Opposition to City of Goleta 2026 DIF Program Update | May 16, 2026 | Page 1 May 16, 2026
Honorable Members of the Goleta City Council
City of Goleta
130 Cremona Drive, Suite B
Goleta, California 93117
Re: Opposition to Proposed 2026 Development Impact Fee Program Update — City Council Vote Scheduled May 19, 2026
Dear Mayor Perotte and Members of the City Council,
We write in strong opposition to the proposed 2026 Development Impact Fee (DIF) Program Update currently before the Council for adoption on May 19, 2026. After careful review of the April 2026 Public Review Draft prepared by Urban Economics, we have identified significant factual, methodological, and legal deficiencies that render the proposed fee schedule unsupportable in its current form.
The proposed increases are among the largest in the City's history. Fees for the average multifamily unit would rise 77 percent — from $31,774 to $56,132 — and bicycle and pedestrian fees alone would increase 222 percent. These are not modest inflation adjustments. They represent a fundamental restructuring of the fee program that demands a correspondingly rigorous evidentiary record. That record is not present in the April 2026 draft.
CENTRAL ARGUMENT: The 2026 draft does not merely update 2019 costs for inflation. It resets the underlying facility inventory baselines upward — in some cases by more than 100% — and then multiplies those inflated baselines by sharply higher 2026 replacement costs. New development is being charged to maintain a level of service that was never used to justify fees before.
I. GOVERNING LEGAL FRAMEWORK
Under the Mitigation Fee Act (Government Code §66001 et seq.), the City must demonstrate:
• Impact: A reasonable relationship between the use of the fee and the type of development project. • Benefit: A reasonable relationship between the need for the public facility and the development project on which the fee is imposed.
• Proportionality: A reasonable relationship between the amount of the fee and the proportionate cost of facilities attributable to new development.
The Act expressly prohibits fees from funding existing deficiencies in public facilities. The City acknowledges this limitation in the draft itself. AB 602, effective 2022, further requires (a) nexus study updates at least every eight years, (b) per-square-foot residential fee structures, and (c) a clear articulation of the methodology basis when level-of-service standards change.
When a study effectively raises the level of service being funded — as this one plainly does — the agency must justify that choice rather than presenting the revision as merely a more accurate inventory. The April 2026 draft fails this test.
II. THE INVENTORY BASELINE RESET — THE DOMINANT FLAW
The City candidly states in Table 1.2 that higher fees are driven by "updated inventories of existing facilities" reflecting a "higher level of service than was previously assumed." This is the single most consequential methodological problem in the entire draft, and it affects four fee categories: Public Administration, Parks, Bicycle/Pedestrian, and Storm Drain.
A. Bicycle & Pedestrian Facilities — Massive Inflation of Baseline Inventory Opposition to City of Goleta 2026 DIF Program Update | May 16, 2026 | Page 2 The 2026 draft increases the bicycle and pedestrian fee by 222 –233% (depending on development category).
This increase is almost entirely driven not by new construction — but by reclassifying and expanding the inventory used to set the baseline standard:
Metric 2019 Nexus Study 2026 Draft Change
Sidewalk inventory (sq ft) 1,399,254 3,418,016 +144%
Service population 36,546 37,525 +2.7%
Sidewalk standard (sq ft/capita) 38.3 91.1 +138%
Replacement cost (per sq ft) ~$18 $44.00 +144%
Resulting fee — All Other Residential $3,006/DU $9,692/DU +222%
Figure 1: Inventory baseline comparisons — 2019 Nexus Study vs. 2026 Draft. Both the sidewalk and civic building per-capita standards more than doubled without any corresponding showing of newly built facilities.
The draft does not demonstrate that 2.4 million additional square feet of sidewalk were built between 2019 and 2025. It appears the City simply performed a more comprehensive field inventory. While a more accurate count of assets is welcome, using a newly discovered inventory as the fee-setting baseline — without any explanation of why the 2019 baseline was deficient — effectively charges new development to buy into historical assets at today's replacement costs. That approach is not defensible under the Mitigation Fee Act.
B. Public Administration — Civic Building Baseline More Than Doubled The 2026 draft uses a civic building inventory of 110,470 square feet (2.94 sq ft/capita) versus only 51,194 square feet (1.40 sq ft/capita) in 2019 — a 110 percent increase in the per-capita baseline. The all-other-residential public administration fee rises from $2,999 to $7,396 per unit as a result.
The land valuation is also problematic. The draft uses $2,695,000 per acre based on the City's 2018 acquisition of the Goleta Train Depot — a single specialized transaction — as a proxy for all future civic land acquisition. No comparative sales analysis, appraisal, or market basket methodology is offered. A single land purchase from seven years ago cannot reliably represent the cost of acquiring diverse municipal properties across the city.
C. Parks — Double Counting Level of Service
The parks fee nearly doubles for multifamily units (from $13,175 to $23,083 under the MFA). The draft simultaneously relies on an expanded park inventory and higher land and improvement costs. The core question the draft fails to answer: is the revised inventory the correct legal baseline, or does it force new development to fund historical assets at present-day replacement cost without the requisite nexus showing?
Opposition to City of Goleta 2026 DIF Program Update | May 16, 2026 | Page 3 Because the City uses an existing-capital-asset standard — which is designed to avoid existing deficiencies — any unexplained upward revision to the asset inventory directly and improperly inflates the fee. The 2026 draft offers no facility-by-facility explanation for why the revised inventories should govern fee-setting when they were not the operative baseline in 2019.
III. TRANSPORTATION FEE — MULTIPLE INDEPENDENT WEAKNESSES The proposed transportation fee rises from $16,665 to $22,687 per PM Peak Hour Trip — a 36 percent increase.
This may appear more modest than other categories, but the methodology contains at least four independent problems, each of which independently warrants rejection or revision.
A. The Denominator Problem — Artificially Low Growth Forecast The cost-per-trip formula is: total project costs allocated to Goleta growth ÷ total new PM peak hour trips. The 2026 draft projects only 3,329 new dwelling units from 2025 to buildout, generating 8,844 total new PM peak hour trips.
This growth figure is inconsistent with the City's own Housing Element, which identifies a sixth -cycle RHNA obligation of 1,837 units by 2031 alone and zoning capacity for 2,624 units through 2031 — yet the nexus study spreads only 3,329 units across a buildout horizon extending to 2050. A thinner denominator means a higher cost per trip.
In 2019, the comparable calculation used 11,508 new PM peak hour trips as the denominator. The 2026 draft uses 8,844 — a 23 percent reduction. This alone accounts for a significant portion of the $6,022/PHT increase from $16,665 to $22,687.
