HomeMy WebLinkAboutAgenda - 12-01-2008 - 5a ORANGE COUNTY
BOARD OF COMMISSIONERS
ACTION AGENDA ITEM ABSTRACT
Meeting Date: December 1, 2008
Action Agenda
Item No. 5-0
SUBJECT: Educational Facilities Impact Fee — Public Hearing
DEPARTMENT: Planning / Budget PUBLIC HEARING: (Y/N) Yes
ATTACHMENT(S): INFORMATION CONTACT:
1. Legal Ad for Public Hearing Craig Benedict, 245-2592
2. Consultant Presentation Donna Coffey, 245-2151
3. Graphs of Historical Impact Fee Perdita Holtz, 245-2611
Collections for Both School Districts
4. A. Impact Fee at Various Levels and
Projected Level Necessary to
Generate $1.6 million in CHCCS
B. Educational Facilities Impact Fees in
Relationship to New Single Family
Dwelling Sales Prices
C. Example of Cost Recovery
5. Adopted student Generation Rates and
Results of 2007 and Relationship to
SAPFO (Schools Adequate Public
Facilities Ordinance)
6. Letters from CHCCS and OCS
7. Draft Report for CHCCS
8. Draft Report for OCS
(Previously Provided Under Separate Cover)
PURPOSE: To conduct a public hearing on the draft reports prepared by TischlerBise, Inc.
which calculate the maximum supportable impact fee for new residential units in each of the two
school districts.
BACKGROUND: Orange County adopted the Educational Facilities Impact Fee Ordinance in
1993 and last updated impact fee levels in 2001. In 2007, the County contracted with
TischlerBise, Inc. to produce an updated impact fee study. Copies of the draft reports were sent
to the School Districts, BOCC, and municipal Planning Directors on July 22, 2008 and the Board
formally received the draft Educational Facilities Impact Fee reports at its October 7, 2008
regular meeting. The topic was also discussed at the September 25, 2008 Joint County/Schools
meeting and at the October 14, 2008 BOCC work session. Letters received from the school
districts are included at Attachment 6.
2
The fee level ranges proposed by staff to be considered for the public hearing are as follows:
• $5,069 - $11,423 for a new single-family detached dwelling in the Chapel Hill — Carrboro
City Schools (CHCCS) district, and
• $3,000 - $5,623 for a new single-family detached dwelling in the Orange County Schools
(OCS) district.
As is shown in Attachment 4A, the projected impact fee required in the CHCCS district to
generate the budgeted amount of $1.6 million to offset a portion of CHCCS debt service is
$5,069. This is the staff-recommended lower end of the impact fee range. The staff-
recommended upper end of the range ($11,423) is 60% of the Maximum Supportable Impact
Fee (MSIF), which is consistent with the adopted percentage of the 2001 MSIF. In the OCS
district, the lower end of the staff-recommended range is the current impact fee of $3,000 and
the upper end of the range ($5,623) is 60% of the MSIF. The MSIF is the highest amount
feasible to be charged and represents new residential growth's fair share of the capital costs to
provide school capacity (the Executive Summary of each technical report further details this
concept).
Attachment 4B shows impact fee levels in relation to the sales price of new single family
detached dwellings. In CHCCS, the 2001-adopted impact fee of $4,407 is 1.21% of the 2001
median sales price of a new single family detached dwelling. If the impact fee were to be
increased to 1.21% of the 2007 median sales price of a new single family detached dwelling, the
corresponding impact fee would be $9,249. In OCS, the 2001-adopted impact fee of $3,000 is
1.32% of the median sales price of a new single family detached dwelling. If the impact fee
were to be increased to 1.32% of the 2007 median sales price of a new single family detached
dwelling, the corresponding impact fee would be $3,762.
Attachment 4C is an example of cost recovery on 1,000 new single family detached dwellings in
the CHCCS District. The example shows the impact fee collected and deficit in funding the cost
of school construction with impact fee levels at 100%, 60%, and 27% of the MSIF.
The impact fee level for housing types other than single family detached dwellings would be set
at the same percentage of maximum supportable impact fee for the particular type of dwelling
as the percentage set for single family detached dwellings. For example, if impact fees were to
be set at 60% of the maximum supportable impact fee for single family detached dwellings, the
impact fee for a manufactured home would be set at 60% of the maximum supportable impact
fee for manufactured homes. Changes in the present fees would be determined by the Board of
Commissioners following public comment at the public hearing and otherwise. In no event
would educational facilities impact fees be changed to an amount or amounts that exceed the
maximums determined by the 2007 Technical Reports.
