the service, including general fund revenues in accordance
with Government Code Section 66019; and
WHEREAS, at least fourteen days prior to the date this resolution is to be
considered, notice was mailed to those persons who had requested same in accordance
with Government Code Section 66019; and
WHEREAS, notice of the hearing on the proposed fees was published twice in the
manner set forth in Section 6062a as required by Government Code Section 66018; and
WHEREAS, a public hearing was conducted and the public notice and availability of
estimated costs were available to the public at least ten days prior to the meeting, all in
accordance with Government Code Sections 66018 and 66019.
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Palm
Desert, California, does hereby approve establishment of an affordable housing impact fee
of two dollars ($2.00) per square foot of livable building area (as defined in Section
3.47.030.13 of the Palm Desert Municipal Code) for new residential market -rate for -sale and
rental dwelling units, including new bedrooms added to existing market -rate dwelling units.
PASSED, APPROVED, and ADOPTED by the City Council of the City of Palm
Desert, California, at its regular meeting held on the day of , 2015,
by the following vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
Susan Marie Weber, Mayor
ATTEST:
RACHELLE D. KLASSEN, CITY CLERK
CITY OF PALM DESERT, CALIFORNIA
COMPUTATION OF POTENTIAL FEE REVENUE
City of Palm Desert — Affordable Housing Impact Fee
Revised 28 May 2015
The computation of potential fee revenues begins with identifying the amount of vacant
land in Palm Desert on which market rate housing can be developed. For this, an
inventory of vacant residential land has been prepared using the current approved
Housing Element inventory as a basis, and supplementing it with other vacant parcels
which are being considered for residential development. This inventory is presented
below.
Assessor's Parcel No.
General Plan/Zone
Size
(Acres)
Potential
Units @ Max.
Density
694-130-017 D
R-M, R-HO/PCD
10.21
176
694-130-021 G
R-M, R-HO/PR-20
24.16
200
694-130-018 D
R-M, R-HO/PR-20
3.48
72
694-190-008 (H)
MU/PR-20
15 of
29.36
160
694-200-014 (J)
R-M, R-HO,
MU/PR-20
11.46
194
694-130-012 1
R-M, R-HO/PR-5
33.71
235
694-130-003 F
R-M, R-HO/PR-20
18.92
302
685-010-005 (A)
C-R/PR-20
30
432
694-310-001 & 005 B)
C-R/PR-22
10
200
694-120-012 1
I-BP/PR-20
10
200
627-273-018
R-M/R-3
0.3
7
627-273-005
R-M/R-3
0.3
7
625-171-001
R-M/R-3
0.3
7
627-121-044
R-H/R-3
0.25
6
627-121-045
R-H/R-3
0.25
6
627-301-022
R-H/R-3
0.31
7
627-153-007
R-H/R-3
0.22
5
627-101-033, -038, -039, -002, -
017
R-M/R-3
1.64
22
627-041-010 through 013, -29, 031
— 033
R-M/OP* and R-2
1'.20
19
627-051-002
R-M/R-2
0.16
2
627-031-030
RM/R-2
0.17
2
Revised Affordable Housing Impact Fee Revenue Calculation Page 1
627-052-006
R-M/R-2
0.17
2
627-052-031
R-M/R-2
0.16
2
627-052-033
R-M/R-2
0.16
2
627-084-001
R-M/R-2
0.22
2
627-084-003
R-M/R-2
0.19
2
627-182-004
R-M/R-1
0.20
1
627-182-005
R-H/R-1
0.20
1
627-182-006
R-H/R-1
0.17
1
627-351-042
R-M/R-2
0.20
2
627-351-019
R-M/R-1
0.17
1
625-224-001
R-M/R-1
0.19
1
625-126-009
R-H/R-3
0.14
2
625-061-018
R-M/R-1
0.15
1
625-021-008
R-M/R-1
0.19
1
625-031-011
R-M/R-1
2.20
1
625-032-011
R-M/R-1
0.21
1
624-241-008
R-M/R-1
0.12
1
Total Units (Table III-38 of
HousingElement)177.1
2,285
Potential Santa Rosa Golf
Course Project
79.5
306
Millennium — SFHs and
apartments
63
660
132 Acre Site (Shepherd Lane
132
660
170-Acre Site — Specific plan
under development — assume
75% residential
127
1,270
Less affordable apartments on
City land
-20
-400
TOTAL POTENTIAL AT MAX.
DENSITY
558.6
4,781
TOTAL POTENTIAL UNITS AT
LIKELY DENSITY (6-8 Dwelling
Units / acre
3,351 to 4,469
Revised Affordable Housing Impact Fee Revenue Calculation
Page 2
REVISED COMPUTATION OF POTENTIAL FEE REVENUE (continued)
City of Palm Desert — Affordable Housing Impact Fee
The total fee potential for all new residential development equals the sum of the fees for
each Dwelling Unit (DU), plus the sum of fees for additions to existing homes. A range
of fees will be calculated, since there are a range of manners in which the undeveloped
residential property in Palm Desert may be developed. The total fees collected will
depend upon the density of future residential development, and the size of the dwelling
units (both homes and apartments). Although the development pattern in Palm Desert
has historically been suburban, low density, single -story, single-family golf resort style
homes, the changing demographics and lifestyles indicate that future development
might be unlike development to date. Therefore, there is necessarily a degree of
uncertainty in these calculations.
Formulas:
Total Fee Revenue = Fees from new dwelling units + Fees from additions to existing dwelling units
Fee for Each Dwelling Unit = (Square Feet of Dwelling Unit) X (Fee per Square Foot)
Fee for Average DU = (Square Feet of Average DU) X (Fee per Square Foot)
Total fees for all new DU's = (Fee per SF) X (average SF of new DU's) X (total # of new DU's)
FIRST:
Calculate the total fees for all new dwelling units using expected densities of
development and estimated sizes of homes and apartments:
From the inventory table on the previous page, the total number of new dwelling units
may be as low as 3,351 but may be as high as 4,781.
Assuming that, in response to changing demographics and lifestyles, future
development of the inventoried lands will feature homes smaller than those historically
constructed in Palm Desert, the average size of new market -rate DU's is likely to be
between 1,600 and 2,100 square feet (SF) of livable space (excludes garages).
On the low end of the range, at an average size of 1,600 SF, the potential fee revenue
for 3,351 dwelling units would be:
Sum of fees for all new DU's = ($2.00 per GSF) X (average of 1,600 SF) X (3,351 DU's)
_ $10.7 Million
Revised Affordable Housing Impact Fee Revenue Calculation Page 3
while on the high end of the density range, but still with an average size of 1,600 SF, the fee
revenue for 4,781 dwelling units would be:
Sum of fees for all new DU's = ($2.00 per GSF) X (average of 1,600 SF) X (4,781 DU's)
_ $15.3 Million
Now for the high end of the range, at an average size of 2,100 SF, the potential fee revenue for
3,351 dwelling units would be:
Sum of fees for all new DU's = ($2.00 per SF) X (average of 2,100 SF) X (3,351 DU's)
_ $14.1 Million
and the fee revenue for 4,781 dwelling units would be:
Sum of fees for all new DU's = ($2.00 per SF) X (average of 2,100 SF) X (4,781 DU's)
_ $20.1 Million
NFXT-
Calculate the total fees for additions and remodels to existing homes.
Note that the number of residential remodels and additions that increase the number of
bedrooms is not directly tracked. However, an approximation can be made by starting
with the number of residential remodel/addition projects with construction values of
$15,000 or more in one year. (A bedroom addition likely will cost more than $15,000.)
In the calendar year 2014, the City of Palm Desert issued 178 building permits for
residential remodels and additions with a value of $15,000 or more. Assuming that 2/3
of these projects are for interior remodels of bathrooms, kitchens, and other living
space, without involving an increase in the number of bedrooms, there are 1/3 of 178 or
60 existing homes that increase the number of bedrooms, presumably by one bedroom
each, over the course of one year. The affordable housing impact fee for these projects
over the course of 20 years would be:
(60 bedrooms) X (avg. 250 SF per bedroom) X ($2.00 per SF) X (20 years) _
$600,000
The total fee potential for all new residential development equals the sum of the fees for
each DU, plus the sum of fees for additions to existing homes. From the information
above, the project range of the total fee revenues is:
Low end: $ (10.7 to 15.3)M + $600,000 = $ 11.3 to $15.9 million
High end: $ (14.1 to 20.1)M + $600,000 = $ 14.7 to $20.7 million
Revised Affordable Housing Impact Fee Revenue Calculation Page 4
2015 BOARD OF DIRECTORS
PRESIDENT
Joseph Hayes
First Bank
If VICE PRESIDENT
Bruce Maize
Fidelity Title
2nd VICE PRESIDENT
Fred Bell
Nobelf Energy Solutions
SECRETARYITREASURER
Eileen Eske
Pacific Premier Bank
VICE PRESIDENT
OFASSOCIATES
Allan Levin
Allan Levin & Associates
PAST PRESIDENT
Mark Benedetti
BMC Select Build
CHIEF EXECUTIVE OFFICER
Gretchen Gutierrez
DIRECTORS
Brian Benedetti
Brian Benedetti Construction
Andy Brakebill
Paul Associates Printing
Tom DuBose
Development Design & Engineering
Margaret Drun
Margaret Drury Construction
Nklario Gonzales
GHA Companies
Mark Gran
Strictly Business Consulting
Todd Hooks
Agua Caliente Band of Cahuilla Indians
Dave Lippert
Lippert Construction. Inc
Heather Loutsenhizer
Petta Building Group
Paul Mahonev
PMA Advertising
Deborah McGarrev
The Gas Company
Dan Olivier
Nethery Mueller Olivier
Alan Pace
Petra Geotechnical
John Powell. Jr.
Coachella Valley Water District
Marvin Roos
MSA Consulting Inc
Gre- Smith
Smith-Kandal Insurance/Real Estate
Phil Smith
Sunrise Company
Rvan Smith
Shea Homes
Patrick Swarthout
Imperial Irrigation District
City of Palm Desert
Community Development
May 12, 2015
MAY 18 2015
City of Palm Desert
John Wohlmuth, City Manager
73-610 Fred Waring Drive
Palm Desert, CA 92260-2578
Dear Mr. Wohlmuth,
The Desert Valleys Builders Association appreciates the time and
opportunities provided to the construction industry regarding the City's need
and desire to provide affordable housing accessibility within the City of Palm
Desert.
In a perfect world or even a stable economy, housing would be provided at a
full range of prices. For where there is a market, there will be someone to fill
that niche. Our experience in the home building industry has provided many
examples of when a market is inundated with a particular product to near
saturation, another will change their product line to meet the needs of other
sectors of the market. Of course shifts in such paradigms take time, especially
with the convincing of banks, financiers, and stock holders. But, it does
happen.
The Desert Valleys Builders Association recommends the City Council
NOT adopt the proposed affordable housing fee based on the followin::
reasons.
In the Coachella Valley, each City will have a general sales price point based
on cost of land and fees. Builders have also sized their product to the demand
and found that certain price points require appropriately sized living spaces
including the size of the lot.
Jeff wattenbarger 75100 Mediterranean • Palm Desert a CA 92211
Wattenbarger Construction (760) 776-7001 Office • (760) 776-7002 fax
www.thedvba.org
301*-, BOARD OF DIRECTORS
PRESIDENT
Joseph Hayes
First Bank
13' VICE PRESIDENT
Bruce Maize
Fidelitv Title
"'d VICE PRESIDENT
Fred Bell
Nobel] Energy Solutions
SECRETARYITREASURER
Eileen Eske
Pacific Premier Bank
VICE PRESIDENT
OFASSOCIATES
Allan Levin
Allan Levin & Associates
PAST PRESIDENT
Mark Benedetti
BMC Select Build
CHIEF EXECUTIVE OFFICER
Gretchen Gutierrez
DIRECTORS
Brian Benedetti
Brian Benedetti Construction
Andy Brakebill
Paul Associates Printin;
Tom DuBose
Development Design & Engineeiing
Margaret Drury
Margaret Drury Construction
Mario Gonzales
GHA Companies
Mark Gran
Strictly Business Consulting
Todd Hooks
Agua Caliente Band ofCahuilla Indians
Dave Lippert
Lippert Construction. Inc
Heather Loutsenhizer
Penta Building Group
Paul Mahoney
PMA Advertising
Deborah McGarrey
The Gas Company
Dan Olivier
Nethery Mueller Olivier
Alan Pace
Petra Geotechnical
John Po«ell, Jr.
