alphabetical index of incentive summary sheetsalphabetical index of incentive summary sheets ......

Alphabetical Index of Incentive Summary Sheets

Affordable Housing Grant Programs

B&O Tax Reductions

Brownfield Redevelopment Opportunity Zones (State ROZ)

Density Bonus

Development Agreement

Expedited Permit / Bin Bump‐Up

Innovative Housing Forms (Infill Toolkit)

Local Infrastructure Financing Tool (LIFT)

Main Street Program (State B&O Tax Credit)

Multi‐family Tax Exemption

Park Impact Fee Reduction

Permit Fee Reduction

Pre‐approved Plans

Reduced Parking Requirements

Regional Stormwater Facility

School Impact Fee (SIF) Reduction

Special Valuation (Historic Tax Exemption)

System Development Charge Reduction

Transportation Impact Fee Reduction

Wetland Mitigation Program

PAGE LEFT BLANK FOR PRINTING PURPOSES

Incentive Affordable Housing Funding Programs

Regulatory Authority

Bellingham "Home Fund", Ordinance No. 2012‐06‐033 Community Development Block Grant (HUD) HOME Investment Partnership Funds (HUD)

Summary

"Affordable Housing" means residential housing that is rented by a person or household whose monthly housing costs, including utilities other than telephone, do not exceed 30% of the household's monthly income. Can be federal money or local levy funding to nonprofit housing providers. Must guarantee affordability for a pre‐determined period of time. The goal of the program is to encourage increased affordable residential opportunities for low‐ to extremely low‐income households and stimulate the construction/rehabilitation of multifamily housing.

How it works

Process: The City receives federal Community Development Block Grant (CDBG), HOME program and Housing Levy funding, which is distributed and allocated through a competitive application process. Projects are annually solicited through a Notice of Funds Available, based on criteria set by the City. The Community Development Advisory Board (CDAB) reviews and recommends submitted project proposals to the Mayor, who selects projects to be funded. For federally funded projects, City Council makes the final confirmation. Once selected, the City enters into a funding agreement with the awarded entity, and a project is monitored over time for compliance with local, state and federal regulations.

Limitations: An entity must meet federal, state and/or local requirements to be eligible for grant and loan programs.

Case Studies

Laurel Village, 206 E Laurel St Bellingham Housing Authority 50 units serving families, disabled and homeless individuals City contribution: $450,000 Washington Grocery, 1133 Railroad Ave Catholic Housing Services Commercial spaces on the ground floor and 36 studio apartments on the second and third floors serving low‐income families and individuals. City contribution: $349,498

1

Case Studies, cont.

Dorothy Place, Forest Street Opportunity Council 21 secure units (6 studio, 8 1‐bed, 8 2‐bed) Dorothy Place provides support services and transitional housing for single women and women with children who are survivors of domestic violence. City contribution: $367,377

Analysis

Affordable housing grants are dependent on federal, state and other public funding (housing levy) and, as such, are subject to fluctuation of available funds.

Recommendation

Long‐term: Continue to focus affordable housing grant resources into projects that also meet other community objectives, such as locating within an urban village, along transit corridors and within CDBG target areas.

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Incentive B&O Tax Reduction


Authority to Impose B&O Tax ‐ RCW 35.22.280(32) Mandatory Model Ordinance ‐ RCW 35.102.040(2)

Allowance for City Specific Tax Preferences ‐ RCW 35.102.040(3) Bellingham B&O Tax Code ‐ BMC 6.04

Summary

The State of Washington collects business and occupation ("B&O") tax on businesses operating in the state, and authorizes cities to collect local B&O taxes within their respective jurisdictions. Any city that elects to do so must adopt the mandatory provisions of the so‐called "model B&O tax ordinance" developed under state law by a consortium of Washington cities (including Bellingham). Bellingham collects this tax for any individual or entity conducting business within the city limits, with few exceptions.

How it works

City B&O tax returns and payments are due annually, quarterly or monthly (at the discretion of the finance director). B&O taxes are levied at a percentage rate on the gross receipts of the business. Businesses are put in different classes such as manufacturing, wholesaling, retailing, and services. Within each class, the rate must be the same, but it may differ among classes. Bellingham has the following rates and classifications: Extracting/Manufacturing/Retail/Wholesaling: Gross Receipts x .0017 Services and other activities: Gross Receipts x .0044 These rates are lower than the State of Washington's. A typical business with gross receipts of $1 million pays $1,700 in taxes. Businesses with gross receipts less than $5,000 (quarterly filers) or $20,000 (annual filers) must file a tax return, but are not required to pay B&O tax. Annual B&O Tax Payments by NAIC codes:

minimum maximum median averageRestaurants 82.40 5,864.64 748.60 1,290.74 Office Services 166.56 10,854.28 1,094.56 3,345.48 Tech / consulting 123.19 1,155.68 446.87 526.75 Personal Services (Salons) 90.80 3,370.08 557.00 816.82 Industrial (automotive) 220.28 5,304.40 868.64 1,466.90

Case Study In Bellingham, approximately 8,000 active businesses generate $13,000,000 through B&O taxes. Large retail establishments contribute a significant amount to this total.

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Analysis

State law constrains the taxing decisions of cities in many ways, including limiting the number and type of tax classifications the City may adopt to those which are included in the model ordinance. However, state law specifically allows cities to adopt their own B&O tax exemptions, credits, and deductions (collectively, "tax preferences"). This "exception" is narrow but powerful. A targeted B&O tax preference could act as an incentive for businesses to locate in desired areas. A graduated B&O tax credit, with first‐year (new) businesses receiving a credit equal to 100% of the tax due, then an incremental reduction of the credit (up to three years) would encourage new businesses start‐ups by providing a tax break while they are becoming established. Applying this incentive in targeted districts would encourage the growth of new business in desired areas. The City will receive a delayed increase in tax revenue in future years if the businesses is successful. Theoretically, this program would not cost the City because the business eligible for the exemption is not currently located within the City and therefore, no taxes are being collected.

Recommendation

Short‐term: Create a graduated B&O tax credit for new businesses that locate in targeted urban villages as follows:

First year tax credit: 100% of the tax due (no tax) Second year tax credit: 75% of the tax due Third year tax credit: 50% of the tax due

The tax preference would be granted to a business, person, corporation or entity only once. Mid‐term: Explore the feasibility of raising the tax exemption threshold above $20,000 in gross sales, or provide other credits to support start‐up business, in line with State incentives.

