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BOOK 95 PA;E 131 <br />of the more expensive unit's cost. The second disadvantage is that <br />impact fees must be paid in full prior to receiving development <br />approval. This need for upfront payment may create financing <br />difficulties for developers. In the case of housing, the need to <br />pay impact fees upfront may significantly increase the amount of <br />money which must be obtained or financed in order to complete a <br />housing unit. <br />The disadvantages noted, especially the second disadvantage <br />concerning upfront payment, create much of the controversy <br />concerning impact fees, as those fees relate to the provision of <br />affordable housing. It is argued that impact fee costs imposed on <br />housing are added to the price of housing which makes it difficult <br />for persons with very low-, low- or moderate -incomes to obtain <br />housing. With this claim in mind, it is often recommended that <br />local governments provide impact fee alternatives for affordable <br />housing. These alternatives generally take one of two forms: the <br />elimination/reduction of impact fees or the subsidization of impact <br />fees. <br />O Impact Fee Elimination/Reduction <br />The elimination or reduction of impact fees for affordable housing <br />would have an immediate effect, as the amount eliminated or reduced <br />would be eliminated from the housing cost. However, the facility <br />demand created by the housing unit will not be eliminated or <br />reduced. Therefore, the government is faced with obtaining funds <br />for the necessary facility expansion through some other means. In <br />many cases, funds may be obtained through increased tax levies <br />(e.g. property, sales) or through increases in utility rates. The <br />government may also seek alternative methods to fund the necessary <br />expansions. In some cases, the financial impact of an alternative <br />may be just as great as, if not greater than, the financial impact <br />of'the impact fee which would have been charged. <br />As examples of impact fee elimination or reductions for affordable <br />housing, the City of Orlando provides an impact fee exemption for <br />affordable housing, while Orange County provides an -impact fee <br />reduction for affordable housing. The exemption and reduction are <br />provided for in each government's respective impact fee <br />regulations; however, each government must compensate the <br />respective impact fee funds through its other revenue sources. The <br />compensating action of the government is classified as having the <br />government paying the impact fee on behalf of the affordable <br />housing unit, rather than actually eliminating or reducing the <br />impact fee. Another suggested variation on eliminating or reducing <br />impact fees for affordable housing is shifting the impact fee <br />liability to other uses. This would involve recalculating impact <br />fee rates with the amount of the waived affordable housing impac* <br />fee revenue charged to other uses. This concept is inappropriatef <br />as provisions to shift costs may invalidate an impact fee <br />ordinance. Developers would be paying both their own proportionate <br />share of capital costs as well as the share for another project. <br />Legally, this would not conform to the proportionate share concept <br />upon which impact fees are based. <br />0 Impact Fee Subsidization <br />The subsidization of impact .fees on behalf of affordable housing, <br />in which the government specifically identifies monies which may be <br />used to pay all or a part of the impact fees for affordable <br />housing, is the second impact fee alternative for affordable <br />housing. This alternative is similar to the concept of eliminating <br />or reducing impact fees for affordable housing. The subsidization <br />alternative serves as a_method of formally recognizing that, while <br />the affordable housing unit developer is not paying all or a part <br />of an impact fee, the funds must still be provided to compensate <br />for the demand that the affordable housing unit will create. The <br />decisions to be made when the subsidization alternative is used are <br />22 <br />MAY 18, 1995 <br />