B. The Numerator Problem — Zero Grant Deductions
In 2019, the City deducted $13 million in alternative funding and $9.26 million in fund balance from the transportation cost numerator. In the 2026 draft, despite a total project cost nearly doubling to $485.6 million, the deduction for alternative funding is $0.
Figure 2: Transportation fee build-up comparison. The 2026 draft eliminates $13M in alternative funding deductions while total project costs nearly double — directly inflating the per-trip fee.
The draft itself acknowledges that the City must identify approximately $293.7 million in alternative funding sources to fully fund all 32 transportation improvements — and that the City "can concentrate fee revenue on some projects in exchange for using alternative funding sources on other projects." This language concedes that
Opposition to City of Goleta 2026 DIF Program Update | May 16, 2026 | Page 4 grants and alternative funds exist but are not transparently used to reduce the fee basis on a project-by- project basis. This is a critical methodology failure.
C. Average Signal/Roundabout Costs for 12 Intersections For 12 of 32 improvement projects, the cost estimate represents an "average cost between a traffic signal and a roundabout" because the final control type is uncertain. Roundabouts can require materially greater right -of-way, earthwork, and construction cost than signals. Charging new development a midpoint between two materially different facility types — without a final design choice or analysis — creates a weak nexus record and violates rough-proportionality requirements. Approximately $82 million in project costs fall in this category.
D. Incomplete Warrant Screening and Hyper-Sensitive Deficiency Triggers The traffic analysis expressly did not evaluate all signal warrants, relying instead on a peak -hour indicator as a proxy. This acknowledged limitation is significant when the same study supports millions of dollars in intersection exactions.
More critically, the study defines a development-caused traffic deficiency to include increasing an existing queue by more than one vehicle length (25 feet). This threshold is unusually sensitive. It makes it easier to sweep relatively small developments into the funding base for large capital projects, inflating the per -trip cost assigned to new development beyond any reasonable proportionality standard.
IV. STORM DRAIN — FEES RAISED WITHOUT A COMPLETE MASTER PLAN The proposed storm drain fee rises dramatically for industrial uses (+284%) and retail/commercial (+136%). The draft candidly states: the future Storm Drain Master Plan "will be incorporated into the CIP once complete" — meaning the master planning work identifying capacity-expansion projects is still pending at the time fees are being set.
A fee adopted without an identified project list has an inadequate nexus to specific capital improvements. The Council is being asked to raise fees today based on a general infrastructure standard, with the assurance that a master plan will be written later. This is precisely the kind of generalized cost-pooling that courts have found insufficient. The storm drain increases should not be adopted until the Master Plan is complete and a specific project-level expenditure plan is in place.
V. SIGNIFICANT FUND BALANCES UNDERMINE THE URGENCY OF INCREASES The draft's own Table 1.1 discloses the following existing DIF fund balances as of FY 2024 -25:
Fee Fund Balance (FY24/25) Significance
Parks & Recreation — Quimby $6,400,000 Largest single balance; projects delayed Fire $4,100,000 Not updated in 2026 Draft; County-
administered
Parks & Recreation — Non-Quimby $2,320,000 Second parks fund also unspent Transportation $1,296,000 Only $1.3M deducted despite $293M alt. funding gap
Storm Drain $565,000 Master Plan not yet complete
Bicycle & Pedestrian $291,000 Fee proposed to increase 222% despite balance
Library $283,000 Library fee actually decreases in 2026 Draft Public Administration $683,000 Fee proposed to increase 147% TOTAL $15,649,000 Over $15.6M held while new increases
proposed
Opposition to City of Goleta 2026 DIF Program Update | May 16, 2026 | Page 5
Figure 3: Existing DIF fund balances as reported in the 2026 Draft (Table 1.1). Over $15.6M in accumulated impact fees remains unspent while steep increases are proposed.
The City's own annual five-year reporting obligations under the Mitigation Fee Act require a finding that the continued collection of fees with accumulated balances is still necessary. Large unspent balances combined with steep new fee increases — without a clean, project-specific spending plan — does not satisfy this standard. The Council should require a stricter five-year finding and a credible spending plan before authorizing increases.
VI. THE 5% ADMINISTRATION CHARGE IS UNSUPPORTED AT PROPOSED SCALE
Every fee category includes a flat 5 percent charge for program administration — described only as covering "collection, accounting, and compliance." No cost-of-service analysis is provided.
When fee bases nearly double or triple, a percentage-based administration charge produces substantially larger dollar recoveries without any demonstration that the administrative workload increases proportionately. For example, if the public administration fee alone generates $34.7 million through buildout, 5% allocates $1.7 million to administration — for a single fee category. Multiplied across six fee categories, the aggregate administration recovery could exceed $10 million with no documented cost basis.
Required action: Replace the flat 5% administration factor with a documented cost -of-service study or a capped administrative recovery tied to actual program cost. A percentage that was appropriate for a $23M fee package may not be appropriate for a $56M f ee package.
VII. THE NEXUS STUDY APPLIES FAVORABLE ASSUMPTIONS SELECTIVELY A rigorous nexus study applies methodology consistently across all fee categories. The April 2026 draft does not.
In at least three distinct areas, the City made assumption choices that systematically favor higher fees — while applying a more careful, expansive methodology in the one category where doing so reduced the fee. That asymmetry is not a coincidence. It is a pattern that undermines the credibility of the entire schedule.
A. The Library Contradiction — Expanded Methodology Only Where It Reduces Fees The library fee is the only category that decreases in the 2026 draft — falling 34%, from $934 to $613 per multifamily unit. The reason: Urban Economics expanded the library service population denominator to include unincorporated county residents, reducing the per-capita cost standard. This was the methodologically correct choice.
Opposition to City of Goleta 2026 DIF Program Update | May 16, 2026 | Page 6 But the same logic was not applied anywhere else. Regional commuters, UCSB students, and unincorporated county residents regularly use Goleta roads, parks, and bike paths. Including them in the relevant service populations — exactly as was done for the library — would reduce the per-capita cost standard and the resulting fee for transportation, parks, and bicycle/pedestrian categories. The City applied rigorous, accurate methodology only where it produced a reduction, and a narrower, more costly methodology everywhere else.
KEY QUESTION FOR THE RECORD: If expanding the service population denominator is the correct approach for the library, the City must explain on the record why the same expansion was not applied to transportation, parks, and bicycle/pedestrian facilities — categories where a broader service population would substantially reduce the per-capita cost and the fee imposed on new development.
