Collection of Fee - 2020 - Eagle Fire District - Capital Improvement Plan / Impact Fee Study - 6/30/2020FINAL REPORT - May 2018
AMENDED - June 2019
AMENDED - June 2020
Eagle Fire District
Impact Fee Study and
Capital Improvement Plan
Prepared By
Galena Consulting ]{
i
Anne Wescott A1NA �
1925 North Montclair Drive ❑NSULTING
Boise, ID 83702
Section I.
Introduction
This report regarding impact fees for the Eagle Fire District is organized into the following
sections:
An overview of the report's background and objectives;
A definition of impact fees and a discussion of their appropriate use;
An overview of land use and demographics;
A step-by-step calculation of impact fees under the Capital Improvement Plan
(CIP) approach;
A list of implementation recommendations; and
A brief summary of conclusions.
Background and Objectives
The Eagle Fire District hired Galena Consulting to calculate impact fees.
This document presents impact fees based on the District's demographic data and infrastructure
costs before credit adjustment; calculates the District's monetary participation; examines the
likely cash flow produced by the recommended fee amount; and outlines specific fee
implementation recommendations. Credits can be granted on a case -by -case basis; these credits
are assessed when each individual building permit is pulled.
Definition of Impact Fees
Impact fees are one-time assessments established by local governments to assist with the
provision of Capital Improvements necessitated by new growth and development. Impact fees are
governed by principles established in Title 67, Chapter 82, Idaho Code, known as the Idaho
Development Impact Fee Act (Impact Fee Act). The Idaho Code defines an impact fee as "... a
payment of money imposed as a condition of development approval to pay for a proportionate
share of the cost of system improvements needed to serve development."'
Purpose of impact fees. The Impact Fee Act includes the legislative finding that "... an
equitable program for planning and financing public facilities needed to serve new growth and
development is necessary in order to promote and accommodate orderly growth and development
and to protect the public health, safety and general welfare of the citizens of the state ofldaho."2
Idaho fee restrictions and requirements. The Impact Fee Act places numerous restrictions
onthe calculation and use of impact fees, all of which help ensure that local governments adopt
impact fees that are consistent with federal law.3 Some of those restrictions include:
GALENA CONSULTING FINAL REPORT -- PAGE 1
• Impact fees shall not be used for any purpose other than to defray system
improvement costs incurred to provide additional public facilities to serve new
growth;4
• Impact fees must be expended within 8 years from the date they are collected. Fees
may be held in certain circumstances beyond the 8-year time limit if the
governmental entity can provide reasonable cause;5
• Impact fees must not exceed the proportionate share of the cost of
capital improvements needed to serve new growth and development;6
• Impact fees must be maintained in one or more interest -bearing accounts within
the capital projects fund.'
In addition, the Impact Fee Act requires the following:
• Establishment of and consultation with a development impact fee advisory
committee (Advisory Committee);8
• Identification of all existing public facilities;
• Determination of a standardized measure (or service unit) of consumption of
public facilities;
• Identification of the current level of service that existing public facilities
provide;
• Identification of the deficiencies in the existing public facilities;
• Forecast of residential and nonresidential growth;9
• Identification of the growth -related portion of the District's Capital
Improvement Plan;10
• Analysis of cash flow stemming from impact fees and other capital
improvement funding sources;"
• Implementation of recommendations such as impact fee credits, how impact fee
revenues should be accounted for, and how the impact fees should be updated
over time;12
• Preparation and adoption of a Capital Improvement Plan pursuant to state law
and public hearings regarding the same;13 and
• Preparation and adoption of a resolution authorizing impact fees pursuant to state
law and public hearings regarding the same.14
GALENA CONSULTING FINAL REPORT -- PAGE 2
How should fees be calculated? State law requires the District to implement the Capital
Improvement Plan methodology to calculate impact fees. The District can implement fees of any
amount not to exceed the fees as calculated by the CIP approach. This methodology requires the
District to describe its service areas, forecast the land uses, densities and population that are
expected to occur in those service areas over the 10-year CIP time horizon, and identify the
capital improvements that will be needed to serve the forecasted growth at the planned levels of
service, assuming the planned levels of service do not exceed the current levels of service.15
Only those items identified as growth -related on the CIP are eligible to be funded by impact fees.
