Loading...
HomeMy WebLinkAboutRES 4299 CITY �F RENT�N, INASHINGT�N RES�LUTI�N N�. 4299 A RES�LUT��N �F THE CITY �F RENT�N, INASHINGT�N, AD�PTING BY REFERENCE THE "RATE STUDY F�R IMPACT FEES F�R TRANSP�RTAT��N�" DATED JULY 5, Z�1C. INHEREAS, in the Re�ised Code of 1Nashington �"RCW"� 82.�2.D5��1�, the Legislature has stated that its intent is to a�low cities to require new growth and de�elopment with�n the�r boundaries to pay a proportionate share of the cost of system impro�ements to ser�e such new de�elopment acti�ity through the assessment of impact fees; and INHEREAS, the City adopted impact fees for transportat�on, par�s, and fire protection in zo11 and those fees were based on extensi�e research documenting the procedures for measuring the impact of new growth and de�e�opment on public facilities. That research was reflected in the "Rate 5tudy for Impact Fees for Transportat�on, Parks and Fire Protection," City of Renton, dated August 2�, zo11, adopted by the City Council by �rdinance No. 5�7� on �ctober S, 2�12; and INHEREAS. the City has again conducted extensi�e research measuring the impact of new growth and de�elopment on transportation public facilities and that research is ref�ected in a new "Rate 5tudy for Impact Fees for Transportat�on," C�ty of Renton dated July 5, 201�; and INHEREAS, the rates charged are I�sted in the 2�17-2018 City of Renton Fee 5chedule; N�IN� THEREF�RE� THE CITY C�UNCIL �F THE CITY �F RENT�N, WASHINGT�N, D�ES �RDAiN A5 F�LL�1N5: SECTI4N I. The abo�e recitals are found to �e true and correct in al1 respects. 1 RES�LUTI�N N�. 4�99 SECTI�N II. The �ity �auncil af the �ity af Rentan hereby adapts by reference as if fu�ly set farth herein the "Rate 5tudy far Impact Fees far Transpartatian," �ity af Rentan dated �uly 5, ��16, as it amends the "Rate Study far Im�act Fees far Transpartatian, Parks and Fire Pratectian," �ity af Rentan, dated August �6, �011, as that study re�ates ta Transpartatian, but reaffirming its ada�tian af the ��11 study as it relates ta Parks and F�re Pratectian. SECTI�N �II. �ap�es af each rate study adapted herein by reference will be at a�l times an file with the �ity �lerk. PASSED BY THE �iTY ��UN�lL this �1st day af Na�ember, ��16. r •'�. �as A. Seth, City �lerk APPR�VED BY THE MAY�R this �1st day af Na�ember, ��16. Denis Law, Mayar Appraved as ta farm : ,�►�������+�r���� .•�`'��� �r � �N ��''►�� �.'`� � ���►illlllllll� �� i�/� � ��� ��fi /�I `i � �� �.��� ��+�i � � � � �. i � � S ! _ � �� _ � - .. � _ _ _ _ Lawrence J. Warren, �ity Attarney = * = _ � = : •� _ � � - , _ i � �r���'� .�'`�� �� : Date af Pubiicatian : 111�51��16 �Summary} '•�,��'a,pA'�����,�„►►�►�`` .���,.= ~ '��i� �RATE� ������``� �'����«i����►►►''�` R Es: 1�1�:1�I1s�1�:s�r � RATE STUDY FOR IMPACT FEES FOR TRANSPORTATION CITY OF RENTON , WASHINGTON � `_'`'�`�� � '� � � � � � � 'r'��y, � ��� � ��� - - . � � iy5, zo � 6 TABLE OF CONTENTS l. INTRODUCTION ...................................................................................................................................................1 2. STATUTORY BASIS AND METHODOLOGY...................................................................................................3 3. TRANSPORTATION IMPACT FEES................................................................................................................11 APPENDIX A - TRIP GENERATION RATES .....................................................................................................28 LIST OF TABLES TABLE 1 : TRANSPORTATION IMPACT FEE RATES .......................................................................................................... 1 TABLE 2: STREET PROJECTS ELIGIBLE FOR IMPACT FEES............................................................................................ 12 TABLE 3: COST OF EXISTING DEFICIENCIES................................................................................................................. 16 TABLE 4: COST OF FUTURE RESERVE CAPACITY......................................................................................................... 19 TABLE S: TOTAL PROJECT COST ELIGIBLE FOR IMPACT FEES .....................................................................................21 TABLE 6: GROWTH PERSON TRIPS �P.M. PEAK HOUR� ON THE STREET NETWORK.......................................................25 TABLE 7: COST PER GROWTH TRIP .............................................................................................................................25 TABLE g: TRANSPORTATION IMPACT FEE RATES PER UNIT OF DEVELOPMENT...........................................................27 TABLE 9: TRIP GENERATION RATES .............................................................................................................................30 Rate Study for Impact Fees for Transportation • City of Renton 1 . I NTRODUCTION The purpose of this study is to establish the rates for impact fees in the City of Renton, Washington for three types of public facilities authorized by RCW � 82.02.050 - 090. In this study the term "transportation " is used as a shorthand expression for " public streets and roads" that are authorized for impact fees in RCW 82.02.090 (7) . Summary of Impact Fee Rates Impact fee rates for new development are based on, and vary according to the type of land use. The following table summarizes the impact fee rates for several frequently used land use categories. Rates for other non-residential development are presented in Table 8 of this study. Ta ble 1 : Tra nsportation I m pact Fee Rates �� ) �2) �3) Type of Development Unit Transportation Single-Family dwelling unit $ 10,861 .69 Apartment dwelling unit 6,717. 