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l:omment 14: Commercial and Industrial properties should be assessed for the Parks SDC as well. <br /> Finding: This is a policy issue that cannot be addressed in the context of this administrative rule <br /> process, as noted in the opening paragraph of this document. <br /> Comment 16: The City should aggressively campaign and promote passage of legislative bills to change <br /> laws that prevent recovery of some costs (e.g. schools). <br /> Fdnsliiag: This is a policy issue that cannot be addressed in the context of this administrative rule <br /> process. The City Council has reviewed draft bills pertaining to SDCs and has adopted positions <br /> regarding those bills. Staff in the City Manager's office can provide details on the Council's legislative <br /> agenda and the City's position on draft legislation. <br /> Comment 16: Specific policy decisions being proposed that should be reviewed include the elimination of <br /> Stormwater SDC credit for detention facilities, and the lowering of the threshold that may trigger <br /> <br /> Transportation SDCs for changes of use from 3,000 square feet to 1,000 square feet. <br /> Finding: With respect to credit against the Stormwater SDC for detention facilities, the SDC <br /> Methodology states that a credit may be granted "...for any capital improvement constructed as part of a <br /> development to the extent... that it reduces the development's demand upon existing capital <br /> improvements or the need for future capital improvements.. A Credit for detention facilities is being <br /> eliminated because the frequency and distribution of detention facilities does not enable the City to <br /> reduce or avoid the need to provide adequate capacity to serve new development. In addition, the lack <br /> of maintenance requirements and information regarding the overall effect the private facilities may have <br /> on the public system, undermines their effectiveness in reducing peak runoff and contributes to the need <br /> to continue to size public facilities as if all development were discharging to the public system. <br /> This change does not preclude the use of detention facilities. They may be necessary to meet other <br /> objectives that a particular development may want to accomplish. For purposes of clarity, it is noted here <br /> that retention facilities (those that retain water permanently on site and do not have a connection to the <br /> public stormwater system, e.g. dry wells) will continue to be eligible for credit. <br /> With respect to the lowering of the change of use threshold for evaluating if a Transportation SDC will be <br /> charged, based upon further review and analysis, the proposal to consider changes of use less than <br /> 3000 square feet has been dropped. Staff concluded that it would increase administrative costs, without <br /> improving cost recovery for the transportation system. <br /> S:omment 17: There should be no administrative cap for SDCs; huge amounts of staff time are utilized for <br /> processing permits of large projects. <br /> Finding: Staff conducted an analysis of the likely maximum dollar figure that a single permit could <br /> generate in administrative costs, and set the cap at a rate that is intended to ensure that appropriate <br /> administrative costs will be fully recovered through the charge. <br /> Comment 18: Consistent with our ancestors, the community should be willing to cover some of the costs of <br /> improving infrastructure. <br /> Finding: This is a policy issue that cannot be addressed in the context of this administrative rule <br /> process, as noted in the opening paragraph of this document. However, the City's Growth Management <br /> Study will provide an opportunity to review and revise processes and systems that affect development <br /> and growth to more closely align them with adopted City objectives. <br /> Comment 19: Several additional comments submitted were of a general nature which did not specifically <br /> address the proposed changes. These included references to Ballot Measure 47, mechanisms designed to <br /> control growth, quality of life issues related to growth, comparing non SDC fees other cities are charging, and <br /> <br /> the use of alternate standards for public infrastructure design. <br /> Finding: These are policy issues that cannot be addressed in the context of this administrative rule <br /> process, as noted in the opening paragraph of this document. <br /> Exhibit B to Administrative Order No. 58-97-02-F-2 Page 4 <br /> <br />