The governmental entity intending to adopt an impact fee must first prepare a capital
improvements plan." Once the essential capital planning has taken place, impact fees can be
calculated. The Impact Fee Act places many restrictions on the way impact fees are calculated and
spent, particularly via the principal that local governments cannot charge new development more
than a "proportionate share" of the cost of public facilities to serve that new growth.
"Proportionate share" is defined as "... that portion of the cost of system improvements .. .
which reasonably relates to the service demands and needs of the project."19 Practically, this
concept requires the District to carefully project future growth and estimate capital improvement
costs so that it prepares reasonable and defensible impact fee schedules.
The proportionate share concept is designed to ensure that impact fees are calculated by measuring
the needs created for capital improvements by development being charged the impact fee; do not
exceed the cost of such improvements; and are "earmarked" to fund growth -related capital
improvementsto benefit those that pay the impact fees.
There are various approaches to calculating impact fees and to crediting new development for
past and future contributions made toward system improvements. The Impact Fee Act does not
specify a single type of fee calculation, but it does specify that the formula be "reasonable and
fair." Impact fees should take into account the following:
• Any appropriate credit, offset or contribution of money, dedication of land,
or construction of system improvements;
• Payments reasonably anticipated to be made by or as a result of a new
development in the form of user fees and debt service payments;
• That portion of general tax and other revenues allocated by the District to growth -
related system improvements; and
• All other available sources of funding such system improvements.20
Through data analysis and interviews with the District and Galena Consulting identified the share
of each capital improvement needed to serve growth. The total projected capital improvements
needed to serve growth are then allocated to residential and nonresidential development with the
resulting amounts divided by the appropriate growth projections from 2017 to 2027. This is
consistent with the Impact Fee Act.21 Among the advantages of the CIP approach is its
establishment of a spending plan to give developers and new residents more certainty about the use
of the particular impact fee revenues.
GALENA CONSULTING FINAL REPORT -- PAGE 3
Other fee calculation considerations. The basic CIP methodology used in the fee
calculations is presented above. However, implementing this methodology requires a number of
decisions. The considerations accounted for in the fee calculations include the following:
• Allocation of costs is made using a service unit which is "a standard measure of
consumption, use, generation or discharge attributable to an individual unit22 of
development calculated in accordance with generally accepted engineering or
planning standards for a particular category of capital improvement."23 The service
units chosen by the study team for every fee calculation in this study are linked
directly to residential dwelling units and nonresidential development square feet.24
• A second consideration involves refinement of cost allocations to different land
uses. According to Idaho Code, the CIP must include a "conversion table
establishing the ratio of a service unit to various types of land uses, including
residential, commercial, agricultural and industrial."25 In this analysis, the study
team has chosen to use the highest level of detail supportable by available data
and, as a result, in this study, the fee is allocated between aggregated residential
(i.e., all forms of residential housing) and nonresidential development (all
nonresidential uses including retail, office, agricultural and industrial).
Current Assets and Capital Improvement Plans
The CIP approach estimates future capital improvement investments required to serve growth
over a fixed period of time. The Impact Fee Act calls for the CIP to "... project demand for
system improvements required by new service units ... over a reasonable period of time not to
exceed 20 years."26 The impact fee study team recommends a 10-year time period based on the
District's best available capital planning data.
The types of costs eligible for inclusion in this calculation include any land purchases,
construction of new facilities and expansion of existing facilities to serve growth over the next 10
years at planned and/or adopted service levels.27 Equipment and vehicles with a useful life of 10
years or more are also impact fee eligible under the Impact Fee Act.28 The total cost of
improvements over the 10 years is referred to as the "CIP Value" throughout this report. The cost
of this impact fee study is also impact fee eligible for all impact fee categories.
The forward -looking 10-year CIP for the District includes some facilities that are only partially
necessitated by growth (e.g., facility expansion). The study team met with the District to
determine a defensible metric for including a portion of these facilities in the impact fee
calculations. A general methodology used to determine this metric is discussed below. In some
cases, a more specific metric was used to identify the growth -related portion of such
improvements. In these cases, notations were made in the applicable section.
