HomeMy WebLinkAboutFinal adoption of Ordinance No. 1823, revising Section 2.06.1680 prohibit refunds of paid Impact Fees in exchange for credits
Commission Memorandum
REPORT TO: Honorable Mayor and City Commission
FROM: Chris Saunders, Assistant Planning Director
Tim McHarg, Planning Director
SUBJECT: Second reading of Ordinance 1823 which amends Section 2.06.01680,
BMC to prohibit refunds of paid impact fees in exchange for impact fee credits
MEETING DATE: March 19, 2012
AGENDA ITEM TYPE: Action.
RECOMMENDATION: Approve the second reading of Ordinance 1823.
Recommended motion: Having heard and considered public testimony, the recommendation of
the impact fee advisory committee, and information from staff I move to provisionally approve
Ordinance 1823 as presented.
BACKGROUND: The City issues impact fee credits to reimburse persons who build
qualifying capacity expanding projects in defined infrastructure systems. Credits can be issued in
three different form: cash, cash over time with interest, or a book balance which can off-set fees
charged to particular building permits. The City’s preference is to pay in cash as that has the least
long term cost for the City and is most advantageous to the private party. A decision to issue a
book balance credit is done because the decision maker has determined it is in the best interest of
the City to do so at that time.
The City issues refunds of impact fees paid for several reasons. Refunds are given when needed
to preserve standards of fairness and the linkage between the fees charged and delivery of
services.
Recently a question arose of whether a refund can be given when a person who has already paid
impact fees on a project later acquires impact fee credits from a third party and wishes to give the
credits to the City in exchange for a refund of the fee already paid. Finance, legal, and planning
staff discussed the matter. The present code language neither prohibits nor authorizes the practice
at this time leaving the matter to administrator discretion. After discussion, Staff concluded that
there were more possible problems with this practice than benefits. Staff discussed whether less
than an absolute prohibition was workable and concluded that there was no meaningful basis
upon which to draw distinctions in time, cost, or other objective factor. Therefore, Ord. 1823 is
proposed to adopt language specifically prohibiting this kind of refund.
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The impact fee program has been in place for sixteen years. Credits have been issued to many
parties for work performed. It is estimated that there have been over 200 transfers of issued
credits between private parties. This question has only arisen in the last few months and only
from one party. Staff does not believe that there will be any meaningful negative impact on any
credit holder or future project from this amendment to the code.
The Impact Fee Advisory Committee considered this item at its March 8, 2012 meeting. They
recommend approval of this ordinance. Minutes of their meeting are attached.
UNRESOLVED ISSUES: None
ALTERNATIVES: No substantive alternatives have been identified. The Commission may
adopt or not adopt the ordinance as they believe is best.
FISCAL EFFECTS: This ordinance does not have any specific cost associated with it and does
not alter any adopted departmental budget.
Attachments: Draft Ordinance 1823
Impact Fee Advisory Committee minutes
Report compiled on: March 8, 2012
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Ordinance 1823
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Ordinance No. 1823
AN ORDINANCE OF THE CITY COMMISSION OF THE CITY OF BOZEMAN,
MONTANA, PROVIDING THAT THE BOZEMAN MUNICIPAL CODE BE AMENDED BY
REVISING SECTION 2.06.1680 TO PROHIBIT REFUNDS OF PAID IMPACT FEES IN
EXCHANGE FOR IMPACT FEE CREDITS.
WHEREAS, the City of Bozeman is committed to addressing the community’s expressed needs
and desires for services; and
WHEREAS, the City of Bozeman is committed to meeting those desires and demands for
services in a fiscally responsible manner; and
WHEREAS, the City of Bozeman is committed to meeting those desires and demands for
services in a manner which recognizes the fiscal and legal interest of all of the system users now and in
the future; and
WHEREAS, Sections 7-6-1601 through 7-6-1604, MCA provide specific authority and
guidance about the necessary documentation to establish an impact fee and procedures to adopt and
administer an impact fee; and
WHEREAS, the City of Bozeman adopted an impact fee program in 1996 through ordinance
1414 which has been amended from time to time; and,
WHEREAS, it is desirable to clarify elements of the ordinance relating to refunds of impact fees
after having been paid and upon a request to exchange the payment for credits; and
WHEREAS, the City Commission considered all public comment offered at their regular
meeting on March 5, 2012; and
WHEREAS, the Impact Fee Advisory Committee considered the draft ordinance at its March 8,
2012 meeting and recommended approval of the ordinance as written.