10 Office sq. ft. 14.58 Retail (shopping) sq. ft. 26.58 Industrial sq. ft. 9.50 Restaurant sq. ft. 60.95 Impact Fees vs. Other Developer Contributions Impact fees are charges paid by new development to pay local governments for the capital cost of public facilities needed to serve new development and the people who occupy or use the new development. Throughout this study, the term "developer" is used as a shorthand expression to describe anyone who is obligated to pay impact fees, including builders, owners or developers. Local governments charge impact fees for several reasons: 1 ) to obtain revenue to pay for some of the cost of new public facilities; 2) to implement a public policy that new development should pay a portion of the cost of facilities that it � Revised Code of Washington (RCW) is the state law of the State of Washington. Henderson, Young & July 5, 2016 Page 1 Company Rate Study for Impact Fees for Transportation • City of Renton requires, and that existing development should not pay all of the cost of such facilities; and 3) to assure that adequate public facilities will be constructed to serve new development. The impact fees that are described in this study do not include any other forms of developer contributions or exactions, such as: mitigation or voluntary payments authorized by SEPA (the State Environmental Policy Act, RCW 43.21 C) ; system development charges for water and sewer authorized for utilities ( RCW 35.92 for municipalities, 56. 16 for sewer districts, and 57.08 for water districts) ; local improvement districts or other special assessment districts; linkage fees; or land donations or fees in lieu of land . Organization of the Study This impact fee rate study contains three chapters: • Chapter 1 provides a summary of impact fee rates for frequently used land use categories, and other introductory materials. • Chapter 2 summarizes the statutory requirements for developing impact fees, and describes the compliance with each requirement. • Chapter 3 presents impact fees for transportation including the methodology that is used to develop the fees, the formulas, variables and data that are the basis for the fees, and the calculation of the fees. The methodology is designed to comply with the requirements of Washington state law. • Appendix A shows the calculation of trip generation rates. Henderson, Young & July 5, 2016 Page 2 Company Rate Study for Impact Fees for Transportation • City of Renton 2 . STATUTORY BASIS AND METHODOLOGY This chapter summarizes the statutory requirements for impact fees in the State of Washington, and describes how the City of Renton ' s impact fees comply with the statutory requirements. Statutory Requirements for Impact Fees The Growth Management Act of 1990 (Chapter 17, Washington Laws, 1990, 1 st Ex. Sess.) authorizes local governments in Washington to charge impact fees. RCW 82.02.050 - 82.02.090 contain the provisions of the Growth Management Act that authorize and describe the requirements for impact fees. The impact fees that are described in this study are not mitigation payments authorized by the State Environmental Policy Act (SEPA) . There are several important differences between impact fees and SEPA mitigations. Three aspects of impact fees that are particularly noteworthy are: 1 ) the ability to charge for the cost of public facilities that are "system improvements" (i.e., that provide service to the community at large) as opposed to "project improvements" (which are "on-site" and provide service for a particular development) ; 2) the ability to charge small-scale development their proportionate share, whereas SEPA exempts small developments; and 3) the predictability and simplicity of impact fee rate schedules compared to the cost, time and uncertain outcome of case-by-case SEPA reviews. The following synopsis of the most significant requirements of the law includes citations to the Revised Code of Washington as an aid to readers who wish to review the exact language of the statutes. Types of Public Facilities Four types of public facilities can be the subject of impact fees: 1 ) public streets and roads; 2) publicly owned parks, open space and recreation facilities; 3) school facilities; and 4) fire protection facilities. RCW 82.02.050(2) and (4), and RCW 82. 02. 090(7) Types of Improvements Impact fees can be spent on "system improvements" (which are typically outside the development) , as opposed to "project improvements" (which are typically provided by the developer on-site within the development project) . RCW 82. 02. 