Downtown Old

Town Waterfront Fairhaven

Samish

Way Fountain Barkley

Y Y Y Y

X Currently applicable Y Recommended TBD Further discussion or information needed ‐ Not possible given statute or conditions

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Incentive State Brownfield

Redevelopment Opportunity Zone (ROZ)


SB 5296 and Brownfield Redevelopment Opportunity Zone RCW 70.105D.150

Summary

A brownfield is a previously‐developed property that is abandoned or underutilized, where redevelopment is hindered by hazardous substances that require cleanup. A large number of Washington brownfield sites have been identified in the DOE priority list as ready for immediate cleanup. The State Brownfield Redevelopment Opportunity Zone (ROZ) program was developed to drive these cleanup projects forward.

How it works

A ROZ must be designated by a port, city or county. DOE prioritizes funding resources in ROZs, and allows a number of new tools that are only authorized for use in these zones. As a complement to the traditional enforcement‐based approach to cleanup, the ROZ approach creates incentives to reduce risk and improve the financial feasibility of adaptive re‐use of contaminated properties, facilitating the cleanup of the most toxic sites while also providing jobs. Eligibility:

1) At least 50% of the upland properties in the zone must be brownfields;

2) The upland portions of the zone must be comprised of parcels either owned by the designation agency (port, city or county) or whose owner has provided consent to have their property included within the zone;

3) The cleanup will be integrated with planned future uses of the properties and is consistent with the city or county comprehensive land use plan of the zone; and

4) The proposed properties lie within the incorporated area of a city or within an urban growth area.

Limitations: A ROZ can consist of one or more properties and can vary in size, but must be established through a city, county or port commission resolution stating that the criteria are met. Also, if a port establishes the ROZ, the city or county in with the zone lies must also approve the designation by resolution.

Case Study

Bellingham would be the first to implement a Brownfield Redevelopment Opportunity Zone in Washington State. The Port of Bellingham has presented the City of Bellingham with the opportunity to partner to create a Brownfield ROZ in the Waterfront District.

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Analysis

The Port and City has reviewed the legislation and determined that there are a number of advantages to establishing a ROZ within the Waterfront District. Now that the Waterfront Master Plan has been adopted, developer negotiations are underway, and cleanup sites are approaching major milestones, the Port and City are in a good position to move forward on the establishment of a Waterfront District ROZ.

Recommendations

Short‐term: Proceed in partnership with the Port to establish the Waterfront District as a ROZ. Mid‐term: Explore expanding the ROZ into all or parts of Old Town.

Downtown Old Town Waterfront Fairhaven Samish Way Fountain Barkley

TBD Y ‐ ‐ ‐


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Incentive Density Bonus


Growth Management Act RCW 36.70A, Cluster Subdivisions BMC 18.32, Affordable Housing Demonstration Program, BMC 20.27,

Urban Villages BMC 20.37

Summary

Provides an opportunity for developers to build more units (or floor area) than underlying zoning allows, in exchange for public benefit such as affordable housing, public space, etc.

How it works

Floor to Area Ratio (FAR) Bonus: A floor‐to‐area ratio (FAR) bonus allows an increase in the amount of buildable space relative to the area of the land upon which the building is sited. The developer submits an application for a bonus provision during the land‐use approval process. Depending on the type of bonus, some type of certification or ongoing monitoring may be required. The Affordable Housing Demonstration Program allows for an up to 50% bonus for projects that provide 100 percent permanently‐affordable single‐family owner‐occupied homes for low‐income individuals. The cluster subdivision ordinance offers a density bonus of up to 50 percent if the hearing examiner determines the quality of the features offered, compliance with criteria, and public benefit of the project are suitable.

Case Studies

OLD TOWN BONUS SYSTEM:

Type of Bonus Floor Area Ratio* (FAR) Credit Earned

Max. FAR Credit

Public Plaza / Open Space

1.5 square foot for every sq. ft. transferred

1.5

Affordable Housing 4 sq. ft. for each sq. ft. of affordable housing

0.5

LEED Silver Certification

0.5 for LEED Silver (or greater) Certification

0.5

Lake Whatcom Fund 1 square foot per fee unit contributed to the fund

0.5

The Samish Way and Waterfront urban villages contain the same bonus options as Old Town, but at different rates based on the market characteristics of the area.

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Analysis

Density thresholds may be established by local jurisdictions. The goal is to promote additional development in desired areas while benefitting the developer and providing general public benefit. However, the ability to provide a bonus depends on the existence of a density limit, and the use of the bonus may depend on the base rate and the desire of the developer to build beyond this limit. The existing FAR bonus provisions have not been used to date. This may be due partially to the lack of development occurring in these areas since urban village plans were adopted, or the base FAR permitted may be sufficient to achieve a reasonable return on investment without the need to apply for additional square footage bonuses. Regulations were recently updated in Downtown, Fountain and Fairhaven urban villages, however, density bonus provisions were not included in these areas, either because of the lack of density limits (Downtown) or low base densities do not create a gap for a feasible bonus system.

Recommendations

Short‐term: Finalize amendments to the Affordable Housing Demonstration ordinance to offer a density bonus to projects providing 50% permanently affordable housing to incentivize a mix of affordable and market rate units. Mid‐term: Conduct ongoing monitoring of bonus rates within urban villages to ensure the incentive is working as intended. Long‐term:

1. As new urban villages are planned, consider the feasibility of adopting a density bonus system.

2. If regulations for innovative housing forms under BMC 20.28 are updated, evaluate a density bonus provision in certain areas that may be appropriate considering the neighborhood character.

Downtown Old Town

Waterfront Fairhaven Samish Way

Fountain Barkley

‐ X X X


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Incentive Development Agreement


Development Agreements RCW 36.70B.170‐210, Development Agreement between City and Port BMC Resolution No. 2013‐28

Summary

A development agreement is a contract between the local jurisdiction and a person who has ownership or control of property within the jurisdiction. The purpose of the agreement is to specify the standards and conditions that will govern development. The intent of a development agreement is to encourage large‐scale development entities to redevelop underutilized areas that would not otherwise be developed by smaller operators, and clarify the roles and responsibilities of both parties.

How it works

The development agreement provides certainty and predictability to the developer that the property will be subject to the rules and regulations in effect at the time of approval. It also establishes clear expectations of the responsibility of each party. The agreement may include details about redevelopment phasing, timing of public improvements, funding mechanisms, etc. These agreements are voluntary, but once made, they are binding on the parties and their successors. Local jurisdictions must hold a public hearing prior to approving a development agreement and may only impose impact fees, dedications, mitigation measures, and standards as authorized by other laws.

