1. Resolution 5269 - Kalispell Area Transportation Plan (Tabled March 17)RESOLUTION N. 5269
A RESOLUTION FOR THE APPROVAL AND ADOPTION of THE KALISPELL
AREA TRANSPORTATION PLANT UPDATE) DATED FEBRUARY 1, 2008, AS
PREPARED Y ROBERT PECCIA AND ASSOCIATES FOR THE PURPOSE O
REPLACING TH1993E KALISPELL TRANSPORTATION PLAN.
WHEREAS, the City of Kalispell retained the engineering firm Robert Peccia and Associates
to analyze the transportation facilities in and around the City of Kalispell for the
purpose of developing a Kalispell Area Transportation Plan to update and replace
the existing transportation plan that was developed in 1993; and
WHEREAS, the proposed Kalispell Area Transportation flan (2006 Update), dated February 1,
2008, developed by Robert Peccia and Associates addresses the transportation
issues within the City of Kalispell, plus an area up to 3 n- les beyond the City
limits, into those areas the City can reasonably expect to grow; and
WHEREAS, the proposed Kalispell Area Transportation Plan (2006 Update provides an
analysis of existing transportation conditions, transportation demand forecasting,
a discussion of alternative travel modes within the area and identification of
specific problem areas relative to crash occurrences, intersection capacities and
street corridor capacities; and
WHEREAS, the proposed Kalispell Area Transportation Plan (2006 Update) includes
recommendations mendations for travel demand management and traffic calming techniques
and further provides a series of recommendations for improvements to the
transportation system including short term management changes, major street
system improvements and miscellaneous upgrades to the existing transportation
system; and
WHEREAS, the proposed Kalispell area Transportation Plan (2006 Update)further includes a
financial analysis of the capital improvements to implement the plan; and
WHEREAS, S, n December 11, 2007 the Kalispell City Planning Board, after due and proper
notice, met and held a public hearing to consider recommending the adoption of
the Kalispell Area Transportation Plan an 200 Update). The Planning Board met
again on January 8, 2008, after due and proper notice, and after fully considering
the contents of the flan and all of the public comment received, both oral and
written, voted unanimously to recommend approval and adoption of the plan to
the Kalispell City Council; and
WHEREAS, on February 19, 2008, after- due and proper notice and after- making the proposed
Kalispell Area Transportation Plan (2006 Update) available to the public for its
inspection, the Kalispell City Council held a public hearing to receive oral and
written comment on the plan; and
WHEREAS, it 1s in the best interests of the City of Kalispell and its residents that the existing
1993 Kalispell Transportation Plan be updated and replaced using current data
and traffic engineering analysis for the purposes of updating its troth Policy as
required by state statute as well as providing a more timely and functional
analysis in the consideration of implementing transportation impact fees; and
WHEREAS, after fully considering the contents of the Kalispell Area Transportation, Plan
Zoo Update and all of the public comment received, both oral and written, the
Kalispell City Council finds that the proposed Kalispell Area Transportation Flan
(2006Update), dated February 1, 2008, developed by Robert 1 e cxa an
Associates sufficiently provides the data and analysis necessary to update and
replace the existing adopted policy or the 1993 Kalispell Transportation Flan.
NOW, THEREFORE, T RESOLVED BY THE CITY COUNCIL OF THE CITY of
KALISPELL AS FOLLOWS
SECTION 1. That the Kalispell ,Area Transportation Flan (2006 Update), dated
February 1, 2008, developed by Robert l eccia and Associates shall be and
is hereby adopted and approved for transportation policy within the City
of Kalispell.
SECTION 11. This resolution shall be and is hereby effective immediately.
PASSED AND APPROVED BY THE CITY COUNCIL AND SIGNED BY THE MAYOR of
THE CITY of KALISPELL, THIS 2 1 ST DAY of APRIL, 2008.
Pamela B. Kennedy
Mayor
ATTEST:
Theresa White
City Clerk
HUTTON RANcu PLAZA AssociAs C
5 HuTToN RANCH R, SUITE 1 3
KALISPELL, MT 59901
April 16,2008
The Honorable Pamela B. Kennedy
Mayor
yor
City of Kalispell
o Box 1997
Kalispell, MT 501
Dear Madame Mayor:
Because I any not as articulate as I would like when speaking before a group in an
extemporaneous fashion, I am writing this letter to each of you With the hope that I can better
express some of ray eoncers reardl your unpendin actions relating to the imposition o
traffic impact fees and, In fact, many other impact fees already created and assessed by the City.
