 Good morning, everyone. Thank you for joining us for today's planning commission hearing. I'm sorry about the late start today's date is April 28 2021 and the time is 937 today's hearing is completely remote and we are using a zoom video conferencing meeting platform. For you at home who are viewing this hearing or who may wish to participate in this hearing, I wanted to take a moment to explain the technological pieces of the hearing. To participate in the hearing you may connect with us via the zoom link which is posted on the planning department's homepage at sccoplanning.com. Alternatively, you may participate in today's meeting by phone. Please dial 1-669-900-6833 and when prompted enter collaboration code number 885-1871-7533. If you wish to simply view today's meeting it is being broadcast live on television as well and for more information please visit the community television website. A couple of instructions about participating in today's meeting. For each agenda is public hearing item time will be provided for speakers to contribute their testimony. Speakers will be muted until called on to speak. I will ask participants who wish to provide testimony to either remotely raise their hand by selecting the hand icon on their zoom link, or calling him by telephone by remotely raising your hand by pressing star nine on your telephone. I will call on participants by either your name or the last four digits of your telephone number. If you are participating via the zoom link, when I call on you to speak you will see a pop up on your screen that says unmute. Please accept the pop up, state your name for the record and provide your testimony. If calling in via telephone you must unmute yourself by pressing star six on your telephone. Members of the public will be provided three minutes to speak. If at any time you have difficulty connecting to today's meeting, please email me jocelyn drake that's J O C E L Y N dot drake at Santa Cruz County dot us. I will be checking my email periodically throughout the meeting and I'm on standby and ready to assist you. All right, it appears we're situated. So we'll now turn over the hearing to our chair, Judith please and be good morning, Judith. Good morning, Ms Drake and good morning all and welcome to this virtual April 28 2021 meeting of the Santa Cruz County Planning Commission. It is now 940 I will officially open the meeting. And could we have a roll call please. Yes. Commissioner Gordon. Here. Commissioner Shepard. Here. Commissioner Dan. Here. Commissioner Schaefer Freitas. Here. And chair lays and be here. At this point, are there any additions or corrections to the agenda? No, there are not chair. Thank you. And do any commissioners have any ex parte communications that they would like to declare here and none. This is the part of the meeting when the planning commissioners welcome members of the public to speak on any of the issues of concern to them. But these issues cannot be those that are on today's agenda. You will have two minutes. Do we have any participants. Yes, chair. I see one hand raised. All right, I will and I will call on this caller. There is no name associated or phone number with the caller. So I will just go ahead and unmute the caller. Good morning. Please state your name for the record. Good morning. This is Marilyn Garrett. And I'm bringing up an article that is related to what the planning commission will be having before them on 5G. This is from a publication of Weston a price.org. The article is titled the contagion fairy tale by Thomas Cowan, MD and Sally Fallon were out. Our book, the contagion myth is now available banned on Amazon but sold on other outlets and has already generated dozens of comments. Many of them challenging our contention that the Corona virus in quotes does not exist and that the illness attributed to this virus is not contagious. One comment even referred to our book as the fairy tale. Unlike most coronavirus skeptics, we are not arguing that the illness is just a bad case of the flu with deaths due solely to pre existing conditions or inappropriate hospital care. Rather, we postulate that the illness can be very serious and that the likely cause is radiation poisoning probably from the worldwide deployment of 5G starting in Wuhan, China and followed by major cities throughout the world. End quote and another quote shade said 5G at 60 gigahertz stops the human body from absorbing oxygen and we've heard a lot of hypoxia. So when you consider 5G, you must consider the implications and the consequences in a broad range of issues. Thank you. Thank you. Is there anyone else. I am not seeing any additional hands raised chair. Okay, thank you. So then we'll move on to the approval of the minutes of April 14, 2021. Do I hear a motion. I'll move the minutes. A second. Thank you. All in favor. I. Okay. They are approved as submitted. And we'll move on to item number six. Do we have. Mr. Fort on the line. Yes, we do. I will go ahead and promote him. All right, can we please pull up Mr. Fort's PowerPoint. Good morning, Mr. Fort. Can you hear us. Make sure you're unmuted on your side. Can you hear me now. Yes, good morning. Good morning. So we'll, as we're moving through your PowerPoint, just go ahead and say next slide when you'd like us to, to, to advance the slides. Okay, great. Thank you. Good