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Ordinance 1823
Page 2 of 4
NOW THEREFORE, BE IT ORDAINED BY THE CITY COMMISSION OF THE CITY
OF BOZEMAN, MONTANA:
Section 1
That Section 2.06.1680 of the Bozeman Municipal Code be amended so that it reads:
2.06.1680 Refunds of Development Impact Fees Paid
A. Refunds of development impact fees shall be made only in the following instances and in the
following manner:
1. Upon application to the impact fee coordinator by the applicant, the city shall refund the
development impact fee paid if capacity is available and service is denied.
2. Expenses and encumbrances.
a. Upon application to the impact fee coordinator, the city shall refund the development impact
fee paid and not expended or encumbered within ten years from the date the development
impact fee was paid or spent in a manner not in accordance with this division or MCA 17-6-
1602. Refunds shall be paid to the owner of the property at the time the refund is due. In
determining whether development impact fees have been expended or encumbered, fees shall
be considered encumbered on a first-in, first-out (FIFO) basis.
b. When the right to a refund exists due to a failure to expend or encumber development impact
fees, the city shall publish written notice within 30 days after the expiration of the ten year
period from the date development impact fee was paid. The published notice shall contain the
heading "Notice of Entitlement to Development Impact Fee Refund."
3. If an applicant has paid a development impact fee required by this division and has obtained any
of the types of permits or extensions listed in 2.06.1640.A.1, 2.06.1650.A.1, 2.06.1660.A.1, or
2.06.1670.A.1, and the permit or extension for which the fee was paid later expires without the
possibility of further extension, then the applicant who paid such fee shall be entitled to a refund
of the fee paid, without interest. In order to be eligible to receive such refund, the applicant who
paid such fee shall be required to submit an application for such refund within 30 days after the
expiration of the permit or extension for which the fee was paid.
4. A refund application shall be made to the impact fee coordinator within one year from the date
such refund becomes payable under subsections A and B of this section, or within one year from
the date of publication of the notice of entitlement of a refund under subsection B of this section,
whichever is later. Any refund not applied for within said time period shall be deemed waived.
5. A refund application shall include information and documentation sufficient to permit the impact
fee coordinator to determine whether the refund claimed is proper and, if so, the amount of such
refund.
6. A refund shall include a pro rata share of interest actually earned on the unused or excess
development impact fee paid.
7. All refunds shall be paid within 60 days after the impact fee coordinator determines that such
refund is due.
8. Any refund payable pursuant to subsections A and B of this section, shall be made to the record
owner of property as of the date the refund was due.
9. Once paid, an impact fee may not be refunded in exchange for impact fee credits issued
according to 2.06.1690.
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Ordinance 1823
Page 3 of 4
Section 2
Repealer.
All provisions of the ordinances of the City of Bozeman in conflict with the provisions of this
ordinance are, and the same are hereby, repealed and all other provisions of the ordinances of the City of
Bozeman not in conflict with the provisions of this ordinance shall remain in full force and effect.
Section 3
Savings Provision.
This ordinance does not affect the rights and duties that matured, penalties that were incurred or
proceedings that were begun before the effective date of this ordinance. All other provisions of the
Bozeman Municipal Code not amended by this Ordinance shall remain in full force and effect.
Section 4
Severability.
That should any sentence, paragraph, subdivision, clause, phrase or section of this ordinance be
adjudged or held to be unconstitutional, illegal, or invalid, the same shall not affect the validity of this
ordinance as a whole, or any part or provision thereof, other than the part so decided to be invalid, illegal
or unconstitutional, and shall not affect the validity of the Bozeman Municipal Code as a whole.
Section 5
Codification.
This Ordinance shall be codified as indicated in Section 1.
Section 6
Effective Date.
This ordinance shall be in full force and effect thirty (30) days after final adoption.
PROVISIONALLY PASSED by the City Commission of the City of Bozeman, Montana, on
first reading at a regular session held on the _____ day of ________________, 2012.