050(3) (a) an d R C W 82.02.090(6) a n d (9) Henderson, Young & July 5, 2016 Page 3 Company Rate Study for Impact Fees for Transportation • City of Renton Benefit to Development Impact fees must be limited to system improvements that are reasonably related to, and which will benefit new development. RCW 82.02.050(3J (aJ and (c) . Local governments must establish reasonable service areas (one area, or more than one, as determined to be reasonable by the local government) , and local governments must develop impact fee rate categories for various land uses. RC W 82. 02. 060(6) Proportionate Share Impact fees cannot exceed the development's proportionate share of system improvements that are reasonably related to the new development. The impact fee amount shall be based on a formula (or other method of calculating the fee) that determines the proportionate share. RCW 82.02.050(3) (bJ and RCW 82. 02. 060( 1 ) Reductions of Im pact Fee Amovnts Impact fees rates must be adjusted to account for other revenues that the development pays (if such payments are earmarked for or proratable to particular system improvements) . RCW 82.02.050( 1 J (cJ and (2) and RCW 82. 02. 060( 1 ) (bJ Impact fees may be credited for the value of dedicated land, improvements or construction provided by the developer (if such facilities are in the adopted CFP as system improvements eligible for impact fees and are also required as a condition of development approval) . RCW 82. 02. 060(3) Exemptions from Impact Fees Local governments have the discretion to provide exemptions from impact fees for low-income housing and other "broad public purpose" development, but all such exempt fees must be paid from public funds (other than impact fee accounts) . RCW 82. 02. 060(2) Developer Options Developers who are liable for impact fees can submit data and or/analysis to demonstrate that the impacts of the proposed development are less than the impacts calculated in this rate study. RCW 82.02.060(5) . Developers can pay impact fees under protest and appeal impact fee calculations. RCW 82. 02. 060(4) and RCW 82. 02. 070(4) and (5) . The developer can obtain a refund of the impact fees if the local government fails to expend or obligate the impact fee payments within 10 years, or terminates the impact fee requirement, or the developer does not proceed with the development (and creates no impacts) . RCW 82. 02. 080 Henderson, Young & July 5, 2016 Page 4 Company Rate Study for Impact Fees for Transportation • City of Renton Capital Facilities Plans Impact fees must be expended on public facilities in a capital facilities plan (CFP) element or used to reimburse the government for the unused capacity of existing facilities. The CFP must conform to the Growth Management Act of 1990 ( RCW 36.70A.070 (3) ) , and must identify existing deficiencies in facility capacity for current development, capacity of existing facilities available for new development, and additional facility capacity needed for new development. R C W 82. 02. 050(4), R C W 82.02.060(7J, a n d R C W 82. 02. 070(2) New Versus Existing Facilities Impact fees can be charged for new public facilities (RCW 82. 02. 060( 1 ) (aJ and for the unused capacity of existing public facilities (RCW 82.02.060(7J subject to the proportionate share limitation described above. Accovnting Reqvirements The local government must separate the impact fees from other monies, expend or obligate the money on CFP projects within 10 years, and prepare annual reports of collections and expenditures. RCW 82. 02. 070( 1 )-(3) Compliance With Statutory Requirements for Impact Fees Many of the statutory requirements listed above are fulfilled in Chapter 3 of this study that presents the calculation of the transportation impact fee. Some of the statutory requirements are fulfilled in other ways, as described below. Types of Public Facilities This study contains impact fees for three of the four types of public facilities authorized by statute: transportation, parks and fire. This study does not contain impact fees for schools. In general, local governments that are authorized to charge impact fees are responsible for specific public facilities for which they may charge such fees. The City of Renton is legally and financially responsible for the transportation facilities it owns and operates within its jurisdiction . In no case may a local government charge impact fees for private facilities, but it may charge impact fees for some public facilities that it does not administer if such facilities are "owned or operated by government entities" (RCW 82.02.090 (7J . Thus, a city or county may charge impact fees for transportation, and enter into an agreement with the State of Washington for the transfer, expenditure, and reporting of transportation impact fees for state roads. A city may only charge and use Henderson, Young & July 5, 2016 Page 5 Company Rate Study for Impact Fees for Transportation • City of Renton impact fees on State roads if it has an agreement with the State, and the City CFP includes the state road projects. Types of Improvements The impact fees in this study are based on system improvements that are described in Chapter 3. No project improvements are included in this study. The public facilities that can be paid for by impact fees are "system improvements" (which are typically outside the development) , and "designed to provide service