Coachella Valley Water District
Marvin Roos
IvISA Consulting Inc
Greg Smith
Smith-Kandal Insurance,Reai Estate
Phil Smith
Sunrise Company
Rvan Smith
Shea Homes
Patrick Swarthout
Imperial Irrigation District
Compared to 2005 land prices, building in the City of Palm Desert is quite
affordable. But, today's buyers are a bit more wary and frugal. The builders
in Palm Desert are looking at products with 3.5-4 units per acre resulting in
significant land cost per unit. Referencing a recent study produced by Clear
Source Financial Consulting (and provided by the DVBA to City staff), land
cost per door in Palm Desert is approximately $78,500 per unit, when the
same sized property in Indio is $21,400 per unit. No matter which city in the
Coachella Valley, the cost of materials and labor are going to be similar.
Expected and purchased amenities vary greatly from unit to unit, and
community to community. Builders will price accordingly, with the
narrowest of profit margins since the 1980's.
The idea of a new fee at $2/sq.ft. raises significant concerns for the
homebuilding and selling industry. Looking at the same Comparative Fee
Study prepared by Clear Source Financial Consulting, we see that in the
process of total fees from planning thru processing to impact, the City of Palm
Desert falls currently in the middle of Coachella Valley cities in terms of cost
of doing business.
However, adding a $2 per square foot of construction (including garage space)
puts the City in the category of third most expensive City for fees right behind
Coachella (#1) at $47,273 at 3.5 units/acre, or $44,704 at 6.0 units/acre; Indio
(#2) at $45,298 with 3.5 units/acre, or $41,811 at 6.0 units per acre; Palm
Desert fees with a $2/sq. affordable housing fee including garage would cost
$44,838 with 3.5 units/acre, or $42,486 at 6.0 units/acre.
As we mentioned at the prior City Council meeting, there is a direct
correlation between the cost of housing and the number of potential buyers.
For every $1,000 increase in price, 10,000 or more potential buyers are lost
from the opportunity for home ownership. Additionally, a cost increase of
$1,000 in materials or fees do not equate to the cost displayed on the final sell
sheet. Depending upon the terms of the loans, the staff time to process, then
the amount of time before its paid, etc. all add up for the `Cost of Carry,'
which must be passed onto the prospective buyer.
Jeff Wattenbarger 75100 Mediterranean • Palm Desert • CA 92211
Wattenbarger Construction (760) 776-7001 office • (760) 776-7002 fax
www.thedvba.org
2015 BOARD OF DIRECTORS
PRESIDENT
Joseph Hayes
First Bank
If VICE PRESIDENT
Bruce Maize
Fidelity Title
2nd VICE PRESIDENT
Fred Bell
Nobell Energy Solutions
SECRETARYITREASURER
Eileen Eske
Pacific Premier Bank
VICE PRESIDENT
OFASSOCIATES
Allan Levin
Allan Levin & Associates
PAST PRESIDENT
Mark Benedetti
BNIC Select Build
CHIEF EXECUTIVE OFFICER
Gretchen Gutierrez
DIRECTORS
Brian Benedetti
Brian Benedetti Construction
Andy Brakebill
Paul Associates Printing
Tom DuBose
Development Design Br. Engineering
Margaret Drury
Margaret Drury Construction
Mario Gonzales
GHA Companies
Mark Gran
Strictly Business Consulting
Todd Hooks
Agua Caliente Band of Cahuilla Indians
Dave Lippert
Lippert Construction. Inc
Heather Loutsenhizer
Penta Building Group
Paul Mahonev
PMA Advertising
Deborah McGarrey
The Gas Company
Dan Olivier
Nethen Mueller Olivier
Alan Pace
Petra Geotechnical
John Pox%ell. Jr.
Coachella Valley Water District
Marvin Roos
MSA Consulting Inc
Greg, Smith
Smith-Kandal Insurance/Real Estate
Phil Smith
Sunrise Company
Ryan Smith
Shea Homes
Patrick Swarthout
Imperial Irrigation District
4
As requested by Councilmember Sabby Jonathan, the DVBA has looked into
alternatives for funding "affordable housing" units within the city limits of
Palm Desert. We referenced two (2) legislative bills currently moving though
the State Capitol offices and committees we believe could assist the City,
should they pass and get signed into law.
The first is AB 2 (Alejo and Eduardo Garcia) the Community Revitalization
Authority. Should this become law it will act similarly to the old RDA. There
are some exceptions, and some basic requirements. This is an incremental
taxation / bonding program. The designated Community Revitalization and
Investment Area must meet the following requirements:
(1) An annual median household income that is less than 80 percent
of the statewide annual median income.
(2) Three of the following four conditions:
(A) Non -seasonal unemployment that is at least 3 percent
higher than statewide median unemployment
(B) Crime rates that are 5 percent higher than the statewide
median crime rate
(C) Deteriorated or inadequate infrastructure such as streets,
sidewalks, water supply, sewer treatment or processing, and
parks.
(D) Deteriorated commercial or residential structures.
The second legislative bill is AB1335 (Atkins) Establishes the Building
Homes and Jobs Act of 2015 to provide funding for affordable housing.
Establishes the Building Homes and Jobs Trust Fund (the Trust
Fund) within the State Treasury.
Imposes a $75 fee on every real estate instrument, paper, or notice
that is required or permitted by law per each single
transaction per parcel of real property, excluding real estate
instruments, papers, or notices recorded in connection with a
transfer subject to a documentary transfer tax.
Jeff Wattenbarger 75100 Mediterranean • Palm Desert • CA 92211
Wattenbarger Construction (760) 776-7001 office • (760) 776-7002 fax
www.thedvba.org
2015 BOARD OF DIRECTORS
PRESIDENT
Joseph Hayes
First Bank
is, VICE PRESIDEN7
Bruce Maize
Fidelity Title
2„ d VICE PRESIDENT
Fred Bell
Nobell Energy Solutions
SECRETAR YITREASURER
Eileen Eske
Pacific Premier Bank
VICE PRESIDENT
OFASSOCIATES
Allan Levin
Allan Levin & Associates
PAST PRESIDENT
Mark Benedetti
BMC Select Build
CHIEF EXECUTIVE OFFICER
Gretchen Gutierrez
DIRECTORS
Brian Benedetti
Brian Benedetti Construction
Andy Brakebill
Paul Associates Printing
Tom DuBose
Development Design & Engineering
1%dargaret Drury
Margaret Drury Construction
Mario Gonzales
GHA Companies
Mark Gran
Strictly Business Consulting
Todd Hooks
Agua Caliente Band of Cahuilla Indians
Dave Lippert
Lippert Construction. Inc
Heather Loutsenhizer
Penta Building Group
Paul Mahoney
PMA Advertising
Deborah McGarrey
The Gas Company
Dan Olivier
Nethery Mueller Olivier
Alan Pace
Petra Geotechnical
John Powell. Jr.
Coachella Valley Water District
Marvin Roos
MSA Consulting Inc
Greg Smith
Smith-Kandal Insurance,Real Estate
Phil Smith
Sunrise Company
Rvan Smith
Shea Homes
Patrick Swarthout
a
Requires 20% of the money deposited into the Trust Fund to be used
for affordable homeownership activities. Allows the
remaining 80% of money in the Trust Fund, upon
appropriation by the Legislature to be expended for the
following purposes:
a) Development, acquisition, rehabilitation, and
preservation of housing affordable to extremely low-, very
low, low and moderate -income households including necessary
operating subsidies;
b) Affordable rental and ownership housing that meets the
needs of a growing workforce up to 120% of area median
income (AMI);
c) Matching portions of funds placed into local or regional
housing trust funds;
d) Matching portions of funds in the Low- and
Moderate -Income Housing Asset Funds of former redevelopment
agencies retained by successor agencies;
e) Emergency shelters, transitional housing, and rapid
re -housing services;
f) Efforts to acquire and rehabilitate foreclosed, vacant,
or blighted homes; and
g) Homeownership opportunities, including but not limited
to down payment assistance. Etc.
These two bills are in process. The likelihood of them becoming law, is
beyond our knowledge.
If adopted, AB 2 may be difficult for the City of Palm Desert to qualify, due
to the requirements. AB 1335 is similar to many defeated bills of the past,
wherein the California Association of Realtors was successful in beating
them down. Currently, the only opposition to AB 1335 is coming from the
various counties assessor's offices, which we believe is because of the
processing requirements they would incur with adoption of this legislation.
Imperial Irrigation D�stnct 75100 Mediterranean • Palm Desert • CA 92211
Jeff Wattenbarger
Wattenbarger Construction (760) 776-7001 office • (760) 776-7002 fax
www.thedvba.org
2015 BOARD OF DIRECTORS
PRESIDENT
Joseph Hayes
First Bank
I s' VICE PRESIDENT
Bruce Maize
Fidelity Title
2nd VICE PRESIDENT
Fred Bell
Nobell Energy Solutions
SECRET.4R VITREASURER
Eileen Eske
Pacific Premier Bank
VICE PRESIDENT
OFASSOCL4TES
Allan Levin
Allan Levin & Associates
PAST PRESIDENT
Mark Benedetti
BMC Select Build
CHIEF EXECUTIVE OFFICER
Gretchen Gutierrez
DIRECTORS
Brian Benedetti
Brian Benedetti Construction
Andy Brakebill
Paul Associates Printing
Tom DuBose
Development Design &. Engineering
Marearet Drury
Margaret Drury Construction
Mario Gonzales
GHA Companies
Mark Gran
Strictly Business Consulting
Todd Hooks
Agua Caliente Band of Cahuilla Indians
Dave Lippert
Lippert Construction. Inc
Heather Loutsenhizer
Penta Building Group
Paul Mahoney
PMA Advertising
Deborah McGarrev
The Gas Company
Dan Olivier
Nethery Mueller Olivier
Alan Pace
Petra Geoteehnical
John Powell. Jr.
Coachella Valley Water District
Marvin Roos
MSA Consulting Inc
Greg Smith
Smith-Kandal Insurance/Real Estate
Phil Smith
Sunrise Company
Rvan Smith
Shea Homes
Patrick Swarthout
Imperial Irrigation District
Fortunately, a bill that was passed last year, under our radar, is SB 628
Enhanced Infrastructure Financing Districts (EIFDs). This new law, effective
in 2015, "authorize(s) the legislative body of a city or a county, defined to
include a city and county, to establish an enhanced infrastructure financing
district, adopt an infrastructure financing plan, and issue bonds, for only
which the district is liable, upon approval by 55% of the voters; to finance
public capital facilities or other specific of communitywide significance,
including, but not limited to, Brownfield restoration and other environmental
mitigation; ... the acquisition, construction, or rehabilitation of housing
for persons of low and moderate income for rent or purchase;..."
DVBA believes this is the best opportunity for the City of Palm Desert, since
the demise of the RDA. This bill allows the City to be creative in determining
the district and financing plan borders. In the most restrictive plans it could
be limited to areas of the City considered un-developed or under -developed.
Voting parties would only be those property owners in the district. There
should be no cost to builders/developers for the formation of the district and
plan. There is no cost to the homebuyer. And, no additional taxes will be paid
by the homebuyers. As a property tax -increment financing tool, the district
has the potential to raise significantly more revenue than the proposed
mitigation fee to new construction.
To assure our interpretations we have confirmed our understanding of the
benefits of Enhanced Infrastructure Financing Districts by meeting with
representatives of Kosmont Companies. They have a public financing
background and have been assisting cities in Post -RDA issues. DVBA
suggests that staff research this as the most viable alternative.
In continuing to look for alternative solutions, we have also reached out to
other building industry associations in our neighboring states to learn how
their communities are dealing with providing affordable housing
opportunities.
Oregon established legislation in the early 1990s prohibiting local agencies
from developing inclusionary zoning ordinances or in -lieu fees to support
affordable housing efforts. Nevada does not have any inclusionary zoning,
and there aren't any cities of record attempting to adopt such an ordinance.