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Ordinance 1823
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____________________________________
SEAN A. BECKER
Mayor
ATTEST:
____________________________________
STACY ULMEN, CMC
City Clerk
FINALLY PASSED, ADOPTED AND APPROVED by the City Commission of the City of
Bozeman, Montana on second reading at a regular session thereof held on the ___ of
____________________, 2012. The effective date of this ordinance is __________, __, 2012.
_________________________________
SEAN A. BECKER
Mayor
ATTEST:
_______________________________
STACY ULMEN, CMC
City Clerk
APPROVED AS TO FORM:
_________________________________
GREG SULLIVAN
City Attorney
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Page 1 of 4
Impact Fee Advisory Committee Meeting – March 8, 2012
MINUTES
THE CITY OF BOZEMAN IMPACT FEE ADVISORY COMMITTEE
CITY COMMISSION MEETING ROOM,
CITY HALL, 121 NORTH ROUSE AVENUE,
THURSDAY, MARCH 8, 2012
6:00 P.M.
ITEM 1. CALL TO ORDER AND ATTENDANCE
Chairperson Pro Temp Carpenter called the meeting to order at 6:08 p.m., in the City
Commission Meeting Room, City Hall, 121 North Rouse Avenue, Bozeman, Montana.
Members Present Staff Present
Randy Carpenter, Chairperson Pro Temp Chris Saunders, Assistant Planning Director
Erik Nelson
George Thompson
Rick Hixson
Chris Mehl, City Commission Liaison
Members Absent
James Nickelson, Chairperson
Anna Rosenberry
David Graham, Vice Chairperson
Rob Evans
ITEM 2. MINUTES OF JANUARY 26, 2012.
Mr. Thompson moved, Mr. Hixson seconded, to approve the minutes of January 26, 2012 as
presented. The motion carried 6-0. Those voting aye being Chairperson Pro Temp Carpenter,
Mr. Nelson, Mr. Thompson, Mr. Hixson, and by proxy given to Mr. Hixson Ms. Rosenberry
and Mr. Nickelson. Those voting nay being none.
ITEM 3. PUBLIC COMMENT
{Limited to any public matter within the jurisdiction of the Impact Fee Advisory
Committee and not scheduled on this agenda. (Three-minute time limit per speaker.}
No public comment was forthcoming.
ITEM 4. CITY COMMISSION LIAISON
{A standing item to be used as needed}
Mr. Mehl asked the Chairperson Pro Temp is he could wait to give his report until Item 2 under
the Project Reviews. His request was granted.
ITEM 5. PROJECT REVIEW
1. Presentation of Ordinance #1823 to revise credit provisions to prohibit after the fact
refunds based on credits. (Saunders)
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Impact Fee Advisory Committee Meeting – March 8, 2012
Assistant Director Saunders presented the item to the Committee giving a short history of how
the issue came under consideration, the discussion staff had had internally on the issue, and
how they had not been able to define a solid rationale for allowing requests for reimbursement
of fees already paid in exchange for credits for some but not others. The most equitable
approach appeared to either allow for all or none and they had concluded that the possible
benefits for allowing such refunds were not enough to overcome the disadvantages to the City.
He summarized the discussion the Commission had had on the matter on March 5th.
Assistant Director Saunders described the credit program as it operates today and the scope of
the credit processes. He noted the municipal code is currently silent on this issue and staff
believes that the ordinance should be clear on the matter.
Mr. Mehl noted the Commission had voted on this on March 5th as a split 3-2 vote. Chairperson
Pro Temp Carpenter asked why the split. Mr. Mehl noted the infrequency of the issue only once
in 16 years and a desire to not limit the flexibility for businesses in using this option. Credits
function like commodities and there was some concern about possibly reducing their value. Mr.
Nelson said he didn’t see the value being reduced by this approach. The Committee discussed
how the credits can be like commodities; and how the options for exchanging and using them
works now and would work if the ordinance was adopted. The Committee discussed the
possible disadvantages if a large refund was requested in the future and whether it might affect
other projects on the capital improvement program.
Assistant Director Saunders described how the City had handled the first request that gave rise
to the discussion of this issue. Mr. Nelson asked how the transfers would work and why
someone would want to engage in this kind of impact fee credit exchange and refund process.