to service areas within the community at large" as provided in RCW 82.02.050 (9) ) , as opposed to "project improvements" (which are typically provided by the developer on-site within the development or adjacent to the development) , and "designed to provide service for a development project, and that are necessary for the use and convenience of the occupants or users of the project" as provided in RCW 82.02.050 (6) . The capital improvements costs contained in Chapter 3 comply with these requirements. Impact fee revenue can be used for the capital cost of public facilities. Impact fees cannot be used for operating or maintenance expenses. The cost of public facilities that can be paid for by impact fees include design studies, engineering, land surveys, land and right of way acquisition, engineering, permitting, financing, administrative expenses, construction, applicable mitigation costs, and capital equipment pertaining to capital improvements. Benefit to Development, Proportionate Share and Reductions of Fee Amovnts The law imposes three tests of the benefit provided to development by impact fees: 1 ) proportionate share, 2) reasonably related to need, and 3) reasonably related to expenditure (RCW 80.20. 050(3) ) . I n addition, the law requires the designation of one or more service areas (RCW 82. 02. 060(6) 1 . Proportionate Share. First, the "proportionate share" requirement means that impact fees can be charged only for the portion of the cost of public facilities that is "reasonably related" to new development. In other words, impact fees cannot be charged to pay for the cost of reducing or eliminating deficiencies in existing facilities. Second, there are several important implications of the proportionate share requirement that are not specifically addressed in the law, but which follow directly from the law: Henderson, Young & July 5, 2016 Page 6 Company Rate Study for Impact Fees for Transportation • City of Renton • Costs of facilities that will benefit new development and existing users must be apportioned between the two groups in determining the amount of the fee. This can be accomplished in either of two ways: ( 1 ) by allocating the total cost between new and existing users, or (2) calculating the cost per unit and applying the cost only to new development when calculating impact fees. • Impact fees that recover the costs of existing unused capacity should be based on the government's actual cost. Carrying costs may be added to reflect the government's actual or imputed interest expense. The third aspect of the proportionate share requirement is its relationship to the requirement to provide adjustments and credits to impact fees, where appropriate. These requirements ensure that the amount of the impact fee does not exceed the proportionate share. • The "adjustments" requirement reduces the impact fee to account for past and future payments of other revenues (if such payments are earmarked for, or proratable to, the system improvements that are needed to serve new growth) . The transportation impact fee calculated in this study includes an adjustment that accounts for any other revenue that is paid by new development and used by the City to pay for a portion of growth ' s proportionate share of costs. This adjustment is in response to the limitations in RCW 82.02.060 ( 1 ) (b) and RCW 82.02.050 (2) . • The "credit" requirement reduces impact fees by the value of dedicated land, improvements or construction provided by the developer (if such facilities are in the adopted CFP, identified as the projects for which impact fees are collected, and are required as a condition of development approval) . The law does not prohibit a local government from establishing reasonable constraints on determining credits. For example, the location of dedicated land and the quality and design of donated street or road can be required to be acceptable to the local government. 2. Reasonablv Related to Need. There are many ways to fulfill the requirement that impact fees be "reasonably related" to the development's need for public facilities, including personal use and use by others in the family or business enterprise (direct benefit) , use by persons or organizations who provide goods or services to the fee-paying property or are customers or visitors at Henderson, Young & July 5, 2016 Page 7 Company Rate Study for Impact Fees for Transportation • City of Renton the fee paying property (indirect benefit) , and geographical proximity (presumed benefit) . These measures of relatedness are implemented by the following techniques: • Impact fees are charged to properties which need (i.e., benefit from) new public facilities. The City of Renton provides its infrastructure to all kinds of property throughout the City, therefore impact fees have been ca Icu lated for a II types of property. • The relative needs of different types of growth are considered in establishing fee amounts (i.e., different impact values for different types of land use) . Chapter 3 uses different trip generation rates for each type of la nd use . • Feepayers can pay a smaller fee if they demonstrate that their development will have less impact than is presumed in the impact fee schedule calculation for their property classification . Such reduced needs must be permanent and enforceable (i.e., via land use restrictions) . 