While I ann not speaking for any other developers Within the City, I want to make it clear that I
do not oppose the concept of impact fees as a matter'of personal or public policy. I am only
concerned that a particular fee or ordinance establishing a fee comply with constitutional
protections, and Mate ardor Federal enabling laws. I have deep conees in five areas relating to
the City's actions establishing and implementing impact fees in general, and the proposed
traffic impact fee in particular. They are:
Failure to comply with constitutional protection of due process
. Failure to establish correlation between the proposed impact fee and the
development to be charged;
3. The erroneous use of trip generation studies;
. The failure to offset fees by the reasonable value of economic benefits
derived; and
5. The erroneous use o 'Impact fees to cure existing infrastructure deficiencies*
April 16, 2008
Page
1. Federal and State Due Process
Due process, required and guaranteed under the Constitution of the United States and in
all States under either their Constitutions or enacted laws, is a simple concept. It requires that
before an individual or entity can be punished, taxed or otherwise negatively affected by any law
or ordinance, he, she or it, must have notice of the existence of the law. Under the enabling
Statute, Montana defines an impact fee a " a charge unposed upon development by a
government entity as part of the development approval process [sic] to farad the additional
service capacity required by the development from which it is collected." The development
approval process in Kalispell is similar to that which exists in most cities, counties and states in
the United States. It includes a, petition for annexation of property if necessary), a petition for
zoning or modification thereof if necessary), an application for use permit or conditional use
permit, and the execution of a development agreement in concert with creation of a Planned Unit
Development. Once all entitlements have been secured under the above, or under other
discretionary types of applications and/or petitions, the development process has been
completed. At this point, the compliance phase begins. If a developer has come before the City,
received all of the discretionary approvals necessary to allow the developer to move to the
compliance phase, and been given notice that to construct a building there will be particular fees
(of any nature, including impact fees) then the requirements of due process will have been met
and the exaction of fees at that time, or at some future time, will be appropriate.
On the other hand, if a developer receives all of its discretionary approvals, and executes
Development Agreement, and at that time a particular set of fees (such as impact fees) have not
even been publicly discussed, much less voted on, then the developer has had no notice, and
cannot be charged the fees at a later date. As one example, Hutton Ranch Plaza completed the
Development Process for its project in August, 2005. It executed a binding Development
Agreement on January 5, 2006. The City Council did not create a resolution even to appoint an
advisory committee until February 21, 2006 and no members were appointed until March 2006.
Obviously, Hutton Ranch Plaza had no notice that enormous and potentially devastating fees
could be later enacted and charged as a condition to receiving a building permit on land already
having gone through the "Development Process".
Even your own Consultant, randy Geoff, inadvertently deals with the above concept in
section 2.5 of his report where he admonishes the Council not to believe developers that the
creation and exaction of a traffic impact fee will create financial hardship since the developer of
the land will pay less for it knowing that the fee will be assessed.. If err. Geoff is correct, then the
developer would have to have known about the fee at the time he buys the land, makes
concessions to the City for its development, and enters into a Development Agreement,
obligating him to spend enormous dollars for public improvements. Since mutton ranch Plaza
had no knowledge, that unpact fees were on the horizon, it was not able to take into consideration
any of these fees in the acquisition of its property, its pricing of the project for itself or
subsequent users of its space. Hutton Ranch Plaza is only one of several developments that have
406. 7SG.2771 (phone) 406.756.2777 (fax)
April 16, 2008
Page 3
already been charged "look back impact fees' that have clearly violated the constitutional right
to due process.
. Correlation between Impact Fee and the Development to be Charged.
Throughout Sections ---160 and 7-6-1603 of the Montana Code Annotated Zoo, the
drafters require a correlation between any impact fee charged and the benefits to be derived. The
law doesn't allow an advisory co=ittee or the City Council simply to male a finding that a
correlation exists between a development and widening of a road miles away from the
development, because, as was stated at an earlier workshop) "Kalispell is a small town" and
therefore justifies a single service area. It must, in fact, demonstrate a direct and real connection
between the road to be improved and the new development to be constructed. It is dear that if
1000 homes are to be developed and constructed at one end of a new road or newly widened
road, there is a clear correlation between the cost to build or widen it and serving the basic traffic
needs of the development. Mr. Geoff s report shows no connection between public improvement
and new development. It simply assumes it. 'what Mr. Geoff has done in his report is to identify
every road that reeds to be, or has needed to be improved over the past several years. He then
uses trip studies for a hypothetical new commercial development, assuming that there is a 100%
correlation between the trips on each of these roads and the new development.
This is inappropriate because it fails to recognize that all developments, old and new, are
benefited by road improvements. The framers of the enabling laws authorized cities to collect
from new development its "'Proportionate Share" of costs to be incurred, not the entire cost. In
fact., Section 7-6-1603 defines an Impact fee as "a fee for service payable by all users creating
additional demand on the facility". It is inconceivable that a given new shopping center, office
building, or stand alone restaurant could be responsible for creating t00% of the demand on a
roadway located miles from its location. While the enabling laws do not allow you to charge
back against already existing developments, they do restrict you from applying to a new
development more than its proportional share of costs.