B. Increases Far Exceed What Construction Cost Inflation Alone Justifies The City has adjusted fees annually for ENR Construction Cost Index inflation since 2019. That index rose approximately 32 percent cumulatively between June 2019 and June 2025. A fee schedule reflecting only legitimate cost inflation would show increases of roughly that magnitude. Instead, the draft shows 147% for Public Administration, 222% for Bicycle/Pedestrian, and 75% for Parks — multiples of what inflation alone produces.
Figure 4: Fee comparison isolating the excess above pure cost inflation. The middle bar shows what each fee would be if only the 32% cumulative ENR increase had been applied to the 2019 adopted baseline. The gap between the middle and right bars is attributable entirely to inventory resets and methodology changes — not construction cost escalation.
For Bicycle/Pedestrian, the excess above inflation-only is $6,731 per unit — a 227% overage. For Public Administration, the excess is $4,442 per unit (150% above inflation). For Parks, the excess is $12,593 per unit (120% above inflation). These are the direct mathematical consequence of resetting inventory baselines without adequate legal justification, not construction cost escalation.
C. Cherry-Picked Cost Assumptions Compound the Problem Where the draft exercised discretion in selecting cost assumptions, it consistently chose the most expensive available option:
Opposition to City of Goleta 2026 DIF Program Update | May 16, 2026 | Page 7 • Land valuation at $2,695,000/acre rests entirely on a single 2018 transaction — the Goleta Train Depot, a unique transit-oriented civic property. No appraisal range, no market comparables, and no sensitivity analysis are provided. A lower but equally defensible land value would proportionately reduce Public Administration, Parks, and Bicycle/Pedestrian fees across all land use categories. • Transportation project costs use an average between signal and roundabout designs for 12 intersections — defaulting to the higher-cost midpoint rather than the more conservative signal-only estimate — without any analysis of which design is operationally necessary or likely to be built.
No sensitivity analysis is provided showing how fees would change under more conservative but equally defensible assumptions. The Council cannot evaluate whether the proposed fees are proportionate — or merely reflect the upper bound of available assumptions — without that analysis.
VIII. RECOMMENDED ACTIONS FOR THE COUNCIL
We respectfully urge the Council to decline adoption of the April 2026 draft on May 19 and direct staff to return with a narrower, more defensible revision. The following specific corrections are required before any vote to increase fees:
• 1. Recalculate Public Administration, Bicycle/Pedestrian, Parks, and Storm Drain fees using either the 2019 inventory baselines or a fully explained, legally justified new level of service — with a facility-by- facility explanation of why the revised inventories should govern fee-setting under the Mitigation Fee Act. • 2. Recalculate the transportation fee using a realistic housing-growth denominator consistent with the City's Housing Element, RHNA obligations, and zoning-capacity commitments. • 3. Deduct identified grants, SB 1 funds, STIP programming, and other alternative funding sources from applicable transportation project costs on a project-by-project basis, consistent with the approach used in the 2019 nexus study.
• 4. Remove or separately justify the 12 transportation project estimates based on average signal/roundabout costs until the City identifies the actual mitigation concept and control type for each location.
• 5. Defer storm drain fee increases until the Storm Drain Master Plan is complete and a project -specific capital expenditure program is adopted. The City should also analyze whether new development subject to post-construction Low Impact Development (LID) and on-site stormwater retention requirements under the MS4/NPDES permit is being charged a disproportionate share of storm drain costs — given that mandatory on-site retention reduces or eliminates the incremental load those projects place on the City's conveyance infrastructure, yet the draft's EDU methodology does not account for this regulatory burden already borne by new development at its own expense.
• 6. Replace the flat 5% administration factor across all categories with a documented cost -of-service study tying the administrative recovery to actual program costs. • 7. Provide a clean five-year finding addressing the existing $15.6 million in accumulated unspent fee balances before authorizing additional increases.
• 8. Commission and publish a sensitivity analysis showing how fee levels would change under alternative but equally defensible inventory baselines and cost assumptions, including the 2019 inventory baseline as a floor.
• 9. Extend the library service population methodology — accounting for regional facility users — to transportation, parks, and bicycle/pedestrian categories before resetting fees, consistent with the approach applied in Chapter 4 of the draft.
IX. CONCLUSION
The April 2026 draft does not provide the clean, project-specific, and proportionate record that the Mitigation Fee Act, AB 602, and constitutional proportionality requirements demand before fee increases of this magnitude are imposed. Its largest increases are driven not by construction inflation — which would be entirely defensible — but by unexplained inventory resets, aggressive land-value assumptions, zero grant deductions in transportation, and an unfinished storm drain capital program.
Opposition to City of Goleta 2026 DIF Program Update | May 16, 2026 | Page 8 Because the Council may lawfully adopt fees below the maximum justified amounts — and because the City explicitly acknowledges that lower fees would require supplemental general fund support — the most prudent and legally defensible course is to reject the proposed schedule on May 19 and direct a revised nexus package that is narrower, more thoroughly documented, and more clearly aligned with the Mitigation Fee Act, AB 602, and constitutional proportionality standards.
The City's infrastructure needs are real and its long-term financial planning is legitimate. But the fee schedule must rest on a record that survives legal scrutiny. The April 2026 draft, as written, does not.
Respectfully submitted,
________________________
Benjamin Williams
Local property owner and resident
May 16, 2026
Note: This letter was prepared based on review of the April 2026 Public Review Draft of the City of Goleta Public Facilities Impact Fee Program Update (Urban Economics), City of Goleta Development Impact Fee Schedules FY 2019/20 through FY 2025/26, and the City's prior 2019 Nexus Study. All fee data referenced herein is drawn directly from those official City documents.
805.967.2500 | SBSCChamber.com
Mailing Address: 5662 Calle Real #204, Goleta, CA 93117 Visitor Center: 120 State Street, Santa Barbara, CA 93101 5/15/2026
Mayor Perotte and Goleta City Council
City of Goleta
130 Cremona Drive, Suite B
Goleta, CA 93117
RE: Proposed Development Impact Fee Increases
Dear Mayor Perotte and Councilmembers,
The Santa Barbara South Coast Chamber of Commerce remains strongly concerned about the proposed Development Impact Fee increases and urges the Council to reconsider the scale of the proposed adjustments.
Goleta is already one of the more expensive places in the region to build housing and commercial projects.
