Submitted by Gabriel Duncan
Under Oral Communications
3/3/2026
From: Mitch B
To: CITYCOUNCIL-List; City Clerk
Subject: [EXTERNAL] Written Copy of non-Agenda Comment for 3/3/26 City Council Meeting Date: Tuesday, March 3, 2026 9:38:41 AM
Attachments: 3_3_26 City Council Figure (1).pdf
Hello,
I will be making a non-agenda public comment for the 3/3/26 City Council Meeting and wanted to share a written copy with linked citations. In addition, I have attached a PDF figure to be presented during my comment as I have seen other non-agenda item commenters do.
There are many nuances of impact fees calculations and only so much can fit into 3 minutes.
Other concerns about impact fee calculation that should be addressed include the fact that developer improved parks have not been granting developers a discount on the parks and recreation fee and the very unrealistic expectation that cities should maintain the same acres of parkland per capita as they grow. Additionally, council members should also consider that while impact fee cost housing developers greatly they contribute a very small portion to the city budget.
Last Monday, the planning board commission previewed an early look at the housing element report and it showed a truly disastrous situation. While in our previous best year we weren’t on pace to meet half of the RHNA targets, last year showed a uniquely poor performance with less than 10% of target permits issued. This is an emergency. While Alameda has met the housing element zoning requirements, zoning is no longer the bottleneck. California’s housing crisis was not caused purely by bad zoning, but by an insidious nativist and xenophobic ideology that infiltrated and influenced municipal government decades ago producing harmful policies that now seem commonplace today. The new bottleneck is cost of construction, a large portion of which is municipally imposed. While last year’s uniquely poor performance was in part caused by cost drivers outside of Alameda’s control including tariffs, loss of labor, and the Palisades Fire, this should not be an excuse to wring our hands of responsibility, but a wake up call that more drastic action to reverse the injustices of the past need to be taken.
One of the largest municipal cost contributors are impact fees and they are incredibly high in California with average impact fees nearly twice as high as the next state (
http://www.impactfees.com/publications%20pdf/2019survey.pdf). While impact fees must be justified within a nexus study to be “roughly proportional” to the cost new development imposes on a city, there are many ways to calculate these fees and many cities have traditionally selected somewhat questionable methodology to produce higher fees. It appears that the last nexus study Alameda produced in 2014
(https://www.alamedaca.gov/files/assets/public/v/1/publicworks/development-impact-fee- update-2014.pdf) took that approach after losing a lawsuit in 2019 and had to be revised to not include parkland land acquisition (https://alameda.legistar.com/LegislationDetail.aspx? ID=3991248&GUID=51A9206A-8FB4-413E-AA01-EA2D884BBEE3&FullText=1). But within that revision, the estimated cost of parkland improvement was somehow conveniently doubled replacing one questionable justification with another.
One of our planning board members, Andy Wang, has previously thoughtfully proposed to city council a temporary impact fee discount to enable construction of more housing projects (https://alameda.legistar.com/LegislationDetail.aspx?ID=7727809&GUID=542F5E0A-07C6- 437E-9DF1-6093075C5293). I would like to offer one of many ways that Alameda should apply this discount both temporarily and in its upcoming nexus study (https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220AB602).
Most impact fees within the 2014 study were calculated by taking the total value of all future or new city infrastructure and dividing it by the projected number of all future or new units.
Here’s the problem with that: While the RHNA target is 5,353 units over 8 years, this nexus study projects 4,600 units over 27 years amplifying the impact fees. The impact fee calculations assume we fail to meet housing targets and by virtue of that assumption, ensure that that’s what happens! If Alameda is serious about solving the housing shortage crisis, it needs to use the RHNA targets to calculate its impact fees. We shouldn’t be planning to fail.
Every year, more people in Alameda lose their homes, more young people leave the island knowing they’ll never be able to afford to return, and more couples in Alameda give up on the dream of ever starting a family. This is all because for decades we haven’t built enough housing. Previously, this was as an intentional outcome of policy designed to keep poor people, immigrants, and people of colour out. Now, it’s because we haven’t done nearly enough to reform this draconian policy design.
Thank you,
-Mitch Ball
Regional Housing Needs Allocation
(RHNA) Targets
2014 Impact Fee Nexus Study
Housing Unit Assumptions
2031 - 2023 = 8 years 2040 - 2013 = 27 years
5353 units
8 years
4600 units
27 years≠