Case Studies

Parberry/NW Recycling ‐ The City committed to constructing certain public infrastructure improvements such as street improvements, traffic control devices, water and sewer, and storm‐water in exchange for the relocation of the recycling center out of Old Town. The improvements must benefit the community at large. Port of Bellingham ‐ For the Waterfront District, the City has committed to construct necessary public infrastructure (streets, parks, utilities, etc) and the Port has committed to undertake the cleanup of the property, build marine infrastructure, and provide to the City the land for parks, public space and rights of way.

Analysis

Development agreements make the most sense for large areas (usually multiple or large parcels) or in situations where the project or regulations are unusual or complicated.

Recommendations Long‐term: Continue to enter into development agreements when opportunities arise and make sense for all parties.

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Incentive Expedited Permitting / "Bin Bump‐Up"


Administrative. See "City Review Times for Construction Permits"

Summary

Expedited permitting means that projects which comply with certain criteria are granted priority status and moved to the "front of the line" for permit review. Alternatively, under the "Bin Bump‐Up" program, certain projects (ie. green buildings) may be "bumped" to a review category with a faster turnaround time (eg. 7 day target versus a standard 28 days).

How it works

Bin Bump‐Up is currently available only to green building projects. See Bin Bump‐Up Incentive Handout. To receive expedited status, projects must be designed to BIA Built Green 4‐ or 5‐star rating, LEED certified (Silver minimum), or an alternative green standard as approved by the City. Projects must also include a construction waste management plan for deconstruction and demolition. The program allows these qualifying projects to be moved to the lower review time category.

Case Studies

Tacoma, WA offers permit assistance for key projects through the use of a special review team that works with the applicant from early design through building permit issuance and occupancy. King County, WA offers expedited permit review at the cost of 150% of the typical permitting fee.

Analysis

Faster review time provides a financial incentive for projects that meet City goals such as infill, sustainable development, or affordable housing. The majority of permit applications fall into the "7‐day" bin, and turnaround times for all projects have improved through efficiencies in the permitting process over the past several years. Staff time is already maximized from these city‐wide commitments. To avoid compromising established permit review times for projects city‐wide, additional staff (either new internal, overtime hours or hired on a contractual basis) would be needed if other projects were to be expedited to the "front of the line" or added to the "Bin Bump‐Up" program. Additionally, large projects in urban villages typically require a more complicated review, and are often being processed in the minimum amount of time feasible. A primary benefit of the existing green building Bin Bump‐Up program is the assignment of a special project review team to track and support the project from early design through final occupancy. This significantly expedites the building permit process.

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Recommendations

Short‐term: 1. Assign staff to an Urban Village Team to review and support qualifying

projects in targeted urban villages from the beginning to the end of the permitting process. The staff team will receive training to become specialists on the urban village and design review regulations.

2. Evaluate the possibility of expedited land use permit review for qualifying projects within targeted urban villages.

Mid‐term: After LEAN Kaizen events and upgrades to permitting software are complete, consider expanding the Bin Bump‐Up program (for building permit review) to include:

1. Qualifying projects within targeted urban villages.

2. Qualifying innovate housing projects under BMC 20.28 and/or those that provide affordable housing.


Y Y Y Y Y Y Y

X Currently applicable

Y Recommended

TBD Further discussion or information needed

‐ Not possible given statute or conditions

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Incentive Innovative Housing Forms (Infill Toolkit)


Growth Management Act RCW 36.70A, Infill Development

RCW 43.21C.299, Infill Development BMC 20.28

Summary

BMC 20.28 contains guidelines and standards for nine innovative housing forms, with associated design regulations. The forms include:

Small and Smaller Lot detached houses

Cottages

Detached Accessory Dwelling Units

Carriage Houses (over a garage)

Duplex/Triplex

Shared Courtyard

Garden Courtyard

Townhouses.

The intent is to create opportunities for more affordable housing and housing not currently available in the market, while promoting high‐quality traditional neighborhood design.

How it works

Innovative housing forms are permitted in all residential zones except most single‐family zones, neighborhood commercial zones, and the Lake Whatcom Watershed. Applicants may request minor modifications to the general parameters and design standards. Design standards and development regulations within this code trump the standard development code requirement.

Case Studies

Bellingham's Infill Toolkit was developed with extensive community input to create housing types that are compatible with traditional neighborhood character. Infill Design Toolkit ‐ Portland, OR: Focuses on medium‐density residential development (such as rowhouses, plexes, courtyard housing, and low‐rise multifamily development) in established neighborhood areas. Toolkit is composed of the sections: Strategies, Prototypes, Technical Pages, Project Profiles, and Neighborhood Design Policies.

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Analysis

BMC 20.28 does not apply to single‐family zones except for certain areas designated "Residential Transition" adjacent to urban villages or some areas that were annexed into the city. However, one or more housing forms could be proposed by a neighborhood association, property owner or developer for addition to an existing single‐family zone using a legislative rezone process. This does not increase the underlying density of existing zones. The housing forms available under BMC 20.28 are allowed outright in multi‐family zones, which limits their desirability and effectiveness since they are primarily single‐family housing. Additionally, staff has received input from the development community that elements of the document may be overly‐restrictive and prohibitive to the ease of use of the document.

Recommendations

Short‐term: In coordination with any regulatory updates, showcase the regulations and how they may be used. Long‐term:

1. Amend BMC 20.28 to clean‐up any errors and streamline the review process.

2. If the market does not respond to Infill Toolkit opportunities after the regulations are revised, consider implementing an incentive package.

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Incentive Local Infrastructure Financing Tool (LIFT)


LIFT RCW 39.102, Waterfront Planned Actions BMC 16.30

Summary

The State's LIFT program functions similarly to tax increment financing, which is a method of redistributing property and sales taxes collected within designated areas to finance infrastructure improvements.

How it works

Bellingham was selected as the one of the first communities to apply the LIFT program. The city designated the Waterfront District (and some surrounding areas in Old Town and Downtown) as its revenue development area. The City is now eligible to receive up to $1 million per year for 25 years to be used for repayment of bonds issued to finance eligible public improvements (such as streets, utilities, park facilities and recreational areas and parking facilities). The State will send payments based upon the combination of the following:

1. Increase in tax revenue over the base year (2007) AND/OR 2. Investments by the City in infrastructure within the revenue

development area.

