22645 Grand Street | Hayward, CA 94541 | Tel: 510-582-146 | edenhousing.org Broker License No. 872400
June 15, 2026
Mayor Kate Colin and Members of the San Rafael City Council City of San Rafael 1400 Fifth Avenue
San Rafael, CA 94901
RE: Public Comment on item 1(A): Update to Park Impact Fee Programs and Nexus Study
Dear Mayor Colin and Council Members:
On behalf of Eden Housing, I am writing in support of the staff recommendation to reduce park impact fees for affordable housing developments. We appreciate the City's recognition that affordable housing projects operate under fundamentally different financial constraints than market-rate developments and that impact fee policies should reflect those realities.
Eden Housing is a nonprofit affordable housing developer with more than 57 years of experience creating and preserving affordable homes throughout California. In Marin County, we have been proud partners in addressing the region's housing needs, including the recent completion of Vivalon Healthy Aging Campus and Casa Canal – both in the City of San Rafael. These developments provide critical housing opportunities for seniors, families, and formerly homeless households while advancing community goals related to equity, stability, and economic inclusion.
We support the proposed reduction for 100% affordable housing because it acknowledges a simple reality: every dollar collected in fees is a dollar that cannot be invested in affordable housing. Affordable housing projects are financed through a complex combination of public subsidies, tax credits, and restricted rents. When costs increase, affordable housing developers cannot simply raise rents to absorb those costs.
Instead, higher fees typically result in fewer affordable units, additional requests for scarce public subsidy, or projects that become financially infeasible altogether. As well, these fee waivers can also help developments be more competitive for critical State funding sources, which prioritize applications with local investments.
While we support the proposed reduction, we respectfully urge the Council to go one step further and establish a clear, predictable path toward a full waiver or alternative financing mechanism for 100% affordable housing developments.
Affordable housing providers need certainty early in the development process. If the City determines that park impact fees should continue to apply in some form, we encourage the Council to direct staff to return with a specific policy that allows these fees to be satisfied through a residual receipts loan or similar long-term deferred payment mechanism. Such an approach would recognize the public benefit created by affordable housing while preserving the City's ability to recover funds over time if and when project cash flow allows.
A clear policy framework would provide several important benefits:
• It would improve the financial feasibility of affordable housing developments in San Rafael.
• It would reduce the need for additional local subsidy contributions. • It would create transparency and consistency for nonprofit developers and financing partners.
• It would align the City's fee policies with its adopted housing goals and commitment to expanding affordable housing opportunities.
San Rafael has demonstrated strong leadership on housing production and affordability. The proposed fee reduction is an important step in the right direction. We respectfully ask the Council to direct staff to return with a clear recommendation establishing either a full waiver for 100% affordable housing developments or a formal mechanism that allows payment of these fees through a residual receipts loan or other deferred financing structure.
Thank you for your consideration and for your continued commitment to creating housing opportunities for San Rafael residents of all incomes.
Sincerely,
Andrea Osgood
Chief of Real Estate Development and Executive Vice President Eden Housing
[email protected]