3. Use of grip Generation do Studies
The use of trip generation studies to determine how to apportion Transportation Impact
Fees makes a great deal of sense when determining whether a developer should contribute, and
how much, to the widening of a road surrounding the development, or the creation of a new road,
or the placement of a traffic light, or even the widening or creation of roads adjacent to or in the
i mediate vicinity of the development to be charged nested service area). But ITE traffic
generation studies are inappropriate when they are used in a setting where costs have not first
been apportioned between all persons and developments benefited by the infrastructure
construction.
What has happened here is that your consultant has used this particular methodology to work
backwards into a set of numbers that are aimed at paying for all of the costs associated with one
406.756.2771 (phone) 406.756.2777 (fax).
April 16, 2008
Page
particular capital improvement plan. This can be witnessed in the absurdity of some of the
numbers. For example, last year the numbers proposed by Mr. Geoff would have applied a rate
to a new movie theatre that would have resulted in the new Stadium 14 paying almost
I1,0 , 00 in traffic impact fees alone. This inequity was so obvious that Mr. Geoff was asked
to go back and reexamine his numbers. He did such a good job that he deleted movie theatres
altogether in his latest report. While politically expedient, it is totally inappropriate. He has come
p with a set of numbers that would have cost the new Mc onalds on Highway 93, over
100,000 in Traffic Impact fees; a cost that would have amounted to 25% of its building
construction. This fee would have killed the project. Are examination of numerous other
categories results in the same absurd results.
When asked how the attached fee structure compares with other cities and towns of comparable
size, Mr. Geoff stated that the residential fees were 115 to 1 of inost other towns. He stated that
the commercial fees were comparable to other towns and followed up by saying that the
proposed Kalispell commercial fees were also 115 to I of most fees in other towns. This
statement Is ridiculous. If his comment were true,, to construct the aforementioned Me orralds in
other towns would require the payment of a traffic impact fee of over $50 ,000. This is more
than the cost of the building itself.
4. Requirement to offset Fees by Economic Benefits Derived
Section -- -1 2 i1 states that any impact fee MUST consider system improvements
Treasonably anticipated to be made by or as the result of the development in the form of user
fees, debt service payments, taxes ....
Nowhere 1n the report, t, or any report from staff` that I have seen, is there an analysis of the
enormous property tax increment that will flow from any of the developments (residential or
commercial) sought to be charged by this or other of your impact fees. You now have impact
fees for virtually every serve to be provided by the City. Has staff considered that on full build
out in the near future, property taxes generated by Hutton Ranch Playa and Spring Prairie, alone,
should generate between two and tree million dollars each and every year? The City's
proportion of just those taxes would enable bonding of between seven and ten million dollars. If
you add an additional two to three million dollars in gross property fax increment from the
Glacier Town Center project, the Cit 's incremental tax receipts would support bonding that
would pay for all of the improvements in its Transportation flan.
5. The Erroneous Use of Impact Fees to Cure Existing Infrastructure Deficiencies
The enabling Statutes at Section --1 023 provides "The amount of each. Impact fee
rust be based upon the actual cost of public facility expansion or improvements or reasonable
estimates of the cost to be incurred by the govemmental entity as a result of new development."
t Section -- -1 02 5 c the Statute provides that "Costs for correction of existing deficiencies
in a public facility may not be included in an impact fee." virtually every road intended to be
406.756.2771 (phone) 406.756.2777 (fax)
April 16, 2008
Page
improved as described in the impact fee report has an existing substantial deficiency. It is
inconceivable that the reed to, and therefore, the cost of creating, widening or otherwise
improving roads miles away from a particular commercial development could be created only by
new development, Yet Mr. Geoff report suggests that only new development should pay, and
pay l o% of its cost. This is not what Montana law allows.
realize how hard the Impact Fee Committee has worked to provide you with recommendations
regarding various impact fees. However, if you provide any group of bright, well meaning, civic
minded individuals (the vast ma orit of ,Thor otherwise have little if any expe-deuce in the lave,
public financing or real estate development) with bad or incomplete information, what will come
out of the group is exactly what was fed into the group: bad information and bad results.
As a member of the development community here in Kalispell, I am ready, willing and able to
work with the Council and its staff to help solve the infrastructure problems that we face. As a
property owner and developer I am willing to pay my fair and proportionate share of the costs
associated with improving our infrastructure. In return I ask only that you take the time to
consider the tough questions relating not to whether we reed to assess impact fees, but whether
in so doing we are doing it correctly and in compliance with the law.