GALENA CONSULTING FINAL REPORT -- PAGE 4
Fee Calculation
In accordance with the CIP approach described above, we calculated fees for each depaitiuent by
answering the following seven questions:
1. Who is currently served by the District? This includes the number of residents
as well as residential and nonresidential land uses.
2. What is the current level of service provided by the District? Since an
important purpose of impact fees is to help the District achieve its planned level of
service29, it is necessary to know the levels of service it is currently providing to the
community.
3. What current assets allow the District to provide this level of service? This
provides a current inventory of assets used by the District, such as facilities, land
and equipment. In addition, each asset's replacement value was calculated and
summed to determine the total value of the District's current assets.
4. What is the current investment per residential and nonresidential land use? In
other words, how much of the District's current assets' total value is needed to
serve current residential households and nonresidential square feet?
5. What future growth is expected in the District? How many new residential
households and nonresidential square footage will the District serve over the CIP
period?
6. What new infrastructure is required to serve future growth? For example, how
many stations will be needed by the Eagle Fire District within the next ten years to
achieve the planned level of service of the District?"
7. What impact fee is required to pay for the new infrastructure? We calculated
an apportionment of new infrastructure costs to future residential and nonresidential
land- uses for the District. Then, using this distribution, the impact fees were
determined.
Addressing these seven questions, in order, provides the most effective and logical way to
calculate impact fees for the District. In addition, these seven steps satisfy and follow the
regulations set forth earlier in this section.
"GRUM" Analysis
In the District, not all capital costs are associated with growth. Some capital costs are for repair
and replacement of facilities e.g., standard periodic investment in existing facilities such as
roofing. These costs are not impact fee eligible. Some capital costs are for betterment of facilities,
or implementation of new services (e.g., development of an expanded training facility). These
costs are generally not entirely impact fee eligible. Some costs are for expansion of facilities to
accommodate new development at the current level of service (e.g., purchase of new fire station
to accommodate expanding population). These costs are impact fee eligible.
Because there are different reasons why the District invests in capital projects, the study team
conducted a "GRUM" analysis on all projects listed in each CIP:
GALENA CONSULTING FINAL REPORT -- PAGE 5
Growth. The "G" in GRUM stands for growth. To determine if a project is solely
related to growth, we ask "Is this project designed to maintain the current level of
service as growth occurs?" and "Would the District still need this capital project if
it weren't growing at all?" "G" projects are only necessary to maintain the
District's current level of service as growth occurs. It is thus appropriate to
include 100 percent of their cost in the impact fee calculations.
Repair & Replacement. The "R" in GRUM stands for repair and replacement. We
ask, "Is this project related only to fixing existing infrastructure?" and "Would the
District still need it if it weren't growing at all?" "R" projects have nothing to do
with growth. It is thus not appropriate to include any of their cost in the impact fee
calculations.
Upgrade. The "U" in GRUM stands for upgrade. We ask, "Would this project
improve the District's current level of service?" and "Would the District still do
it even if it weren't growing at all?" "U" projects have nothing to do with
growth. It is thus not appropriate to include any of their cost in the impact fee
calculations.
Mixed. The "M" in GRUM stands for mixed. It is reserved for capital projects that
have some combination of G, R and U. "M" projects by their very definition are
partially necessitated by growth, but also include an element of repair, replacement
and/or upgrade. In this instance, a cost amount between 0 and 100 percent should be
included in the fee calculations. Although the need for these projects is triggered by
new development, they will also benefit existing residents.
Projects that are 100 percent growth -related were determined by our study to be necessitated
solely by growth. Alternatively, some projects can be determined to be "mixed," with some
aspects of growth and others aspects of repair and replacement. In these situations, only a
portion of the total cost of each project is included in the final impact fee calculation.
It should be understood that growth is expected to pay only the portion of the cost of capital
improvements that are growth -related. The District will need to plan to fund the pro rata share of
these partially growth -related capital improvements with revenue sources other than impact fees
within the time frame that impact fees must be spent. These values will be calculated and
discussed in Section VI of this report.
Exhibits found in Section III of this report detail all capital improvements planned for purchase
over the next ten years by the District.