The City of Goleta’s development impact fees for single family homes are currently highest in the County, just over seven times that of Lompoc and nearly twice that of Carpinteria as two examples. Under the current proposal, residential development impact fees would nearly double (14x Lompoc & 3.4x Carpinteria). Current construction costs, interest rates, insurance costs, and financing challenges are already straining the feasibility of projects. At this time, increases of this magnitude risk many projects becoming financially untenable.
The Chamber is particularly concerned about the broader economic consequences of these increases.
Housing production is already lagging behind the community need across the South Coast. The proposed increases risk fewer homes being built, further constraining housing supply remains, and worsening affordability challenges. Increased fees can also discourage commercial investment, job creation, and business expansion by pushing projects to other regions (or other States) with lower costs. Our local economy has a unique value proposition, and we are not necessarily only competing with nearby regions.
We recognize that the Nexus Study identifies the maximum fee levels the City may legally justify. However, adopting the maximum is ultimately a policy decision, not a legal requirement. The City has discretion to balance infrastructure funding needs alongside housing production, economic competitiveness, and long- term community goals.
We are also concerned that portions of the proposed fee structure appear to assign a disproportionate share of regional infrastructure and community-wide amenities onto a relatively small amount of new development compared to the city’s existing housing stock. While new housing and businesses should contribute fairly toward infrastructure, they should not be expected to solely carry the financial burden of maintaining or expanding systems that serve the broader region and existing community. The Council’s concerns regarding County projects on the City’s borders is understandable, but still does not account for the impact that shifting the financial burden onto Goleta based projects will have on much needed housing production.
805.967.2500 | SBSCChamber.com
Mailing Address: 5662 Calle Real #204, Goleta, CA 93117 Visitor Center: 120 State Street, Santa Barbara, CA 93101 The Chamber respectfully asks that the Council consider the following options before adopting these fee increases. Conduct a housing feasibility analysis, consider lower residential rates, and explore alternative funding sources. There must be alternatives that can allow Goleta to invest in infrastructure while also protecting housing feasibility.
Goleta’s long-term economic vitality depends on both infrastructure investment and the ability to realistically build housing and support business growth. We believe there is a more balanced approach that can achieve both objectives without unintentionally discouraging the very development needed to address our housing and economic challenges.
Sincerely,
Dustin Hoiseth
Dustin Hoiseth
Director of Economic Development
Santa Barbara South Coast Chamber of Commerce
Santa Barbara Association of REALTORS® | 1415 Chapala Street | Santa Barbara, CA 93101 (805) 963-3787 | (805) 966-9664 FAX | www.sbaor.com REALTOR® is a registered trademark that identifies a professional in real estate who subscribes to a strict code of ethics as a member of the National Association of REALTORS®
May 19, 2026
Mayor Paula Perotte
Mayor Pro Tempore Jennifer Smith
Councilmember Stuart Kasdin
Councilmember James Kyriaco
Councilmember Luz Reyes-Martín
130 Cremona Drive
Goleta, CA 93117
RE: 2026 Development Impact Fee Program Update
Dear Mayor Perotte and Councilmembers,
The Santa Barbara Association of REALTORS® (SBAOR) represents about 1,200 REALTORS® throughout the South Coast and our mission includes engaging in real estate related community issues affecting our members and/or their clients who are homeowners, housing providers, tenants, and commercial owners. Thank you for the opportunity to provide input on the proposed 2026 Development Impact Fee (DIF) Program Update
We understand the City’s need to periodically update its nexus study and ensure compliance with evolving state requirements, including AB 602. We also recognize the importance of funding infrastructure and public facilities needed to support future growth. However, we urge the City Council to carefully consider the cumulative impact these proposed fee increases may have on housing production, project feasibility, and the diversity of housing types developed in Goleta.
According to the staff report, the proposed updates would increase the total residential fee burden from approximately $45,471 to $89,431 for an average single-family unit and from approximately $31,774 to $56,132 for other residential units. These increases come in addition to other costs already affecting housing development, including construction costs, financing costs, affordable housing requirements, labor, insurance, utility infrastructure, and other local and state regulatory obligations.
While the nexus study may justify a maximum fee level, the City is not required to adopt the maximum allowable fees. We encourage the Council to consider a more balanced approach that recognizes the current economic realities facing housing production throughout the region.
Importantly, Goleta needs all types of housing. The community benefits from a diverse housing inventory that includes smaller homes, workforce housing, entry-level ownership opportunities, condominiums, townhomes, apartments, mixed-use projects, and family-oriented housing. As development impact fees continue to rise, the ability to produce this range of housing types becomes increasingly constrained. Higher fees often push development toward only the highest-priced product types capable of absorbing the additional costs, reducing housing diversity and limiting opportunities for moderate-income households, young families, seniors, and local workers.
Santa Barbara Association of REALTORS® | 1415 Chapala Street | Santa Barbara, CA 93101 (805) 963-3787 | (805) 966-9664 FAX | www.sbaor.com REALTOR® is a registered trademark that identifies a professional in real estate who subscribes to a strict code of ethics as a member of the National Association of REALTORS®
We respectfully encourage the City Council to consider:
• Phasing in any fee increases over time;
• Evaluating reduced fee structures for smaller or workforce-oriented housing types; • Considering exemptions or reductions for deed-restricted affordable housing and missing-middle housing; • Conducting additional feasibility analysis regarding the cumulative effect of local development costs; and • Continuing to prioritize policies that encourage housing production across all income levels and housing types.
Goleta has worked hard to position itself as a community that supports thoughtful housing production while maintaining quality of life. We encourage the City to ensure that future fee policies do not unintentionally undermine those efforts.
Thank you for your consideration.
Sincerely,
Jennifer Berger
SBAOR President
18 May 2026
City of Goleta
Attn: Mayor Perotte and Council Members
130 Cremona Drive
Goleta, CA 93117
Subject: Public Comment – Item C.2 - May 19, 2026 Council Agenda 2026 Development Impact Fee Program Update
Dear Mayor Perotte and Council Members,
On behalf of SEPPS Land Use Consulting, I am writing to express our thoughts and concerns with certain proposed Development Impact Fee Increases . Our office has represented a broad range of clients through the City’s land use entitlement process including single-family homeowners, multifamily residential operators, local businesses and institutions , non-profit organizations, housing developers, and renewable energy developers. While we appreciate the City’s need to responsibly plan for infrastructure and fiscal stability, we respectfully submit comments related to the magnitude of certain Development Impact Fee increases currently under consideration.
