HomeMy WebLinkAboutMINUTES - 05221990 - S.4 MAY -jam 1"7-- 90 MON 9 t 14 SUP TOM TORLAKSON t' P . 03
j LAW OFFICESOF ���j R
JEFFREY D. HUFFAKER �EFFREY D. Hiam FFAK`R Ttlt/MON[
ATTORNEY AT LAW (416) 767.0771
CHERYL L. HAMMERS 811 WEST THIRD STREET
LtGM. ASSIDTANT ANTIOCH.CALIFORNIA 94809 RecitIVEr
April 18, 1990 � " 2 19
Tom Torlakson, Supervisor
District Five
300 East Leland Road
Pittsburg, CA 94565
RE: Fees on New Developers
Dear Tom:
This is a follow up to our discussion held in your
office last week, wherein I advised you that the California
Court of Appeal had recently ruled in a case ijupholding a
City ordinance requiring new developers to pay a fee to
defray the cost of additional public facilities 4nd capital
improvements.
The case is. Building Industry Association ;of Southern
California v. The City of Oxnard, Cal. App. ;d, No.
B037716, March 23, 1990. The text of this case appears in
the Daily Appellate Report on page 3316. I do {not have an
official citation for the case as of this date. In this
case, the City of Oxnard passed an ordinance requiring that
developers pay a "growth requirements capital :teeF1 at the
time that they apply for building permits. Thejcity passed
this ordinance in response to the need forj additional
public facilities and capital improvements ,created by
increased residential and commercial development. The fees
were placed by the City into a "capital outlaylfund11 which
they used for the cost of-capital-i-mprovements. `,
The Building Industry Association . of Southern
California challenged this ordinance contendingthat it was
facially void, and that contending that thelfee was an
unconstitutional taking. They further contended that it
was an illegal tax, and was pre-empted by-the Subdivision
Map Act.
The Trial Court upheld the ordinance based upon a
finding that the fee had a reasonable relationship to the
need for public improvements created by new development and
further held that the fee did not violate the California
Constitution. The California Court of Appeal for the
Second District affirmed the Trial Court's decision,
MAY - 21 - 90 M O N S : 1 5 S U P T O M T O R L A K S O N P . 04
upholding the ordinance. The Court of Appeal held there
was a reasonable nexus between the fees charged and the
need created by new development.
Had the ordinance constituted a "buy-in" plan wherein
newcomers were required to buy-in to existing facilities,
the Court would have probably struck the ordinance down.
Instead, the Court found that the fee would be used to
support new or expanded public facilities to meet the need
created by new development.
As we discussed in youroffice; `would 'contend that
the same principals should be applicable to any public
facilities or capital improvements needed by a community,
in particular, the capital improvements required to develop
and put in place new parks needed by new subdivisions.
The current park dedication fee of $1,350.00 only
meets the land acquisition need, and does not .provide any
monies whatsoever to provide for developed park land.
Similarly, the park dedication fee of $1,350.00 only
meets land acquisition requirements for neighborhood parks
only, and does not meet the need for community parks under
the parks master plan requirements.
It is our calculation that in order to not only
acquire the land for park development but to develop that
. land so that it is useable, will require a fee of
approximately $2,500.00 per dwelling. This fee would be
somewhat more were we to include the cost of acquisition
and development of the trail system.
I would be interested in your County Counsells
comments L on the applicability of. SIA v. Oxnard to this
question.
Thank you for your continuing support and cooperation.
re
uffaker airman
OMAC Parks and ecreation
Subcommittee
JDH:ch
.cc: Members of Parks Subcommittee