Letter to Allan Burke re TFC
City of Yelm
Community Development Department
105 Yelm Avenue West
P.O. Box 479
Yelm, WA 98597
September 24, 2003
Alan Burke, Superintendent
Yelm Community Schools
P.O. Box 476
Yelm, WA 98597
Dear Alan:
This is in response to your letter of September 18, 2003, in which you request reconsideration the policy of charging new or renovated schools sites with a traffic impact fee.
First, the imposition of traffic facilities charge is not policy, but is codified at Chapter 15.40 Yelm Municipal Code. This chapter states that a concurrency determination is required
for any division of land or for approval of a site plan, such as for a commercial or institutional use. Concurrency is a basic requirement of the Growth Management Act and requires
that infrastructure necessary to serve new development is in place or funded at the time of development. It is the basis for the imposition of all the impact fees in the City of Yelm,
including the traffic facility charge, sewer and water connection fees, and school mitigation fees. There is no exemption from concurrency management requirements for schools.
A finding of concurrency relating to transportation can be made when: a project makes on-site and frontage improvements consistent with City standards; off-site improvements are made
that are necessary to meet City standards for the safe movement of traffic; and the applicant makes a contribution to the facilities identified in the six year transportation improvement
program. The current TFC fee is $750.00 per peak P.M. trip as established Table 14.40.030 (B)(1), which identifies a rate of 0.04 trips per student for high schools and a rate of 0.02
trips per student for elementary and junior high schools. The imposition of the TFC is either through the SEPA determination or the land use permit approval, either of which can be
appealed to the City of Yelm Hearing Examiner.
Additionally, I could not support an amendment to the concurrency management code which exempted schools from payment of the traffic facility charge.
You provide three separate justifications in support of an exemption, which I summarize and analyze as follows:
Applying the TFC to a school is doubling the fee as Traffic Impact Fee’s are accessed during the planning and development of subdivisions and paid during the construction of residential
units.
TFC’s are applied to all land uses within the City of Yelm, not just new residential subdivisions. Commercial, institutional, recreational, and residential development is charged a
traffic facilities charge. The peak P.M. trip measures a trip end and a specific land use generates new trip ends if there is any traffic to the property.
Further, the School District boundaries extend well outside the City limits, and even beyond Thurston County into Pierce County. According to the latest census information, 84% of the
population in the school district boundaries live outside the City of Yelm. As noted in the Winter 2003 Show-N-Tell, Yelm is unusual in that all seven of the schools are located relatively
close to the central corridor of the City. City infrastructure is bearing the brunt of development outside our jurisdiction and for which we collect no TFC, even for a new housing start.
According to some of the calculations in the Schools Capital Facilities Plan, the majority of residential growth is in Thurston County and not the City of Yelm.
Public schools do not attract additional population and thus do not create additional traffic.
As noted above, the School District does import traffic into the City of Yelm from developments outside the City limits. In addition, the localized impacts of the construction or expansion
of a school may be significant even if the system-wide impacts aren’t changed. For example, construction of a school at the end of a local access residential street could cause significant
delays or safety issues due to new turning movements.
Money approved by the taxpayers for the construction of schools were not intended to ‘reconstruct’ the area traffic infrastructure.
I would hope that the cost of development of new or expanded school facilities, including the infrastructure needed to support these facilities, had been considered when budgeting for
the project. In addition to the transportation system, the costs of required infrastructure such as water, sewage disposal, and stormwater management are typically an anticipated cost
of development.
If you have any further questions regarding the traffic facilities charge, please do not hesitate to contact the Community Development Department.
Sincerely,
Grant Beck, Director
Department of Community Development
c. Shelly Badger, City Administrator
Erling Birkland, YCS Director of Facilities