Ms. Julie Herlands of TischlerBise, Inc. will be in attendance at the public hearing to give a
presentation and to answer questions regarding the reports (see Attachment 2 for the basics of
the presentation). The consultant's role relates to the technical aspects of determining the MSIF
and not aspects regarding what the County decides on the MSIF or percentage thereof.
FINANCIAL IMPACT: Other than staff time and the consultant contract, there is no financial
impact in conducting a public hearing on this issue. As Attachment 4A shows, an increase in
impact fees to $5,069 per new single family detached dwelling is projected to be necessary to
generate the budgeted amount of$1.6 million to offset part of the CHCCS debt service.
3
RECOMMENDATION(S): The Manager recommends the Board:
1. Conduct a public hearing on the draft reports,
2. Direct the consultant to finalize the reports,
3. Close the public hearing, and
4. Direct staff to bring back amendments to and effective date of the Educational Facilities
Impact Fee Ordinance for adoption consideration at December 11, 2008 regular Board
meeting.
Attachment 1
4
NOTICE OF PUBLIC HEARING
ORANGE COUNTY BOARD OF COMMISSIONERS
A public hearing will be held in the Judge F. Gordon Battle Superior Courtroom of the
New Orange County Courthouse, 106 E. Margaret Lane, Hillsborough, North Carolina, on
Monday, December 1, 2008, at 7:30 PM for the purpose of giving all interested citizens an
opportunity to speak for or against the following item:
1. Draft Educational Facilities Impact Fee Reports
Effective July 1, 1993, the Board of County Commissioners established a system of
impact fees to help recover a portion of school capital projects that add student capacity
necessary to serve residential growth in the county. Since that date, an impact fee has
been collected for each new housing unit constructed or installed in the county,
including single-family home, multi-family housing units, apartments, and manufactured
homes. Fees collected in each of the two school districts within the county (Chapel Hill
— Carrboro City Schools and Orange County Schools) are deposited into separate
special accounts and used exclusively for the construction of new school facilities in the
school district in which the fee was collected. The impact fee supplements funds
provided by the County from sales tax and property tax revenues for school capital
projects. The educational facilities impact fee presently collected (last updated in 2001)
in each district for each new residential unit is as follows:
Adopted School Impact Fees (2001)
[NOTE: Fee levels were adopted at 60%of the Maximum Supportable Impact Fee(MSIF)
for CHCCS and 56% of the MSIF for OCS]
Chapel Hill-Carrboro Schools Orange County Schools
Single-Family & Multi-wide $4,407 $3,000
Manufactured Homes
Multi-Family & Single-wide $1,979 $1,420
Manufactured Homes
Since 2001, construction costs have increased significantly and land prices have
appreciated.
The Board of County Commissioners employed a consultant to evaluate impact fee
levels and determine the maximum legally defensible fee for new development in each
of the school districts. The full draft reports (one for each school district) are available
on the Orange County website at:
http://www.co.orange.nc.us/OCCLERKS/0809166d0.pdf (Orange County Schools) and
http://www.co.orange.nc.us/OCCLERKS/0809166dC.pdf (Chapel Hill - Carrboro City
Schools).
The 2007 Technical Reports determined the Maximum Supportable Impact Fees as
shown in the Table below. THE MAXIMUM LEGALLY PERMISSABLE FEES
CALCULATED IN THE REPORTS OF THE CONSULTANT ARE NOT A PROPOSAL
TO CHARGE THOSE LEVELS OF FEES. The Board of Commissioners is currently
considering an impact fee in the range shown in the table.
0
2007 Study Maximum Supportable Impact Fees (MSIF)
and Range Under Consideration
Chapel Hill-Carrboro Schools Orange County Schools
MSIF Range Under MSIF Range Under
Consideration Consideration
Single-Family Detached $9,372
$19,039 $5,069 -$11,423 $3,000 -$5,623
Single-Family Attached $11,016 $2,974-$6,610 - -
Multifamily $2,144 $579 -$1,286 - -
Single-Family Attached/ $2,905
Multifamily - - $930 -$1,743
Manufactured Homes $8,232 $2,223-$4,939 $4,463 $1,428 -$2,678
The Board of Commissioners will consider whether or not to change educational
facilities impact fees following the December 1, 2008 public hearing. Impact fees for
each housing type within each school district would be set at the same percentage point
within its respective range. For example, if impact fees are set at 60% of the maximum
supportable impact fee for single family detached dwellings, the impact fee for
manufactured homes would be set at 60% of the maximum supportable impact fee for
manufactured homes. Precise changes, if any, in the present fees will be determined
by the Board of Commissioners following public comment at the public hearing and
otherwise. In no event will educational facilities impact fees be changed to an amount
or amounts that exceed the maximums determined by the 2007 Technical Reports.