Thank you for your time and consideration.
i i ljp ar
gs
_ 4
r
Y
c Council Members
Charles Harball, City Attorney
,lames H. Patrick, City Manager
406.756.2771 (phone) 406.756.2777 (fax)
rage -i mi .i
Theresa Whit
From; Planning Department [planning@kalispell.com]
Sent: Wed nesday, April 16, 2008 8 :11 AM
To: Tory ent ; Theresa White
Subject: FW: Impact fees
From: Gateway Properties Inc, rnailto:gat way@cent rytel.net]
Seat: Tuesday, April 1, 2008 4:22 P
To: planning@kalispell.com
Subject: Impact tees
l have been following the events on the impact fees and I would like to let the council know I am against the current impact fee
structure. I think this valley really needs the new mall right now for jobs as well as shopping dollars staring home. As well for the
residential side the new fees make it harder for developer, builder, and buyer to achieve an affordable home. I know you are looking
at information I have not seen yet and do trust you to make a sound decision in light of ALL the concerns.
Please pass on to council members,
bers,
Brent Card
1P Gateway Properties, Inc.
1 8
r dgu I U1 I
Theresa White
From: jpress@centurytel.net
Seat: Tuesday, April 15, 2008 3:01 P11
To: citycouncil@kalispel1.com
Subject: Road impact fees
Dear City Mayor and Coun ilr err ber :
any writing in support of the proposed road -impact fees. I feel it is only fair that fees reflect the overall,
present AND long-term impacts of new development. We already have a huge backlog of maintenance for
existing roads. Any new development must be required to assume all the true costs associated with that
development.
According to the April o Inter Lake article, Wolfo rd Development is threatening to "pull their project" for the
Glacier Torn Center due to the proposed impact fees. They feel that the fees, as proposed, are unrealistic. I
feel the fees are not too high, but very realistic, given the significant impacts that would result from such a
huge construction project. It would be extremely upsetting to me if a development as large as the Wolford
Mall received building permits before these road -impact fees were in place and the city taxpayers were forced
to assume the associated road costs.
Thank you.
Judith Pressmar
POB 2063
Kalispell MT
/1.6 2008
JAmEs H. CossiTT, Pc
ATTORNEY & COUNSELLOR T LAW
Board Certified
Business & Consumer
Bankruptcy Law
MEMORANDUM
To: Kalispell City Council
From; James H. Cossitt
202 KM Building
o 2nd Street East
Kalispell, MT S o 1 R 6
Tel 06 -516
jhc@cossittlaw.com
wwwosittlatw. corm
e: Comments on Impact Foes for Transportation System, Fi aI Report dated
March 2008
Date: April 14, 2008
The Kalispell Impact Fee Advisory Committee Y AC , of which I have been a member
since , has proposed a variety of fees which have been adopted by you without controversy
or fanfare. The propose Transportation System fee is not being met with the same welcome and
various arguments have been advanced against adoption of those Fees. This memo will respond
to some of those criticisms.
No one has retained me to represent them on this issue and these remarks are mine, an
solely mine.
THE CITY COUNCIL HAS ALREADY SET A PRECEDENT BY
ADOPTING TIN OL FIRL. WATER AND WASTEWATER IMPACT
FEES
y adopting other impact fees, the City Council has already confronted and dismissed the
same criticisms that are being leveled at the current fee and has set a policy precedent for the
City that "growth must pay for growth". The approval process, both explicitly in the prior HDR
reports) and implicitly endorsed adopted the basic philosophy, justification, fairness and equity
of impact fees for the full amount recommended by HDR and the IFAC.
Were the council to act differently on this proposed fee it would: l be inconsistent with
it's adoption of prior fees; 2 undermine the legitimacy, fairness and equity of the entire impact
fee system; set a poor precedent for the imposition of future fees.
What principled intellectual basis can any one of. you articulate for: l adopting and
approving the earlier fees; an b not doing the same with the proposed transportation fee
You've already adopted and agreed that the basic principles and methodology of impact fees are
soured -- now some of you are balling at how they are applied in the real world.
Business & Commercial Litigation, Secured Transactions, UCC, Bankruptcy & Workouts, Real Estate Law
Admitted In Montana, Colorado, Michigan and Iowa
To: Kalispell City Council
From: James H. Cossitt
e: Comments on Transportation System Impact Fees
Date: April 14, 200
Page
The basic problem currently confronting you is that;
1 roads are not cheap;
2) commercial development generates lots oftrips;
3) taxpayers currently subsidize way too mucky of the road growth.
No wonder our local ground transportation grid is in a shambles and getting worse monthly.