morning commissioners. My name is Will Fort. I'm a park planner with the county parks department. And today I'm going to give some background information on the proposed updates to the park dedication fee program and also have. I believe Debbie Kern from KMA and Kim Namba from the parks department here as well who may be able to help answer questions if needed at the end. And to start park dedication fees sometimes referred to as Quimby fees or the related park impact fees are different types of fees on new development that can provide funds to expand park facilities to meet the new demand created by that new development. So next slide please. For your consideration in conducting the public hearing today, I'll go through three sections here. First, I'm going to give some background information on the underlying policies on our existing park dedication fee program. And then I'll go through the two different types of proposed actions that will be required to implement these updates. These actions include first ordinance amendments. There are four chapters listed and second up amendments to the unified fee schedule. Slide please. So I will present the information related to the entire program update today. This has already been reviewed by the Parks and Recreation Commission on February 8, and that commission has recommended the board take the associated actions. So there are only some ordinance amendments that require review and recommendation by the planning commission. So these are the subject of today's hearing. These are local coastal program implementing sections of the county code. And these include these three chapters that are highlighted on this slide 1501, 1505 which is a new chapter and 13050. These will be the subject of today's hearing. However, I will go through all of the updates today, including those being reviewed by the planning commission as well as the other updates. But today's hearing is only about the items to be reviewed by the planning commission slide please. All of these associated actions will go under subsequent review by the board of supervisors through public hearings upon a recommendation from the planning commission. And after that, the three that are local coastal program implementing will require certification by the California Coastal Commission through a subsequent hearing. Slide please. So I'll start with some background information next slide please. The goals of updates that we're talking about today are one to comply with current law including the Quimby Act and the Mitigation Fee Act. Two to align the county code with what is in the general plan. Three, increase social equity and how fees are applied. Four to institute an incremental fee increase under a new fee structure. Five to provide for the effective use of these limited funds. This is a small amount of funding for the overall parks budget. So there's a limited amount of development and say increase counting to make sure that these funds can be used effectively. And number six is to incorporate fees for non residential development as well. Next slide please. So to understand these goals here's some background information on underlying policies and the staff report as well. So California code includes the possibility of loving two different types of fees related to this program. The first one is the Quimby Act. Quimby fees are for residential subdivisions. They are fees that are in lieu of dedicating new parkland with that subdivision. The second is the Mitigation Fee Act. This allows fees or jurisdictions to apply fees to developers to pay to allow the jurisdiction to provide an expansion to the park system. These two types of fees have similar goals, but some differences in the requirements and how they're set up. Currently, county park dedication fees are codified in Chapter 1501. This includes a formula for the in lieu fees. And these are mostly related to the Quimby Act. There is some room to improve the clarity between the Quimby Act and the Mitigation Fee Act fees, which we'll talk about later. In Santa Cruz County, general plan and local coastal program includes underlying policies and objectives related to park service standards that are being implemented by Chapter 1501. And currently, the formula is in 1501 and the service standards and general plan are not consistent. Next slide please. So here is a table summarizing the existing fees in the county as well as for each of the four cities within the county for comparison only. And then there's a column showing the fees for an estimated fee for an average size home. The fees depend on size and rooms and in our case location. The fees for the county are considerably lower than neighboring jurisdictions, and they have not been updated for over 20 years. So since fees are relative to the cost of acquiring new parkland and developing new park facilities, we appreciate the increased cost of acquiring land and construction in the last 20 years. So these fees are essentially lower now than they were 20 years ago when they were last updated when you account for inflation. Next slide please. And currently the fees are also collected and held within a set of these 15 park dedication districts these are shown in the black outlines on this map. There are independent park and recreation districts in the county, so they're actually 19 separate park