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.Comment 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 15: 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 />Finding: This is a policy issue that cannot be addressed in the context of this administrative rule <br />process. -The City Council has reviewed graft 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 thaf should be reviewed include the elimination of <br />Stormwater SDC credit for detention facilities, and the lowering of the threshold that maytrigger <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 forfuture capital improvements..." 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 paficular 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 />.Comment 1T: There should be no administrative cap for SDCs; huge amounts ofstafftime 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 19: Consistent with our ancestors; the communityshould 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 />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 />