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®
June 17, 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
SBAOR recognizes the importance of ensuring that new development contributes its fair share toward the infrastructure and public facilities necessary to serve a growing community. We appreciate the City's efforts to update its Development Impact Fee Program, comply with the requirements of AB 602, and maintain a legally defensible nexus study.
The City of Goleta has made a significant commitment to addressing California's housing shortage through its certified Housing Element and its Regional Housing Needs Allocation (RHNA). The City has recognized that increasing housing opportunities, expanding housing choice, and encouraging the development of housing for residents across all income levels are essential to maintaining a healthy and vibrant community. Those commitments should serve as the lens through which the proposed Development Impact Fee update is evaluated.
While the nexus study identifies the maximum fee the City may legally impose, it does not answer the equally important policy question of what fee level best advances Goleta's housing, economic, and community goals. The City Council retains the discretion to adopt fees below the maximum supported by the nexus study, and we respectfully encourage the Council to exercise that discretion.
The question before the City is not whether infrastructure should be funded, it absolutely should. The question is how to fund infrastructure in a manner that does not unintentionally reduce the very housing production the City has committed to encouraging.
The proposed fee increases represent a substantial increase in the upfront cost of developing housing in Goleta.
These increases come at a time when housing projects are already facing unprecedented financial challenges, including rising construction costs, elevated interest rates, higher insurance premiums, labor shortages, utility connection fees, inclusionary housing requirements, permit fees, and lengthy entitlement processes. Development
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®
Impact Fees are only one component of an already significant cumulative cost burden that ultimately determines whether a housing project moves forward or remains on the drawing board.
Goleta needs all types of housing.
Meeting the City's housing needs is not simply about producing more units, it is about producing a diverse housing inventory. Condominiums, townhomes, apartments, mixed-use developments, smaller single-family homes, workforce housing, family housing, accessory dwelling units, and ownership opportunities all play an essential role in creating a healthy and resilient housing market.
Housing diversity does not occur by accident, it occurs when projects of different sizes, product types, and price points remain financially feasible. As regulatory costs continue to increase, the housing market naturally shifts toward larger and higher-priced developments that can better absorb those costs. The result is not simply fewer housing units, it is fewer housing choices.
Higher Development Impact Fees make it increasingly difficult for smaller, more attainable housing types to be financially feasible. This disproportionately impacts first-time homebuyers, middle-income families, seniors, young professionals, and local workers seeking housing within the community. It also affects smaller local builders and infill developers who frequently deliver the missing-middle housing that cities throughout California are working to encourage.
The proposed fee increases should also be evaluated for consistency with the City's adopted Housing Element.
Policies that substantially increase the cost of residential development risk making it more difficult to achieve the City's own housing objectives by reducing project feasibility and limiting the production of workforce housing, ownership opportunities, and diverse housing types.
Recent state actions reinforce the importance of reducing unnecessary barriers to housing production. While AB 602 strengthened the methodology for preparing nexus studies, it does not require local governments to adopt the maximum legally supportable fee. More recently, Governor Newsom signed AB 179 as part of California's broader effort to reduce the cost of producing housing and accelerate housing development. Together with other recent housing reforms, the State's policy direction is increasingly clear: infrastructure must be funded, but local policies should also encourage the timely construction of housing across all income levels.
Independent research supports this balanced approach. RAND Corporation's recent report, Understanding How Impact Fees Shape Housing Development Feasibility, evaluated how residential development impact fees affect both housing production and local government finances. Using parcel-level financial feasibility modeling, RAND found that reducing residential impact fees by 25 percent made hundreds of additional housing projects financially feasible. Perhaps most importantly, the study concluded that the initial reduction in fee revenue could be offset within approximately four to seven years through increased property tax revenue, sales tax revenue, and broader economic activity generated by the additional housing that was built. While the study evaluated multiple California jurisdictions, its central finding is directly applicable here: carefully calibrated residential impact fees can improve housing feasibility while strengthening, rather than weakening, a community's long-term fiscal health.
In other words, maximizing impact fee revenue does not necessarily maximize public benefit.
