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04-03-2023 - 04-03 12:01 Meredith HolzemerCITY OF Federal Way ,'entered on Opportunity Public Comment - Written Meeting Type: LUTC - Regular Meeting Meeting Date: April 3, 2023 Name: Meredith Holzemer Resident/Business Owner: 0 Yes ❑ No Comment Topic: Vesting to School Impact Fees to Support Housing Development Written Comment: Dear Councilmembers, Mill Creek Residential is proposing a multifamily development project with approximately 350 units located at 3202- 3702 S. 320th in Federal Way. We are optimistic about this investment in the City of Federal Way and feel confident that the project will help to further the City's Housing Action Plan goals. The City Council's decision to eliminate school impact fees for the 2023 year was the primary catalyst for our decision to invest in Federal Way. If school impact fees are reinstated, we are uncertain whether we would continue this pursuit. To address this, we are writing to recommend that the City include an amendment to its Land Use Code that provides for vesting to school impact fees upon the date of a complete land use entitlement application. We are happy to work with you and planning to staff to propose a succinct draft of such an amendment. We have reviewed the proposed amendments to section FWRC 19.95.050 which limit annual increases to school impact fees by a percentage, not to exceed a certain amount when the prior year rate was zero. Unfortunately, varying fee amounts are not sustainable in a development proforma. As a result, a developer would need to assume the highest rate scenario for the purposes of underwriting. While we appreciate the intent of the proposed amendment, it may negate the positive effects of lowering or removing school impact fees in the previous year. For this reason, we hope you will consider allowing for vesting as to school impact fees, so that investors may proceed with development plans in Federal Way with a reasonable amount of certainty. We believe this solution will provide needed stability and continue to build on the positive results created by eliminating the school impact fees in the current year. We are looking forward to working with the City of Federal Way. Please do not hesitate to contact me with any questions about this. Sincerely, Meredith Holzemer Managing Director, Mill Creek Residential Received: 0410312023 12:01