Jeff Wattenbarger 75100 Mediterranean • Palm Desert • CA 92211
Wattenbarger Construction (760) 776-7001 office • (760) 776-7002 fax
www.thedvba.org
2015 BOARD OF DIRECTORS
PRESIDENT
Joseph Hayes
First Bank
I" VICE PRESIDENT
Bruce Maize
Fidelity Title
end viCE PRESIDENT
Fred Bell
Nobell Energy Solutions
SECRETAR YITREASURER
Eileen Eske
Pacific Premier Bank
VICE PRESIDENT
OF ASSOCIATES
Allan Levin
Allan Levin & Associates
PAST PRESIDENT
Mark Benedetti
BMC Select Build
CHIEF EXECUTIVE OFFICER
Gretchen Gutierrez
DIRECTORS
Brian Benedetti
Brian Benedetti Construction
Andy Brakebill
Paul Associates Printing
Tom DuBose
Development Design & Engineering
Margaret Drury ✓
Margaret Drury Construction
Mario Gonzales
GHA Companies
Mark Gran
Strictly Business Consulting
Todd Hooks
Agua Caliente Band ofCahuilla Indians
Dave Lippert
Lippert Construction, Inc
Heather Loutsenhizer
Penta Building Group
Paul Mahonev
PMA Advertisins
Deborah McGarrey
The Gas Company
Dan Olivier
Nethery Mueller Olivier
Alan Pace
Petra Geotechnical
John Powell. Jr.
Coachella Valley ater District
Marvin Roos
MSA Consulting Inc
Greg Smith
Smith-Kandal Insurance,Real Estate
Phil Smith
Sunrise Company
Rvan Smith
Shea Homes
Patrick Swarthout
Imperial Irrigation District
Jeff Wattenbarger
Wattenbar2er Construction
Most recently, April 1, 2015 to be exact, a law went into effect in Arizona
prohibiting any local agency from affecting the sale price of a home, in their
efforts to provide affordable housing. These states are partnering with non-
profit builders, using state housing tax credits (when available) and other cost
saving incentives to provide affordable housing opportunities.
Finally, beyond the economics of pricing out the middle class by increasing
the cost of market rate housing to supplement housing for those at a lower
economic level, we believe there are some constitutional issues that have yet
to be answered. We have consulted with the Law Offices of Walter P.
McNeill for a review of the proposed ordinance. The opinion letter provided
separately speaks to advances in the interpretation of Koontz and the effects
of Proposition 26 on regulatory law. Both of which DVBA believes
establishes that the advancement of an affordable housingfee on new market
rate construction to be a violation of law.
Therefore, based on the above referenced issues, The Desert Valleys
Builders Association recommends the City Council NOT adopt the
proposed affordable housing fee, and further investigate the possibilities
provided in SB 628 Enhanced Infrastructure Financing Districts.
Once again, the DVBA appreciates the opportunity to provide input to this
issue.
Cc: Lauri Aylaian, Director of Community Development
Mayor Susan Marie Webber
Mayor Pro Tern Robert A. Spiegel
Council Member Jan Harnik
Council Member Sabby Jonathan
Council Member Van Tanner
75100 Mediterranean • Palm Desert • CA 92211
(760) 776-7001 office • (760) 776-7002 fax
www.thedvba.org
JA no 0 rx- 114 Tin
- I
GOVERNMENT FEE LIT 1� A 7 1 N
April 23, 2015
Gretchen Gutierrez, CEO
Desert Valley Builders Association
75100 Mediterranean
Palm Desert, CA 92211
by E-mail and U.S. Mail
re: Legal Analysis of City of Palm Desert proposed Affordable Housing Fees
Dear Ms. Gutierrez,
At your request I have analyzed the City of Palm Desert's proposed
"affordable housing fees" to provide an opinion as to their vulnerability to legal
challenge should one occur. In summary, it is my opinion that the proposed fees
are legally invalid on a variety of grounds. Most prominent of those grounds are
that: (1) the fees (insofar as they are treated as "mitigation impact fees" —a
questionable assumption as described below) clearly violate the strict scrutiny
nexus requirements now applicable to all impact fees for development permits
for land per the U.S. Supreme court decision in Koontz v. St. Johns Water Mgmt.
Dist. (2013) ---U.S.—, 133 S.Ct. 2586, 186 L.Ed. 2d 697; (2) the fees, insofar as a
California Court may treat them as being in substance a "regulatory fee," violate
the provisions of Proposition 26 (Cal. Const. XIIIC §1(e)(3)) which require that a
charge for a permit shall not exceed the reasonable regulatory costs for issuing
the permit and enforcing the permit (i.e. the building permit as opposed to a
regulatory program for affordable housing); (3) the fees, under any
circumstances and assuming for sake of argument that they are otherwise
legitimate, are far in excess of mitigating the purported costs for affordable
housing allegedly created by the construction of market rate housing, by a factor
of 2X up to about 10X; (4) the fees are inconsistent with the City General Plan
Housing Element, and are therefore arbitrary, capricious, and invalid on those
grounds. Other factors are present which make the fees either invalid or
problematic at best; I will mention some but not all of those below.
This is not meant to be an exhaustive treatment of the subject but it should
be sufficient to raise the key issues and make it apparent that these fees cannot
be adopted without violating current law. I would be glad to answer any
questions you may have. Thank you for this interesting assignment.
1. PROCEDURE: It should be noted at the outset that the proposed
procedure for adoption and implementation of the proposed affordable
housing fees violate the basic tenets of both resolution/ordinance
adoption and (considered as "impact fees") the provisions of Gov. Code
§66017(a) of the Mitigation Fee Act.
280 Hemsted Drive. Suite E. Redding. California 96002 i WMcNeill@McNLaw corn
TEL 5_30.222.8992 1 FAX 530.222.8892
It is clear that the City intends to adopt the more or less standard vehicle
for authorizing and implementing fees: an authorizing ordinance as to the
purposes of the fee, combined with an implementing resolution that contains
the specifics for the fee, in particular the amount of the fee; and in the future,
when or if the fee needs to be modified, only the resolution is modified while
the ordinance remains unchanged. That general structure is acceptable, but it is
fundamental that you cannot adopt an implementing resolution until you first
have a valid authorizing ordinance legally adopted. In this case the resolution
cannot, as planned, be adopted concurrently with the "first reading" of the
ordinance, because the ordinance is not even capable of being legally voted
upon until its second introduction to the City Council. Here, the City intends to
vote on the resolution immediately at the "first reading" of the ordinance. A
resolution adopted in that fashion is invalid.
Treating the "affordable housing fee" as an attempted "mitigation fee"
under the Mitigation Fee Act [MFA] (Gov. Code §66000 ei seq.) brings into play
Gov. Code §66017(a), which provides that when there is adoption of a new fee,
the fee "shall be effective no sooner than 60 days following the final action on
the adoption of the fee or charge or increase in the fee or charge." In this case
neither the ordinance nor the implementing resolution comply with §66017(a)
by providing for that 60 delay in the implementation of the fee. That delay is
critical for a variety of reasons, the most obvious being that builders who have
invested heavily in developments right up to the precipice of issuance of
building permits deserve the opportunity to obtain permits without paying a
new fee that they had previously not incorporated into their careful financial
analysis of building costs — a development budget that typically ultimately
yields a relatively slim profit margin which could disappear entirely if
consumed by a new fee that had not been planned for when the development
process began. A fee adopted without this delay mechanism is invalid.
2. VIOLATION OF Koontz v. St. Johns Water Mgmt. Dist. (2013) ---U.S.—,
133 S.Ct. 2586,186 L.Ed. 2d 697 ["Koontz"].
The 2013 ruling of the U.S. Supreme Court in Koontz v. St. Johns River Water
Management District [hereinafter "Koontz"] establishes newly defined
constitutional requirements for monetary exactions as a condition of land
development, which must be satisfied for collections of the Palm Desert
affordable housing fee not to be deemed unlawful "takings" in violation of the
5V- Amendment of the U.S. Constitution. The City and its consultant have relied
on the pre -Koontz case law (eg. Commercial Builders of Northern California v. City of
Sacramento, 941 F.2d 872 (9th Cir.(Cal.),1991) to support an affordable housing
fee which uses a collective analysis (not geared to individual fee payers) and
only a general associational relationship between the fee and affordable housing
as the legally required "nexus," as well as the proposition that legislatively
created non -proportional fees can be charged as long as the amounts of revenue
collected in the aggregate are less than the total mitigation cost as derived from
general programmatic calculations of the total cost of mitigation. Palm Desert's
2
proposed affordable housing fee clearly and obviously follows the "old"
template of the law.
Without going into unnecessary detail here (you already know generally
how the proposed fee is supposed to work) this affordable housing fee is based
on the loose premise that the construction of market rate housing - basically
housing for "moderate income" families and higher incomes - creates a
corresponding need for services supplied only by workers from lower income
levels ("very low income" to "median income") that need housing that
corresponds to their incomes but is not currently sufficiently available in Palm
Desert. To meet this alleged "need" the affordable housing fee is to be collected
and deposited in the City's "affordable housing fund" and shall be spent only to
promote the "policies and programs" identified in the Housing Element of the
City's General Plan as supporting affordable housing. Had the law for
mitigation fees remained static in recent years there is at least a possibility that
this concept of impact fees charged for the right to obtain a building permit
might meet constitutional muster. That is not the case today.
Some history of the case law is helpful in understanding the changing
landscape of the law as it relates to fee exactions placed on permits to develop
property. In Koontz, supra, the property owner requested drainage and wetlands
mitigation permits from the St. Johns River Water Management District to allow
him to develop 3.7 acres on his 14.9-acre property. The District demanded as part
of the process of imposing standard conditions on issuance of the permits that he
either restrict his development by an additional 2 acres or pia the District for
unrelated offsite mitigation work that would enhance about 50 acres of land
owned by the District. Koontz found the District's demands excessive and on his
refusal to agree to these demands his permits were denied by the District. Florida
law allows a claim for damages for unconstitutional demands by public agencies,
so Koontz sued. The issue presented to the Court was whether the District's
demanded exactions - particularly the monetary demand - should be examined
under the "heightened scrutiny" review of Nolan / Dolan. The majority of the
Court decided that "heightened scrutiny" is applicable. The minority of the Court
felt that Nolan / Dolan scrutiny was not warranted for a "monetary exaction," nor
in cases where the exaction was not clearly an ad hoc individualized
determination that maximizes the risk of extortionate use of the police power
right to demand concessions. The majority opinion, however, found that, in the
context of conditions placed on the development of land, "monetary exactions"
are just as deserving of constitutional protection as demands for an interest in
real property, and there is no reason that equivalent protection should not be
given to legislative "impact fees" and other standard conditions placed on land
development that have become commonplace methods of funding public
improvements. The Court noted that, contrary to the warnings of the minority
opinion that "heightened scrutiny" would have calamitous consequences for
municipal finances and the ability of cities to fund infrastructure with
legislatively created fees on permits for land development, many states around
the country have been applying Nolan/Dolan "heightened scrutiny" to such
impact fees and legislative exactions on land for years, without any evidence of it
causing financial ruin in those states.
3
The "heightened scrutiny" now required by the Koontz decision demands
that by way of an individualized determination for each fee payer (rather than a
collective analysis) the exaction placed on land development must have an
"essential nexus" to the impacts/harm to be alleviated by governmental
expenditure of the exaction funds, and that the amount of the exaction have
"rough proportionality" to the impact/harm it is intended to mitigate. In
California and in the 9- Circuit this is a dramatic change in the law. (See
Commercial Builders of Northern California v. City of Sacramento (1991) 941 F.2d 872
["Commercial Builders"]; McClung v. City of Sumner 548 F.3d 1218 (2008)
["McClung"].)
In Commercial Builders the City of Sacramento had passed a Linkage Fee
ordinance that conditioned nonresidential building permits on payment of a fee
to offset the burdens associated with the alleged influx of low-income workers to
work on such developments and the demand for low-income housing. The
plaintiffs claimed that the ordinance worked an unconstitutional taking because
there was an insufficient showing that non-residential development contributes
to the need for low-income housing and that the amount of the fees was not in
proportion to any alleged burden on housing. But the 9- Circuit held that a
legislative monetary exaction should not be invalidated unless there was "no
rational relationship" or "no evidence of a nexus" between the development and the
problem that the exaction seeks to address. The Court found that even though
building market rate housing has an attenuated indirect economic relationship to
affordable housing needs that was largely associational rather than clearly
causative, this was sufficient to meet this extraordinarily lenient nexus standard.