2
3
As explained further in this study, proportionality is the foundation of a defensible impact fee. To meet substantive due
process requirements, an impact fee must provide a rational relationship (or nexus) between the impact fee assessed
against new development and the actual need for additional capital improvements. An impact fee must substantially
advance legitimate local government interests. This relationship must be of "rough proportionality." Adequate
consideration ofthe factors outlined in Section 67-8207(2) ensure that rough proportionality is reached. See Banbury
Development Corp. v. South Jordan, 631 P.2d 899 (1981); Dollan v. District of Tigard, 512 U.S. 374 (1994).
4
See Section 67-8203(9), Idaho Code. "System improvements" are capital improvements (i.e., improvements with a
useful life of 10 years or more) that, in addition to a long life, increase the service capacity of a public facility. Public
facilities include fire, emergency medical and rescue facilities. See Sections 67-8203(3), (24) and (28), Idaho Code.
See Section 67-8202, Idaho Code.
GALENA CONSULTING FINAL REPORT -- PAGE 6
See Sections 67-8202(4) and 67-8203(29), Idaho Code.
5
See Section 67-8210(4), Idaho Code.
6
See Sections 67-8204(1) and 67-8207, Idaho Code.
7
See Section 67-8210(1), IdahoCode
8
See Section 67-8205, Idaho Code.
9
See Section 67-8206(2), Idaho Code.
10
See Section 67-8208, Idaho Code.
11
See Section 67-8207, Idaho Code.
See Sections 67-8209 and 67-8210, Idaho Code.
See Section 67-8208, Idaho Code.
See Sections 67-8204 and 67-8206, Idaho Code.
12
13
14
15
As a comparison and benchmark for the impact fees calculated under the Capital Improvement Plan approach, Galena
Consulting also calculated the District's current level of service by quantifying the District's current investment in
capital improvements, allocating a portion of these assets to residential and nonresidential development, and dividing
the resulting amount by current housing units (residential fees) or current square footage (nonresidential fees). By using
current assets to denote the current service standard, this methodology guards against using fees to correct existing
deficiencies.
17
See Section 67-8208, Idaho Code.
19
See Section 67-8203(23), IdahoCode.
20
See Section 67-8207, Idaho Code.
21
The impact fee that can be charged to each service unit (in this study, residential dwelling units and nonresidential
square feet) cannot exceed the amount determined by dividing the cost of capital improvements attributable to new
development (in order to provide an adopted service level) by the total number of service units attributable to new
development. See Sections 67-8204(16), 67-8208(1(f) and 67-8208(1)(g), Idaho Code.
22
See Section 67-8203(27), IdahoCode.
23
See Section 67-8203(27), IdahoCode.
24
The construction of detached garages alongside residential units does not typically trigger the payment of additional
impact fees unless that structure will be the site of a home -based business with significant outside employment.
25
See Section 67-8208(1)(e), IdahoCode.
26
27
See Section 67-8208(1)(h).
This assumes the planned levels of service do not exceed the current levels of service.
28
The Impact Fee Act allows a broad range of improvements to be considered as "capital" improvements, so long as the
improvements have useful life of at least 10 years and also increase the service capacity of public facilities. See Sections
67- 8203(28) and 50-1703, IdahoCode.
29
30
This assumes that the planned level of service does not exceed the current level of service.
This assumes the planned level of service does not exceed the current level of service.
GALENA CONSULTING FINAL REPORT -- PAGE 7
Section II.
Land Uses
As noted in Section I, it is necessary to allocate capital improvement plan (CIP) costs to both
residential and nonresidential development when calculating impact fees. The study team
performed this allocation based on the number of projected new households and nonresidential
square footage projected to be added from 2019 through 2029 for the District. These projections
were based on the most recent growth estimates from COMPASS, data provided by the City of
Eagle, regional real estate market reports, interviews with developers and recommendations
from District Staff and the Impact Fee Advisory Committee.
Demographic and land -use projections are some of the most variable and potentially debatable
components of an impact fee study, and in all likelihood the projections used in our study will
not prove to be 100 percent correct. The purpose of the Advisory Committee's annual review is
to account for these inconsistencies. As each CIP is tied to the District's land use growth, the
CIP and resulting fees can be revised based on actual growth as it occurs.
