05-01-2023 - 05-01 10:06 David AvenellCITY OF
Federal Way
Centered on Opportunity
Public Comment - Written
Meeting Type: LUTC - Regular Meeting
Meeting Date: May 1, 2023
Name: David Avenell
Resident/Business Owner: ❑ Yes ✓❑ No
Comment Topic: Vesting to Park Impact Fees
Written Comment:
Planning Commission
City of Federal Way
33325 8th Avenue South
Federal Way, WA 98003
Re: Vesting to Park Impact Fees
Dear Planning Commissioners
Intracorp Real Estate is currently pursuing development of approximately 133 market -rate townhomes at the site located at 32818
1 st Avenue South in Federal Way and would evaluate other pursuits in the City. Our decision to continue to pursue the 1 st Avenue
development was based in large part on the City's decision to eliminate school impact fees, and it assumes no park impact fees.
Like many jurisdictions, we understand that Federal Way is working to address multiple planning challenges simultaneously. The
City's 2021 Housing Assessment concluded that the rate of housing production is not keeping pace with demand, in part due to the
multifamily housing moratorium and an
increased school impact fee. The Housing Assessment states the City needs an average production of 339 units per year to meet
its new missing middle housing goals. While the City removed school impact fees for the current year, we understand the City is
now considering adding park impact fees.
We reviewed the staff report and memorandum from the Parks Director about park impact fees. Intracorp understands that planning
for increased impacts to public infrastructure parks is a necessary element of long-range planning. However, we suggest that any
proposal for new fees be weighed amongst other
planning priorities such as encouraging housing development investment and providing certainty to projects currently pursuing
entitlements.
The City has sparked interest from the investment community with its recent removal of school impact fees and proposed zoning
changes. We would ask the Commission to consider delaying any implementation of impact fees at this time. Moreover, certainty as
to fees associated with development is required in order for development projects to remain financeable. If the City must pursue
park impact fees, we ask you to consider a code amendment that would provide for vesting to park impact fees upon the date of a
complete land use application. We are happy to work with you on a draft amendment that would ensure this needed certainty as to
fees.
We appreciate the opportunity to comment. As always please do not hesitate to contact me about this.
Sincerely,
David Avenell
Intracorp NW, LLC
Received: 0510112023 10:06