05-01-2023 - 05-01 10:09 Meredith HolzemerCITY OF
Federal Way
Centered on Opportunity
Public Comment - Written
Meeting Type: LUTC - Regular Meeting
Meeting Date: May 1, 2023
Name: Meredith Holzemer
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
Mill Creek Residential appreciates the opportunity to comment on the proposal for park impact fees. MCR is currently 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.
The City's 2021 Housing Assessment states the City needs an average production of 339 units per year to meet its new missing
middle housing goals. The Housing Action Plan identified reducing the City's school impact fees as a key strategy to address
underinvestment in housing. Impact fees generally reduce overall land value and increase development risk. The recently
conducted Heartland study advised the City to reduce fees associated with development.
While the City removed school impact fees for the current year, we understand the City is now considering adding park impact fees.
Mill Creek understands that each department needs to plan for future impacts of development. However, the prerequisite to
collecting impact fees is investment in development that leads to issued building permits.
Land values became more attractive in Federal Way when school impact fees were removed. Mill Creek would ask the Commission
to consider delaying any implementation of other impact fees at this time. 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. Major variations in development costs such as impact
fees are not sustainable within a development pro forma. The vesting option would allow developments that are mid -entitlements to
deliver housing to proceed with needed certainty.
Mill Creek looks forward to future collaboration in Federal Way. Please reach out to me with any questions about this
Sincerely,
Meredith Holzemer
Managing Director, Mill Creek Residential
Received: 0510112023 10:09