ONLY A SMALL BUT VOCAL MINORITY IS OBJECTING
The primary objection to the transportation fees arises from a small, but vocal, minority
of commercial developers. These persons are poised to tale advantage of the rapid growth in
Kalispell for their own personal ._gain and that of the equity interests in the companies they
control. Their voices, via their lawyers and others, drown out the voices of individual citizens.
They will commit the resources to this effort because of the potential upside benefit. The
average citizen, myself included, is not likely r to be willing to tale the time to offer comments.
Thus, the voice of the developers speaks far louder than is representative.
IMPACT FEES CREATE EQUITY AMONG USERS AND DO NOT
RETARD ECONOMIC DEVELOPMENT 4R, IF THEY DO, S4 BE IT
The March 2008 HDR report squarely addresses both the equity § 2.4 and hindrance of
development § . issUes. From a citizen"s standpoint, both of'these sections are worthy of
your close scrutiny.
First, this issue is addressed in the comment about precedent above.
Even if impact Fees do slow down development, they will do so only at the margins. By
forcing development to internalize and bear the true cost (instead of skating on a taxpayer
subsidy) it will raise prices for commercial development. Development providing marginal
projected economic benefit will not proceed as the upside gain with the added impact fee cost
will not be adequate to justify the risks s associated with development. However, as market
et
conditions charge to provide higher projected rates of return from development, even with
impact fees, those development ent will absorb the costs.
THE NECESSITY OF CRITICAL EVAULATION, ANALYSIS AND
CRITY UE OF THE WOLFORD ARGUMENT /THREAT
To: Kalispell City Council
From: Jaynes H. Cossitt
Ike: Comments on Transportation System Impact Fees
Date: April 14, 2008
Page
wolford alleges, without any substantiation, his market wont bear the proposed fee and it will
make his project unfeasible. The wolford pre impact fee financial analysis obviously includes a
rate of return or profit margin.
The Council must critically evaluate and analyze these claims and not allow itself to be spoon
feed or swayed by this "doom and gloom".
What is really going on here ? wolford is most likely really saying instead of X ° rate of
return, it will be 10% less or some such thing.
_Doo't let the developers frame the debate* restate or mischaracterize it. The issue is not
whether development is going to leave Kalispell -- given the history of this community, it
borders on ludicrous to so assert. The issue is how much are the developers or their stockholders
going to male and will they, or the taxpayers, bear all of the true costs of their profit making
commercial ventures
f wolford is serious about this assertion, it should be willing to put it's financials on the table to
the Council, HDR or City staff, (under a protective order or agreement so competitors do not see
it) in order to test the veracity of his assertions of unfeasibility. If he is unwilling to do so, it
calls into question his sincerity, credibility and veracity and leaves the impression that these
assertions are nothing more than a scare tactic.
With all the publicity related to impact fees and wolford's intimate familiarity with the City's
adoption of them, it is incomprehensible and implausible that it would have entered into Fetters
of Intent or Leases with potential tenants that did not contain clauses that allowed it to pass on
these (and other) added costs.
At the end of the clay, if any project is not commercially viable, then don't commit the
investment capital to build it. If it is not economically feasible to do the deal with all the true
costs imposed, then don't do it.
When and if conditions change that make the project, or some other project, feasible, the market
will respond. This is how capitalism works.
Congress, the legislature and local governments enact lags daily that alter the economic
fusibility of all kinds of marketplace conduct. The risk of legislative or regulatory action is one
that all marketplace players must take into account. Changes in tax law, land use law or zoning
can have a profound impact on economic conduct but that is one of the risks that developers
must bear.
Consumer Confidence Index
..y Y ...
J FK
Kalispell City Council
Jams H. Cossitt.
nents on Transportation System Impact Fees
April 14, 2008
THE TRANSPORTATION IMPACT FEE IS BECOMING A SCAPEGOAT
FOR DETERIORATION of OTHER FACTORS AFFECTING THE
FEASABILITY of THE WOLFORD PROJECT
It is important to place this discussion, and the W l ord assertions, in the larger context
of the current economic climate and the multiplicity of factor that may affect the feasibility of
the Wolford project. The current economic climate is terrible, the Conference Board reports:
The Conference Board Consumer Confidence Index Declines Almost 12
Point
March 25, 2008
The Conference Board Consumer Confidence Index, which had declined sharply in February, fell further in
March. The Index now stands at 64.5 (1955=100), down from 76.4 in February. The Expectations Index
declined to 47.9 from 58.0. The present Situation Index decreased to 89.2 from 104.0 in February,
The Consumer Confidence Surrey is based on a representative sample of 5,000 U.S. households. The
monthly surrey is conducted for The Conference Board by TICS. TINS is the world's largest custom research
company_ The cutoff date for March's preliminary results was March 1 th.
Says Lynn Franco, Director of The Conference Board Consumer Research Center: "Consumers' confidence
in the state of the economy continues to fade and the Index remains at a fire -year low (March 2003, 1.4).