Every housing project that is delayed, redesigned, or abandoned represents more than the loss of housing units. It also represents lost construction jobs, reduced purchases from local businesses, delayed property tax revenue, reduced sales tax revenue, and fewer opportunities for residents to live and work within the community. As the RAND research demonstrates, a balanced fee structure can produce greater long-term economic benefits than
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®
maximizing upfront fee collections. The City's fee policy should account for both the immediate fiscal benefits of impact fees and the long-term fiscal and economic benefits generated by successful housing production.
Recent legal developments likewise reinforce the importance of carefully calibrating development impact fees. In Sheetz v. County of El Dorado, the United States Supreme Court reaffirmed that legislatively adopted development exactions remain subject to constitutional scrutiny and must maintain an essential nexus and rough proportionality to the impacts of development. While we recognize that the City's updated nexus study is intended to satisfy these legal requirements, the decision serves as an important reminder that impact fees should remain carefully tailored, equitable, and proportionate.
For these reasons, SBAOR respectfully recommends that the City Council:
• Adopt residential Development Impact Fees below the maximum levels identified in the nexus study. • Evaluate a 25 percent reduction to the proposed residential fee schedule, consistent with the scenario modeled by RAND, to better balance infrastructure funding with long-term housing production and fiscal sustainability.
• Phase in any approved fee increases over several years to minimize impacts on projects currently in the development pipeline.
• Evaluate reduced fee structures for smaller homes, condominiums, townhomes, accessory dwelling units, and other housing types that expand ownership and workforce housing opportunities. • Continue exploring incentives for deed-restricted affordable housing and projects that help the City meet its Regional Housing Needs Allocation (RHNA).
• Consider the cumulative impact of all local development costs, not solely Development Impact Fees, when evaluating project feasibility and housing production.
Goleta has worked diligently to position itself as a leader in thoughtful planning and housing policy. The City now has an opportunity to ensure that its Development Impact Fee Program advances, not unintentionally undermines, those efforts. We respectfully urge the City Council to adopt a balanced fee structure that funds needed infrastructure while preserving the financial feasibility necessary to produce the broad range of housing envisioned in the City's Housing Element.
Thank you for your consideration of our comments and for your continued commitment to balancing fiscal responsibility with housing opportunity.
Sincerely,
Jennifer Berger
SBAOR President
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805.963.7000 main
1020 State Street
Santa Barbara, California 93101
Amy Steinfeld
Attorney At Law
805.882.1409 direct
[email protected]
www.bhfs.com
Brownstein Hyatt Farber Schreck, LLP
July 20, 2026
RE: Opposition to Proposed Increase in Development Impact Fees, Agenda Item C.3 26-275
Dear Mayor Perotte and Honorable Councilmembers,
On behalf of my clients and as a board member on the Santa Barbara South Coast Chamber of Commerce, I’m submitting submit this letter in opposition to the proposed Development Impact Fee (DIF) Program Update (Draft Update) scheduled for the July 21, 2026, City Council hearing.
The extraordinary increase in all DIFs is unreasonable, inconsistent with State law, and detrimental to housing feasibility within the City of Goleta.
1. Fees Massively Unproportional to Surrounding Cities Using a 1,500 square foot (sq ft) single-family home (around the average size of a single family home in Goleta), a 1,000 sq ft multi-family home, and a 1,000 sq ft commercial building as development models, we have calculated the approximate fees that a developer would incur if they were to develop either a residential or commercial project in Santa Barbara (County and City), Santa Maria, Carpinteria, Lompoc, and Goleta (current and as proposed). (See Table 1.)
Table 1. Estimated Fee Cost for Residential or Commercial Developments 1 Jurisdiction Approx. Fees (1,500 sq
ft Single Family Home)
Approx. Fees (1,000 sq
ft Multi Family Home)
Approx. Fees
(1,000 sq ft
Commercial)
Santa Barbara County2 $7,428 $5,1303 $3,8684
City of Santa Barbara5 $21,400 $15,500 $25,000
City of Santa Maria6 $31,015 $28,212 $45,207
City of Carpinteria7 $26,070 $17,380 $12,450
City of Lompoc8 $6,220 $7,590 $1,620
City of Goleta (current)9 $45,471 $31,774 $96,194
City of Goleta (draft
maximum justified)10 $88,690 $55,717 $130,792
a. Single Family Home Proportionality
Goleta's existing Development Impact Fees (DIFs) are already substantially higher than those imposed by other jurisdictions within Santa Barbara County, and the proposed increases would further widen that disparity.