dedication districts currently fees collected in a district currently must be spent in that district this is not a requirement by the code or by the statute but it is an administrative policy, and it has created through the unified fee schedule. Additionally, there are three fee zones which are showing in these three green colors. These zones have differing fee rates currently based on their based on average land values when they were created which was in the early 1980s. And fee zones are also not required by code and they're created through the unified fee schedule. The goals of these districts and these zones were presumably to spend park funds close to where the fees were collected, and to be equitable in the rates of these fees. In practice, both of these goals are inhibited by this practice first park districts are small in the balances of the funds stay small in a district. They're too small, usually to fund a single park project. There may not be opportunities in that district limits the ability to spend these funds on the most impactful parks projects for the county park system. To address this there have been loans from one district to another in the past, and this has created some unnecessary complications. Also the fee zones with the different fee rates are not equitable and how the fees are applied. I'll just talk about this later as well. Next slide please. So to look closer at how these districts are functioning park staff completed a series of random park user surveys in the fall of 2018. And so this was a random survey of people in five different parks over two different days park users were asked if they lived worked or we're staying in the same district as that part. And what we found is that more than two thirds of park users survey did not live in that district work in that district or we're staying in that district. This demonstrates that the districts are not an effective boundary for allocating the fees. And it demonstrates that the park system works as a network throughout the county park users use the parks throughout the county. Next slide please. Here's a map showing median income from census data by block group and the blue colors and the outlines of the fee zones and the orange and brown it's kind of hard to read next slide please. This is a table summarizing that the data in that map when you summarize these data it's clear that areas with the lowest income are paying the highest park dedication fees. Generally, and this is an additional problem created by these fee zones that goes against the county's goals for increasing social equity. Next slide. And so that was a summary of some of the background current issues that we're trying to address in this program update so now I will go through the actual ordinance updates required to address these issues so I'll discuss the four check our sections of county code that we will be amending three of those are local coastal program implementing ordinance that are part of the resolution recommended to the planning Commission today subject of today's hearing next slide please. I'll start with chapter 1501 currently 1501 has all the policies related to Quimby fees, as well as trail and beach access dedication. So the proposed update that we're talking about today includes moving the trail and beach access policies to a different chapter, this will be the new chapter 1505. This will allow chapter 1501 to be solely about park dedication. There are also some other proposed revisions to this existing chapter. These include first separating and clarifying that these are related to in lieu fees for the Quimby act as distinct from park impact fees which will be part of the new chapter and described in the new chapter 1503. Second, it'll establish park acreage standards that are consistent with the current general plan and related to that revise the methods for calculating the park land dedication are in lieu fees. Fourth, adjust the reporting and trust administration requirements, which are different from the mitigation fee act. So make it clear these how these funds are being administered. And lastly, other miscellaneous changes to the organization and wording of chapter 1501 next slide. The chapter the creation of chapter 1503 is again not part of the local coastal program. So not part of today's hearing, but similar to the other impact fee section such as affordable housing and school say. So it is not part of your review today but I'll just summarize this quickly the new impact fee section will provide fees that are distinct and separate from the Quimby act fees. It'll have new reporting and trust administration requirements related only to the mitigation fee act requirements. Third require regular board of supervisors review and consideration of the adjustment of these fees. Fourth, allow the creation of fees for for non residential development. Fifth, change the fee structure from per bedroom to per square foot. This is a recommendation by the housing advisory commission for all impact fees in the county. And lastly, it will retain and actually expand some of the exemptions for affordable housing and for small ed us. Next slide. So then portions of the existing chapter 1501 that are related to trail and beach access are recommended to be moved to a new chapter 1505. There are also some other minor changes associated