Assistant Director Saunders explained how it would work. Mr. Nelson asked if the City helps
facilitate connecting people who have the credits and people who may be able to use them and
asked if more effort could be put in that direction. Assistant Director Saunders described the
process the City uses and that the issue usually comes up with a larger commercial project. He
noted that there have been several creative ways people have come up with to monetize a non-
cash impact fee credit through private transactions.
Chairperson Pro Temp Carpenter asked if there had been any public comment on the ordinance
at the City Commission meeting. Assistant Director Saunders replied that there had not been.
Assistant Director Saunders noted that either allowing or not allowing the ability to do a credit
refund should be legally fine and it is a matter of deciding the City’s preference.
Mr. Nelson noted it could enable an upfront exchange of credits and avoid the concerns about
timing if there was more effort put into sharing the opportunity for purchase of credits with the
users so more people were seeking to acquire and use those credits. Assistant Director Saunders
noted that the City prefers to simply pay for qualifying work with cash rather than a book
balance impact fee credit as it is simpler for both the City and the person doing the work.
Credits other than direct cash have only been issued in limited circumstances. There was a
discussion on if there were credits which could move as there were changes in development on
lots with constructed buildings.
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Impact Fee Advisory Committee Meeting – March 8, 2012
Mr. Hixson moved to recommend approval of Ordinance 1823 to the City Commission. Mr.
Thompson seconded. The motion carried 6-0. Those voting aye being Mr. Hixson, Chairperson
Pro Temp Carpenter, Mr. Thompson, Mr. Nelson, and by proxy given to Mr. Hixson Ms.
Rosenberry and Mr. Nickelson. Those voting nay being none.
2. Update on March 5, 2012 City Commission discussion. (Saunders)
Assistant Director Saunders noted that the City Commission had conducted a work session with
the Committee and the consultants in February to consider several policy issues relating to the
update to the transportation impact fees. He gave a report of the actions the City Commission
took on each of the items at their follow up meeting on March 5th. He noted the Commission’s
decisions have been forwarded to the consultants and he will be working with the consultants to
move the update project forward. The Commission direction was:
Methodology – Use the incremental expansion option. Be very clear about what projects are
currently expected to be constructed with this approach and how the existing/new split is
worked out.
System Improvements – Use the major street network as shown on Figure 9-2 in the
transportation plan including the collectors. When describing the basis of the network please
call out those elements that are state highways. The Commissioners are very interested in
seeing what this means in the actual fee outcomes.
Funding Mix – The Commission asked the consultants to assume 75% of the urban funds
dedicated to maintenance and 25% to capacity expansion. These funds may be used in both
ways in the same project.
Categories of uses – Residential: Commission chose to use increments of 200 square feet and
delete the income based cost differential in the residential categories. This was discussed
between the Committee and the consultants during the review of the Setting the Stage
document.
Categories of uses – Non-residential: Commission wanted to consolidate the uses to broader
bands of similar activities. We will be looking to see how the major outliers fit into the new
structure.
Mr. Mehl gave his liaison report on how the Commission had voted. There were questions and
discussion on how the urban funds system works for designating particular streets as urban
routes and how the funds are used on the urban routes. It was noted that urban funds are usually
used for larger scale projects rather than routine small scale maintenance to get the most results.
It takes years to save up enough money in the urban fund account to do a big enough project to
make a difference in the level of service.
Impact fees can’t be used for maintenance but urban funds can be as can local assessments.
ITEM 6. OLD BUSINESS
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Impact Fee Advisory Committee Meeting – March 8, 2012
No old business was raised.
ITEM 7. COMMITTEE COMMENTS
Mr. Hixson noted that Bozeman had been included in a recent list of the seven strongest
micropolitan economies in the country. There was a discussion of the many good media reports
on the City and that is was likely that there will be growth in the future as there are so many
good attributes to the City. Mr. Hixson noted the City has been financially solid and that is a
significant thing in combination with the many good reports to draw people to the City.
ITEM 8. ADJOURNMENT
There being no further business to come before the Committee at this time, Chairperson Pro
Temp Carpenter adjourned the meeting at 6:56 p.m.
Randy Carpenter, Chairperson Pro Temp Chris Saunders, Assistant Planning Director
Impact Fee Advisory Committee Dept. of Planning & Community Development
City of Bozeman City of Bozeman
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