Even excluding the comparatively lower fees charged by the City of Lompoc and the County of Santa Barbara, Goleta's current impact fees are, on average, 126% higher than those of neighboring cities. Under the Draft Update, if the City adopts the maximum justified fee levels, July 20, 2026
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Goleta's DIFs would increase to approximately 262% higher than those of surrounding jurisdictions.
Differences in home values do not explain or justify this disparity. While average home prices in Lompoc and Santa Maria are lower than the countywide average, home prices in Santa Barbara and Carpinteria are significantly higher. Nevertheless, both Santa Barbara and Carpinteria maintain development impact fees that are generally consistent with those charged by neighboring jurisdictions. This comparison demonstrates that the infrastructure and service impacts associated with new development, and the corresponding mitigation fees required to address those impacts, remain relatively consistent throughout the county, regardless of variations in housing prices or other local economic factors.
The Draft Update therefore raises serious questions as to whether the proposed fee levels are reasonably related to the impacts attributable to new development and whether they place Goleta at a competitive disadvantage relative to other local jurisdictions. b. Commercial Development Proportionality
Commercial impact fees vary significantly depending on a city’s desire to attract commercial development. Goleta’s current and proposed DIFs suggest the City intends to strongly discourage commercial development. The current fee is more than twice the cost of single family home impact fees. In addition, Goleta’s proposed increase in commercial DIFs creates an even greater outlier when comparing to neighboring jurisdictions. The significant leap from approximately $96,194 to $130,792 shows a 36% increase in overall fees. It also means Goleta’s fees will be 158% higher than the current highest commercial DIFs nearby (Santa Maria).
This proposal will disincentivize new commercial growth in the City, which is at odds with the City’s General Plan. For example, the General Plan seeks to “provide lands in locations that are suitable, functional, attractive, and convenient for an appropriate mix and scale of residential- and business-serving commercial uses.” (General Plan, Land Use Element, p. 2-12.) However, the increase in commercial fees, meaning increase in upfront capital costs (without corresponding increases in revenue potential), creates a likely outcome where certain projects become infeasible, investment capital shifts to neighboring jurisdictions with lower fees, and job-producing development is delayed or cancelled.
The Draft Update discourages commercial development rather than finding an appropriate balance between encouraging development and generating fee revenue.
2. Flaws in the Draft DIF and Updated Study
a. High Existing Facility Standards Drive Fees Beyond Regional Norms
The Draft Update attributes significant fee increases to revised facility inventories that purportedly show the City provides a higher level of service than previously assumed. However, Goleta's elevated service standards are largely the result of extensive parks, open space, and trail systems that were acquired and established over decades. Requiring new residents and new development to fund the maintenance of service levels driven by these historic public investments unfairly inflates development impact fees. While reasonable contributions toward maintenance and modest capital improvements may be appropriate, the City's existing abundance of recreational and open space assets does not justify the substantial fee increases proposed in the Draft Update.
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Moreover, the study places undue responsibility on new development by assuming that increased population will proportionally increase demand for facilities that are already widely used and enjoyed by residents and visitors from throughout the region. Goleta is exceptionally rich in park and open space resources compared to neighboring jurisdictions, and the City has not demonstrated that substantial additional land acquisition is necessary to maintain existing service standards at a reasonable level. Accordingly, we respectfully request that the Council direct staff to revisit the Nexus Study and reevaluate the assumptions underlying the parks and open space fee calculations to ensure that the proposed fees remain reasonably related to the impacts attributable to new development.
b. New Development Bears 40% of Transportation Costs
The transportation program as outlined in the Draft Update includes 32 projects totaling $485.6 million, with $191.9 million charged to new development. This disproportionately assigns 40% of the expenses for the regional transportation program to Goleta’s limited new developments. These projects include major U.S.-101 improvements and other regional projects which serve the entire region and should not be funded on the backs of new development.
i. Mitigation Fee Act (Gov. Code § 66000 et seq.)