with that creation of a new chapter one is to make some miscellaneous changes, just to make it work as a standalone chapter and part of the LCP. Second upon review by coastal commission staff. Third, they have recommended changing the word beach to coastal access throughout and third, they also have recommended changing the minimum public shoreline access easement where required of a width from 5 feet to 10 feet. And then lastly section 1305 lists which chapters of county code are local coastal program implementing so that will have to be amended as well to reference this new chapter 1505. So that concludes the ordinance amendments that are being considered in today's hearing. I will also present a little more context by summarizing the unified fee schedule amendments quickly that will be going along with this overarching program to be considered by the board next slide please. And these for your reference these unified fee schedule amendments will include one separating and clarifying distinct fees for Parkland dedication and new fees from parking impact fees. Second, changing that the fee structure for the impact fees from per bedroom to per square foot. Third, adding recommended fee rates for the non residential impact fees. And for eliminating the three zones and the 15, actually 19 districts park dedication districts, and five, recommending incremental fee increase as compared to the existing fees. Next slide I think this is the last one. So two accounting changes that will go along with this one is to consolidate future fees and the current funds into one account and to clean up the park dedication from loans between districts. And lastly to review fees regularly in the future to account for inflation and increased land acquisition and construction costs. And next slide is the last one that's the end of what I had to go over today and you can take any questions. Thank you Mr. Fort. It was a very complete presentation. I will start with the commissioners do commissioners have any questions or comments. I had a comment. Commissioner commissioner shepherd go ahead. I think these are well crafted changes. It's hard to believe that these fees are lacking so badly. I think that's part of one of our friends organizations and I would agree, especially since the pandemic start started we get more people from outside our district way more. And I use other county parks all the time. The kind of antiquated notion that the fees are specific to the district. Assuming that we all only go to the park in our districts. I think that needs updating the fees need updating. I think there's the well crafted and I support them. Thank you. Anyone else. I have some questions. Commissioner go ahead. Thank you. And thank you, Mr. report for that presentation. This is a lot of information to put into into a small presentation so I appreciate it. And appreciate all the work that it takes to get there so a couple quick questions is the increase in fees solely to adjust for the change from us that going from three acres per thousand to five acres per thousand. I mean I understand that it's also because we haven't changed them in a long time. I get that but is a is that the change in acreage of major portion of this. My mic still on here. It is not. Yes. Yes. No, actually so the, the change in acreage is part of the formula that's used to in the study that's attached to the staff report there's all the math that goes behind this. What that does is that it creates a maximum justified fee, which would be the fee needed to really keep this level of standard according to all this math with new development. The fees that will be recommended to the board will be significantly lower than that, maximum allowed fee, because it to do that change it once would be. It would be like seven times as much as the current fees or different amounts depending on each fee, but it would be a huge increase so and rather than doing a large increase like that. The board typically will set fees that are lower than the maximum allowed rate. So that will be what goes to the board. So, Claire, we are. The general plan says three acres per thousand people, but we historically have more five or more acres per thousand right now and so we're trying to adjust to bring us up to where we're actually what we're actually utilizing. But that in turn creates a higher fee, correct. Yeah, exactly. Okay. So again, a little bit more. We didn't create. We are creating housing is, you know, and so that means that our acres per thousand people is higher because we don't have the people, but if we had more people than the acres per thousand would actually be a lower number. Is that correct. If we weren't to increasing the acreage of Parkland and yes, right. Thank you. A couple other clarifying questions here. What is the. What is the proposed fee going to be here and Mike, I'm a little confused as to what it's actually going to be it said it'd be around 25% of the new assumed maximum total. Is that correct but we don't know exactly what it's going to be. Yeah, so I didn't include the actual fees because this is not part of today's hearing. So that will be part of the unified fee schedule amendment hearing. I can read the the fee rates. I can. I can read the draft rates that we are currently anticipating recommending to the board. Residents are for residential