The Court also accepted the "proportionality" of the fee as it was much less than
the total amount of a potential fee that the study claimed to be authorized.
Generally the Court regarded the fee as a legislative act that required great
deference from the court, and — ignoring the crucial fact that legislation is just as
effective as an ad hoc exaction to extort money for exercising the right to develop
property — gave the fee the same deference it would give in refusing to interfere
in ordinary legislation.
Long after Commercial Builders, in the McClung (2008) case the 9th Circuit
reviewed a development condition of general application passed by the City of
Sumner that required the builder to install and overbuild a 24-inch storm drain
pipe, even though the property development did not need a pipe of that size or
expense. The Court made the explicit determination that Nolan/Dolan
"heightened scrutiny" does not apply to monetary exactions (because "money is
fungible") as contrasted with dedications of land, nor does it apply to legislative
exactions of general application as opposed to ad hoc or adjudicative
individualized exactions. The McClung court cited with approval the decision in
Commercial Builders among the cases it believed to be correctly decided on these
principles (McClung, at 548 F.3d 1228).
Koontz explicitly abrogates McClung (p.22 of Koontz decision) and by
implication also abrogates Commercial Builders. The anticipated affordable
housing fee in Palm Desert accordingly must be reviewed under "heightened
9
scrutiny' to determine if fee payers are accorded an individualized
determination to assure that there is an "essential nexus" and individualized
"rough proportionality" to the effects of the proposed land use. The more
demanding "essential nexus" from Koontz and NolanlDolan requires more than a
general associational relationship between the development activity (commercial
building) and the impact/harm to be alleviated (unaffordable housing) which
otherwise might clear the low bar of "no evidence" or "no rational relationship"
set in Commercial Builders. Moreover, the amount of fee cannot be arbitrarily set
for administrative convenience; nor can the proportionality of fee collections in
either the individual case or in the aggregate be ignored, much less glossed over
on the assumption that total fee revenues are less than what might be demanded.
The Palm Desert proposed affordable housing fee uses a collective analysis
that fails to protect individual fee payers by an individualized determination
that there is an "essential nexus" between the fee exacted and causation of a
specified need for affordable housing, and it further fails to show how defined
corresponding affordable housing would mitigate the impact of the particular
development paying the fee. Proportionality of the fee to the alleged impact is
lacking both as to the individual fee payer, and as to all fee payers who are
called on to pay more in revenues than any potential total cost for affordable
housing. The affordable housing fee fails on all counts.
The terminology and requirements set out in Koontz are not unique, but
rather come from the context of pre-existing case law where it has been
determined that "heightened scrutiny" is called for because "[1]and use
applicants are especially vulnerable to ... coercion ... [and] extortionate
demands." Koontz,133 S.Ct. 2586, 2594-2596. Some further background on these
requirements in Koontz illuminates the failure of the Palm Desert proposed
affordable housing fees to meet current legal standards in respect to: (1)
causation as a requirement of the "essential nexus"; (2) direct and proportional
mitigation rather than programmatic funding; and (3) the prohibition on fees that
exceed costs, whether individual or collectively.
(1) Causation as a requirement of the "essential nexus."
The "essential nexus" prong of Koontz /NolanlDolan demands a
"substantial connection" between the public burden created by the construction
and the necessity for the exaction (Surfside Colony, Ltd. V. California Coastal Comm.
(1991) 226 Cal.App.3d 1260,1267). The strength of that connection must
"substantially advance" the state interest served by imposing the exaction
(Nollan, supra, 483 U.S. 825, 834-835). While the case law does not necessarily
require that the construction be the sole cause or an absolutely direct cause of the
public burden, it is clear that the nexus analysis must show a cause -and -effect
relationship between the two. In this regard the dissent by Justice Beezer in
Commercial Builders, a dissent now vindicated by Koontz, was on target in stating
(Commercial Builders, supra, 941 F.2d at 877):
Sacramento has commissioned a study that demonstrates at best a
tenuous and theoretical connection between commercial
development and housing needs. But the Takings Clause requires a
5
cause -and -effect relationship between the two. Pennell v. San Jose,
485 U.S. 1, 20,108 S.Ct. 849, 862, 99 L.Ed.2d 1 (1988) (Scalia,
dissenting). In my view, Sacramento has not shown such a
relationship. Even the study relied on by the city to support the
ordinance states that its "nexus analysis does not make the case
that building construction is responsible for growth."
The issue arose again in Surfside, supra, where the California Coastal
Commission demanded a lateral access beach easement as a condition of the
permit allowing construction of a revetment to protect against erosion on the
beach front of the Surfside Colony housing development. The "nexus" for the
Commission's exaction of an easement was the assertion that the revetment
would exacerbate erosion in front of the revetment (which was built on an
emergency basis and therefore completed before the Commission's
administrative proceedings were completed). The Commission had several
scientific studies concerning the effects of revetments; some of the studies
indicated that revetments accelerate erosion of the beach in front of them,
leaving the beach steeper, more narrow and "perched"; while another study
indicated that beach erosion was more complex and variable, depending on
localized factors like wave conditions, sand supply, bedrock, etc., so that a
"rational" determination of the effect of a revetment can only be made by a site -
specific analysis. The Colony submitted an expert report to the Commission that
asserted that this particular revetment did not exacerbate erosion and in fact
stabilized the beach. In addition, the Commission was given pictures of the
revetment (which was built in November/December 1982) showing the
revetment in January 1983 with an eroded beach in front of it, and in July 1993
with the sand having come back and covered over the revetment so that it was
not then visible. (In essence, the revetment here was actually restoring an
already damaged beachfront rather than exacerbating erosion). Nonetheless, the
Commission, which takes the general policy position that revetments exacerbate
erosion and discourages them, voted to maintain the easement exaction. Colony
sued, and the trial court upheld the exaction.
The Court of Appeal in Surfside Colony reversed the trial court decision,
focusing its decision on the strength of the essential nexus required by Nolan. It
found "there must be a solid connection between the public burden created by
coastal construction and the necessity for a public easement" (Surfside Colony,
226 Cal.App.3d at 1263, emphasis added). Stating further (id. at 1267, fn.10,
emphasis in original):
The strength of the connection required by Nollan is not spelled out
in so many words, but appears to be at least a substantial one. At
483 U.S. at pp. 834-835,107 S.Ct. at pp. 3146-3147 the court
indicates the need for a "substantial" connection between the
public burden imposed by the proposed construction and the
condition imposed by the government: "Our cases have not
A revetment is a sloping structure or fortification placed on the shoreline to disrupt the force of
waves and protect the beach land from erosion or loss.
elaborated on the standards for determining what constitutes a
'legitimate state interest' or what type of connection between the
regulation and the state interest satisfies the requirement that the
former 'substantially advance' the latter.
The Court then distinguished Whaler's Village Club v. California Coastal
Comm. (1985)173 Cal.App.3d 240, which had upheld the Commission's policy of
exacting public access easements for the construction of revetments, but was
decided before Nollan. Whaler's Village had employed a "rational basis" test and
had determined that it was enough that the project incurred "incidental" effects
on the public's right to shoreline access. The Whaler's Village court stated (at 173
Ca.App.3d 260-261) "the validity of the condition is not destroyed because the
development has no direct nexus to the condition, the benefit to the public is
greater than to the developer, as future needs are taken into consideration. It
was enough that the project 'contributes in an incidental manner to the need for
a particular extraction." The Surfside Colony court found that the foregoing
holding of Whaler's Village no longer controls in light of the nexus requirements
of Nolan for a "close connection" or "substantial relationship" between the
burden and the condition. Then, after rejecting the Commission's legal
arguments that an indirect or incidental relationship is sufficient, it found that in
the absence of evidence that revetments necessarily cause accelerated beach
erosion, there could be no finding of the legally required nexus in the case
before it. Accordingly, the Commission's exaction of an easement was an
unconstitutional taking.
The proposed affordable housing fee in Palm Desert suffers from this
infirmity. There is no evidence that construction of market rate housing causes a
greater need for affordable housing. The data used in the study is purely
associational, based on the unproven/unwarranted assumption that there is an
idealized mix of income strata, and that the increase of one stratum necessarily
requires corresponding increases of the other strata to bring to bring back the
idealized balance. The reality is that there is no such idealized mix of income
strata. There are largely wealthy communities that don't require the idealized
level of hypothetical support services from low-income workers and are quite
stable in that form. By the same token, it isn't hard to imagine that low-income
populations can grow and predominate in a community without high -income
residents flooding back in to restore balance. The notion that construction of
market rate housing requires servicing by low-income workers is pure fiction, if
not almost demeaning to low-income workers. High income housing residents
can get along just fine without gardeners, nannies, wet -nurses, maids, and pool
boys. Other potential low-income services are not by definition essential to the
functioning of higher income residents (witness the gradual disappearance of
cashiers in stores) and are a product of opportunistic pre-existing availability
rather than generated need and attraction. There is no appellate case in the state
of California that has upheld the concept underpinning the fee study in this
case, that higher income residents of market rate housing somehow generate low
income populations. No wonder.
Consider for a moment the legitimate proposition that the income strata in
any community are to some degree interdependent in both directions. That is,
increases in low-income populations also have a need for services from higher
income residents, and room also has to be made for the moderate- to high -
income residents. Low-income residents need health care services from doctors
and skilled nurses; if they get divorced, suffer an injury caused by others, or are
arrested, they need an attorney; they need the police to protect them; they need
fireman to put out their fires; they need good school teachers for their children.
Ironically, fees that falsely inflate the cost of housing can push some moderate -
income earners into median and lower categories for housing — a dilemma that's
real for too many schoolteachers. The notion that constructing houses creates a
need for more houses in a particular income stratum is a ruse for extortionate
governmental exactions, not a cause -and -effect phenomenon based on fact.
(2) Direct and proportional mitigation rather than programmatic
funding.
The "individualized determination" of Koontz requires that the impacts of
land development be mitigated in a direct and proportional way, rather than
simply collecting funds to go to "programs" that do not directly ameliorate the
impacts of the individual project, much less do so in way that is clearly
proportional to the impacts of the individual project. In the Koontz case itself, the
Court invalidated the government's proposed mitigation of Koontz's
development, where the government had suggested it was adequate to spend
money for mitigation work on 50 acres of government land distant from the
Koontz property. Here, the proposed Palm Desert affordable housing fee utterly
fails the requirements of Koontz.
To begin with, there is no mechanism in the affordable housing fee for
actual individualized determinations whatsoever. It's little more than a broad -
based exaction of $2 / sq.ft. for new market rate construction. One fee fits all.
To make it worse, the fee revenues have no avenue of direct or
individualized mitigation for the impacts of the individual fee payers. Instead,
the fee revenues are all thrown into a single "housing fund" and then spent on
the "policies" and "programs" of the Housing Element of the General Plan,
which permits expenditures anywhere in the City for the most vaguely defined
purposes, having as a the common thread only the goal of improving
availability of affordable housing for the entire City, even if the specifics are yet
to be determined. This handing of the funds guarantees that Koontz cannot be
satisfied.
And then the concept of "proportionality", even of total expenditures to
total impacts (which isn't sufficient anyway but might be better than nothing), is
thoroughly undercut by the following factors that distort "proportionality"
beyond recognition:
• Contributions from the ancient but still present commercial linkage fee (City
of Palm Desert Resolution 90-130) are ignored, with no justification.
• There are two irrational exemptions for mobile homes and "granny flats"
(secondary dwellings of 1250 sq.ft. or less). All else being equal, exempting
and then subsidizing mobile homes and "granny flats" distorts the fee,
causes over -collection, and raises equal protection issues.
• "Leveraging" of fee funds with funds obtained from other outside sources
(like state and federal grants, etc.) has to taken into account but is totally
ignored. The City of San Diego, for example, "leverages" $8 for every dollar
it obtains locally. Palm Desert may not be that successful, but even partial
success dramatically changes and reduces the fee calculations.