Under the Mitigation Fee Act, impact fees cannot be used to correct existing deficiencies, rather they must reflect the proportionate cost of the public facilities “attributable to the development on which the fee is imposed.” (Gov. Code, §§ 66001(b), (g).) However, improvements in the transportation list address current operational issues such as safety concerns or congestion, not only growth-related demand. By law, new development cannot be charged to fix today’s problems. (See Building Industry Assn. v. City of San Ramon (2016) 4 Cal.App.5th 62, 89.)
Nevertheless, of the 32 transportation capital improvement projects identified in the Draft Update, 15 involve correction of existing deficiencies. Although the Draft Update purports to exclude the cost of correcting existing deficiencies from the fee calculation, several projects allocate significant costs to new development despite being triggered by present-day failures. For example, Project - 08 (Patterson Avenue at US 101 SB Ramp) is identified as an existing AM/PM deficiency operating at LOS E/F, yet 25% of its $44.45 million cost—approximately $10.98 million—is allocated to total growth. (Draft Update, Part 2, p. 33.)
The Mitigation Fee Act explicitly prohibits using fees to correct existing deficiencies. The City must reassess whether the proposed fees appropriately separate existing deficiencies from new demand.
c. Developers Charged for Regional Projects
The Draft Update does not comply with the California and US Constitutions. Under both, a DIF imposed as a condition of project approval—whether imposed ad hoc or legislatively—must satisfy the heightened scrutiny test of Nollan v. California Coastal Commn. (1987) 483 U.S. 825 and Dolan v. City of Tigard (1994) 512 U.S. 374. (Sheetz v. County of El Dorado (2024) 601 U.S. 267, 268.) Under this test, the burden is on the public agency to make an individualized determination that there is an (1) essential nexus and (2) rough proportionality between the government’s demand and the proposed land use. As described in Nollan, an “essential nexus” is established when the condition imposed directly advances the same purpose that would justify denying the permit. (Nollan, supra, 483 U.S. at 836-37.) As described in Dolan, “rough proportionality” is July 20, 2026
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established when the local agency makes an individualized determination that the required dedication is related both in nature and extent to the impact of the proposed development. (Dolan , supra, 512 U.S. at 391.)
As noted above, the Draft Update charges developers for services and infrastructure utilized at a regional, rather than local, level. For example, the extremely high transportation fees proposed in the Draft Update could be mitigated by properly considering non-residential and/or regional usage of roadways such as the US 101. State (or County) funds can assist in supporting the cost of construction, remodel, or upkeep for regional services. There is no justification—i.e., no essential nexus—for charging developers and homeowners an exorbitant fee to support said projects.
Additionally, and as also noted above, charging new development for improvements necessitated by existing traffic failures breaks the essential nexus required by Nollan.
Moreover, new development will constitute only 21% of the total service population at buildout. (Draft Update, p. 40.) Yet the proposed fee increases are staggering and bear no evidence proportional relationship to that modest growth increment:
• The Bicycle & Pedestrian Facilities Fee increases by 222-233% across all land use categories;
• The Public Administration Fee increases by 147-155%;
• The Storm Drain Fee for industrial uses increases by 284%; • The Parks & Recreation Fee increases by 75-107%; and
• Total combined fees for a single-family detached dwelling unit nearly double—a 95% increase.
(Draft Update, pp. 5-6.) Dolan requires that fee amounts be “roughly proportional” to the actual impact of new development. Increases of this magnitude—driven primarily by increased construction costs, higher land values, and revised asset inventories rather than by any demonstrated increase in the impact of new development—fail to satisfy this test. (Draft Update, pp. 32-33.) Rising construction costs are a macroeconomic phenomenon borne by the entire community, not an impact caused by new development. Shifting these generalized cost increases entirely onto new development through DIFs violates the proportionality requirement of Dolan. d. DIF Charges Maximum Possible, Not What is Reasonable
The nexus study uses the maximum possible fee methodology, which uses the entire existing inventory of assets per capita to calculate fees. Goleta’s DIFs are high not because development is unusually burdensome, but because Goleta already owns an unusually expensive and extensive public infrastructure system. The City is choosing to make new housing and commercial development buy into that system at full replacement value.
This is a policy choice, not a legal mandate, and it is a choice that directly drives fees above regional norms and harms California’s efforts to ease the housing crisis by rendering new projects cost-prohibitive.