Our office supports new housing and development consistent with the City’s general Plan, contributing to a strong and healthy local economy. New development generates long-term benefits for Goleta, including property tax growth, sales tax revenue, job creation, local spending, and reinvestment in aging neighborhoods. The challenge before the City is striking the right balance to ensure that growth pays its fair share without pushing fees to levels that unintentionally stifle the very development needed to support the City’s fiscal and community goals. Higher fees could also unintentionally incentivize taking the risk to complete work without required permits (which could potentially impact public health and safety).
The draft 2026 Development Impact Fee (DIF) Update proposes increases that are substantial across nearly every category. While the nexus analysis demonstrates that higher “maximum justified” fees may be legally defensible, in some cases adopting fees at those levels could materially change the feasibility of entitling development in Goleta.
By way of example:
• Total impact fees for an average single -family dwelling unit would increase from approximately $45,000 to nearly $90,000 per unit, representing almost a doubling of fees.
DIMF Update
• Public Administration fees increase by over 150%, from about $4,100 to more than $10,500 per dwelling unit.
• Parks and Recreation fees increase dramatically , with a combined impact of approximately $37,000 per single -family unit under the Mitigation Fee Act framework.
• Bicycle and Pedestrian fees rise by more than 200%, increasing from roughly $4,100 to nearly $13,800 per unit.
• Storm Drain fees for single -family homes more than double to over $10,800 per dwelling unit.
Even when fees are converted to a per-square-foot basis in compliance with AB 602, the cumulative effect remains the same: a dramatically higher upfront cost burden placed on new development. While larger developers may be able to absorb or partially offset increased fees, many of our clients cannot. These include homeowners seeking to add modest square footage, rebuild after years of deferred maintenance, or construct an accessory dwelling unit (ADU) over 750 square feet to house family members or generate supplemental income.
For these households, impact fees are paid in cash before occupancy —often at the Building Permit stage—at a time when construction costs, interest rates, and insurance costs are already at historic highs. It is easy to anticipate the adding tens of thousands of dollars in new fees will, in some cases:
• Render otherwise code-compliant projects financially infeasible; • Force homeowners to significantly downsize or abandon projects; • Discourage ADU construction, undermining stated housing goals; and • Delay reinvestment in existing neighborhoods.
Please also consider similar impacts on small businesses.
From a market perspective, fees of this magnitude risk stifling new development activity altogether. When projects do not pencil, they do not move forward meaning no new housing, no new or expanded businesses, no related temporary or permanent jobs, and no long-term tax base expansion. Over time, this can lead to slower economic growth and greater reliance on existing residents and businesses to fund City services.
Rather than relying primarily on steep impact fee increases, we urge the City to explore a broader set of funding strategies, such as:
• Phased or incremental fee increases tied to market conditions; • Greater use of grant funding , state and federal infrastructure programs, and competitive transportation funds;
DIMF Update
• Enhanced use of the General Fund for facilities that benefit both existing and new residents; and
• Targeted fee reductions , credits, or incentives for modest residential and commercial projects.
If the City does adopt these relatively drastic fee increases, we ask that the City consider freezing fees for applications that have been deemed complete (we realize impact fees due are typically based on the fee schedule in place when the fees are paid). In most cases these applicants have assessed their anticipated costs in their decision whether to process an application. An applicant might typically absorb a CPI based increase in fees, but the proposed increases are considerably more significant.
SEPPS acknowledges that the City has certain provisions to reduce fees for non -profits, certain community benefit projects, and certain Smart Growth projects. We urge the City to keep these provisions in place, and potentially consider a wider range of applicability.
Goleta’s desirability and economic vitality depend on continued, well -planned investment. Impact fees should support that future, not inadvertently constrain it. We respectfully request that the City Council reconsider the scale of the proposed increases and seek a more balanced approach —one that ensures fiscal sustainability while preserving the feasibility of new housing, reinvestment, and economic growth.
Thank you for your thoughtful consideration and for the opportunity to comment on this important policy decision.
Sincerely,
SEPPS LAND USE CONSULTING
Sarah Marshall
Associate Planner
1 May 16, 2026
Mayor and Members of the City Council
City of Goleta
130 Cremona Drive
Goleta, CA 93117
Re: Public Comment on the 2026 Development Impact Fee Program Update (Public Review Draft, April 2026) — Request to Continue the Hearing and Re-evaluate the Proposed Fee Methodology and Schedule
Dear Mayor and Council members:
I write to urge the Council, at its Monday meeting, to pause adoption of the proposed 2026 Development Impact Fee (DIF) update and direct staff to re-examine the methodology, the magnitude of the proposed increases, and the legal and policy risks the draft creates for the City of Goleta. The April 2026 Public Review Draft, prepared by Urban Economics, recommends fee increases that, taken together, would raise total impact fees on a single-family home from $45,471 to $89,431 — a 97% increase — and from $31,774 to $56,132 — a 77% increase — on a typical multifamily unit, in a single update cycle. Specific categories rise even more: bicycle and pedestrian fees are proposed to increase by 222% to 233%; public administration by 147% to 155%; parks by 75% to 107%; and storm drain by as much as 284% on certain land uses.
These are not modest inflation adjustments. They are a structural reset of the cost of building in Goleta, proposed at the worst possible moment for housing production and during an active HCD compliance posture.
1. The proposed fees create a serious barrier to housing production at the moment the City can least afford one.
The City is operating under the 6th Cycle (2023–2031) Housing Element, and the Department of Housing and Community Development’s September 27, 2022 letter to Director Imhof identified fees as a governmental constraint requiring affirmative analysis under Government Code section 65583(a)(5). HCD specifically required the City to “list and evaluate planning and permit fees” and to address their “impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities.” An across-the-board fee increase of 77% to 97% on residential development, due to a questionable change in impact fee calculation methodology, and adopted without a defensible housing-impact analysis, is in direct tension with the City’s obligations under the Housing Element Law and with the constraint analysis HCD has already flagged.
2 2. The largest fee increases are driven by re-cataloged inventories, not by new infrastructure demand created by growth.
The draft is candid that the principal driver of the increases is not a surge in new capacity needs, but “updated inventories of existing facilities” that the City now believes show a higher pre-existing level of service than the 2019 study assumed. The Bicycle and Pedestrian category — proposed to rise 233% — is the clearest example. The City has not built triple the sidewalks and bike facilities since 2019. The 2025 Infrastructure Inventory Update simply identified more existing facilities than the prior nexus study counted. The same dynamic drives a portion of the Public Administration, Park, and Storm Drain increases.