The City may also count other (non‐state) funds that are spent in the revenue development area towards the $1 million/year if the incremental increase from sales and property tax do not reach that limit.

Analysis The application process for the LIFT program is now closed. Approval of additional projects would require future legislative action.

Recommendation

Mid‐term: Continue to participate in the LIFT program. Long‐term: If State funding is allocated to expand the program, assess the feasibility of expanding the incentive to other areas.

Downtown Old Town

Waterfront Fairhaven Samish Way

Fountain Barkley

‐ ‐ Y ‐ ‐ ‐ ‐


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Incentive Main Street Program B&O Tax Credit


Washington Main Street Tax Credit Incentive Program RCW 82.73

Summary

The Washington State Main Street program provides a financial incentive to businesses within a designated Main Street area that donate to the affiliate organization by providing a tax credit on state B&O taxes.

How it works

The Downtown Bellingham Partnership (DBP) was recently designated a Main Street organization. Businesses that donate to the DBP are now eligible for a B&O tax credit worth 75% of their donated amount. DBP can receive up to $133,333.33 in donations, and businesses can donate up to $250,000. To receive the Main Street Tax Credit, businesses must be registered to file their state excise tax electronically and a donation request must be filled out and submitted online. The donation can be spread out throughout the calendar year, but must be fulfilled by December 31. A business must take the tax credit the following year the donation is made. The tax credit cannot be carried forward and there is no refund for any credit above and beyond a business’ tax liability. Businesses statewide can also donate to the Main Street Trust Fund and receive a 50% tax credit. Donors may also be eligible for a federal income tax deduction as a charitable contribution, since the DBP is registered as a 501 c(3) organization.

Case Studies

City/Organization Main Street Tax Credit Incentive

Bainbridge Island DT Association $ 110,850

Ellensburg DT Association $ 70,800

Wenatchee DT Association $ 132,773.33

DT Walla Walla Foundation $ 131,785

Analysis

Because of limited available funds, businesses are encouraged to pledge early and often to guarantee the donation is eligible, as this is a first‐come first‐serve program. There is a statewide limit of $1.5 million per year. State law specifically allows cities to adopt their own B&O tax exemptions, credits, and deductions (collectively, "tax preferences").The City could create its own local Main Street to provide credit towards local B&O Taxes. However, since the state program has just gotten underway, information is not yet available to inform whether the state donation limits will be met (or exceeded).

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Recommendations

Short‐term: 1. Support Downtown Bellingham Partnership efforts to advertise the

program to downtown businesses through a redevelopment incentives webpage.

2. Evaluate the level of participation and funds generated through the state program for the next three years.

Long‐term: If, after a three‐year evaluative period, the State donation limits are met or exceeded, the City should explore the creation of its own local Main Street B&O Tax Incentive program.

Downtown Old

Town Waterfront Fairhaven

Samish

Way Fountain Barkley

Y ‐ ‐ TBD ‐ ‐ ‐


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Incentive Multi‐family Tax Exemption (MFTE)


New and Rehabilitated Multiple‐Unit Dwellings in Urban Centers RCW 84.14,

Multi‐family Housing BMC 17.82

Summary

The MFTE is State program, adopted by the City, which offers an 8‐year state and local property tax exemption on the residential value of new multi‐family construction (or 12 years for projects that dedicate a minimum 20% of the units for people of low or moderate incomes). The goal of the program is to stimulate new construction or rehabilitation of vacant/underutilized buildings in target areas, and to encourage increased residential population at a range of income levels.

How it works

The tax exemption is currently available in the Downtown, Old Town, Samish Way and Fountain District urban villages, and applies only to the value of new residential improvements (not land or commercial improvements). Project restrictions include prohibition of tenant displacement, minimum of four units, completion within 3 years of application, and no displacement of historic resources.

Case Studies

Since 1998, 683 multifamily units have been constructed under this program. All but 20 of these units are located Downtown. Examples include the Morse Hardware Site (2006, 374 units) and Marketplace Building (2003, 40 units). Morse Square Condominium ‐ Tax Years 2007 thru 2015 (Estimate for 2015) Total Tax Savings $ 1,260,494.00 The City of Spokane has adopted MFTE in both Urban Centers and designated corridors.

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Analysis

The MFTE program has been successful in spurring residential development downtown, which was the extent of the program area when the ordinance was adopted in 1998. The program was expanded to several other urban villages in 2010. Utilization in areas outside of Downtown has been limited to one 20‐unit project in the Fountain District. This may be due to lack of awareness within the development community and/or the slow regeneration of the housing economy, and likely not to any specific program barrier. The Waterfront District urban village plan was adopted in 2013 and did not include MFTE because the LIFT program incentive in this area is dependent on increase in tax revenue to provide funding for infrastructure improvements. Otherwise, the MFTE does not affect City of Bellingham revenues and should be strategically expanded in certain areas support residential infill goals. Barkley and Fairhaven are beginning to see residential growth and robust market response, but limited construction of affordable income‐restricted housing.

Recommendation

Short‐term: Promote the availability of MFTE in the applicable urban villages through a new development incentives webpage. Mid‐term: Expand the incentive in Fairhaven and Barkley Village for income‐restricted affordable housing projects.


X X Y1 X X Y1

1 Recommendation is to apply to income‐restricted housing as described in State regulations X Currently applicable Y Recommended TBD Further discussion or information needed ‐ Not possible given statute or conditions

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Incentive Park Impact Fee (PIF)


Growth Management Act (GMA) RCW 82.02, Park Impact Fees BMC 19.04

Summary

An impact fee is a fee charged by a city or county to developers to pay for the

costs of providing public facilities or of improving existing ones needed as a

result of the new development. PIF funds are used solely for the purpose of

acquiring and/or making capital improvements to city parks, as prioritized in

the adopted capital facilities plan, and not for maintenance or operations.

How it works

The PIF rate is established by resolution based on maintaining a certain Level of Service (LOS) for parks as adopted in the Comprehensive Plan. Developers are typically required to pay impact fees prior to building permit issuance. The City assesses a PIF on residential development only, using the following formula:

CURRENT PIF CALCULATION AND FEES Housing Type

Calculation of PIF/unit Single‐family

Multi‐family

Value of ELOS parks/person $5,562.00 $5,562.00

Avg. persons/unit 2.47 1.81

Value of ELOS parks/housing type $13,738.14 $10,067.22

Percent of cost recovered by impact fee 35% 35%

TOTAL IMPACT FEE PER UNIT $4,808.35 $3,523.53

Accessory dwelling units are currently charged the multi‐family rate.