Purpose: To receive public comment on the Draft Educational Facilities Impact Fees
reports and the impact fee range under consideration.
Changes may be made in the advertised proposal that reflect debate, objections
and discussion at the hearing.
Accommodations for individuals with physical disabilities can be provided if the
request is made to the Director of Planning at least 48 hours prior to the Public
Hearing by calling the appropriate number listed below.
Questions regarding the proposal may be directed to the Orange County Planning
Department located in the Planning and Agricultural Center, 306F Revere Road,
Hillsborough, North Carolina. Office hours are from 8:00 a.m. to 5:00 p.m. Monday
through Friday. You may also call 245-2575 or 245-2585 and you will be directed to a
staff member who will answer your questions.
PUBLISH:
News of Orange Chapel Hill Herald
November 19, 2008 November 19, 2008
November 26, 2008 November 26, 2008
14-finch rv-l-ent Z
0
Educational Facilitie- Impact Fees ' - ew
Orange County Schools . .... -
Chapel HiIi-Carrboro City Schools
orange County,North Carolina • Introduction
• Overview
Pwe n etioe to .,..l - -Impact Fees
Orange County _ - Process for the Studbs
C`moECounty • Im act Fee Results b S stem
Commissioners �, p � Y System)
"`" -Methodologies
December 1,2008 - Levels of Service&Costs
- Maximum Supportable Amounts
TISCdtlf $ n • Q&A
• National Practice The purpose is to:
• Impact Fees(700+) ;: , "%
__<• Fiscal Impact ". , . Help defray the costs to the County
Evaluations(600+) ..2.-:.„. °. __ -,-„*...7`...:,.-„ of constructing certain capital
• Infrastructure Needs •": •��
�� ; ' • '' •' '•, . improvements, the need for which is
&Revenue Strateges , created in substantial part by the new
• Public and Private `-f development that takes place within the
Sector Experience* County."
•Norte Corollas ala+tsr CaWrrvs county,Comden C purity,C7raw6►Co war, St.1987460:'4n Act Maklrc Sundry Mam:to nts
anthem county,C.MWd3 car MY'patx county,G1aRrdCOUnty,tnwNam.a Conceminplocal Governments in Orange and Chatham
lc gemsr *e. wane coo nty,Can,www.,,o r,owe am,na «Mae, - CWmttes,Trtte VI:Orange Countyimpect Fees.”
ladnonvxae,N aas trarb taR.wNmurato n,and tnNDn,
ore awK.ac.a I o"wwvuc••
• Represent new growth's fair share of the • Interview key staff
cost for capital facility needs • Analyze demographic data
• Used for capacity expansions • Consider methodologies and determine levels of
• Not a revenue raising mechanism but a service
way to provide growth-related • Determine capital costs
infrastructure • Evaluate inclusion of credits
•Three requirements must be met: • Determine maximum supportable fee
- Impact:Growth is generating need for infrastructure amounts for each School System
- Benefit:Timing of improvements;Accounting and
• Staff review
expenditure(*taro& = • Presentations to the Pubic
- Proportionality:Pair share of cost • Decision by elected officials
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• • Cost Recovery (past) Demand Infrastructure
. -- -Oversized and unique facilities Units Units Dollars
• Incremental Expansion (present) per X per X
- Formula-based approach documents level-of- Development Demand Infrastructure
.-. service with both quantitative and qualitative Unit Unit Unit
• measures;common for schcois
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Acreage Po Studeni 0937 OAK 0039
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rrotal Gloss Capital Cost Per Stusta0 I $24691 I MON I 991.669 I
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Ont Par Portal.Comm 810,030 SIO,C00 S10,000 Dial Geoss Local Capitil Cost PerStudelt $24424 94719 033.952
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OCICHCCS Transp.Peal*Con Per Mudget 191
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3
School Construction Impact Fee
Chapel Hill Carrboro City Schools
$3,000,000 - - 1,200
o School Construction Impact °'
-0 0.