Market adjustment by private development and travel. It's a fact of
capitalism that increased demand (if there is any) will result in market
adjustment. If builders are not saddled by excessive fees and regulatory
constraints, they will build low-income housing given the chance to make a
profit, and it is well known that private builders can deliver low-income
housing at significantly lower construction costs than government -built
housing. Also, even if the City claims it would prefer that low-income
workers live locally in Palm Desert, any increase in demand will likely be
met by workers travelling from areas where they already live and/or which
are more hospitable to low-income housing. The City cannot choose whether
workers travel or not, nor designate where workers must live. The market -
driven effect of travel will happen whether the City prefers it or not. The
error here is the City's failure to properly account for inevitable market
effects.
Measurement of "low income" households, as opposed to "low income"
jobs, is unreliably inaccurate. Data on jobs is easy to measure, but cross-
referenced data to determine whether individuals hold more than one job
(normally "part-time" jobs) is not readily available. Census data is helpful
but not frequent and specific enough for useful measurement. Recent trends,
pushed in part by the ACA, have dramatically increased part-time jobs in the
employment pool. Statistics on "low-income" workers tend to be grossly
overstated in that there is no reliable accounting for 2-job workers and
workers with part-time jobs in households ancillary to a spouse or partner
also holding full or part-time employment. The errors are exacerbated by a
tendency for "off the books" cash employment among some low-income
service workers that may supplement reported employment, and other
forms of income generation that avoid reporting. The errors in accounting
fall toward significantly over -counting "low-income" households based only
on reported low-income jobs. In effect, the goal of even gauging
"proportionality" of impacts on "low-income" households is wishful
thinking at best, and any fee structure that purportedly relies on such
unreliable data is inherently arbitrary and capricious.
• The fee study blithely ignores the enormous vacancy rate of existing housing
in Palm Desert, much of which could be converted to low-income housing
without the inordinate expense of newly constructed low-income facilities.
According to current Ca. Dept. of Finance population and housing estimates,
the City of Palm Desert has a 37.6517o housing vacancy rate, which adjusted
for seasonality is 9.5%, making this City the third highest vacancy rate city
(behind Indio and Rancho Mirage) among 28 cities in the County of
Riverside. It is beyond irresponsible for the City to seek funding through a
new fee for construction of low-income housing, when there is a gigantic
unoccupied stock of existing housing obtainable at a fraction of the cost of
new construction.
A final irony is that many households that are currently "low-income" are
comprised of construction workers that were laid off in the recession and
have not yet returned to productive full employment. That is to say, their
regular employment is either direct participation in or as part of the vast
support services network for construction of market rate housing. Obtaining
employment means they would be lifted out of the "low-income" categories
and at least into the moderate -income level or better. They want jobs — not
government subsidies that perpetuate their current circumstances. The
substantial (and ineffective) levy of "affordable housing fees" on market rate
construction of housing has only one real effect, the suppression of
construction industry construction of market rate housing and the enormous
pool of labor it supports when otherwise functioning in a healthy economy.
Creation of this new "affordable housing fee" will have a greater effect of
perpetuating and creating low-income households, rather than ameliorating
the problem it purports to solve.
In sum, it is impossible for the proposed fee to function legally as a
proportional mitigation for impacts of development of market rate housing,
particularly given the constraints of the Koontz decision.
(3) The prohibition on fees that exceed costs, whether individually or
collectively.
It is axiomatic that fees that collect more than costs are unlawful. Koontz v.
St. Johns Water Mgmt. Dist. (2013) --- U.S.—,133 S.Ct. 2586,186 L.Ed. 2d 697
["Koontz"]; see also Shappell Industries, Inc. v. Governing Board (1991)1 CA 4- 218;
Sinclair Paint Co. v. State Board of Equalization (1997)15 C 4- 866; and Warmington
Old Town Associates v. Tustin Unified School District (2002)101 CA 4- 840). The fee
study is in direct conflict with the Housing Element of the General Plan in that it
totally ignores the Regional Housing Needs Allocations ["RHNA"] developed
according to State law and incorporated in the Housing Element. The RHNA
numbers show a need for "affordable housing" on the order of approximately
203 units., In stark contrast, however, the fee study calculates generated low-
income housing, depending on the size of market -rate constructed rental or SFD
housing, in a range from 444 units (if 10017o of market rate construction is only
The RHNA number for "moderate income" includes both "median income" and "moderate
income" (at 120% AMI), requiring an adjustment in that number to pull out only "median
income" housing for that category. This highlights yet another fatal defect in the fee study — its use
of income categories that don't correspond to the City's Housing Element.
10
the smallest size of rental housing, a virtual impossibility) to 2,031 units if all
market -rate housing consists of palatial single family dwellings. Of course,
reality will dictate a mix of market -rate housing that falls between these two
numbers, but even the lowest number is twice the RHNA number for
"affordable housing" and on the high end the number is roughly 10 times the
RHNA requirements. The proposed "affordable housing fee" is calibrated to
meet unreal sky-high demand levels that are flatly inconsistent with the RHNA
relied upon by the City's own Housing Element and unavoidably generate
massive surplus revenues.
As a purported "mitigation fee" the City of Palm Desert proposed
"affordable housing fee" cannot possibly withstand legal scrutiny, especially
given the legal constraints now applicable throughout the country (based on the
U.S Constitution Fifth Amendment prohibition against uncompensated
"takings") based on the Koontz decision.
3. PROPOSITION 26: The proposed fees, insofar as a California Court
may treat them as being in substance a "regulatory fee," violate the
provisions of Proposition 26 (Cal. Const. XIIIC §1(e)(3)) which require
that a charge for a permit shall not exceed the reasonable regulatory
costs for issuing the permit and enforcing the permit (i.e. the building
permit as opposed to a regulatory program for affordable housing).
Courts have a salutary habit of looking at enactments such as new fees in
accordance with what the purported fees actually are based on their substance,
rather than accepting at face value the label that a government agency may
place on the exaction (Weisblat v. City of San Diego (2009)176 Cal.App.4- 1022,
1038):
"Although the classification of a revenue -producing device can be
determinative of the lawfulness of the device, courts look to the
actual attributes of the device as enacted in order to arrive at the
proper classification; the label attached to the device by the local
government is not determinative." (Kern County Farm Bureau v. County
of Kern (1993)19 Cal. AppAth 1416, 1422, 23 Ca1.Rptr.2d 910, italics
added.)
In the present matter the City of Palm Desert chooses to label its proposed
"affordable housing fee" a "mitigation fee." There is, however, a strong
possibility that a reviewing court would determine that this fee is actually an
attempted "regulatory fee" that is barred by the provisions of Proposition 26
(Cal. Const. XIUC §1(e)(3)) which require that a charge for a permit shall not
exceed the reasonable regulatory costs for issuing the permit and enforcing the
permit (i.e. the building permit as opposed to a regulatory program for
affordable housing). The reason this fee is at risk of legal characterization as a
"regulatory fee" is quite simple: all revenues from the fee are collected into the
City's "affordable housing fund," and from there the fees are spent to effectuate
the "policies" and "programs" of the Housing Element of the General Plan that
are well-intentioned as to their purposes but vague (at best) for specific
expenditures and unlimited as to the City's evolving regulatory program to
11
generally address affordable housing needs in the City. The attributes of this fee
appear to be regulatory in nature, as opposed to standard mitigation fees that are
directly addressed to funding identified prospective public facilities.
In November of 2010, Proposition 26 amended the California Constitution
(Art. XIII C §1) and completely changed the legal paradigm for judging the
validity of fees and charges imposed by local agencies in California. It was the
outgrowth of frustration with the unchecked proliferation of fees and charges
that are really "hidden taxes," especially fees to simply raise revenues for
regulatory programs. The onslaught of new fees had been made possible by the
California Supreme Court's decision in Sinclair Paint, and appellate decisions in
its wake, that: gave every new fee a presumption of validity; that put the burden
on fee payers to prove there was no evidence to support a fee; that allowed fees
for regulatory programs based on a general associational relationship between
the class of fee payers and the societal problem to be solved by the use of the fee
revenues; and that allowed fees that were not apportioned to fee payers in
relation to the payers' burdens on or benefits from the governmental activity.
Prop 26 turned the tables on that. Now any fee or charge created by a local
agency is defined to be a tax unless the local agency can prove that it is not a tax by
showing that it fits within one of seven specific exceptions that allow certain
defined types of fees/charges. The burden of proof is on the local agency to show
by a preponderance of the evidence that the fee is not a tax and that it is reasonably
allocated to fee payers. Deliberately absent from the list of exceptions for
permissible fees are regulatory fees of the type allowed by the Sinclair Paint
decision. Very simply, Prop 26 puts an end to new or increased regulatory fees;
they must now be approved by the voters as taxes.
There is one exception in Prop 26 for "a charge imposed as a condition of
property development," but that exception does not allow the imposition of fees
merely as a requirement of issuing a building permit. As explained in CBIA v.
SJVAPCD (2010)178 Cal.App.4-120,130-131, a regulatory fee may be made a
requirement of issuing a building permit without losing its character as a
"regulatory fee" and subjecting itself to the requirements of the Mitigation Fee
Act. The key distinction is not the mandatory nature of paying the fee when the
permit is taken, but rather whether the fee truly arises under the local agency's
police power authority to condition development permits so that the specific
consequences of the permit are mitigated. In the SJVAPCD case the court held
that an "indirect source fee" to fund the regulatory program of the SJVAPCD
In Sinclair Paint a paint manufacturer challenged a new fee charged for every bucket of paint to
help the State pay for a lead screening program for children potentially exposed to lead from lead
based paint — though lead had been banned from the manufacture of paint for well over 15 years;
the paint company challenging the fee didn't even exist when lead was a common ingredient in
paint. The Supreme Court generally classified fees/charges as falling into categories of (1) special
assessments, (2) development fees, or (3) regulatory fees. It upheld the fee imposed on the paint
industry as a bona fide regulatory fee, stating that it is constitutionally permissible under the police
power to impose industry -wide fees to address the past, present or future impacts of the industry's
operations, and that such fees are a valid method to shift the "societal costs" from the government
to the industry, regardless that the industry and its fee payers had not been responsible for these
impacts for many years.
12
addressing air pollution caused by development was in fact a "regulatory fee"
not subject to the Mitigation Fee Act. In the present case, we similarly have a fee
directed to the City's regulatory program for addressing affordable housing
needs. There appears to be little substantive legal distinction, and the chances
are significant that a court would view the "affordable housing fee" as truly a
"regulatory fee." As noted above, Prop 26 ends regulatory fees by making them
taxes that require a vote of the people to legitimize them as "taxes." Here the
City of Palm Desert has no intention of putting the "affordable housing fee" up
to a vote. If passed merely by the City Council it will be unlawful.
4. The "Fees" are far in excess of the City's costs and the alleged "impacts"
of market rate housing development.
This legal deficiency was discussed above under the topic of
"proportionality" as well. To reiterate: the proposed fee ranges from 2X to 10X
of the City's costs and / or the alleged impacts of market rate housing
development. The fee is legally unsustainable.
5. The fees are inconsistent with the City General Plan Housing Element,
and therefore arbitrary, capricious, and invalid on those grounds.
As also noted previously, the proposed "affordable housing fee" is
completely incongruent with the Housing Element of the General Plan. To begin
with, the categorizations of affordable housing needs don't even match up to the
categories used in the Housing Element. On top of that, the nexus study
completely ignores the RHNA allocations driven by State law, and the
quantification of affordable housing units actually needed in the City of Palm
Desert. Instead, the nexus study takes off into the nether realm of 2X to 10X the
RHNA housing needs and overcharges market rate housing without factual
substantiation and in complete conflict with the Housing Element requirements.
Under these circumstances any attempted adoption of this "affordable housing
fee" would be patently arbitrary, capricious and unlawful.
The review and analysis above addresses the most salient legal
deficiencies in the Palm Desert proposed "affordable housing fee". If you have
any questions I would be glad address them.