Case Studies

In Bellingham, a 60‐unit apartment complex would pay a PIF of $211,411.80. Olympia Municipal Code Sec. 15.04.040(H) ‐ To defer impact fee payment, a developer is required to execute an impact fee deferral agreement, which is recorded and creates a lien on the property. Pierce County Code Sec. 4A.10.080 and Ordinance No. 2010‐65s allows owners of residential properties being constructed or improved for resale to request a voluntary lien to defer paying traffic and park impact fees until a property is sold, but no later than 2 years from the date of building permit issuance, whichever comes first.

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Analysis

The current PIF formula relies on the average number of people per type of

housing unit, data no longer provided through the U.S. Census Bureau.

Future updates using this methodology are problematic unless the City

undertakes its own research and analysis. A calculation based on SF/unit is

not feasible because there is no nexus between the size of the unit and

number of occupants.

A calculation based on the average number of people per bedroom could

utilize data provided by the Census Bureau and the City. This would result in

a decrease in the impact fees charged for 1 or 2 bedroom units, and an

increase for units with 3 or more bedrooms:

Avg. Persons per Bedroom 0.862 (per City Data)

Value of ELOS parks/person $1,946.70 (Consistent with current LOS and

35% share)

people/unit Fee UV Fee

Studio/One Bedroom 0.862 $1,678.06 $1,342.44

Two Bedroom 1.724 $3,356.11 $2,684.89

Three Bedroom 2.586 $5,034.17 $4,027.33

Four Bedroom 3.448 $6,712.22 $5,369.78

Five Bedroom 4.31 $8,390.28 $6,712.22

Recommendations

Short‐term:

1. Waive up to 80% of PIF for qualified affordable housing projects.

2. Eliminate the PIF for accessory dwelling units.

3. Revise BMC to reflect new State regulations not requiring back‐fill of

waived fees.

Mid‐term: During the 2015 Comprehensive Plan update:

1. Consider policy language to reduce the PIF in targeted urban villages

for qualifying projects.

2. Assess level of service and PIF calculation methodology.


TBD TBD TBD TBD TBD TBD TBD


Y Recommended



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Incentive Permit Fee Reductions


Building Permit Fee Schedule BMC 14.32, 1997 UBC Table 1‐A Building Permit Fees, Land Use Permit Fee Schedule Resolution 2007‐23and 2009‐26 (infill

toolkit)

Summary

When a permit is required, fee are charged to cover the cost of permit processing, plan review, and/or inspections. No overhead cost may be covered by these fees.

How it works

Building Permit Fees: Fees are assessed based on the valuation of the project. These calculations are from the 1997 Uniform Building Code and are updated every six months. Fees range from $66 (for projects valued at less than $500) to over $6,933 (for projects valued $1 million plus). Electrical Permit Fees: Calculated based on project valuation, regardless of the number of connections. Fire Fees: Updated at the same time as building permit fees. Operational permits are charged a $100 flat fee regardless of the scope. Other fees are charged based on recovering 100% of the cost of staff time ($120/hour). All non‐residential projects are reviewed and assessed a fee by Fire. Land Use Permit Fees: Adopted by resolution. Fees range from $106 for small reviews (such as minor clearing/grading, home occupations, and zoning compliance letters) up to $12,750 for rezone and comprehensive plan amendment applications. Stormwater Fees: Adopted by ordinance. Fees are separated by the amount of impervious service, ranging from $113 for projects between 330‐1,000 s.f. up to $844 for projects that contain over an acre of impervious surfaces.

Case Studies

City of Ferndale administrative fee reduction program offers incentives for small and downtown businesses. "Administrative fees" are defined as building permit, plan check, site plan review, technical review committee, storm inspection, plumbing and mechanical permit, water meter installation, sewer hookup inspection, encroachment permit, land disturbance permit, and environmental checklist fees. Lakewood, WA section 18A.50.760 reduces land use application fees up to 75% for projects targeting very low and extremely low income households. Puyallup, WA waives building permit fees for low‐income single family residences and duplexes or if the structure is constructed by a nonprofit or volunteer labor.

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Analysis

The method of calculating building permit and land use fees is a common practice nationwide and a defensible method of assessing a fee. The City has the discretion to adopt fees at a rate to cover eligible costs. A 2009 review of land use fees showed the hourly fees account for only 15% of the cost of staff time (charged at $107/hour, compared to $125/hour in Ferndale). Infill toolkit projects are charged the Planned Development Permit fee (a base of $3,188), which has been identified as a barrier. A significant reduction in combined permit fees could be compelling to encourage development in targeted areas.

Recommendations

Short‐term: 1. Reduce permit fees for qualifying projects within targeted urban

villages. 2. Seek opportunities to reduce the land use fee for Infill Toolkit

projects by eliminating redundant fees. 3. Waive administrative fees for qualifying affordable housing projects.


Y Y


Y Recommended



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Incentive Pre‐Approved Plans


Construction Administrative Code BMC 17.10.020

Summary

The City's "registered plan" program creates a library of options for pre‐approved housing plans that adhere to City requirements and design patterns. Design assistance may also facilitate faster permit review times, while promoting well‐designed projects.

How it works

The library of options pulls from plans created either by the architect, developer, or design plans pooled from contest winners. The applicant can choose a plan from the Registered Plan library and continue with the permitting process with minimal review time. Some communities restrict the number of times a plan set can be used in repetition or within a specific neighborhood, or require a certain spacing or modulation between plans.

Case Studies

Portland, OR held a design competition for courtyard housing prototypes to promote child‐friendly developments in the urban areas. Sacramento, CA developed an Infill House Plan Program to streamline the process for development of high quality single family homes in the City's older neighborhoods and redevelopment areas. Under this program, users can purchase plans that are pre‐approved through the City's design review and building plan check review process, saving time and money. Roanoke, VA developed a Pattern Book as a design aid for new construction and renovation of residential buildings (single‐family dwellings, two‐family dwellings, townhouses, and multifamily dwellings).

Analysis

The City currently has a "same‐as" plan approval process, whereby a (typically single‐family) plan‐set has been reviewed independently from a location. A few architects have utilized this service, primarily for larger housing developments, saving both time and money. This service could be a useful incentive for innovative housing forms under BMC 20.28. Providing pre‐approved plans for the types of multi‐family or commercial projects desired for urban villages is more challenging due to the particular site considerations for these types of development. Plans could be selected via a competitive process that would be reviewed and pre‐approved through the Design Review Board and permitting staff. The cost to purchase plans would be approximately $2‐3 per square foot (another type of recognition or prize to the architect may be possible in lieu of fee payment).