This matters legally and as a matter of fairness. Under the Mitigation Fee Act, the fee must reflect new development’s incremental burden on facilities. Where the City has already provided facilities at a given level of service to existing residents — funded by prior fee payers and the General Fund — converting an inventory recount into a 233% increase on future homebuyers and builders extracts value for facilities that already exist. The Fee Mitigation Act prohibits fees from being used to fund existing deficiencies; the same logic counsels against using fees to fund the City’s own re-discovery of facilities it already owns.
Some anchor unit costs in the draft also rest on single, non-comparable transactions:
• Land cost is set at $2,695,000 per acre based on the City’s 2018 acquisition of the Goleta Train Depot — a unique transit-related parcel — and is used to value all civic land and all future park land citywide.
• Park development cost is set at $919,000 per acre based on the rehabilitation budget for Stow Grove Park, a single CIP line item that is a rehab project, not a greenfield park development.
No sensitivity analysis is presented. The Council should not adopt a structural fee increase of this magnitude on the strength of single-point cost assumptions and borrowed inputs.
3. The proposed fees impose costs on small infill projects that bear no rational proportion to the facilities being funded.
This is the most serious nexus problem in the draft. The transportation and bicycle/pedestrian fee programs are dominated by a small number of large regional projects with no direct relationship to most small infill development. The clearest example is Project R-05, the proposed US 101 Bicycle and Pedestrian Overcrossing, at $92.3 million — by itself nearly one- fifth of the entire $485.6 million project list. The draft allocates 50% of R-05 ($46.15 million) to the transportation fee and 50% to the bicycle and pedestrian fee. A small infill project on a Calle Real parcel, or a four-plex on Cathedral Oaks would be charged a per-trip and per-capita share of this regional overcrossing regardless of whether the project’s residents would ever cross U.S. 101 at that location.
Under the U.S. Supreme Court’s decision in Sheetz v. County of El Dorado, 601 U.S. 267 (2024), legislatively-imposed monetary exactions are no longer exempt from the Nollan/Dolan tests.
3 Every fee must satisfy an essential nexus to a legitimate government interest and rough proportionality to the project’s impacts. Aggregate citywide service-population math does not satisfy Sheetz at the project level. The draft’s reliance on “cost per peak-hour trip” and “cost per capita” figures, multiplied by trip rates or occupancy factors, is the same generalized methodology that Sheetz now requires courts to scrutinize. A small infill housing project that does not generate measurable demand for the U.S. 101 overcrossing, the Cathedral Oaks roundabouts, the Storke Road interchange improvements, or other regional facilities is exposed to fees that are not roughly proportional to its actual impact. The Council should expect, and should reduce its exposure to, project-level Sheetz challenges.
4. Requested Actions.
I respectfully request that the Council, at its Monday meeting, take the following actions:
1. Continue the public hearing on the 2026 DIF Update for at least sixty days to allow meaningful public review, independent peer review of the nexus study, and a documented housing-impact analysis.
2. Direct staff and the consultant to present a side-by-side reconciliation of the 2019 and 2025 facility inventories — line item by line item — identifying which items reflect genuinely new construction and which reflect re-cataloged pre-existing facilities, and removing the re-cataloged items from the fee calculation.
3. Direct sensitivity analysis on each single-source unit cost (Train Depot land, Stow Grove park development, borrowed building costs) showing the proposed fees at the 25th, 50th, and 75th percentiles of comparable transactions, and adopting the conservative end where data are thin.
4. Withhold the Storm Drain fee increase until the Storm Drain Master Plan (CIP Project No. 9085) is adopted, so that the facilities to be funded are identified before the fee is set. Also, consider whether storm drain fees are appropriate at all for new development that is already subject to strict water retention requirements, often at a great cost to new projects.
5. For the Transportation and Bicycle/Pedestrian fees, separate Project R-05 (the US 101 overcrossing) and any other regional megaproject from the per-trip and per-capita rate calculations and fund those projects through a defined regional or grant-funded source rather than loading them onto small infill applicants.
6. Adopt fees below the maximum justified amount where the methodology is fragile and exercise the Council’s clear statutory authority to do so. The draft itself reminds the Council that “the City can adopt any fee lower than the maximum justified amounts.”
7. Adopt a clear, automatic affordable-housing waiver or reduction program funded by the General Fund or a dedicated source, so that all affordable housing units are exempt from having to absorb increases of this magnitude.
4 The City of Goleta has worked too hard to regain housing-element compliance and has too much at stake in state grant programs and in regional infrastructure cost-sharing, to adopt a fee schedule that doubles the cost of building a home in Goleta on a foundation of single-source unit costs and re-cataloged inventories. I urge the Council to take the time required to get this right.
Thank you for your service, and for considering these comments.
Respectfully,
Jason Jaeger
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Board of Directors Jon Standring, President Barry Taugher, Vice President Anthony Tomasello, Secretary Wes McRae, Treasurer Laura Benard Ellen Bildsten AIA Roxanna Bonderson Christopher Guillen Olivia Marr Krista Pleiser P.O. Box 1076 Santa Barbara CA 93102 (805) 403-2752 www.coastalhousingcoalition.org Fed Tax ID # 20-1652456 May 18, 2026 Goleta City Council Via Email: [email protected] Subject: Opposition to Proposed Development Impact Fee Increase (Agenda Item C.2) Dear Mayor and City Council Members: The Coastal Housing Coalition (CHC), formed in 2005, is a non-profit organization and the voice of local employers and employees in support of workforce housing. The CHC advocates for housing available to households earning 120-200% of the area median income (AMI). We believe that the lack of available, affordable housing near jobs is adversely affecting our region’s economy, environment, and civic life, all of which will worsen if we do not address this crucial problem. CHC cautiously opposes the City’s proposed Development Impact Fee (DIF) Program Update (Draft Update) at this time because the proposed fee increases will unreasonably increase the cost of new housing development. The Draft Update’s dramatic increase in DIFs will increase the cost of housing production, render infeasible new housing projects, and worsen housing affordability within the City of Goleta. Prior to approving the Draft Update, CHC respectfully requests that the City Council direct staff to prepare an economic feasibility analysis of residential development under the proposed DIFs so the Council can make an informed decision about the housing production and affordability tradeoffs. CHC also wants to highlight the following key issues with the Draft Update: 1. The City’s current residential DIFs are the highest of all the jurisdictions in the County and the Draft Update would further increase this disparity. The proposed total maximums DIFs are $89,431 for a single-family home and $56,132 for an apartment or condominium. Based on standard multifamily development economics, each $10,000 in additional per-unit costs typically requires roughly $60–$100 per month in additional rent to meet financing and return requirements. So, the proposed $24,358 increase in per-unit multifamily DIFs is expected to increase rents by approximately $145-$243 per month, imposing significant financial burdens on renters in new developments. Moreover, if a new multifamily development project cannot obtain these higher rents, it will not be built. 2. Construction costs, interest rates, insurance costs, and financing challenges are already straining the feasibility of residential development projects, and the proposed DIFs only add to the strain. The Draft Update contains no meaningful