Very truly yours,
MCNEILL LAW OFFICES
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WALTER P. MCNEILL
13
April 23, 2015
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1891 11"Strect
Rkerside. California 92501
(951)781-7310
Fax 9951) 781-0509
Re: City of Palm Desert — City Council Agenda — April 23, 2015
Objections to Proposed "Affordable Housing Impact Fees" and Request for Continuance of
Council Consideration
To the Honorable Mayor and Members of the City Council:
This letter is respectfully submitted on behalf of the Riverside County Chapter of the Building
Industry of Southern California and its members, in response to the proposal that the City adopt a new
and unsanctioned "impact fee" to be used to subsidize "affordable housing" in the City of Palm Desert.
This letter summarizes some of our concerns and potential legal complications to the proposed new
"affordable housing impact fee."
The Council is respectfully urged to reject the proposal, at least in its present form, and to
instead direct City Staff to work with the BIA and other critical stakeholders to develop a more lawful,
effective and market driven approach to improving the affordability of housing in Palm Desert.
Below you find a brief summary of our general objections to the proposed fee as well as a list of
our legal concerns on the matter. Additionally, Attachment A elaborates on each specific legal issue.
Introduction and Request for Deferral of Council Consideration:
It should be noted at the outset that we greatly appreciate the opportunity to comment. We do
regret that we have been forced to communicate our concerns in this rushed manner, and so close to
the scheduled Council meeting. However, BIA and other members of the public were not given
adequate prior notice of this proposed action, nor any meaningful opportunity to review the associated
nexus studies that assumes supports the proposed resolutions. The BIA did not receive notification until
April 13, 2015 and then had to request for an electronic copy of the study which was not initially
provided. There were no advance informal meetings between staff and the affected stakeholders, nor
any study sessions or opportunities to question the consultant about the novel methodology and
assumptions used in creating the nexus studies, nor to discuss the negative impacts of this fee on all
housing construction activity in Palm Desert. We strongly recommend that this matter be deferred and
continued, to allow for further public review and input, should the Council choose or choose not to
consider it at a later date.
The BIA does not question the importance of attempting to improve the affordability of housing
in Palm Desert and other Riverside County communities. That is a worthy and legitimate public
An Affiliate of the National Association of Home Builders and the California Building Industry Association
objective. The BIA and its members are among the most supportive advocates for constructive,
reasonable, and lawful measures that will actually improve the supply and affordability of housing,
including policies promoting the increased production of homes affordable to residents in all income
ranges. Local governments concerned about the affordability of housing should therefore be
encouraging new housing production and adopting policies to incentivize new housing development as
opposed to creating new burdens on housing development that many have determined to be counter-
productive as such is the case with inclusionary zoning type impact fees.
Housing "impact fees" and their relational inequities are regressive. They disproportionately
burden entry-level renters and homebuyers. They are generally ineffective and in many cases counter-
productive to their objective. Planning professionals and housing advocates increasingly recognize them
as constraints on the production of housing and the supply of affordable housing in particular.
This letter summarizes legal objections to the proposed imposition of affordable housing impact
fees and deficiencies of the purported nexus study. However, the City is urged to also take note of the
policy criticisms and economic objections to such the proposed impact fees and exactions (E.g., Cal. Gov.
Code § 65589.5(a)(2): "The excessive cost of the state's housing supply is partially caused by activities
and policies of many local governments that limit the approval of housing, increase the cost of land for
housing, and require that high fees and exactions be paid by the producers of housing.")
• Objections to Unlawful Fees on New "For Sale" Homes
• No Statutory Authority for "Impact Fees" to Fund "Affordable Housing"
• The Proposed "Impact Fees" Are NOT Justified by the "Nexus Studies"
• The Purported "Nexus Studies" Are Flawed and Fail to Meet Evidentiary Requirements to
Demonstrate a Reasonable Relationship Between New Housing Development and Increased
Public Needs for Privately -Subsidized Affordable Housing
• Failure to Comply With the Mitigation Fee Act
• The Proposed New "Impact Fees" Would Violate California Constitutional Prohibitions Against
"Special Taxes" Without Voter Approval
• General Plan "Consistency" Issues
• State Housing Law Issues
• Denial of Equal Protection of the Laws and Substantive Due Process
• Unlawful Fees on New "For Rent" Homes
• Unlawful Circumvention of State Rental Housing Law
We again appreciate the opportunity to comment and respectfully reserve the right for
additional review of the study and supplemental documentation to determine additional legal conflicts
and issues as our time frame to do so in this circumstance has been unfortunately limited.
If you have any questions regarding this request of notification please do not hesitate to contact me at
(951) 505-2594 or nmiller@riversidebia.org.
Sincerely,
(50
Nathan A. Miller
Director of Government Affairs
An Affiliate of the National ASsoclatlon of llonle Builders and the California Building Indust v Association
i3UTAN
RUTAN & TUCKER. LLP MEMORANDUM
TO: Mr. Bill Blankenship, CEO,
Building Industry Ass'n — Riverside County
FROM: David P. Lanferman
DATE: April 22, 2015
FILE NO.: 031455-0002
RE: Legal Objections -- Palm Desert's Proposed New Affordable Housing Fees
This Memo summarizes some of the more obvious legal questions and deficiencies raised
by the proposal for the City of Palm Desert to consider and adopt new "affordable housing
impact fees" to be imposed on new residential development. This is based on our preliminary,
and time -constrained, review of the purported "nexus studies" and cover memo. Additional
issues, inconsistencies, and flaws may be revealed upon more detailed review.
Legal Objections to the Proposed New Affordable Housing Impact Fees:
There are numerous legal grounds for questioning or objecting to the proposed
"affordable housing impact fees" (on both "for sale" and "for rent" homes), which include, but
are not limited to, the following:
1. No Statutory Authority for "Impact Fees" to Fund "Affordable Housing."
The documentation offered in support of the new "impact fees" acknowledges that the
proposed use of such fees would be to generate revenues from the private development sector
which would then be used by the City to subsidize the production of new affordable units.
However, California cities may not impose fees on development projects for the purpose of
reimbursing or subsidizing costs incurred by other private parties. (Price Development Co. v.
Redevelopment Agency of the City of Chino Hills (9th Cir. 1988) 852 F.2d 1123.)
Moreover, under California's Mitigation Fee Act, development impact fees may only be
imposed to finance the construction of "public facilities," as defined in Goverrunent Code section
66000. A City may not lawfully impose "impact fees" except for the purpose of providing
up blic facilities or improvements, the need for which is caused by new development. The
proposed new housing fees do not meet these statutory or constitutional criteria. Neither the
Staff Report nor the consultant's materials provide any legal authority for these fees.
2. The Proposed "Impact Fees" Are NOT Justified by the "Nexus Studies."
Even if there were authority to consider adopting fees for privately owned or occupied
housing, the City would need to provide evidence of a "nexus" between impacts on public
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affordable housing needs and the amount and use of the proposed "impact fees." In this context,
the California Supreme Court has explained: "As matter of statutory and constitutional law, such
legislatively -established fees must be shown to be reasonably related in both use and amount to
deleterious public impacts of new development." (San Remo Hotel v. City & County of San
Francisco (2002) 27 Cal .4th 643.)
In addition, the U. S. Supreme Court re -confirmed in 2013 that as a matter of federal
constitutional law, "monetary exactions [fees] are subject to [heightened] scrutiny under" the
Court's earlier holdings requiring that such demands be shown to be reasonably related. and
"roughly proportional," to impacts or needs created by those on whom the fees are imposed.
(Koontz v. St. John's River Water Management District (2013) 133 S.Ct. 2586 ["the government
may choose whether and how a permit applicant is required to mitigate the impacts of a proposed
development, but it may not leverage its legitimate interest in mitigation to pursue governmental
ends that lack an essential nexus and rough proportionality to those impacts."].)
The proposal for establishing these housing impact fees acknowledges these
constitutional requirements, and seeks to pass off two so-called "nexus studies" as satisfying
these evidentiary requirements (one for "for -sale" homes, and one for "for -rent" homes). The
consultant's reports, however, fail to adequately demonstrate the required "nexus" between new
homes and the proposed new housing impact fees.
They do not follow any judicially -approved or legislatively -sanctioned methodology for
demonstrating a reasonable relationship between the development of new market -rate housing
and any increased needs for privately -subsidized "affordable housing" in the City of Palm
Desert. (Cf., Building Industry Assn. v. Ciry of Patterson (2009) 171 Cal.AppAth 886, the Court
of Appeal invalidated the City's "affordable housing in lieu fees" because the study prepared by
the City's consultant did not show a causal relationship between new housing and increased
needs for affordable housing.) To the contrary, it has long been recognized that there is in fact
no such nexus between increasing the supply of housing in a community and increased needs for
subsidized housing. See, e.g., Altshuler & Gomez -Ibanez, REGULATION FOR REVENUE: THE
POLITICAL ECONOMY OF LAND USE EXACTIONS (1993, The Brookings Institution & The
Lincoln Institute of Land Policy) p. 5: " FT]he development of market rate housing ... clearly
does not create a need for more subsidized housing.")
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3. The Purported "Nexus Studies" Are Flawed and Fail to Meet Evidentiary
Requirements to Demonstrate a Reasonable Relationship Between New
Housing Development and Increased Public Needs for Privately -Subsidized
Affordable Housing.
The purported "nexus studies" offered here are premised on very speculative and
unfounded assumptions. They are largely based on generic statistical data rather evidence of
actual local conditions, and key assumptions in the report are not based on relevant data from
Palm Desert or even from Riverside County. For example, they admit that "Riverside County
data was not available for every Economic Census industry" which was to be used in speculating
as to the typical household expenditures based on the job -type of speculative new households.
(See, EPS, "Study for For -Sale Housing," p. 13.) The studies are, at least in part, inconsistent
with actual facts and data, and inconsistent with projections in the City's own Housing Element
and General Plan. For example, even though the American Community Survey reports that
"average household size in Palm Desert is 2.05 people" (ibid., p. 7), the City's consultants
nevertheless disregarded the actual facts and instead based their analysis on the contrary
"assumption" that the average household size for future workers is 3 persons per household.
(EPS, p. 7.) In addition, while the studies acknowledge that many Palm Desert residents are (and
will continue to be) retired persons, they nevertheless rely on assumptions about different
household spending and lifestyles that do not reflect the actual population of Palm Desert.
While the new "nexus studies" purport to provide some evidentiary justification for the
new fees, they failed to use a legally -sound methodology, and erroneously relied upon a series of
unfounded and unsupportable assumptions. In essence, the studies base their conclusions on the
highly speculative assumed disposable incomes of the households projected to move to Palm
Desert, not on the "impacts" of the construction of new housing. Moreover, since the proposed
fees are based largely on the assumption of increased disposable income being added to the
community, they are really much more like taxes on new residents than true "impact fees."
The unfounded assumptions and speculative methodology used by the City's consultants
was the subject of scathing academic critique in a study published by the Goldman School of
Public Policy at the University of California, Berkeley, The Use of Residential Nexus Analysis in
Support of Inclusionary Housing Ordinances: A Critical Evaluation, (November 2011): "In
general, the methodology is untested and has not been vetted by peer review.... Moreover,
several issues common among residential nexus analyses call into question the accuracy of the
methodology as a whole." As noted above, no statute or court decision authorizes or approves
the speculative "analysis" used in these nexus studies. The Council should carefully consider
whether Palm Desert truly wants to be the "guinea pig" or test case for such unauthorized
housing impact fees.
There are a number of flaws in the basic methodology created by EPS, including at least
three (3) fundamental infirmities summarized here. First, the consultants admit that their
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analysis "assumes that all households renting new market -rate units in Palm Desert are `net new'
households to the City." (EPS, p. 11.) From that unfounded assumption, the study further
assumes or speculates that every sale (or rental) of a new home results in the sudden, immediate
appearance additional household income in Palm Desert, inferred simply from the costs of
buying or renting the home in question. Neither of these assumptions are reasonable or
supported by relevant local and substantial evidence. In a great many cases when a new home is
bought or rented, the accompanying occupancy (and the assumed household income) — and the
consumption that the consultant assumes to be associated with it — are not new or "additional" to
the general locale or even to the City itself, but rather may be relocating locally
The assumptions in the consultant's studies depend on ignoring all the effects of (1) local
and regional organic population gromth and its consequences for both household formation and
eventual income formation, (2) the fact that nearly one-half of home sales are typically to so-
called "move -tip" buyers whose "enabling incomes" indicate already higher levels of
consumption and demand, (3) nationally, nearly one-fourth of home sales are to non -occupant
investors whose incomes — and assumed consumption — may never appreciably touch the City
(while their tenants' consumption would likely be far different from what the consultants
speculate), and (4) the disbanding of assumed "households" due to extraneous events (such as
job changes, scholastic graduations, changes in health or mobility), into separate homes with no
concomitant change in individuals' incomes and consumption.
