04-03-2023 - 04-03 12:03 David AvenellCITY OF
Federal Way
,'entered on Opportunity
Public Comment - Written
Meeting Type: LUTC - Regular Meeting
Meeting Date: April 3, 2023
Name: David Avenell
Resident/Business Owner: 0 Yes ❑ No
Comment Topic: Vesting to School Impact Fees to Support Housing Development
Written Comment:
Dear Councilmembers,
Intracorp Real Estate is currently pursuing development of market -rate townhomes at the site located at
32818 1 st Avenue South in Federal Way. We appreciate the City's recent efforts to spur housing
development to meet the goals laid out in its Housing Action Plan. The City Council's decision to
eliminate school impact fees for the 2023 year is an important part of the City's strategy to encourage
development. This council decision was also a vital contributing factor of Intracorp's decision to pursue
development of market -rate townhomes in Federal Way.
Given that impact fees are set annually, we understand the Committee is reviewing a proposed code
amendment to section FWRC 19.95.050 that would limit the year -over -year increase in impact fees by
a certain percentage, not to exceed a maximum dollar amount per unit. We recognize that the
proposed amendment is an effort to provide some certainty in annual increases for school impact fees.
Unfortunately, however, the proposed amendment as written would require developers to assume the
worst -case fee scenario for the purposes of underwriting. We fear this would negate the intended
investment -generating effect of lowering school impact fees.
As a solution, we would ask you instead to consider a code amendment providing for vesting to school
impact fees upon the date of a complete land use entitlement application. We are happy to collaborate
on a draft amendment that would implement vesting in such a way.
We believe this proposal would be most supportive of the effort to generate new housing development
in the City, which we understand was a major factor behind the Council's decision to reduce school
impact fees for the current year.
We appreciate the opportunity to provide input and look forward to working in the City of Federal Way.
Please do not hesitate to contact me with any questions about this.
Sincerely,
David Avenell
Intracorp NW, LLC
Received: 0410312023 12:03