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Recommendations

Short‐term: Continue to offer the "registered plan" program for residential projects, and promote the availability of this option to the design community through a new redevelopment incentives website. Mid‐term: During the review of ADU regulations, evaluate the opportunity to develop pre‐approved plans for these housing types to showcase and incentivize quality design. Long‐term: If BMC 20.28 is amended, consider opportunities to develop pre‐approved plans for innovative housing types.

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Incentive Reduced Parking Requirements


Transportation Demand Management RCW 70.94.537, Commute Trip Reduction Program Chapter 468‐63 WAC, Infill Toolkit BMC 20.28, Urban

Village BMC 20.37,

Summary

A reduced number of parking spaces are required for new or renovated development in targeted pedestrian‐oriented areas or for development that has a lower parking demand.

How it works

Parking reductions are outright in urban village development regulations and within the Infill Toolkit. The Planning Director may also further reduce parking administratively in other areas for projects that will result in less auto dependence, such as low‐income housing.

Case Studies

All of Bellingham's adopted urban village regulations contain reduced parking requirements, as does the Infill Toolkit.

STANDARD PARKING REQUIREMENTS

Residential 1 space per studio

1.5 spaces per 1‐ or 2‐bedroom units

2 spaces per 3 bedroom unit

1 additional space per bedroom over 3 per unit

Commercial 1 per 250 open to the public (general)

1 per 350 sq. ft. (office)

1 per 75 sq. ft. open to the public (restaurant)

SAMISH WAY URBAN VILLAGE PARKING REQUIREMENTS

Residential 1 space per studio, 1‐ or 2‐bedroom units

Additional 0.5 space per unit over 2‐bedrooms

Commercial 1 space per 500 sq. ft. of gross floor area

Further reductions are allowed for shared parking, or through the adoption of programs that reduce auto dependence

A portion of Downtown is parking exempt area, which does not require parking for either new construction or redevelopment.

Analysis

Market forces often dictate parking requirements beyond the City‐required minimums. However, there has been a positive response from the development community about allowing the market to drive the parking supply in these areas instead requiring more parking then what may be considered necessary.

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Recommendations

Mid‐term: 1. Adopt regulations to administratively reduce the parking

requirement city‐wide for qualified affordable housing projects.

Long‐term: 1. Continue the practice of adopting reduced parking standards with

new urban village plans.


X X X X X X


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Incentive Regional Stormwater Facilities


Stormwater Control Facilities RCW 90.03.525, Stormwater Management BMC 15.42

Summary

A regional retention/detention system is a stormwater facility designed and sited to detain stormwater runoff from a number of new developments or areas within a catchment basin or sub‐basin, versus those which occur on a specific parcel. These facilities allow a developer to pay a fee in lieu of providing onsite stormwater management.

How it works

The City conducts an assessment of the watershed drainage basin and must find a suitably located and sized parcel to accommodate the intended runoff capacity. The regional system is then designed to accommodate the maximum feasible runoff capacity for the basin. This location and design must be approved by the Department of Ecology. A developer within this same drainage basin can then buy into the capacity of the system to manage the calculated runoff from the proposed development volume base on square footage of impervious surface contributing to the pond.

Case Study

The North Bellingham regional stormwater facility is currently under construction. The size of this facility has been maximized to accommodate the maximum amount of runoff, which will facilitate the development of several parcels in the area. The proportional cost of the regional pond to individual properties versus individual on‐site vaults will cost substantially less for the developer.

Analysis

Advantages:

Storage volume can be more efficiently.

They are more efficient. One large pond has a more efficient surface area to volume ratio than multiple small ponds.

Lower maintenance costs. Regional facilities owned by the City can be service on a regular maintenance schedule vs. local site facilities.

Can be used for multiple purposes, including habitat enhancement, recreation, and open space.

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Analysis, cont.

Disadvantages:

Difficulty finding locations downstream without damaging the natural drainage system or locating within critical area buffers.

Require a significant amount of land area.

Inability to fund and construct regional facilities prior to pending upstream land development.

New DOE stormwater requirements require infiltration of stormwater unless it can be determined that the soils won't allow for infiltration. Requires detailed soil analysis to prove that infiltration is not a viable technique for handling runoff.

Stormwater management must be engineered based on a drainage basin analysis, not based on zoning or other geographical preferences.

Stormwater detention is not required for areas that drain into Bellingham Bay, including large portions of Downtown, Old Town and the Waterfront District.

Recommendations

Short‐term: Sell the remaining capacity of the North Bellingham stormwater facility to developers within the drainage basin. Long‐term: Assess other regional facilities on a case‐by‐case basis as opportunities are identified.

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Incentive School Impact Fee (SIF) Reduction


Growth Management Act (GMA) RCW 82.02, School Impact Fees BMC 19.08

Summary

Since 1992, the City of Bellingham and the Bellingham School District have

collected school impact fees with the construction of new housing. The

impact fees are intended to require new development to pay a proportionate

share of the cost of new school facilities needed to serve the growing

population. The School District is responsible for setting the school impact

fee rate and for using the fees to construct growth related school

improvement projects.

How it works

The SIF rate is established based on the cost of projects outlined in the Bellingham School District's 6‐year Capital Facilities Plan. This plan must be adopted by both the School Board and the City Council. This document includes school district facility needs, financing options, and an estimated student generation rate per housing type.

SIF CALCULATION AND FEES

Single‐Family Residence, Single‐Family Attached, Duplex

$1,854 / unit

Multi‐Family Unit (3+ units) $1,154 / unit

In Bellingham, a 60‐unit apartment complex would pay a SIF of $69,240.

Case Studies

Morse Square, 1010‐1020 Railroad Avenue (Phase I and 2) No SIF charge to the developer for studio units (96 total) for a savings of $109,784

Analysis

A SIF waiver or adjustment is currently available for development projects meeting specific criteria. The adjustment or waiver may be approved by the Planning and Community Development Director, in coordination with the school district, for projects that have little or no impact on school facilities, construct affordable housing, or contribute land or buildings for schools. In order to provide clarity and streamline the waiver or adjustment process, the City could provide a list of qualifying criteria for a waiver.

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Recommendations

Short‐term:

1. Consider working with the School District to adopt a policy outlining

qualifying criteria for SIF waiver or reduction, including:

‐ Up to 80% reduction of SIF for qualified affordable housing

projects.