A second fatal flaw in the consultants' methodology is the assumption that all direct
spending by new -home buyers or new -home renters will result exclusively in new jobs for lower -
income workers who have neither (i) pre-existing jobs for which there is slack demand, nor
(ii) proximately -located housing. This is another unfounded assumption. The studies ignores the
fact that many of the service workers who it presumes (1) would be "attracted" to the City
because of the new market -rate home occupants' (imputed) consumer spending, and (2) would
be paid low wages by local employers, already live in the vicinity; already have households; and
already occupy housing in or around the City that is affordable to them.
A third flaw in methodology lies in its apparent assumption that any household that buys
or rents a new home in the City of Palm Desert will focus all of its direct spending exclusively
within the City's boundary lines. However, since the City is surrounded by other similar
communities where new households may also find services and retail opportunities, such an
assumption does not seem accurate. Much of the direct consumer spending by occupants of
newly -built housing homes will likely fall outside the City's limits. As a consequence, the nexus
studies have overstated the assumed generation of lower -income jobs within the City by a sizable
factor. The resulting "impact fees" conjured up by this speculative methodology are therefore
substantially over -stated, and unsupported by credible evidence.
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4. Failure to Comply With the Mitigation Fee Act,
The proposed "impact fees" would be deemed to violate the Mitigation Fee Act (Gov't
Code §§ 66000 et seq.) which codifies the specific findings and supporting evidence that must be
provided in order to lawfully enact any fees imposed as conditions of development approvals.
The City's documentation does not identify any particular new public facilities to be
financed with the fees. And, as noted above, it also fails to provide substantial evidence in the
record (as opposed to assumptions and speculation) to demonstrate any reasonable relationships
or nexus between the type of development and the use of the fee or the need for the unidentified
public facilities attributed to residential development. Section 66005(a) further states that any
fee or exaction imposed as a condition of development approval "shall not exceed the estimated
reasonable costs of providing the service or facility for which the fee or exaction is imposed."
California case law and the Mitigation Fee Act both prohibit the use of fees to attempt to
alleviate or correct any perceived existing deficiencies in the community's existing facilities or
level of service, so the new fees could not lawfully be used to help the City correct any existing
shortages of affordable housing. (Gov't Code § 66001(g).) Here, the City has acknowledged
that the lack of affordable housing is an existin community -wide problem, whether or not any
new housing is developed in the City.
5. The Proposed New "Impact Fees" Would Violate California Constitutional
Prohibitions Against "Special Taxes" Without Voter Approval.
The City's affordable housing requirements may be deemed to be unlawful special taxes.
The California Attorney General has published an Opinion explaining that such a "fee" on
market rate housing development to provide a subsidy for affordable housing programs would be
an unlawful "special tax" — invalid under the Cal. Const. (art, XI11) unless first approved by 2/3
of the voters. (62 Ops. Ca1.Atty. Gen. 673.)
Under the California Constitution, purported "fees" which exceed the reasonable costs of
providing facilities or services shown to be necessary as a result of development activities may
be deemed to be "special taxes" — which are unconstitutional and invalid in the absence of the
necessary voter approval. (E.g., Jacks v. City of Santa Barbara (2015) _- Cal.AppAth ;
Weisblat v, City of San Diego (2009) 176 Cal.AppAth 1022 [rental housing administrative "fee"
held to be an illegal general tax, because not based on evidence of the City's reasonable costs of
providing services].).)
6. General Plan "Consistency" Issues.
The proposed "housing impact fees" may be deemed to be inconsistent with several
policies included in the City's General Plan and its current Housing Element, which encourage
the development of more housing, and reducing constraints on such development.
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7. State Housing Law Issues.
City policies imposing unjustified or excessive exactions or fees on new development as
conditions of developing new housing in general are viewed as constraints on the supply of
housing generally by the California Department of Housing and Community Development, and
are deemed to operate as deterrents to affordable housing, which is contrary to State Housing
Law. Adoption of such new constraints may require the City to amend its Housing Element.
Denial of Equal Protection of the Laws and Substantive Due Process.
The City's impact fees, as applied to new residential development such as this project,
would arbitrarily require one class of residents (developers and purchasers of new market -rate
for -sale housing, and new rental housing, and their tenants) to contribute more to affordable
housing programs (which ostensibly benefit the community as a whole) than other residents. In
the absence of evidence demonstrating any rational basis for shifting such a public burden to the
private builders and residents of new homes on this selective basis, requiring these fees appears
to be arbitrary, in violation of constitutional rights to due process and to equal protection of the
laws
9. Unlawful Fees on "For Rent" Homes -- Circumvention of State Rental
Housing Law.
The proposed new housing "impact fees" on rental developments would be invalid for the
reasons summarized above, but also would also likely be deemed invalid for an additional reason
— inconsistency with controlling State Rental Housing Law.
The proposed new fees on "for rent" housing appear to have been suggested as an attempt
to circumvent State law. California's Costa -Hawkins Rental Housing Act [Cal. Civ. Code
§§ 1954.50 of seq.] prohibits cities from regulating the rents charged on most new rental housing
units. Palmer 1,. City of Los Angeles (2009) 175 Cal.App.4th 1396, held that an ordinance that
required developers of new rental housing to set aside a percentage of the new units to be
occupied at restricted, below market, rents for lower income residents violated the Costa -
Hawkins Act, The Court also held that the ordinance's provision for payment of "in lieu fees" as
an alternative means of satisfying the requirements were inextricably intertwined with the
underlying set -aside requirements and thus were equally invalid. The Supreme Court declined to
review or change that decision, and the Governor vetoed proposed legislation in 2013 that
purported to overturn that decision. Accordingly, fees imposed as conditions of approving new
for -rent development projects — regardless how "relabeled" as impact fees rather than "in lieu
fees" remain unauthorized, contrary to State law, and are unlawful.
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May 14, 2015
Lauri Aylaian
Director of Community Development
City of Palm Desert
73-510 Fred Waring Drive
Palm Desert, CA 92260
Subject: Review of Comments regarding the Affordable Housing Nexus
Studies for Palm Desert; EPS #141134
Dear Lauri:
Thank you for forwarding the materials submitted by the Desert Valleys
Builders Association (DVBA) regarding the affordable housing nexus studies
and fees under consideration by the City of Palm Desert. As the authors of
the nexus studies and feasibility assessment for Palm Desert, as well as
similar studies for other California communities, we at Economic & Planning
Systems (EPS) are pleased to have the opportunity to engage with the
development community on this important topic.
The DVBA's letter makes several good points regarding the potential merits of
pending and recent legislation in addressing affordable housing goals in Palm
Desert and throughout the State. EPS consistently recommends that
jurisdictions consider a wide variety of funding approaches to affordable
housing, so that the costs of meeting this important community need can be
shared broadly, rather than solely by increasing costs for homebuilders (and
potentially reducing values for landowners). EPS has been working on
Infrastructure Financing Districts ("Enhanced" and otherwise) and agrees that
this tool is worth exploring as one of the City's options for raising revenue for
affordable housing.
It is also fair to say that inclusionary zoning in California has been challenged
in several lawsuits in recent years, and may or may not survive as it has
traditionally been practiced for several decades in this State. However, the
studies we have done for Palm Desert represent the current industry standard
alternative to inclusionary zoning (which historically was based simply on local
policy preferences), as our studies are focused on establishing a nexus
relationship between new market -rate housing and increased demand for
EtOnOmrCRF'annrny-Systems,Inc. below -market -rate ("affordable") units. The first such fees that we are aware
One xarser P,aza, s`,ne 1410 of were calculated in Santa Monica and have been in place for many years,
Oak,'and, CA 94612 and many cities have been pursuing nexus -based fee programs in the wake of
510841 9190 te; the Palmer and Patterson cases. While we are not aware of any legal cases
510 740 2080 tax
focused on the validity of these nexus arguments thus far, it is worth noting
Oak;and that several California jurisdictions (Sunnyvale, Mountain View, Santa Rosa,
sacramento and Sonoma County) have adopted fees based on our methodology, and other
7env pr
De ryeles jurisdictions have adopted similar fees based on comparable studies by some
www.epsys.eom P: 1141000s1141134ParmDe5etr1Report1EP5CommentLtr051415.db x
Lauri Aylaian
May 14, 2015
Page 2
of our competitors. That said, we at EPS are not legal advisers and certainly would suggest that the
City's own legal counsel review our studies and applicable statutes and case law to gain comfort in
the validity of the approach.
Elsewhere in the DVBA letter, we are not certain of the validity of the uncited claim that each $1,000
of additional home price eliminates 10,000 or more potential buyers from the opportunity for home
ownership. This seems like a number based on a much broader population than Palm Desert or the
Coachella Valley (perhaps the entire nation?), particularly given that an additional $1,000 of home
price equates to only about $5/month on mortgage payment. While financing requirements have
tightened following the recession, it seems unlikely that a bank would qualify a given mortgagee (let
alone 10,000 mortgagees) for a $250,000 home but not a $251,000 home. Perhaps their citation is
an interpolation of studies on the impacts of an extra $50,000 or $100,000 of home price?
Regarding the legal opinion letter from McNeill Law Offices, many of the points raised in that letter
are legal questions, such as the standard of review and whether the fee is a "mitigation" or
"regulatory fee," and again EPS suggests that the City's legal counsel review those questions and
concerns. However, there are several technical issues that we would like to speak to. Pursuant to
their concern regarding the date of implementation noted on page 2, please note that some
communities do elect to apply any newly adopted fees only to projects not yet in review or entitled
by the City, or otherwise delay implementation of the fee, to address the concern that such fees will
affect the economics of ongoing projects in negative ways.
Also, on page 7, the letter asserts that the underpinning of the nexus analysis is the notion that
there is an "idealized mix of income strata" that the fee aims to promote and balance. Whereas
certain existing State and regional policy goals such as the Regional Housing Needs Allocation
(RHNA) may aim to promote such a balance, the nexus analysis aims to objectively illustrate how
the typical spending of households at different income levels translates into demand for goods and
services and workers to provide them (including legal, healthcare, and public services as
recommended in the McNeill letter, not just "wet -nurses" and "pool boys" as dismissively stated in
the letter).
On page 10 and twice again on page 13, the letter states that the fee from the study "exceeds costs"
because it calculates maximum fees based on impacts rather than using the RHNA goals for
affordable housing in Palm Desert. Here, I will point out that: 1) I am not certain how the author is
reaching his conclusion that our study suggests demand for 444-2,031 affordable units, as he does
not "show his work" in calculating these figures; 2) the RHNA numbers reflect policy goals for
housing production in a specific period of time, whereas the nexus study calculates the relationship
between market -rate home production and affordable housing demand based on market -rate unit
pricing but not for any specific time period, and thus are not directly comparable; 3) the maximum
nexus -based fees are calculated based on the worker demand associated with new market -rate
households at various income levels, and would be proportionately the same whether assuming the
City adds 100 market -rate units or 1,000 at a given price point; and 4) we understand that the
Patterson case with which the attorneys should be familiar specifically found that City at fault for
relying on RHNA as a proxy for affordable housing demand (and thus costs) rather than calculating
the impacts from development more specifically (as we have done in our study).
Finally, the letter asserts that the fee study is inconsistent with certain aspects of the City's Housing
Element, and thus is "arbitrary, capricious, and invalid." As alleged evidence, the letter states that
the EPS study calculates housing demand for income categories including "very low", "low",
"median", and "moderate" income, while the Housing Element discussion of income levels subsumes
P �141000sV4ll34P4lmDesertkReportkFPSCommentLtrOS1415.docx
Lauri Aylaian
May 14, 2015
Page 3
"median income" within the category of "moderate income" households. While again this may be a
matter of legal technicality that deserves review by the City's legal counsel, it strikes me as a great
overstatement to claim this as a "fatal defect in the fee study."
I hope you find this response helpful, and thank you again for the opportunity to respond to
comments regarding our work.
