Long-Term financing for TIM fees

The supervisors of the county gave to their vote approval early last week that softens the blow of the additional cost to building permits.  In addition to all other fees and cost, new TIM fees as high as $37,000 per house is mandated in the new General Plan approved by voters this year.

The Supervisors approved the recommendation by unanimous vote last week.  Details of the proposal are outlined here.

EL DORADO COUNTY BOARD OF SUPERVISORS

Consideration of Participation in Statewide Community lnfrastructure Program (SCIP)

 

Recommendation:

The Department of Transportation is recommending the Board of Supervisors approve in concept participation in the Statewide Community lnfrastructure Program (SCIP) to give property owners an option to finance Traffic Impact Mitigation (TIM) fees.

 

Reasons for Recommendation:

California Statewide Communities Development Authority (CSCDA) is a joint powers authority sponsored by the League of California. Cities and the California State Association of Counties. The member agencies of CSCDA include approximately 230 cities and 54 counties throughout California, including El Dorado County. SCIP was instituted by CSCDA in 2002 to allow owners of property in participating cities and counties to finance the development impact fees that would be payable by property owners upon receiving development entitlements or building permits. If a property owner chooses to participate, the development impact fees owed to the County will be financed by the issuance of tax-exempt bonds by CSCDA. CSCDA will impose a special assessment on the owner's property to repay the bonds issued to finance fees.

 

Participation in SCIP is being recommended specifically to provide a financing option for TIM fees, however, any County fees collected now or in the future for the purpose of building public infrastructure are eligible for SCIP financing. Additionally, fees levied within the County by another government entity may be financed through SCIP provided that entity enters into a "Fee Accounting Agreement" with CSCDA.

 

Within SCIP, there are two programs, which can be mixed and matched, or used individually:

> The Impact Fee Reimbursement Program where the impact fee is paid at the time of building permit issuance (or occupancy for commercial projects) and reimbursed from the SCIP bond proceeds when bonds are issued

> The Impact Fee Prefunding Program where fees are prepaid to the County from the proceeds of the SCIP bonds.

 

Under both programs, our County would not be at risk for the receipt of the impact fees.

 

Through the Impact Fee Prefunding Program, large blocks of development impact fees can be financed and paid up front, prior to the issuance of building permits, and in dollar amounts large enough to provide funding for necessary infrastructure before development takes place. El Dorado County has accepted prefunding of fees in the past, with the authorization being incorporated into subdivision map conditions and where prepayment was made through Mello Roos Bond proceeds issued by our County. This program would be similar except the bonds would be issued by CSCDA. Through participation in SCIP, owners of smaller projects, both residential and commercial, can have access to tax-exempt financing of infrastructure where currently only projects large enough to justify the formation of an assessment or communities facilities district have access to this tax-exempt financing.

While there is no minimum development size required for participation in SCIP, as a practical matter, each property owner would need to compare the advantages of a favorable interest rate to the cost of application fee (currently $1,500) and time to make the application.

 

In summary, the benefits to the property owner include:

 

1.     Only property owners who choose to participate in the program will have assessments imposed on their property.

2.     Instead of paying cash for development impact fees, the property owner receives low-cost, long-term tax-exempt financing of those fees, freeing up capital for other purposes.

3.     The property owner can choose to pay off the special assessments at any time.

4.     For homebuyers, paying for the costs of public infrastructure through a special assessment is superior to having those costs "rolled" into the cost of the home.  Although the tax bill is higher, the amount of the mortgage is smaller, making it easier to qualify. Moreover, because the special assessment financing is at tax-exempt rates, it typically comes at lower cost than mortgage rates.

5.     Owners of smaller projects, both residential and commercial, can have access to tax-exempt financing of infrastructure.

 

The benefits to the County include:

 

1.     In contrast to conventional assessment financing, the County is not liable to repay the bonds issued by CSCDA or the assessments imposed on the participating properties.

2.     CSCDA handles all district formation, district administration, bond issuance and bond administration functions.

3.     A participating county can provide tax-exempt financing to property owners through SClP with minimal staff time to administer the program.

4.     Providing tax-exempt financing would help cushion the impact of rising development impact fees for property owners.

5.     The availability of financing will encourage developers to pull permits and pay fees in larger blocks, giving our County immediate access to revenues for public infrastructure, rather than receiving revenues stretched out over time.

6.     As part of the entitlement negotiation process, the possibility of tax-exempt financing of fees can be used to encourage a developer to pay fees up front.

7.     In some cases, the special assessments on successful projects can be refinanced through refunding bonds. Savings achieved through refinancing will be directed back to the participating county for use on public infrastructure, subject to applicable federal tax limitations.

 

The SClP Manual of Procedures provides all of the details related to the program and is available on the web page for the California Statewide Communities Development Authority.

 

A couple of key points from the manual warrant highlighting here:

 

o       The SClP requires that the SClP trustee in an interest bearing account for each city or county hold all fees paid either through reimbursement or prefunding. The SClP administrator is therefore responsible for arbitrage calculations.

o       Funds will be paid to the County upon written request and in conjunction with incurred capital costs.

o       Funds must be expended within three years of the bond issuance.

o       The prefunding alternative would require changes to the provisions of our TIM fee resolutions to provide for pre-payment. It is recommended that where fees are prefunded the payments be considered a credit toward the fee in place at the time the building permit is issued. In other words, the fee is not locked in by the prepayment.

o       To participate in SClP your Board must approve a resolution (see attached) that authorizes CSCDA to form an assessment district covering our planning jurisdiction, conduct assessment proceedings and levy assessments against the property of participating owners. It also authorizes miscellaneous related actions and makes certain findings and determinations required by law.

 

Fiscal Impact:

Staff time associated with the coordination of this program is estimated to be minimal and less than the time requirements of a County bond issue.

 

Net County Cost:

There is no net County cost.

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