subdivisions that are zone single family would be 4200 or parcel for multifamily 3,150 and then the new impact fees for residential projects that do not dedicate land or paying in lieu fee. There's a per square foot feet single family would be $2 multifamily $1 50 for residential projects that do dedicate parkland or pay in lieu fee. There's a per square foot fee of 23 cents person for single family or 17 cents for multifamily and for retail. So for non residential this is all by square foot retail restaurant and office would be $2 per square foot hotel motel and short term rentals three would be $2 per square foot retail and R&D would be one. And those are draft those may, it may change and those will be set by the board. But what you're saying is that today we're not. We are not considering whether or not those fees are right or should be right or anything like that, we're correct. So that's not part of the resolution or the actions before the commission today. Last question here. In the reported states that there's roughly $94 million worth of improvements needed solely based on new projects. And I, that's just like a hard number to swallow considering the amount of projects that actually happened here so to clarify is that 94 million that year it's affecting to have to spend really based on new projects or is it actually things that are existing problems that we need to fix something sense. Right, that that number is coming from the capital improvement program. And it's, it's both it is a list of mostly new park projects and new parks. But some of those are in existing or includes renovations as well. Thank you. That was all my questions. Thank you. Can I just make one more comment. I forgot to mention. Yes. I just want to say that as every I, I'm assuming that all of us in the community, you know how much more park use parks are getting more as we try to get more infill and more ad use and more people. Having adequate housing moving in the direction that we all are interested in and so far as possible. That means more park use are the park that I monitor use has increased two or 300% Henry calls use up is uses up by a very large percentage. It hasn't changed as things have opened up since the pandemic so parks are really getting a lot of use so I think putting the fees back where they obviously this is 1998 is last time fees were looked at. That's like 20 something years and parks are really always strapped always strapped they have hardly budget for anything. And this is of course in lieu fees when we build housing projects. The, you know, the builders contractors or whoever is doing it has the option to provide to provide the park fees, or they can pay the end loop. This is it in lieu fee that they're paying so that we can establish and improve the park so it sounds to me like it's well overdue especially given the just intensive use of parks. We've never seen anything like it at our park. We've had to add additional parking and it's amazing. I have a question. Thank you. I just want to thank will for your presentation. It was well laid out the staff report was well laid out I like the new format. I just wanted to ask a question about the general plan. I just want to thank you for that. I just want to thank you for the proactive. 7.3. That we provide, you know, two to three acres of usable park acres per 1000. And I think Tim was talking about this too. And you mentioned that we're more at like five acres per 1000. But I wonder, because I know that in our district. In densely populated areas. And so I wonder what that would look like what that acre per 1000 would look like if we just looked at the developed acres. I mean, the developed part of the county like so if you just looked at like live oak. I mean, I'm kind of guessing that it would that it would because if you take out, you know, Greyhound, Brock and a lot of those rural parks. That it would show that actually in our dense areas and especially in some of the lower income areas that we have a need for parks and kind of, you know, jumping on what commissioner shepherd was saying that, you know, that, you know, are using them more and so do you know, do you, you have thoughts on that or was that analysis done. Yeah, we, and Debbie if you're there if you want to raise your hand and chime in if I get something wrong you can correct me but the study looked at the unincorporated county and just the county parks as a whole and it did look at the usable park acreage. That is somewhat accounted for it's not including all the acreage of open space. It's more the. So it's according to neighborhood community and rural park classifications and the usable acres. If you do look at more if you look more specifically at different parts of the county, particularly in live oak and just look at county park acres per 1000 it is much lower. Yeah, the state parks does have they have a web mapping system that they use for their grant program and you can, you can see how they calculate it there and get a good, good sense of it that way. Okay. Great, thank you. Will. Can you hear me. Yes. Okay, I'm sorry that my, my video is not working but we did calculate what those averages are in the different areas and so. And this for community park acres per 1000 urban residents. The existing service level is approximately 5.11 acres per 1000 residents. And