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analysis of development feasibility or housing development economics under the proposed DIFs, does not it contain any analysis of whether the proposed fee levels affect housing production, affordability, or project viability. Absent this information, the Council cannot make an informed decision about whether these fees are appropriately tailored to meet the City’s policy goals. Although the Draft Update claims that it does not seek to use DIFs to fund existing deficiencies, the Draft Update relies on replacement cost of full asset to estimate certain DIFs, which indirectly incorporates past deficits of the City’s expensive public infrastructure. The Draft Update also charges new development for regional services and infrastructure that should be distributed among all property owners within the City or regionally funded. In sum, the Draft Update likely imposes a disproportionate burden on new development to fund maintenance and improvement projects that are not reasonably tethered to the impacts associated with the development. 3. DIFs only are effective if new development happens. Excessive fees render new development infeasible, and the City will be unable to meet its regional housing needs assessment goals, especially for below market rate housing development since these projects are more financially vulnerable. The City must avoid adopting excessive DIFs that prevent the anticipated growth from ever happening. Thank you for your consideration of these comments. CHC respectfully urges the City Council to ensure that its DIFs do not impose constraints on new housing development and align with its 2023-2031 Housing Element. Analyzing how the City’s proposed DIF increase will impact housing production is critical for the Council and public to understand and evaluate these fees, and the desirability and need for the underlying construction projects. CHC looks forward to continue working with the City on policies that support housing development. Sincerely, Craig Minus Executive Director
May 13, 2026
Mayor Paula Perotte and Members of the City Council City of Goleta 130 Cremona Drive, Suite B Goleta, CA 93117 and via email
RE: Opposition to Proposed 2026 Development Impact Fee Program Update — Request for Continuance, Independent Peer Review, and Stakeholder Engagement
Dear Mayor Perotte and Members of the City Council,
The Home Builders Association of the Central Coast (HBACC) respectfully submits this letter in strong opposition to the proposed 2026 Development Impact Fee (DIF) Program Update and formally requests that the City Council continue this item, commission an independent peer review, and convene a collaborative process with the builder and housing community before any adoption. After careful review of the DIF Update Report (April 2026), the Traffic Needs Analysis (Appendix A, DKS Associates, April 9, 2026), and the Transportation Improvement Project Cost Estimates (Appendix B), HBACC has identified serious concerns about the program's proportionality, legal compliance, internal consistency, and impact on the City's ability to meet its housing goals.
I. The Proposed Fees Nearly Double What CPI Alone Would Justify The City last adopted its impact fee nexus study in 2019 (Ordinance 19-04). Since that time, the City has appropriately applied annual inflation adjustments to the fee schedule. As a direct result, the current FY 2025-26 fees for a single family detached home total $45,471 — virtually identical to what a straight CPI adjustment would yield. Based on U.S. Bureau of Labor Statistics CPI-U data, the cumulative increase from the 2019 annual average (255.66) to April 2026 (333.02) is 30.3%, which applied to the 2019 adopted fee schedule produces a CPI- justified total of $45,247. The $224 difference between that figure and the City's current fee confirms that the annual adjustment mechanism has been working accurately.
The proposed maximum justified fees, however, would set a single family detached home fee of $89,431 — an increase of 97 percent over the current fee and nearly double what CPI- based inflation would justify. The table below illustrates this comparison:
Fee Category 2019 Adopted CPI-Adjusted
(+30.3%)
Current FY25-
26 Max Justified
Parks & Recreation $11,900 $15,509 $15,928 $32,895
Transportation $12,077 $15,740 $15,165 $20,466
Bicycle & Pedestrian $3,092 $4,029 $4,142 $13,812
Storm Drain $3,596 $4,686 $4,817 $10,845
Public Administration $3,086 $4,022 $4,132 $10,540
Library $959 $1,250 $1,287 $873
TOTAL (SFD) $34,710 $45,247 $45,471 $89,431
The $44,184 gap above the CPI-justified amount is not the result of catching up on lost ground — the City's annual adjustments have already done that. Instead, it is driven entirely by methodology changes: revised facility inventories, new cost assumptions, and the inclusion of questionable projects such as the US 101 Bike/Ped Overcrossing. These methodology choices are precisely what warrant independent scrutiny before adoption.
II. The Program Likely Fails the Nexus and Proportionality Standards Required by Sheetz v. County of El Dorado (2024)
In Sheetz v. County of El Dorado, 601 U.S. 267 (2024), the United States Supreme Court held unanimously that the Takings Clause's essential nexus and rough proportionality requirements established in Nollan v. California Coastal Commission and Dolan v. City of Tigard apply to legislatively imposed permit conditions — including standardized fee schedules like this DIF program — and not only to individualized adjudicative conditions. This is a material change in the constitutional landscape since the City's 2019 nexus study.
Under Sheetz, each fee category must demonstrate (1) an essential nexus between the fee and the government's stated interest, and (2) rough proportionality between the fee amount and the projected impact of the specific development paying it. Several fee categories in the proposed program fail this standard:
• Bicycle & Pedestrian (233% increase): The fee triples based on an updated inventory showing higher levels of existing service — but no proportionality analysis demonstrates that new development's marginal impact on bicycle and pedestrian infrastructure justifies a fee that increases from $4,142 to $13,812 per home. The City must disclose the full inventory methodology and demonstrate that each dollar of fee is proportional to the infrastructure demand generated by that specific development. • Public Administration (155% increase): The facility inventory includes the Boys & Girls Club buildings (~29,000 sq. ft.), the Stow House/Rancho La Patera museum complex (~18,000 sq. ft.), and the Train Depot at a replacement cost of $2,444 per square foot — nearly five times the rate used for civic buildings. The nexus between new residential development and the expansion of museum, historic preservation, and nonprofit youth facilities is not established in the record. • Parks (107% increase): The land acquisition cost of $2,695,100 per acre is pegged to a single 2018 transaction (the Goleta Train Depot acquisition) that the report itself acknowledges is significantly below the City's recent right-of-way costs. Using a stale,
single-sale benchmark — rather than a current market analysis — does not meet the rough proportionality standard under Sheetz.