‐ Waiving SIF for Accessory Dwelling Units.

‐ Reduction for unit types that do not typically generate students

(eg. studio apartments)

2. Revise BMC to reflect new State regulations not requiring back‐fill of

waived fees for affordable housing projects.

3. Work with the Bellingham School District to update and adopt a new

six‐year capital facilities plan and school impact fee ordinance.

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Incentive System Development Charges (SDCs)


Municipal Utilities RCW 35.92.010, 35.92.025, 35.92.380 Occupations Subject to Tax BMC 6.06.050, BMC Title 15, Water and Sewers,

BMC 15.08, 15.12, 15.16

Summary

System Development Charges ("SDCs") (also referred to as General Facilities Charges or Connection Charges) are up‐front charges imposed on new connections to the City sewer, water, and stormwater utilities. SDC waivers or deferred payments may incentivize redevelopment in designated locations within Bellingham.

How it works

Per state law, SDCs must be "reasonable" and must be based on the property owner's "equitable share of the cost of the system". SDCs should be distinguished from ongoing monthly (or bimonthly) service rates. Per state law, service rates must be "uniform for the same class of customers or service". Currently, SDCs and service rates are sized to reflect the user's relative demand on the system as determined by meter size and consumption. This demand‐based structure is consistent with state law‐‐i.e., it is reasonable, equitable, and uniform. It is also easy to administer and predictable for developers considering projects.

SYSTEM DEVELOPMENT CHARGE UTILITY TYPE

Type of Service Water Sewer Irrigation

5/8" X ¾ " Meter $3,956 $7,637 $2,139

¾ " x ¾" Meter $5,934 $11,456 $3,208

1" Meter $9,891 $19,093 $5,347

1 ½ " Meter $19,782 $38,185 $10,695

2" Meter $31,653 $61,097 $17,110

3" Meter $63,306 $122,193 $34,200

4" Meter $98,916 $190,927 $53,469

Type of Use Stormwater

Single‐family residence $678

All other types $0.226 per square foot of impervious surface

For example, a 5‐story 6‐unit downtown development may have 1.5 inch meters; a typical SFR may have 5/8" x ¾" meters.

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Case Studies

Port Townsend, WA defers SDC charges for nonprofit housing developments, and for other projects determined by the city manager to promote substantial additional private sector jobs and/or leverage private sector investment to substantially increase the city's tax base.

Analysis

The City may reduce or waive SDCs to incentivize redevelopment. The lost revenue to each utility must be recouped from the General Fund. The City cannot, consistent with state law and generally accepted rate‐setting principles, directly shift the cost of the program to other utility users through increased SDCs or service rates. A 50% credit for stormwater SDC is currently available for projects that are designed as "low‐impact development"; however, this incentive is rarely used due to associated open‐space requirements. The City is authorized to use General Fund revenues for economic development purposes consistent with a comprehensive plan and with a demonstrable public benefit. Use of General Fund revenues for new programs may adversely affect existing programs and should be carefully prioritized.

Recommendations

Short‐term: 1. Reduce SDC's for qualifying projects within targeted urban villages. 2. Reduce SDC's for qualified affordable housing projects. 3. Revise BMC to reflect new State regulations that do not require

backfill of waived fees. 4. Continue to offer and promote credit for historic use and for

improvements beyond minimum requirements city‐wide, and codify where necessary.

5. Continue to offer deferred SDC payments for qualifying projects, on a limited timeframe.


Y Y


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Incentive Special Valuation (State Property Tax Exemption)


Washington State RCW 84.26, Bellingham Historic Preservation Ordinance BMC 17.90

Summary

The Washington State Legislature created the Special Valuation Historic Tax Exemption Program in 1985 to encourage the maintenance, improvement, and preservation of privately owned historic landmarks in Washington State. “Special Valuation” is the revision of the assessed value of a historic property which subtracts, for up to 10 years, qualified rehabilitation costs that are approved by a local review board. The primary benefit of the program is that during the 10‐year special valuation period, property taxes will not reflect substantial improvements made to a property. Prior to the passage of this law, historic buildings were subject to increased property taxes once improvements were made, a discouraging effect which kept some owners from rehabilitating their historically significant buildings.

How it works

Washington State RCW 84.26 specifies that to be classified as eligible for special valuation a property must first meet the following criteria: 1. It must be listed in the National Register of Historic Places (NRHP),

individually, or certified as contributing to the significance of a National Register Historic District, OR

2. It must be listed in the Local Register of Historic Places (LRHP) established by a Certified Local Government, AND

3. It must be of a class of properties approved by the local government.

While the State RCW 84.26 requires only National Register listing, BMC 17.90.070 requires that a property be listed in the Bellingham Register of Historic Places (BRHP) to be eligible. Eligible properties which undergo substantial rehabilitation may receive special valuation if the rehabilitation work has been 1) approved by the Bellingham Historic Preservation Commission; 2) completed within two years prior to application; and 3) must cost at least 25% of the assessed value of the structure prior to rehabilitation. Property owners must sign an agreement with the local review board that guarantees they will meet certain standards during the ten‐year property tax exemption. The penalty for violating the agreement can be substantial.

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Case Studies

Immanuel School of Industries 1303 Astor Street Listed in both NRHP and BRHP Rehabilitation cost: $761,600 Total Tax Savings, 2008 thru 2015 (Estimate for 2015) = $62,044

Fairhaven Fire Station No. 2 1314 Harris Avenue Listed in BRHP Rehabilitation cost: $82,735 Total Tax Savings, 2008‐2015 (Estimate for 2015) = $6,786

Analysis

To date, only a handful of property owners have taken advantage of the Special Valuation Tax Program, reportedly due to the requirement to list the project property on the Bellingham Register of Historic Places (which imposes regulatory requirements). Also cited as a barrier is the lack of certainty in receiving a Certificate of Alteration and the vague evaluative criteria provided as guidelines. As the program does not require any out‐of‐pocket costs upfront to the City, more property owners should be encouraged to take advantage of the program. The Special Valuation program applies to historic buildings city‐wide and is not permitted to be applied specifically in any particular urban village or other geographical area.

Recommendations

Short‐term: Promote the availability of the Special Valuation Program through a new redevelopment incentives website. Mid‐term: 1. Amend the program eligibility requirement to include National or

Bellingham Register listed properties. 2. Adopt the Department of the Interior's Standards for Rehabilitation as a

basis for alteration criteria. 3. Provide training for the Historic Preservation Commission and staff

regarding alterations to historic buildings (provided at no‐cost from the State).