then for neighborhood neighborhood parks per 1000 urban residents. It's about 1.04 acres. That's throughout the entire unincorporated. Yes, we don't have it broken down by each of the 19 areas. It's just the areas that were designated as urban versus rural. So is that, can I extrapolate from that then that there is more of a need for the urban parks. Is that what that's telling us. Well, what that is saying in the existing, when you look at the existing park acreage, right, that that's the existing level of service. Go ahead. So that means that there are more air, there's more acres, there's more park service in the urban areas than there is in the rural. Oh, I see what you're saying. Okay, interesting. Okay, did it account for situations like like Pinto Lake Park, which is, you know, a gem of a county park. And so that's probably heavily utilized by city residents as well I would imagine I mean I'm a city resident and you know my husband's there almost every weekend playing to school. So did that factor into any of the analysis. Well, I guess that what is the designation of that park. It's regional. It's a regional. So we have maybe, actually, it's probably regional community and neighborhood I'd have to confirm that a lot of our parks have multiple classifications. But I guess just in general then the purpose of why we're here is I'm really glad this is being done. It sounds like it's been a long time in the works and I really appreciate the analysis and the staff work and the nexus study that had to be done to get us to this place so I'll wrap up my comments. Thank you. Commissioner Schaefer Freitas. Are you on mute. I'd like to wait until after public comments, and then I'll make my own comment. Thank you. So at this time I will open the public hearing. And those of you who are online. You can, you will have three minutes each person. So many straight can you open that up. Yes. All right, so I'm going to our list of callers and I'm going to venture to guess that we have our previous color on the line. So I'm going to go ahead and unmute. Please state your name for the record. One more time. Good morning. This is Marilyn Garrett again, and thank you for clarifying questions. Commissioner Gordon. So I have questions too, and I'm joining you on a landline. So I'm not seeing any visual peer if I were at the board meeting in person. Of course I would, but are we talking about entrance fees? Are we talking about before you answer my questions? I have some comments. Additional property tax, which I pay a hefty amount of. And so I want that clarified, but I'm in this current economic state due to the destruction of small businesses during all this lockdown and the practical exploration of the middle class. People are lacking funds and parks are places that belong to the people, the comments and people need to get out in the parks and some basic. Right, I think in democracy. I think of this bumper sticker I have on my car for years. It'll be a great day when the schools have all the money they need. And the Air Force has to have a big sale to buy a bomber. That has to do with, you know, it'd be a great day when all our public services, parks, et cetera, are funded and over about half our tax dollars don't go to the military. That's where they go now. So if you could answer, you know, my questions, I'm not wanting increased taxes when people don't have it. Don't have jobs. I've got retirement money thankfully still coming in from teaching. Okay, that's my comments and questions. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you, Ms. Garrett. Mr. Ford. Yeah, so thank you for the questions. So the first question about entrance fees. This is. These are not park entrance fees. They have nothing to do with park entrance fees. They're currently aren't. Park entrance fees would have to be set through the unified fee fee. So I don't think there's anything that's going in here. And second, it's not a property tax either. These are development impact fees. So these are fees that would be paid at either at the time of subdivision. Or at the time of permitting a new development. And what about the property tax? It's, yeah, it's not a property tax. Thank you. Are there other. Members of the public online. I'm looking at our list of attendees. And I just wanted to remind everyone that is joining us today. If you wish to speak on this item, please press star nine on your telephone or raise your hand on the zoom link. Okay, chair. I'm not seeing any additional members of the public who wish to speak on this item. Okay. That being said, I will close the public hearing and then there will be no further participation by the members of the public. I'll bring this back to the commissioners. Chair. Yes. Yeah. I just want to commend staff on this report. It's so extensive and comprehensive. And especially the charts and are easily readable so that things that can be understood. I can only imagine how many hours we're put into this by staff and by other county commissions too. So I want to thank staff for their report. And I'm prepared to approve it when the motion is made. Other comments from me commissioners. I'm I echo commissioner shape afraid us and I will, I wouldn't move the staff recommendation. Second. Okay, we have a motion to approve the staff recommendation and a second. Any discussion. I'd like to