The District serves the population of the City of Eagle, as well as portions of unincorporated Ada
County. The following Exhibit II-1 presents the current and estimated future population for the
District.
Exhibit II-1.
Current and Future Population within the boundaries of the Eagle Fire District
Population
2019 2029 Net Increase Percent Increase
37,400 60,455 23,055 62%
The District currently has approximately 37,400 persons residing within its service boundary.
Current and future population estimates were derived by isolating the population within each
Transportation Analysis Zone (TAZ) within the District's boundaries according to current
COMPASS data. This data was compared to current population estimates from the City of Eagle,
which is within the Fire District boundaries, as well as recent permit activity and the number of
permits recently approved for future residential and non-residential construction. More multi-
family projects are being approved within the District than before, increasing the capacity for
population growth in the future.
Over the next ten years, COMPASS models indicate the District to grow by approximately
23,055 people, or at an annual growth rate of 6.2 percent. Based on this population, the following
Exhibit II-2 presents the current and future number of residential units and nonresidential square
feet for the District.
GALENA CONSULTING FINAL REPORT -- PAGE 8
Exhibit II-2.
Current and Future Land Uses, Eagle Fire District
Net Net Increase in Percent of
2019 2029 Growth Square Feet Total Growth
Population 37,400 60,455 23,055
Residential (in units) 13,357 21,591 8,234 20,584,821 89%
Nonresidential (in square feet) 2,404,286 4,857,991 2,453,705 2,453,705 11 %
Total 23,038,527 100%
As shown above, the Eagle Fire District is expected to grow by approximately 8,234 residential
units and 2,453.705 nonresidential square feet over the next ten years. Eighty-nine percent of this
growth is attributable to residential land uses, while the remaining eleven percent is attributable to
nonresidential growth. These growth projections will be used in the following sections to calculate
the appropriate impact fees for the District.
GALENA CONSULTING FINAL REPORT -- PAGE 9
Section III.
Impact Fee Calculation
In this section, we calculate impact fees for the Eagle Fire District according to the seven -question
method outlined in Section I of this report.
1. Who is currently served by the Eagle Fire District?
As shown in Exhibit II-2, the District currently serves 13,357 residential units and approximately
2.4 million square feet of nonresidential land use.
2. What is the current level of service provided by the Eagle Fire District?
The Eagle Fire District provides a level of service of an 85 percent fractile response time of 4
minutes. As the population of the District grows, additional infrastructure and equipment will be
needed to sustain this level of service. Based on conversations with District staff, it is our
understanding that the planned level of service is equal to the current level of service.
3. What current assets allow the Eagle Fire District to provide this level of service?
The following Exhibit III-1 displays the current assets of the Eagle Fire District.
Exhibit III-1.
Current Assets —Eagle Fire District
Type of Capital Asset
Facilities
Station #1
Station #2
Station #3
Square Replacement
Footage Value
21400 $ 8,560,000
5256 $ 2,102,400
8000 $ 3,200,000
ApparatusNehicles
3 Engines $ 1,950,000
1 Truck/Ladder $ 1,300,000
4 Brush Trucks $ 400,000
1 Tender $ 350,000
1 Heavy Rescue $ 500,000
8 Command Vehicles $ 520,000
1 Water Rescue vehicle $ 200,000
1 Safety Trailer $ 100,000
2 Command Trailer $ 100,000
Equipment
40 SCBAs $ 240,000
1 generator $ 13,000
42 Radios $ 294,000
Air Compressor $ 80,000
Total Assets $ 19,909,400
Plus Cost of Fee -Related Research
Impact Fee Study $ 6,000
Plus Avimor Fund Balance $ 100,000
$ 19,915,400
GALENA CONSULTING FINAL REPORT -- PAGE 10
As shown above, the District currently owns approximately $19.9 million of eligible current assets.
These assets are used to provide the District's current level of service.
4. What is the current investment per residential unit and nonresidential square foot?
The Eagle Fire District has already invested $1,391 per existing residential unit and $0.56 per
existing nonresidential square foot in the capital necessary to provide the current level of service.
This figure is derived by allocating the value of the District's current assets between the current
number of residential units and nonresidential square feet.