3. Development Becomes Economically Infeasible
If adopted, this Draft Update will severely restrict new housing, especially affordable units. Nearby jurisdictions are already working to restrict overly burdensome fee structures. When DIFs exceed $60,000 per home (as they do under this proposal), small infill projects often become financially July 20, 2026
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impossible. This undermines state housing goals and local regional housing needs assessment (RHNA) obligations by suppressing feasible housing production.
The City of Lompoc serves as an impressive example of how a City Council can take action to ease fees. After concluding that its Nexus Report overstated impacts and deterred development, the Lompoc City Council voted to adopt Ordinance No 1726(25), which reduced total DIFs for single‑family homes from approximately $47,000 to around $3,100.
During Lompoc’s deliberations on April 15, 2025, Councilmember Ball cautioned:
“We could pass this and see no development for another ten years… in a vacuum these fees are fair… but my concern is: are we just shooting ourselves in the foot where most developers wouldn’t even look at us because maybe we’re a little outside of what’s reasonable?”
11 Councilmember Bridge reinforced this point by recounting the case of a homeowner who was charged $70,000 in impact fees just to refurbish a garage. Councilmember Bridge then proposed a significant reduction, rather than an increase, in impact fees.12 City officials later confirmed that Councilmember Bridge’s proposal would not only be possible, but would not cause city needs to go unaddressed as funding can be gathered through capital improvement plans, grants, or state and federal aid. The Lompoc ordinance then went even further, introducing an appeal provision that allows developers to contest any fees that they believe are not applicable to their projects.
Lompoc has set an incredible example for how a city council can support its city, especially amidst the housing crisis that has severely impacted California residents.
Goleta currently risks making the same mistake that Lompoc avoided. Excessive fees do not generate revenue—they eliminate the projects that would have paid them. Rather than shifting disproportionate costs onto new residents or developers, Goleta’s city government should continue to use the resources it has at its disposal, and seek state support for its public infrastructure.
Consistent with AB 602, we request a prototype feasibility analysis (SFD & MF) using the current Budget/CIP so City Council and the public can see whether the update would effectively chill feasible housing.
Conclusion
We strongly urge the City Council to reject the proposed Draft Update and direct staff to revise the Nexus Study so that fees are accurate, proportional, legally defensible, and economically viable. A balanced approach that relies on diversified funding—not solely on new development—will better serve Goleta’s long‑term housing, affordability, and infrastructure goals.
Sincerely,
Amy Steinfeld
1 These fee estimates are not exact and are calculated assuming the projects reflect “standard” development paths / no extraordinary site conditions. As a result, most fees listed are a conservative estimate, but may be an underestimate rather than an overestimate. 2 https://content.civicplus.com/api/assets/5ecc70aa-7d9f-4a01-b722-16f9c741c9e8 July 20, 2026
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3 Assumes an apartment development. Because the particular transportation impact fee for apartments is not identified in this fee schedule, we assume for purposes of analysis adoption of the highest listed transportation impact fee.
4 Assumes retail commercial, and the highest transportation impact fee. 5 https://santabarbaraca.gov/sites/default/files/2025-
06/Adopted%20FY2026%20Combined%20Fee%20Schedule.pdf
6 https://www.cityofsantamaria.org/home/showpublisheddocument/32706/638874994145770000 7 https://carpinteriaca.gov/wp-content/uploads/2025/03/Development-Impact-Fees_Schedule.pdf 8 https://www.cityoflompoc.com/home/showpublisheddocument/45935/639002629255170000 9 https://www.cityofgoleta.org/home/showpublisheddocument/32103/638906094747270000 10https://goleta.legistar.com/View.ashx?M=F&ID=15695130&GUID=09172609-1032-4733-A778- 521401D9FD70
11 Lompoc City Council, Meeting on April 15, 2025. Agenda Item No.10, Resolution No. 6747(25).
Timestamp 1:55:41. https://youtu.be/Q0PTZ8UtviM?si=8pGYYW8oaLXXKFIY&t=6941 12 Lompoc City Council, Meeting on April 15, 2025
https://youtu.be/Q0PTZ8UtviM?si=dyUUsV0tHThwXh9R&t=7132
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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 July 20, 2026 Goleta City Council Via Email: [email protected] Subject: Opposition to Proposed Development Impact Fee Increase (Agenda Item C.3) 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