chime in. I agree. I appreciate this is a lot of effort and work that goes into it. I appreciate it. I have probably a different stance. It sounds like the most of my fellow commissioners. And if I could take five minutes to kind of talk about it, I'd appreciate it. You know, a little history on, on, on in lieu and impact fees. You know, they started in the great depression when. Taxes, people weren't paying their property taxes because everyone's losing their homes and things like this, right? And so that's the impact fee. And, and over time, that's dramatically evolved into. You know, into jurisdictions that in theory could use this for new public infrastructure that was a result of new housing. Like if you build a subdivision at the end of town, it needs roads, water lines, et cetera. And so either the developer paid for it or the city did. If the city paid for it, it wasn't in loopy to take care of it. Now we're at this point where developments are. Required to pay for the upgrades and the in lieu or impact fees. And so we're kind of, you know, paying for two things. You know, and it's. It's kind of this. Result. Of a long gone broken. Like not long gone, but kind of a broken system of taxation. City counting. City and county funding. So that's what we're going to do. We're going to be looking at all the new funding, the new funding for tax, taxation. City counting city and county funding sources. That have tried to span the gap of, like the inefficiencies in our funding. Especially as a realist prop 13 and things like that. So what we've done is create this gap or try to fill the gap with forcing new developments to pay. have a like the most efficient system of getting funding for cities and just local jurisdictions, right? So what does that really do? That creates the cost of burden on the developer who you all know can't officially pay for all, like they can't pay to produce housing out of their own pocket. It's a business, right? In reality, where does that fee go then? That fee goes to the new tenant or to the new homeowner. So what that means is that our housing prices go up when fees go up. That is clear. On multiple reports you can read it goes up and some say, you know, every dollar in new fee is $1.50 in sales prices. So what does that in turn do? It creates two big problems, right? Historically it can be used to limit growth, super high fees mean less construction doesn't get built, right? Then we have a problem where we're in right now, the county is in right now where we have a high number, you know, we're shooting for three acres per thousand and we're at five because we didn't build the housing. So we don't have the people, you know, that would make that number lower. And so now we're raising our fees because we don't have the people, then we start going to get less people so then our fees will go up. So it's just like circular reference that's this inherent problem in my opinion. And what has that done? In another way, it limits housing production, which has been historically a systematic form of racism and challenge in our community to be able to create housing that's affordable and more of it. And I won't get into all that right now, but I think it's a, you know, a challenge that we need to be serious about. There are some things with this that I really appreciate. I think that affordable housing should not have to pay for impact fees. I think that's a great step in the right direction. I don't, I do think that it should be shared not just by jurisdiction, I think that that is a good move. I agree with the fee going to square foot that's going to have that should happen that'll happen in any case I assume at the state level fairly soon. And changing the use of funds of certain zones. Yeah, as I mentioned, I think that that that's a big, big, big benefit there. But like all that kind of said, I do have some concerns and some problems with this. I think that, you know, as a park fee is really important for all of us. As everyone has said in 100% agree our parks over the last year have just been hammered right there's so many people out and about people are are really using them and we need to make sure they're funded 100% agree with that. I think that this is one of many impact fees that are going to hit developments that you know as some go up others go up and then all of a sudden our house of cost of housing is too great. So it goes to the tenants, it goes to the homeowners right. So we're just upping the ballot or the cost of construction and essentially final sales price. I think another problem that I'm seeing here is that our, we're not currently accounting for the high values of construction costs at today's rate right and so construction is higher than it's ever been not just because of, you know, the economy is COVID fires, all kinds of things that are make it just exorbitantly expensive to build. And so while we're saying that we want to make sure we keep up with that from the park standpoint, we're also not considering that it's the most expensive time it's ever been to build comparatively right now. So that we're going to start charging commercial clients and commercial buildings for parking Luffy's and we all know that commercial spaces are what we need to incentivize right now because over the last year, so many businesses have shut down. And so, in