We will compare our final impact fee calculations with these figures to determine if the two
results will be similar; this represents a "check" to see if future District residents will be paying
for infrastructure at a level commensurate with what existing District residents have invested in
infrastructure.
5. What future growth is expected in the Eagle Fire District?
As shown in Exhibit II-2, the Eagle Fire District is expected to grow by approximately 8,234
residential units and 2.4 million square feet of nonresidential land use over the next ten years.
6. What new infrastructure is required to serve future growth?
The following Exhibit III-2 displays the capital improvements planned for purchase by the Eagle
Fire District over the next ten years.
Exhibit III-2.
Eagle Fire District CIP 2019 to 2028
Type of Capital Infrastructure
Facilities
Station #4 - Northwest
Vehicles
Engine for Station #4
1 Heavy Brush Truck
2 TRV for BLM trails and paths
Replacement of Existing Vehicles
CIP Growth Amount to
Value times Portion equals Include in Fees
Amount from
Other Sources
$ 6,900,000 100% $ 6,900,000 $
$ 650,000 100% $ 650,000 $
$ 600,000 100% $ 600,000 $ -
$ 60,000 100% $ 60,000 $ -
$ 4,552,125 0% $ $ 4,552,125
Equipment
11 additional SCBAs $ 88,000 100% $ 88,000 $
9 handheld radios $ 63,000 100% $ 63,000 $
Air trailer $ 100,000 100% $ 100,000 $ -
Replacement of Existing Equipment $ 553,000 0% $ $ 553,000
Total Infrastru $13,5• • - $ 5,105,125
Plus Cost of Fee -Related Research
Impact Fee Study $ 8,000 100% $ 8,000 $
Minus Avimor/Dry Creek Mitigation Fund Balance $ 200,000 100% $ 200,000 $
Grand Total 3,374,1 $ 5,105,125
GALENA CONSULTING FINAL REPORT -- PAGE 11
As shown above, the District plans to purchase approximately $13.4 million in capital
improvements over the next ten years, $8.3 million of which is impact fee eligible. These new
assets will allow the District to achieve its planned level of service in the future. Assuming
current housing and development trends continue at projected rates and desired land for Station
#4 is available for acquisition, the estimated date for the commencement of the construction of
Station #4 and purchase of additional apparatus and equipment identified above is 2026. The
additional heavy brush truck and two TRV are anticipated to be purchased in 2025.
The remaining approximately $5.1 million is the price for the District to replace existing
apparatus, vehicles and other equipment. Replacement of existing capital is not eligible for
inclusion in the impact fee calculations. The District will therefore have to use other sources of
revenue including all of those listed in Idaho Code 67- 8207(iv)(2)(h). The District has
identified property tax revenue as the source for funding non growth -related capital
improvements, and will replace its apparatus and equipment as they reach their industry life
span throughout the 10-year period.
The Idaho Development Impact Fee Act at I.C. § 67-8208 (j) provides: " If the proposed system
improvements include the improvement of public facilities under the jurisdiction of the state of
Idaho or another governmental entity, then an agreement between governmental entities shall
specify the reasonable share of funding by each unit, provided the governmental entity
authorized to impose development impact fees shall not assume more than its reasonable share
of funding joint improvements, nor shall the agreement permit expenditure of development
impact fees by a governmental entity which is not authorized to impose development impact fees
unless such expenditure is pursuant to a developer agreement under section 67-8214, Idaho
Code; ..." The proposed system improvements identified in this Eagle Fire District Impact Fee
Study and Capital Improvement Plan are those of the Eagle Fire Protection District alone and do
not include or involve any funding by or cost sharing with the City of Eagle or Ada County.
7. What impact fee is required to pay for the new capital improvements?
The following Exhibit III-3 takes the projected future growth from Exhibits II-2 and the growth -
related CIP from Exhibit III-2 to calculate impact fees for the Eagle Fire District.
Exhibit III-3.