Sincerely,
ECONOMIC & PLANNING SYSTEMS, INC.
Darin Smith
Managing Principal
P U41000s\141134Pa1mDesertlReportlfPSCommentCtrOS1415.0o x
1101k
BEST BEST & KMEGFA
ATTORNEYS AT LAW
Memorandum
To: Palm Desert City Council Members File No.: 72500.00001
From: Robert W. Hargreaves, Assistant City Attorney
Date: May 19, 2015
Re: Affordable Housing Mitigation Fees
The Desert Valley Builders Association (DVBA) and Riverside Chapter of the Building
Industry Association (BIA) have submitted letters from their attorneys that raise a number of
legal issues regarding the proposed affordable housing mitigation fee program. Those arguments
are addressed briefly below. In summary, numerous other California jurisdictions have relied on
nexus studies similar to the ones prepared for the City's to impose affordable housing mitigation
fees. To our knowledge, those fees have not been successfully challenged. The City is not
breaking new ground with these fees. In our opinion the affordable housing mitigation fees can
be successfully defended against these challenges.
Below are responses to the numbered issues raised by the two letters.
I. DVBA ( Letter dated April 23, 2015 from Mr. McNeill, Esq. to Gretchen
Gutierrez)
1. Procedural issues. The City agrees that the new fee cannot be imposed for 60 days
after the final action to impose the fee.
2. Nolan/Dolan. DVBA argues strenuously and at great length that the fee must meet the
nexus and rough -proportionality tests of the Nolan/Dolan line of Supreme Court cases. We
concur. The mitigation fee statute under which the City is proceeding, Gov't Code section
66001, requires as much.
As explained at length in the staff report, the City has met those tests with industry -
standard nexus studies: Nexus -Based Affordable Housing Fee Analysis for Rental Housing and
Nexus -Based Affordable Housing Fee for For -Sale Housing. Both studies clearly establish the
nexus between the construction of new market -rate housing and the need for affordable housing.
Both studies, using detailed factual analysis, have quantified the fees needed to fully mitigate
those impacts (59.24-$20.21 per square foot). The fee proposed by staff (S2 per square foot) is
substantially less. Consequently, the nexus and rough -proportionality tests are fully satisfied.
Numerous other California jurisdictions have used similar studies to justify implementation of
affordable housing impact fees at much higher levels.
3. Regulatory fees. DVBA argues that the fees do not meet the standards for
"regulatory fees". The City has not claimed otherwise and, to the contrary, has proceeded under
the rubric of "mitigation fees".
72500.00001 `•.9790040.2
1101k
BEST BEST & KRIEGER
ATTORNEYS AT LAW
4. Fees are excessive. DVBA argues that the fees are "far in excess" of the impacts.
DVBA does not provide any factual analysis to substantiate that allegation. In contrast, the
City's nexus studies provide detailed factual analysis to quantify the impacts.
5. Fees are Inconsistent with the Housing Element. Staff has provided a detailed
memorandum "Estimate of Costs for the City of Palm Desert Affordable Housing Program As
Approved in Housing Element Adopted For 2014-2021" that demonstrates how the affordable
housing mitigation fees are designed to meet the objectives of the Housing Element.
IT. BIA (Memorandum dated April 22, 2015 from Mr. Lanferman, Esq. to Mr.
Blankenship)
1. No statutory authority. BIA argues that mitigation fees can only be charged to
construct public facilities. In this case, the fees will be used to acquire for the City interests in
real property that provide affordable housing.
2-3. The nexus studies do not support the fees. BIA argues that the fees are not justified
by the nexus studies. As noted above, the City respectfully disagrees. .The studies are factually
detailed and demonstrate nexus and proportionality. Similar studies have been used to justify
fees in other jurisdictions, and have not been successfully challenged.
4. Failure to comply with Mitigation Fee Act. Those arguments are addressed above.
5. The fees would be special taxes. Impact fees are not taxes.
6. Fees are inconsistent with General Plan and Housing Element. This issue is addressed
above.
7. State Housing Law Issues: State housing law fully supports efforts to promote
affordable housing.
8. Denial of equal protection: The nexus studies provide the rational basis for the
imposition of fees on new housing development
9 Unlawful fees on rental housing. The fee program is not intended to, and does not in
fact, regulate rents of market rate housing.
-2-
72500M001\9790040.2
Aylaian, Lauri
From: Aryan, Steve
Sent: Tuesday, May 19, 2015 12:49 PM
To: Aylaian, Lauri
Subject: FW: Governor's May Revise 2015-16
Attachments: AB 2.pdf; AB 2 Analysis.htm; AB 1335.pdf, AB 1335 Analysis.htm; SB 628 chaptered.htm;
SB 628 Analysis.htm
From: Joe A. Gonsalves & Son [mailto:Gonsalves@gonsalvi.com]
Sent: Monday, May 18, 2015 12:04 PM
To: Aryan, Steve
Subject: RE: Governor's May Revise 2015-16
Steve and Lauri,
I have provided you with some background on each bill individually. In addition, I have attached for
your review a copy of each bill along with their analysis.
AB 2 (Alejo):
This bill would allow local government entities, excluding schools, to form an Authority to collect tax
increment and issue debt. The Authority could use its powers to invest in disadvantaged
communities with a high crime rate, high unemployment, and deteriorated and inadequate
infrastructure, commercial, and residential buildings. Three of these four conditions would constitute
blight. The area where the Authority could invest would also be required to have an annual median
household income that is less than 80% of the statewide annual median income.
Like redevelopment agencies, this bill would allow Authorities to freeze the property taxes at the time
the plan for revitalizing the area is approved. The Authority will collect all the tax increment or the
increase in property taxes that is generated after that point and use it on specified activities. Unlike
redevelopment agencies, this bill would require the taxing entities in the area including the county,
city, special districts, or a military base to agree to divert tax increment to the Authority. No portion of
the local schools' share of tax increment may go to the Authority.
AB 2 changes the affordable housing requirements of RDAs in three ways. It increases the amount
an Authority must set aside for affordable housing from 20% to 25%. Second, the bill requires a
community revitalization and investment plan to ensure that housing affordable to and occupied by
extremely low-, very low-, and low-income households within an area does not decrease during the
life of the area plan. Third, the bill requires the authority to provide replacement housing in two rather
than four years. The Authority would be allowed to transfer the funds collected for affordable housing
to a housing authority within the project area or to the successor agency to a former redevelopment
agency.
This bill is very similar to AB 2280 (Alejo) of 2014 which was vetoed by the Governor because it
allowed local governments to establish a Community Revitalization and Investment Authority to use
tax increment revenues to invest in disadvantaged communities a vests this new program in
redevelopment law. In an attempt to address some of the Governor's concerns, this bill takes portions
of the Community Redevelopment Law (CRL) and incorporates it into this bill rather than cross
referencing the CRL.
This bill will very likely be passed by the Legislature and sent to the Governor. The question is
whether the Governor will sign it or not? We have had many conversations with the Governor's office
and the Department of Finance about this issue and they have repeatedly told us that any changes to
current law will be done through the budget process and not part of legislation.
AB 1335 (Atkins)
AB 1335, The Building Homes and Jobs Act, will generate hundreds of millions of dollars annually for
affordable housing through a $75 fee on real estate recorded documents, excluding those documents
associated with home sales. Funds generated will leverage an additional $2 to $3 billion in federal,
local, and bank investment.
Last session, SB 391 (DeSaulnier) would have imposed a $75 fee on every real estate instrument,
paper, or notice that is required or permitted by law, excluding real estate instruments, papers, or
notices recorded in connection with a transfer subject to a documentary transfer tax. The bill was
held in Assembly Appropriations Committee. The differences between this bill and SB 391 are as
follows:
1. Sets a cap of $225 on fees charged on a per parcel per transaction basis,
2. Creates a 20% set aside of funding for homeownership programs,
3. Requires the creation of an advisory board made up of experts and stakeholders to help
develop the investment strategy,
4. Directs the county recorders to stop collecting the fee if HCD determines that the funds are not
being used to support the purposes authorized by the Building Homes and Jobs Act,
5. Declares the intent of the Legislature to create a Secretary of Housing to oversee all of the
housing activities related to the state and to have a clearer and more unified approach to
housing in the state.
AB 1335 is currently in the Assembly Appropriations Committee. The bill requires the approval of 2/3
of the membership of the Senate and the Assembly to be enacted. Prior to 2010, specified fees could
be enacted by majority vote, but this authority was significantly limited by Proposition 26 (2010). This
will create some difficult hurdles for this Legislation to overcome.
SB 628 (Beall)
Senate Bill 628 was signed into law by the Governor last year.
This bill allows city or county officials to create an Enhanced Infrastructure Financing District (EIFD),
which is governed by a public finance authority, to finance public capital facilities or other specified
projects of communitywide significance that provide significant benefits to the district or the
surrounding community. SB 628 also allows EIFDs to finance housing for low- and moderate income
households and requires EIFDs to replace low- and moderate- income housing that is removed or
destroyed. The amount of tax increment revenues available to EIFDs is generated only by those local
governments that choose to participate, and doesn't include any revenues drawn from the State
General Fund. The bill requires any IFD that constructs dwelling units to set aside not less than 20%
of those units to increase and improve the community's supply of low- and moderate -income housing
available at an affordable housing cost to persons and families of low- and moderate -income.
This bill provides a means to finance the reuse and revitalization of former military bases, fund the
creation of transit priority projects and the implementation of sustainable communities plans,
construct and rehabilitate affordable housing units, and construct facilities to house providers of
consumer goods and services in the communities served by these efforts.
Should you have any questions or concerns, please feel free to contact our office,
Thank you,
Anthony
Anthony D. Gonsalves
Joe A. Gonsalves & Son
916-441-0597 office
916-441-5061 fax
From: saryan@cityofpalmdesert.org[mailto:saryan@cityofpalmdesert.org]
Sent: Thursday, May 14, 2015 2:50 PM
To: Joe A. Gonsalves & Son
Cc: layla ian (@cityofpa I mdesert.org
Subject: FW: Governor's May Revise 2015-16
Can you please respond to the question below? Thanks for your help!
Stephen
Stephen Y. Aryan
Risk Manager
Office Direct: (760) 776-6326
E-mail: saryan(d_)cityofpalmdesert.org
73-510 Fred Waring Drive
Palm Desert, CA 92260
www.cityofpalmdesert.org
From: Aylaian, Lauri
Sent: Thursday, May 14, 2015 12:17 PM
To: Aryan, Steve
Subject: RE: Governor's May Revise 2015-16
Steve,
Can you ask Anthony for his opinion regarding the likelihood of passage of AB 2, AB 1335, and SB 628? 1 would like his
professional opinion in writing (email is OK) so that I can share it with the City Council as part of a response to proposals
by the DVBA to avoid implementation of an affordable housing fee in Palm Desert. (The DVBA has suggested that Palm
Desert needn't impose any such fee, no matter how small, because these other mechanisms for providing affordable
housing are in the works at the State level, and will obviate the need for local funding.)
I'd like to get this by next Tuesday, please.
Thanks,
Lauri A.
Lauri Aylaian
Director of Community Development
City of Palm Desert
73-510 Fred Waring Drive
Palm Desert, CA 92260
760.346.0611 phone
760776.6417 fax
rom: Aryan, Steve
S t: Thursday, May 14, 2015 11:19 AM
Subj : FW: Governor's May Revise 2015-16
From: Joe A. Gbqsalves & Son fmailto:Gonsalves@clonsalvi.com]
Sent: Thursday, M 14, 2015 11:03 AM
Subject: Governor's PtQy Revise 2015-16
FROM: ANTHONY, JASON &,P'AUL GONSA-LVES
SUBJECT: GOVERNOR'S Y REVISE — 2015-2016
DATE: THURSD , MAY 14TH, 2015
OVERVIEW:
This mZwith
emor released the 2015-16 May Revision to the state budget that reflects a 7 billion increase in
Generaes compared to the January Budget. This year's budget is 1 /3 larger than the bu is during the
econowhich shows the economic rebound that the state is on. However, if the Legislature d Governor are
not pruew revenues, it is likely the state will face budget deficits in the out years. The follows will
providmmary of the use for these new revenues:
4