The decline in the present Situation index implies that the pace of rowth in recent months has
weakened even further. Loo in ahead consumers' outlook for business conditions the job market
and their income prospects is quite. -pessimistic and sug-gests further weakening,may be on the
horizon. The Expectations Index, in fact is now at a ear low(Dec. 1973, 4 .2 levels not seen
since the Oil Embargo and Watergate."
Consumers' assessment of present-day conditions weakened further in (larch, Those claiming business
conditions are 'bad" increased to 25.4 percent from 21.3 percent, while those claiming business conditions
are "good" declined to 15.4 percent from 19.1 percent.Consumers' appraisal of the job market was also
more pessimistic than last month. Those saying jobs are "hard to get' rose to 25.1 percent from 23.4
percent, while those claiming jobs are 'plentiful" decreased to 1 -8 percent from 21.5 percent.
Consumers" short-term expectations also deteriorated further in March, Those expecting business conditions
to worsen over the next six months increased to 25.4 percent from 21.6 percent, while those anticipating
business conditions to improve declined to 8.1 percent from 9.7 percent in February.
The outlook for the labor market was also more pessimistic. Consumers expecting fewer jobs in the months
ahead increased to 29.0 percent from 2 -0 percent, while those anticipating more jobs declined to 7.7
percent from 8.9 percent. The proportion of consumers expecting their incomes to increase declined to 14.9
percent from 18.0 percent.
tp: ww_w.coat~ot- n e-1 oai.�..or(-Ye ii nii s `onSL[i r otifid ii .ofni
To: Kalispell City Council
From: James H. Cossitt
Fie : Comments on Transportation System Impact Fees
Date: April 14, 2 0
Page
How much of the alleged infeasibility is really attributable to the transportation impact fee ? Or
other factors such as consumer demand 'here is the data from Wolford that back up the
alleged nexus ?
CONCLUSIONS
I will end where I began
l . roads are not cheap;
. commercial development generates lots of trips;
. taxpayers currently subsidize way too much of the road growth.
The Council has endorsed the equity, fairness and methodology of impact fees. Intellectual
honesty and consistency compels the adoption of the proposed transportation fees. It is not
enough to engage in a knee jerk reaction and say "these cost too much". There is no logical or
principled justification or basis upon which to alter city policy.
Thank you for your consideration of my views.
JI:chj
cc: file
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EXISTING LOS - 2008 PROJECTED LOS WITHOUT IMPACT FEES - 2013
TEEN A. KAL I
ken@kalviglaw.com
angie@kalviglaw.com
MA.RSHALL MURRAY
a s all9kalvi law,eo
ERic S. HumMEL
eric(Pkalilglaw,com
KALVIG & Duc, P.C.
ATTORNEys AT LAw
Southfield Tower
P.O. Box 167
KALISPEL , MT 59903
PHONE: 6- 7-6 01
A:406-257-6082
KALI5PELL TRANSPORTATION IMPACT FEES -
INFORMATION YOU MIGHT WANT TO KNOW
The value of the new residential construction in 2007 was $40.8 million.
The value of the new commercial construction in 2007 was $37.5 million.'
1 See P.9, table 5. 2007 Construction, Subdivision and Annexation Report - Kalispell, Montana
I
In 2007, 322 residences were built in K IiSp ll.
The 322 residences consisted of:
146 single family residences
14 duplexes
7 townhouses
95 multi -family units
Kalispell is proposing transportation impact fees as a condition for approval
of any building permit.' The proposed fees are:
$989 per single family detached dwelling
$757 per rented townhouse/duplex
$606 per residential condoAownhouse under single family ownership
$ 95 per rental dwclling with at least 3 units
If the 322 residences built in 2007 had been subject to transportation impact
fees, they would have generated:
146 single family residences
14 duplexes
7 townhouses
95 multi -family units
$9 9 = $14470 0
$ $ 101000
$606— $ 4,00O
$95 — $ 66P0
$260,000
Source - 2007 Construction, Subdivision and A ne ation Report - Kalispell, Montana, pA
Available online at: http://www.kalispell.com/downloads/kal07finalreport.pdf
3 l - Revised Final Draft Report -- Impact Fees for the Transportation System.
2
In 2007, the City of Kalispell approved 16 new commercial construction
projects.
According to the transportation impact fee report, impact fees for most
commercial buildings are based on leasable area (or floor space) and the
type of commercial building. Hotels and motels are assessed based on the
number of rooms.
If the commercial structures built in 2007 had been subject to transportation
impact fees, they would have generated approximately $1,140,652.