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Incentive Transportation Impact Fee (TIF) Reduction


General Provisions RCW 82.02, the Washington Growth Management Act (GMA) RCW 36.70A.070, and Transportation Impact Fees (TIFs) BMC 19.06

Summary

TIFs are assessed for vehicle trip generation expected from new development based on the current edition of the Institute of Transportation Engineers (ITE) Trip Generation Manual. Vehicle trips are multiplied by the adopted TIF base rate per trip ($1,869 per trip in 2015).

How it works

A 22% to 25% vehicle trip and TIF reduction is currently provided for projects in proximity to GO Lines in urban villages where sidewalks and bike facilities are available. Up to 50% vehicle trip and TIF reduction is possible with developer purchase of WTA bus passes or a combination of other Transportation Demand Management (TDM) strategies. This program encourages and incentivizes infill development consistent with land use, transportation, and economic development goals and policies. Reduced vehicle trips = reduced TIFs. 100% credit is awarded for previous uses and TIF is only assessed if net new trips exceed credit, which means redevelopment pays little to no new TIF. TIF reductions can total up to 50% maximum, as follows: Automatic Trip Reductions to Reduce TIFs: 15% ‐ Urban Village Mixed Use Environment 10% ‐ Abutting WTA GO Line in Urban Village 7% ‐ Within ¼‐mile of WTA GO Line In Urban Village 10% ‐ Large Employer (100 employees) consistent with WA Commute Trip Reduction goals Voluntary Performance Measures to Reduce TIFs (Up to 50% maximum):

Purchase of WTA Bus Passes at 25% discount rate (1% per pass)

Purchase of car share membership or vehicle (2% per membership)

City‐approved bicycle rack installation (Limited to 1 trip reduction)

Dedication of ROW for and/or construction of transportation system improvement adopted in City 6‐Year Transportation Improvement Plan

Other TDM strategies considered with documented trip reduction effect

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Case Studies

From adoption in March 2011 through September 2014, the Urban Village TIF Reduction Program has saved developers over $360,000 in TIF costs for:

450 Residential Units; 123,496 SF Commercial; and 58,958 SF Office

$19,170 TIF savings for City approved bike racks (installed by 10 developers)

50% TIF reductions have been achieved by 3 developments through purchase of Quarterly WTA bus passes at a 25% discount rate for two years.

120 Morse Square Apartments in Downtown ‐ $45,045 TIF savings

112 Cornerstone Apartments in Barkley Village ‐ $41,758 TIF savings

Analysis

State law requires impact fee reductions to be tied to reduction of impact, not merely to incentivize development. The Urban Village TIF Reduction Program is based on legally defensible industry data, standards, and best practices. Deferral of impact fees could be considered, but there are both legal and enforcement concerns with deferral and other Washington jurisdictions have not had great success with this approach to date.

Recommendations

Short‐term: 1. Continue to apply TIF credit to qualifying projects located within urban

villages. 2. Broadly advertise that TIF estimates are already provided with every

Transportation Concurrency application and can be obtained quickly through a self‐calculation worksheet or by contacting the Public Works Transportation Planner.

3. Waive TIF for qualified affordable housing projects per RCW 82.02.060 (3) and Accessory Dwelling Units.

4. Revise BMC to reflect new State regulations not requiring backfill of waived fees.

Mid‐term: 1. Improve Permit Center website to allow on‐line TIF estimates. 2. Formalize the practice of applying credit for the highest historical use of

an existing building.


X X X X X X X


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Incentive Wetland Mitigation Program


Section 404 Clean Water Act, Section 10 Rivers and Harbors Appropriation Act, Critical Areas BMC 16.55

Summary

This project would create the option for developers (including Parks and Public Works Departments) to purchase mitigation credits in-lieu of constructing project-specific wetland mitigation. This would mitigate for lost wetland function in a thoughtful and comprehensive way, while simplifying the review process.

How it works

A City of Bellingham in‐lieu fee wetland mitigation program would provide a funding source for mitigation and restoration projects within the City limits and UGA, particularly along Squalicum Creek and other sites identified in a comprehensive Habitat Asset Map. Mitigation and restoration would be conducted on a watershed‐scale basis so that mitigation occurs in the same watershed as the impact. (Many sites on the Habitat Asset Map might not be under City ownership and would require purchase as part of the program.) The fee charged would be proportional to the development's impact on

critical areas (ie. $250‐400k per acre).

Case Studies

The Lummi Nation Wetland and Habitat Mitigation Bank ("Lummi Bank") is the only wetland mitigation program currently operating in Whatcom County. Anyone within the designated "service area" (which includes most of western Whatcom County) can purchase mitigation credits from the bank. However, the bank funds restoration projects in the Nooksack Delta, subject to the terms and conditions of the Lummi Nation, and not projects within the City of Bellingham. King County started the first "in‐lieu fee" program in Washington State. The Mitigation Reserves Program is guided by an instrument that includes an agreement and technical guidelines. The Hood Canal Coordinating Council uses a similar instrument as King County's. The HCCC ILF Program will provide compensatory mitigation through a variety of strategies (e.g., enhancement, restoration, establishment, preservation) to ensure there is no net loss of aquatic resource functions and values within the area served by the HCCC ILF Program.

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Analysis

The City's Critical Areas Ordinance (CAO) currently allows developers to either buy mitigation credits from the Lummi Bank or to construct wetlands (onsite or offsite) to replace those impacted by development. These two approaches are not in the best interest of Bellingham because use of the Lummi Bank exports Bellingham's environmental assets. The wetland mitigation program ("instrument") requires approval by the State Department of Ecology, the Federal Army Corps of Engineers, and the Environmental Protection Agency; a process that often takes five or more years. There have been very few other instruments approved in WA, increasing the uncertainty of this timeline. Development of the instrument, establishment of fees, and administration of the program are time‐intensive activities exceeding the capacity of the existing staff. This incentive is most appropriate to apply on a city‐wide basis for projects that have on‐site, low‐functioning critical areas, and is not recommended to be applied to urban villages or other specific geographical areas or building forms, other than those constrained in this way.

Recommendation

Mid‐term: As part of the Comprehensive Plan update, consider adopting goals and policies to support development of the wetland mitigation program. Long‐term: After policy language is adopted, conduct an analysis to determine whether to fund additional staff to support the development and administration of the program, or to have it developed and managed by the private sector.

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alphabetical index of incentive summary sheetsalphabetical index of incentive summary sheets ......

Documents