Impact Fee Calculation, Eagle Fire District
Amount to Include in Impact Fee Calculation $8,269,000
Percentage of Future Growth
Residential
Non Residential
89%
11%
Amount Attributable to Future Growth
Residential $ 7,388,315
Non Residential $ 880,685
Future Growth 2017-2026
Residential (per unit) 8,234
Non Residential (per square foot) 2,453,705
Impact Fee
Residential (per unit) $ 897
Non Residential (per square foot) $ 0.36
GALENA CONSULTING FINAL REPORT -- PAGE 12
As shown above, we have calculated impact fees for the Eagle Fire District at $897 per
residential unit and $0.36 per nonresidential square foot. In comparison, as indicated in
question #4 above, property taxpayers within the District have already invested $1,391 per
residential unit and $0.56 per nonresidential square foot in the capital inventory necessary to
provide today's level of service. The difference between the current investment and the impact
fee per unit indicates current taxpayers have already built in some capacity for future
development.
The District cannot assess fees greater than the amounts shown above. The District may assess
fees lower than these amounts, but would then experience a decline in service levels unless the
District used other revenues to make up the difference.
GALENA CONSULTING FINAL REPORT -- PAGE 13
Section IV.
Fee Analysis and Administrative Recommendations
A comparison of the calculated Fire impact fee to similar fees to that being assessed by the Kuna
Rural Fire District, Star Rural Fire District, City of Meridian, City of Nampa, City of Caldwell and
City of Boise, as well as being considered by the North Ada County Fire and Rescue District and
the Middleton Fire District is provided in Exhibit IV-1:
Exhibit IV-1.
DRAFT Impact Fee Comparison - Fire
Eagle Star Kuna North Ada Co. City of City of City of Caldwell/ City of Nampa/ Middleton Wilder Marsing
Fire Fire Fire Fire and Rescue Boise Meridian Caldwell Nampa Rural Fire Fire Fire
District District District Rescue Rural Fire Rural Fire District District District
draft
$ 897 $ 829 $ 701 $ 647 $ 526 $ 693 $ 665 $ 560 $ 849 $ 825 $ 1,285
$ 0.36 $ 0.39 $ 0.35 $ 0.32 $ 0.15 $ 0.53 $ 0.33 $ 0.28 $ 0.42 $ 0.41 $ 0.64
The calculated impact fee for the Eagle Fire District is very close in range to the Star Rural Fire,
Kuna Rural Fire, Middleton Rural Fire and Wilder Rural Fire District's fees. The calculated
impact fee is higher than those fees currently being assessed by some municipal fire departments in
the valley for several reasons. First, these fire departments have been in service decades longer
than the Eagle Fire District and have created capacity in their capital facilities and other assets with
which to provide service to new growth. Second, growth in these areas has begun to become more
dense and urban, which does not necessitate new stations being built to serve new growth as there
are stations already appropriately located to serve this growth.
Some communities express concern that impact fees will stifle growth. Empirical data indicates
impact fees are not a primary reason for a decision to build or not build in a particular area. Factors
including the price of land and construction, market demand, the availability of skilled workers,
access to major transportation modes, amenities for quality of life, etc. all weigh more heavily in
decisions to construct new homes or businesses, as well for business relocation. Ultimately the
impact fee, which is paid at the time of building permit, is passed along to the buyer in the purchase
price or wrapped into a lease rate. Therefore, in a market with a high demand for development, an
impact fee higher than other jurisdictions is unlikely to slow growth.
An impact fee program will enable the District to plan for growth without decreasing its service
levels (response time), which can decrease buyer satisfaction and cause property insurance
premiums to increase. It will also allow the District to collect a proportionate share of the cost of
capital improvements from growth instead of funding all future capital through property taxes
assessed to existing residents and businesses.
As the District Commission evaluates whether or not to adopt the Capital Improvement Plan and
impact fee presented in this report, we also offer the following information regarding District
participation in funding, and implementation recommendations for your consideration.
GALENA CONSULTING FINAL REPORT -- PAGE 14
Implementation Recommendations
The following implementation recommendations should be considered:
Intergovernmental Agreements. The Eagle Fire District is enabled under Idaho Code as a
governmental entity to adopt impact fees. However, because impact fees are paid upon
building permit, and the District does not participate in this process, it needs another
governmental entity to collect these fees on its behalf. Idaho Code 67-8204(a) authorizes the
District to enter into an intergovernmental agreement with a city or county which can collect
fire fees on their behalf. In the case of this District, which includes one municipality and one
county, two intergovernmental agreements for the collection of Fire District impact fees would
have to be developed and adopted by the corresponding bodies.