III. Appendix A Reveals a $6.9 Million Internal Inconsistency in the Transportation Fee A detailed comparison of the Traffic Needs Analysis (Appendix A, Table 12) and the main DIF Update Report (Table 6.1) reveals a material numerical discrepancy in the calculation of Goleta's fair share responsibility for Project R-05 (US 101 Bike/Ped Overcrossing):
• Appendix A, Table 12 calculates Goleta's fair share of the transportation half of R-05 at $39,252,000, based on an 85% Goleta trip share applied to the $46,150,000 transportation portion.
• Main DIF Report, Table 6.1 assigns the full $46,150,000 (100% of the transportation half) as the Goleta growth share, without applying the jurisdiction-specific trip share calculated in Appendix A.
• The resulting discrepancy is $6,898,000 — and this figure exactly accounts for the difference between Appendix A's total Goleta fair share of $185,014,000 and the main report's $191,912,000. The fee schedule is built on the higher, internally inconsistent figure.
This is not a rounding issue. It is a direct inconsistency between the technical analysis prepared by the City's traffic consultant (DKS) and the fee calculation prepared by the City's economic consultant. The fee schedule as proposed overcharges new development by approximately $6.9 million in transportation fee revenue relative to what the City's own technical analysis supports.
This must be reconciled before adoption.
IV. Project R-05 Lacks a Defensible Nexus to Vehicle Transportation Demand Appendix A explicitly characterizes Project R-05 — the US 101 Bike/Ped Overcrossing — as "strictly a pedestrian/bicycle facility improvement." The justification for including 50% of its $92.3 million cost in the vehicle transportation fee rests entirely on the claim that it will create mode shifts sufficient to keep the Hollister/Storke intersection at LOS D under 2050 conditions.
This is a highly attenuated nexus. Charging vehicle-trip-based transportation fees to fund a bicycle bridge based on a projected mode shift is not the type of "essential nexus" the Mitigation Fee Act and Sheetz require. No peer-reviewed ridership model, mode shift elasticity study, or sensitivity analysis is presented to validate that the assumed bicycle diversion will actually materialize at the scale needed to relieve LOS deficiency at Hollister/Storke. The $46.15 million allocated to the transportation fee from this single project alone drives more than 24% of total transportation fee costs attributed to Goleta.
V. Project R-14 Relies on a 17-Year-Old Technical Study Project R-14 (South Fairview Avenue Widening, $6.2 million) is identified in Appendix A with the footnote: "Deficiency and improvement identified in South Fairview Technical Memorandum, Dowling Associates, 7/23/2009, in Appendix A.8." This deficiency determination is based on a study conducted in 2009 — 17 years before the fee adoption now proposed. Land use conditions, traffic patterns, and development assumptions along South Fairview Avenue have changed materially since 2009. Including this project in a 2026 fee program without re-analyzing current conditions is inconsistent with the Mitigation Fee Act's requirement that fees be based on current and reasonably anticipated future impacts.
VI. The Worker Weighting Factor Disproportionately Burdens Residential Development The nexus analysis weights workers at 0.20 relative to residents in calculating the service population for public administration, library, parks, and bicycle/pedestrian fees. The report acknowledges that time-based analysis (40 hours/week of work versus 128 hours/week of residential occupancy) would support a factor closer to 0.30. The report then selects 0.20 without adequate justification, stating only that "master planning for these facilities typically focuses more on residential demand." This policy choice has a direct and material effect: by reducing the worker weighting, the analysis shifts a greater share of fee burden onto residential development and away from nonresidential. HBACC requests that the City provide a full sensitivity analysis demonstrating the fee impact of both the 0.20 and 0.30 weighting factors, and that any final selection be supported by site-specific user survey data rather than a generalized assumption.
VII. No Economic Feasibility Analysis Has Been Conducted The proposed fee update includes no economic feasibility or developer pro forma analysis to determine whether the proposed fee levels are absorbable within the current housing market.
Given that the aggregate fee for a single family detached home would nearly double — from $45,471 to $89,431 — and that this represents an additional $43,960 per home on top of already constrained construction economics in Santa Barbara County, the absence of feasibility analysis is a significant omission.
The City's RHNA obligation requires production of 3,329 new dwelling units through buildout.
Fee levels that price new housing production out of feasibility do not advance this goal; they undermine it. AB 602 and the Mitigation Fee Act both contemplate that fee programs should be calibrated to allow development to proceed. An independent residual land value or developer feasibility analysis should be a prerequisite to adoption of any fee schedule of this magnitude.
VIII. Formal Requests
Based on the foregoing, HBACC respectfully makes the following formal requests:
• Continue this item and do not adopt the 2026 DIF Program Update at this time. • Commission an independent peer review of (a) the transportation fair share analysis, including reconciliation of the $6.9 million discrepancy between Appendix A and the main report; (b) the R-05 mode shift analysis and its nexus to vehicle transportation LOS; (c) the bike/ped and public admin facility inventory methodologies; and (d) the land cost assumptions underpinning the parks fee.
• Conduct an economic feasibility analysis to assess whether proposed fee levels are compatible with housing production in Goleta's current market, and publish the analysis for public review.
• Convene a stakeholder working group that includes HBA members, affordable housing advocates, and economic experts prior to any revised fee schedule being brought back to Council. Housing production is a public interest, and the builder community must have a meaningful seat at the table when fees of this magnitude are under consideration.
• Re-analyze R-14 (South Fairview Avenue Widening) using current traffic data rather than the 2009 Dowling Associates study, and re-evaluate whether it continues to meet the nexus standard under current conditions.
• Provide a sensitivity analysis on the worker weighting factor (0.20 vs. 0.30) and publish the results alongside any revised fee schedule.
Conclusion
HBACC does not oppose the City's right to fund necessary infrastructure through impact fees, and we acknowledge that the library fee decrease reflects sound methodology. However, the proposed program's aggregate doubling of fees — built on methodology changes that lack adequate transparency, internal inconsistencies between the appendices and the main report, reliance on a stale technical study, inclusion of a bicycle bridge in a vehicle transportation fee, and the absence of any feasibility analysis — does not meet the standard of a nexus study that is legally defensible under the Mitigation Fee Act or the constitutional requirements now clarified by Sheetz v. County of El Dorado. We urge the Council to take the time necessary to get this right.
HBACC stands ready to participate constructively in a revised process and looks forward to working with City staff and the Council toward a fee program that is both legally sound and supportive of Goleta's housing goals.
Respectfully submitted,
Home Builders Association of the Central Coast
cc: City Attorney Public Works Director, Nina Buelna Community Development Director