TE
Address
Name/Description
hnpact
Square feet
Total
code
fee(per
per unit
thousand)
493
190 Meadow
The Meadows
$3695
4.948
$18 5283
Vista Loop
Clubhouse
931
2340 Hwy 93 N
Famous ave's
5187
8.840
$45,5853
Restaurant
851
2910 Hwy 93 S
Town Pump
$29,757
4.115
$122,450
Tavern/Casino
310
1680 Hwy 93 S.
Econolod e
S63558
ff units
Hotelfotel
unknown
814
125 Sutton
Glacier Quilts
$37 7
5.820
$21,8
Ranch
Store
933
110 Hutton
Hutton Ranch Food
$37,013
6.600
$244,28
Ranch
Ct.
Restaurants
814
284 N. Meridian
Universal Athletics
3757
1 .85
$4 ,774
Retail Store
841
2545 Hwy 93 N.
Eisinger Honda
$2827
22.700
$ 49173
Car dealership
841
2545 Hwy 93 N.
Eisinger Chevrolet
$2827
42.90
S 120,84
Car dealership
912
120 Hutton
Flathead Ban
13107
6.429
$ 8 , 83
Ranch
Bank
814
145 Hutton
Sportsman Ski FIaus
37 7
5 .8' 4
$2215190
Ranch
Retail Store
817
2320 Hwy 93 S.
Murdoch's
4348
7.560
21871
Greenhouse/store
934
2310 Hwy 93 N.
McDonald's
2 , 74
3.253
$83142
Restaurant
814
35 5t Ave. West
5h Ave. Salon
377
3.432
$127894
Hair Salon
841
2310 Hwy. 93 S.
Penco
$2827
4.000
11,308
Sore/warehouse
47
2792 Hwy. 93
Sem's Car Wash
$4913
2.800
$13,756
Car wash
Total
114052*
* Does not M'clude Econolodge
In 2007, the City of Kalispell approved 16 new commercial construction
projects.
According to the transportation impact fee report, impact fees for most
commercial buildings are based on leasable area (or floor space) and -the
hype of commercial building. Hotels and motels are assessed based on the
number of rooms.
If the commercial structures built in 2007 had been subject to transportation
impact fees, they would have generated approximately $1,140,652.
ITE
AddressName/Description
Impact
Square feet
Total
code
fee
(per
per unit
thousand)
493
190 Meadow
The Meadows
$3 695
4.948
$18,283
Vista Loop
Clubhouse
931
2340 Hwy 93 N
Famous Dave'
$5187
8.840
$45, 53
ran
Restaurant
851
2910 Hwy 93 S
Town Pump
$295757
4.115
$122A5
Tavern/Casino
310
1680 Hwy 93 S.
Econolodge
$63 $58
ft units
Hotel Motel
unknown
814
125 Hutton
lacier Quilts
$3757
0
$2118 5
Ranch
Store
933
110 Hutton
Hutton Ranch Food
$37,013
6.600
$244528
Ranch
Ct.
Restaurants
14
284 N. Meridian
Universal Athletics
$3757
10.853
$40,774
Retail Store
41
2545 Hwy 93 N.
Eisinger Honda
$2827
21700
$64,3173
Czar dealership
841
2545 Hwy 93 I .
Eisinger Chevrolet
$2827
42.69
$1207 84
Car dealership
12
120 Hutton
Flathead Bank
$135507
6.429
$867836
Ranch
Bank
914
145 Hutton
Sportsman Ski Haus
$3757
58.874
$221,19
Ranch
Retail Store
817
2320 Hwy 93 S.
Murdoch's
$4348
7.5
$3 ,871
Greenhouse/store
34
2310 Hwy 93 N.
McDonald's
$25f 74
3,253
$8334 9
Restaurant
814
35 5 Ave. west
Ave. Salon
$3757
3.432
$1 1894
Hair Salon
841
2310 Hwy. S.
Penoo
$2827
4.000
$11938
Sore/warehouse
947
2792 Hwy. 93
Sem's Car Wash
$ 913
2.800
$131)75
Car wash
Total
194 # 5
* Does not include Econolodge
Kalispell proposes to raise as much in traffic impact fees from all
residential development in 2007 ($260,000) as only two commercial
developments selling athletic/outdoor gear and apparet,
Examples:
ITE code
Description
Impact fee per
Square feet
total
unit
(per
thousand)
Universal
814
Sinall strip
$3757
10.853
$4 1774
Athletics
shipping center
Sportsman
814
Small strip
3 7
5. 74
$221 189
us
Ski �-
shipping center
'dotal
$261.3963
Or one food court:
ITE code
Description
Impact fee per
Square feet
total
unit
(per
thousand
Hutton
933
restaurant
$37M 3
6.600
$244,296
Ranch
Food Ct,
Total$2449286
r�
In 2007, the City of Kalispell approved 4 new office buildings.4According
to the transportation impact fee report, impact fees for office buildings are
based on leasable area.