order to incentivize that it doesn't it doesn't feel like adding more fees is going to incentivize that commercial construction. And I think, yeah, the biggest thing as I've mentioned is that you know what really happens with these in Luffy's is that the community ends up paying for it whether they think they do or not they want to put it on developers but what does that mean. It goes to the new tenants the new homeowners. So all that being said, long rant I appreciate everyone listening, I personally can't support it as is I would want to see some adjustments I think that, you know, and I think that there's a few things here that I would need to see. First off fees paid at occupancy. I think that it's a mistake to force developers to pay fees early before the actual impact is created. The problem with doing it at early on in the process is that the fees get paid. And then it takes years to actually build the project so while I appreciate that it can help the part all the jurisdictions that charge fees. In reality that is a refundable fee. So they can't really spend it unless they're going to put themselves the county can spend it unless they put themselves at risk right. And so what are we doing we're saying we have to charge more for developers early on so that we can hold their money which fine but then what happens in reality is that people don't want to build so I think that putting the be at the occupancy is critical and I know that there are some adjustments in there that it's kind of close to that language at the directors to set discretion, but I would love to see that that is fully implemented that and the second thing I think the term affordable I really appreciate how that's getting updated to include affordable units. Excuse me let me rephrase that we're not going to charge more fees on affordable units. I appreciate that. I think that as well as a small ad use I think that there's a couple things that we could adjust and benefit from there. Non de restricted units, as we learned through our arena numbers can count towards arena goals, as long as they're affordable. So it'd be great if we could reduce or remove fees for affordable units that count towards arena goals as well. It would seem like those should match. And ideally smaller units if we're saying that ad use count because they're 750 square feet or less affordable by design essentially, we have certain policies like SRO policy that creates affordable by design units right. So those should also be included in here in my opinion. I would like to see like before I could be fully happy this I this little side note but I'd like to see a plan for how to create housing faster. The problem is that we're not creating a fast enough so we don't get the money but now we're going to charge more because we didn't get the money. So now we're still going to get no money. So 100% of this huge number, you know, is still going to be zero if we're not producing the housing. So really we need to incentivize housing to go faster so that we can get more money to pay for parks. In reality, we don't get that money because we don't build the housing. So I have a couple challenges with the study that was done. I think that the valuation based on of $1.4 million per acre based on recently sold properties is a little challenging to under to agree with because the properties listed are all over the board as far as zoning location and all kinds of things. So essentially what we're saying is we're going to base our fee off of $1.4 million per acre cost of land when in reality we're talking about molded family property that doesn't relate to actual costs of parkland. And that one I have a hard time kind of swallowing. Additionally, the use of looking at neighboring areas to compare prices is not always the best idea. We're a little safer in that here because you know, one of the comparisons is the city, you know, but the county is a little bit different, you know, Scott's Valley is different they're all different so it's really hard to look at a study that's based on comparison because they're not all exactly the same. A couple more things here that the actual increase and I appreciate you stating those I was really helpful I think that needs to be very clear. A lot of studies including those posted on the HDD's website say that if you're going to charge fees needs to be very clear, barely updated clearly outlined for everyone to see. And the reason for that is that transparency goes a long way with development. And it's not transparent people feel risk right and it's already a very risky thing to build housing to build commercial space so full transparency is something that I would like to promote. Three more things here, thanks for listening. These don't go down as the market goes down I think that's a huge challenge and when we look at the fees, you know, like I mentioned before right now we're going to start charging a fee on commercial space at the absolute worst time realistically for commercial buildings right and so what we're going to do is get no money there because people are not going to build and so updating those fees based on on the the current economic state goes both ways right yes let's update when it's time but let's go back when it's not time. So I think I think it's probably an inappropriate time to add a fee to commercial space.