3. Reasonably Related to Expenditures. Two provisions of Renton ' s impact fee municipal code comply with the requirement that expenditures be "reasonably related" to the development that paid the impact fee. First, the requirement that fee revenue must be earmarked for specific uses related to public facilities ensures that expenditures are on specific projects, the benefit of which has been demonstrated in determining the need for the projects and the portion of the cost of needed projects that are eligible for impact fees as described in this study. Second, impact fee revenue must be expended or obligated within 10 years, thus requiring the impact fees to be used to benefit to the feepayer and not held by the City. 4. Service Areas for Impact Fees Impact fees in some jurisdictions are collected and expended within service areas that are smaller than the jurisdiction that is collecting the fees. Impact fees are not required to use multiple service areas unless such "zones" are necessary to establish the relationship between the fee and the development. Because of the compact size of the City of Renton and the accessibility of its transportation network to all property within the City, Renton ' s transportation system serves the entire City, therefore the impact fees are based on a single service area corresponding to the Henderson, Young & July 5, 2016 Page 8 Company Rate Study for Impact Fees for Transportation • City of Renton boundaries of the City of Renton . Exem ptions The City' s impact fee municipal code addresses the subject of exemptions. Exemptions do not affect the impact fee rates calculated in this study because of the statutory requirement that any exempted impact fee must be paid from other public funds. As a result, there is no increase in impact fee rates to make up for the exemption because there is no net loss to the impact fee account as a result of the exemption . Developer Options A developer who is liable for impact fees has several options regarding impact fees. The developer can submit data and or/analysis to demonstrate that the impacts of the proposed development are less than the impacts calculated in this rate study. The developer can appeal the impact fee calculation by the City of Renton . If the local government fails to expend the impact fee payments within 10 years of receipt of such payments, the property owner can obtain a refund of the impact fees. The developer can also obtain a refund if the development does not proceed and no impacts are created . All of these provisions are addressed in the City' s impact fee municipal code, and none of them affect the calculation of impact fee rates in this study. Capital Facilities Plan There are references in RCW to the "capital facilities plan " (CFP) as the basis for projects that are eligible for funding by impact fees. Cities often adopt documents with different titles that fulfill the requirements of RCW 82.02.050 et. seq . pertaining to a "capital facilities plan " . The Transportation Element, Park Element and Capital Facilities Plan Element of the City' s Comprehensive Plan fulfill the requirements in RCW, and are considered to be the "capital facilities plan " (CFP) for the purpose of this impact fee rate study. In addition, the City' s Capital Investment Program (CIP) section of the City' s Budget provides up-to- date and detailed information about the projects in the CFP . The City also produces an annual update of the multi-year Transportation Improvements Plan (TIP) All references to a CFP in this study are references to the Comprehensive Plan elements, City CIP and TIP documents listed above. The requirement to identify existing deficiencies, capacity available for new development, and additional public facility capacity needed for new development is determined by analyzing the volume and capacity of transportation facilities in Chapter 3. Henderson, Young & July 5, 2016 Page 9 Company Rate Study for Impact Fees for Transportation • City of Renton New Versus Existing Facilities, Accovnting Reqvirements Impact fees must be spent on capital projects contained in an adopted capital facilities plan, or they can be used to reimburse the government for the unused capacity of existing facilities. Impact fee payments that are not expended or obligated within 10 years must be refunded unless the City Council makes a written finding that an extraordinary and compelling reason exists to hold the fees for longer than 10 years. In order to verify these two requirements, impact fee revenues must be deposited into separate accounts of the government, and annual reports must describe impact fee revenue and expenditures. These requirements are addressed by Renton ' s impact fee municipal code, and are not factors in the impact fee calculations in this study. Data Sources The data in this study of impact fees in Renton, Washington was provided by the City of Renton, unless a different source is specifically cited . Data Rounding The data in this study was prepared using computer spreadsheet software. In some tables in this