If these office buildings approved in 2007 had been subject to transportation
impact fees, they would have generated $58,904.
ITT code
Address
Name/Description
Irnpact fee
Square feet
Total
er unit
er thousand
770
125 School House
Glacier Investment
$1 19
12.934
171059
Loop
Offices
715
3430 Hwy 93 N.
S1lverbroo Sales
$11 1
1.380
162
Offices
720
1050 N. Meridian
N. Meridian Dental
$3735
4.200
$155687
Dental Office
750
723 5 Ave. East
Eastside Brick
$11 1
20.751
$ 4,5 6
Office/Coffeehouse
Total
$58,904
In 2007, the City of Kalispell approved 7 other buildings (schools,
warehouses, hospitals).5According to the transportation impact fee report,
impact fees for these buildings are based on square footage.
If these buildings approved in 2007 had been subject to transportation
impact fees, they would have generated $91,662.
ITT code Address
Name/Description
hn act fee
Square feet
Total
per unit
er thousand)
53 6644 4 Ave. W.
School Dist. #5
$133
18.953
$516
High School
Addition
715 650 Yoltack way
USDA
1196
28.120
$3351
150 1 34 1' Ave. W.
City of Kalispell
$513
3.600
1 46
'warehouse
5-0 171 School House
City of Kalispell
$513
1.0
13
soap
Warehouse
610 Ryan Lane
City of Kalispell
$513
13.500
$6925
Aircraft Hanger
10 1 S nnyvi w
1c"C
$1 1
.1
$1 18
Cancer Treatment
Center
610 310 Sunnyview
1RMC
l 17
5.760
$ l 05 465
Hospital
Total$919662
Source - 2007 Construction, Subdivision and Annexafion Report - Kalispell, Montana, p. .
1d.
z
The draft transportation plan bases transportation impact fees on the
type of commercial development.
The type of commercial development is decided based on its description
from the 2007 ITE Trip Generation Manual.
Can you decide what category the following permit would be?
TOWN PUMP ---- TAVERN/CASINO
City descriptions:
24 hour convenience market? (sells convenience Foods, newspapers,
magazines and often beer and wine, open 24 hours per day).
Proposed rate per 1000 square feed - $29,757
High turnover sit-down restaurant? (sift down eating establishment with
turnover rates of less than 1 hour).
Proposed rate per 1000 square feet - $7,362
Gas station with convenience market? (sells gasoline and may also provide
vehicle service and repair. May also contain a convenience market).
Proposed rate per 1000 square feet - $7,405
There is no separate category for a drinking establishment.
PENCO — STORE/WAREHOUSE
City desetipt iolls .,
Specialty retail? (small strip shopping centers containing a variety of retail
shops that specialize in apparel ...)
Proposed rate per 1000 square feet - $3757
Car dealership? New and used car dealership with sales, service and parts.
Proposed rate per 1000 square feet - $2,827
- The City's response is to require a property owner to prepare a
traffic impact study at its own expense.
R
There is a disparity with the amount of traffic impact fees depending on
the building type*
Compare:
Hilton Garden Inn
144 rooms
Restaurant
Bar
Convention space
North Bay Grill
addition of second dining room
771 square feet
Famous Dave's
ITE code
Impact fee per unit
Units
Total
or per 1000 square
feet
Hilton,
310
$63
144 roams
$9,072
Garden
Nosh Bair
931
$5.187
771
$3,999
Famous
931
1 7
8.840
$93
Dave" s
Restaurant
h
The Aspen Group is planning to build up to 3000 units in its Starling
Subdivision.
Up to 10% of the 3000 units can be commercial.6
Assuming 2700 of the residential units are single family detached dwellings,
with a transportation impact fee of $989 per unit, over the lifetime of the
Starling Project, in current dollars, the Starling Subdivision will pay $2.67
million in transportation impact fees.
Source - The Aspen Group, April 8, 2008, See also Kalispell Planning Board Minutes dated May 22,
o.
N
Areas of immediate concern:
1. Has the City adequately considered whether more than one service area is
necessary for a fair ff*npaet fee regulation as required under 7- -1 o l ?
2. How has the City ensured that none of the projects in the CIP are really "existing
de eieneles" and therefore ineligible for impact fee use?
. After reviewing the CIP projects to ensure that none of the project -represent
"existing deficiencies" the CIP must then he updated to ensure that all appropriate
projects are included. For example, despite being located in a soon -to -be -annexed
area, the Rose Crossing Project is still listed as a 1 0% county project.
4. The City should develop a process to calculate and unsure that all appropriate
credits are factored into the impact fee assessments as provided in '-- -1 03 .