Capital Improvements Plan. Should the Advisory Committee recommend this study to the
District Commission and should the Commission adopt the study, the District should also
formally adopt this Capital Improvement Plan. While not subject to the procedures of the Local
Land Use Planning Act (LLUPA), the adoption of the Capital Improvement Plan would comply
with the Act's requirements of other governmental entities to adopt capital improvement plans
into a Comprehensive Plan as part of the adoption of impact fees.
Impact Fee Ordinance. Following adoption of the Capital Improvement Plan, the Commission
should review the proposed Impact Fee Ordinance for adoption via resolution as reviewed and
recommended by the Advisory Committee and legal counsel.
Advisory Committee. The Advisory Committee is in a unique position to work with and advise
Commission and District staff to ensure that the capital improvement plans and impact fees are
routinely reviewed and modified as appropriate.
Impact fee service area. Some municipalities have fee differentials for various zones under
the assumption that some areas utilize more or less current and future capital improvements. The
study team, however, does not recommend the District assess different fees by dividing the areas
into zones. The capital improvements identified in this report inherently serve a system -wide
function.
Specialized assessments. If permit applicants are concerned they would be paying more than
their fair share of future infrastructure purchases, the applicant can request an individualized
assessment to ensure they will only be paying their proportional share. The applicant would be
required to prepare and pay for all costs related to such an assessment.
Donations. If the District receives donations for capital improvements listed on the CIP, they
must account for the donation in one of two ways. If the donation is for a non- or partially
growth -related improvement, the donation can contribute to the District's General Fund
participation along with more traditional forms, such as revenue transfers from the General Fund.
If, however, the donation is fora growth -related project in the CIP, the donor's impact fees should be
reduced dollar for dollar. This means that the District will either credit the donor or reimburse the
donor for that portion of the impact fee.
Credit/reimbursement. If a developer constructs or contributes all or part of a growth -related
project that would otherwise be financed with impact fees, that developer must receive a credit
against the fees owed for this category or, at the developer's choice, be reimbursed from impact
fees collected in the future.37 This prevents "double dipping" by the District.
The presumption would be that builders/developers owe the entirety of the impact fee amount
until they make the District aware of the construction or contribution. If credit or reimbursement
GALENA CONSULTING FINAL REPORT -- PAGE 15
is due, the governmental entity must enter into an agreement with the fee payer that specifies the
amount of the credit or the amount, time and form of reimbursement.38
Impact fee accounting. The District should maintain Impact Fee Funds separate and apart
from the General Fund. All current and future impact fee revenue should be immediately
deposited into this account and withdrawn only to pay for growth -related capital improvements
of the same category. General Funds should be reserved solely for the receipt of tax revenues,
grants, user fees and associated interest earnings, and ongoing operational expenses including the
repair and replacement of existing capital improvements not related to growth.
Spending policy. The District should establish and adhere to a policy governing their
expenditure ofmonies from the Impact Fee Fund. The Fund should be prohibited from paying
for any operational expenses and the repair and replacement or upgrade of existing infrastructure
not necessitatedby growth. In cases when growth -related capital improvements are constructed,
impact fees are an allowable revenue source as long as only new growth is served. In cases when
new capital improvements are expected to partially replace existing capacity and to partially
serve new growth, cost sharing between the General Fund or other sources of revenue listed in
Idaho Code 67-8207(I)(iv), (2)(h) and Impact Fee Fund should be allowed on a pro rata basis.
Update procedures. The District is expected to grow rapidly over the 10-year span of the CIPs.
Therefore, the fees calculated in this study should be updated annually as the District invests in
additional infrastructure beyond what is listed in this report, and/or as the District's projected
development changes significantly. Fees can be updated on an annual basis using an inflation
factor for building material from a reputable source such as McGraw Hill's Engineering News
Record. As described in Idaho Code 67-8205(3)(c)(d)(e), the Advisory Committee will play an
important role in these updates and reviews.
37
See Section 67-8209(3), Idaho Code.
38
See Section 67-8209(4), Idaho Code
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