study, there may be very small variations from the results that would be obtained using a calculator to compute the same data . The reason for these insignificant differences is that the spreadsheet software was allowed to calculate results to more places after the decimal than is reported in the tables of these reports. The calculation to extra places after the decimal increases the accuracy of the end results, but causes occasional minor differences due to rounding of data that appears in this study. Henderson, Young & July 5, 2016 Page 10 Company Rate Study for Impact Fees for Transportation • City of Renton 3 . TRANSPORTATION IMPACT FEES Impact fees for transportation begin with the list of projects in the Transportation Element and Capital Facilities Plan Element of City's Comprehensive Plan and the City' s CIP and TIP (which are considerer part of the " CFP" , as noted in Chapter 2) . The projects in these elements are analyzed to identify capacity costs attributable to new development. The costs are apportioned between existing deficiencies (if any) and growth capacity. The capacity costs for growth are further apportioned to eliminate the cost of future reserve capacity. The costs are adjusted to reflect other sources of revenue that reduce the cost of the facility that is to be paid by impact fees. The eligible costs are divided by the growth in trips to calculate the cost per growth trip . The cost per growth trip is applied to the unique trip generation rates for each type of land use. The amount of the fee is determined by charging each fee-paying development for cost of the number of growth trips that it generates. These steps are described below in the formulas, descriptions of variables, tables of data, and explanation of calculations of transportation impact fees. Formula T- 1 : Transportation Proiects Eligible for Impact Fees The City has many projects in its transportation plan . Only those that add capacity to the streets in order to maintain the City' s adopted standard for level of service are eligible for impact fees. Non-Capacity All Capital Projects or Not _ Projects Eligible for T- 1 . . - - Pro�ects Needed for Level Impact Fees of Service There is one variable that requires explanation : (A) street capacity projects needed for level of service. Variable (A): Street Capacity Projects RCW 82.02.050 (4) (c) requires identification of public facility improvements needed to serve new development. Projects in the Transportation Element and Capital Facilities Plan Element, the CIP and TIP, and previously constructed projects are not eligible for impact fees if they do not add capacity to the City's current street system . Henderson, Young & July 5, 2016 Page 1 1 Company Rate Study for Impact Fees for Transportation • City of Renton In addition, capacity projects that are not needed for level of service are also not eligible for impact fees. For each capacity project, the future traffic volume (the amount of traffic on the street) was compared to the current capacity of the street (the amount of traffic the street is designed to carry without exceeding the adopted level of service standard) . If the future volume is greater than the current capacity, the project is needed in order to increase the capacity to serve the future volume, and the project is included in the impact fee. If, however the future volume is less than the current capacity, the City does not need the project for level of service, therefore the project is not eligible for impact fees2. A similar analysis was conducted of level of service for previously constructed projects eligible for "reimbursement" impact fees. RCW 82.02.050 (4) (b) requires this analysis of the additional demands placed on existing public facilities by new development. Table 2 lists the transportation projects that are eligible for impact fees. Numbered projects (i.e., 3, 4, 5, 12, etc .) are new projects that will be built in the future. Projects A - E were completed by the City and they have unused capacity that is available to serve new development ( "reimbursement projects" ) 3. Table 2: Street Projects Eligible for Impact Fees (1 ) (2) (3) (4) (5) # Street From To Description New Projects 3 Lake Washington Blvd Park Ave N Coulon Park Widen existing roadway to Entrance provide dual southbound left turn lanes on Lake Washington Blvd approach to Logan Ave/Garden Ave/N Park Dr intersection. 4 Park Ave N Extension Logan Ave N 1200 ft north of Extend Park Ave N north of Logan Ave N Logan Ave N by construction of a new 4-lane roadway with center left turn lane, where needed. Include pedestrian and bic cle facilities. 2 The City may have other reasons to build the project, and the project may provide additional capacity, but the project is not eligible for impact fees if it is not needed for level of service. 3 RCW 82.02.060(7) authorizes the City to impose impact fees for system improvement costs previously incurred by the City to the extent that new growth and development will be served by the previously constructed improvements. RCW 82.02.060 ( 1 ) (d) authorizes the cost of existing public facilities improvements in the calculation of impact fees. Henderson, Young & July 5, 2016 Page 12 Company