c• $2,500,000 - ° Fee Increase Effective June - 1,000 t
- j rte, c 25,2001 0
972 0
= 1 G° y
0. 851
✓ $2,000,000 - 800 0
.0 0
Co. 99 628 -0 .0 0
• 8 0 l:
$1,500,000 CD - 600 H v
� � °,-° 0 571 H
c., co
a V c(0 E e=o
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m $1,000,000 o - 400 0_
V rn X50 336 a
to .5
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3 ra
a $500,000 200
c 67
I .-) a
c
$0 o
1999-00 2000-01 2001-02 2002-03 2003-04 2004-05 2005-06 2006-07 2007-08
Fiscal Year
(1) Building permit data provided by Towns of Chapel Hill and Carrboro Planning Departments
O
School Construction Impact Fee 09/16/2008
Orange County Schools
Does Not Reflect School Construction Impact Fees Collected on Behalf of City of Mebane
$1,400,000 700
654 School Construction
Impact Fee Increase 620
$1,200,000 Effective June 25, 2001 • 600
c 6 >.
c a
cv .8
L. w$ 1,000,000 500 y a
c N >. Cn
C)• U co E
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7 $800,000 98 400
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$600,000 0 a)
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0
ifk V $400,000 N 200
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a $200,000 o a 100
N
co 0)
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$0 0
1999-00 2000-01 2001-02 2002-03 2003-04 2004-05 2005-06 2006-07 2007-08
Fiscal Year
(1) Includes School Construction Impact Fees Collected for Certificates of Occupancy Issued by Orange County Planning
Department. Does not inlcude School Construction Impact Fees collected on behalf of City of Mebane.
(2) Certificates of Occupancy data provided by Orange County Planning Department.
0
School Construction Impact Fees 09/16/2008
Orange County Schools
$1,600,000
$1,400,000
$1,200,000
im
,O MI
$1,000,000 ,0
Dkb
$800,000
$600,000
$400,000 0
$200,000
$
I
0
1999-00 2000-01 2001-02 2002-03 2003-04 2004-05 2005-06 2006-07 2007-08
Fiscal Year
•Collected by Orange County Planning for Certificates of Occupancy Issued 0 Collected by Orange County Planning on Behalf of City of Mebane
III
R
THIS PAGE INTENTIONALLY LEFT BLANK
0
Attachment 4A
Impact Fee at Various Levels and Projected Level Necessary to Generate$1.6 million in CHCCS
The tables below provide impact fee levels at various percentages of the maximum supportable impact fee(MSIF)as defined in the 2007 technical reports prepared by TischlerBise,Inc.
Cun eft Impact Fee for
Single Family Homes
located in CHCCS School
District
Chapel Hill Carrboro City Schools __________ .■
100% 90% 80% 70% 60% 50% 40% 32% 30% 27% 23% 20% 10%
Single Family Detached $19,039 $17,135 $15231 $13227 $11,423 $9,520 $7,616 $6,092 $5,71 $5,069 __MAW $3,808 $1,904
Single Family Attached $11,016 $9,914 $8,813 $7,711 $6,610 $5,508 $4,406 $3,525 , 05 $2,203 $1,102
Multifamily $2,144 $1,930 $1,715 $1,501 $1,286 $1,072 $858 $643 $429 $214
Single Family N/A N/A N/A N/A N/A N/A N/ N/A N/A N/A N/A
Attached/Multifamily
Manufactured Homes $8,232 $7,409 $6,586 $5,762 $4,939 $4, $3,293 $2,634 $2,470 $1,646 $823
Average number of building
permits issued by Towns of 316
Chapel Hill and Carrboro in FY
2005-06 through 2007-08
Amount of Impact Fee revenue
anticipated to offset CHCCS debt $1,600,000
service
Impact Fee Level to Generate Current Impact Fee for
$1.6 million $5,069 Single Family Homes
located in OCS School
District
Orange County Schools
100% 90% 80% 70% 60% 56% 50% 40% '' 32% 30% 27% 20% 10%
Single Family Detached $9,372 $8,435 $7,498 $6,560 $5,623 $5248 $4,686 $3,749 $3,000 $2,812 $2,530 $1,874 $937
Single Family Attached N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Multifamily N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Single Family $2,905 $2,615 $2,324 $2,034 $1,743 $1,627 $1,453 $1,162 $872 $784 $581 $290
Attached/Multifamily
Manufactured Homes $4,463 $4,017 $3,570 $3,124 $2,678 $2,499 $2,232 $1,785 $1,339 $1,205 $893 $446
Attachment 4B
14
Educational Facilities Impact Fees
Fees in Relationship to New Single Family Dwelling Sales Prices
Chapel Hill — Carrboro City Schools District
New SF 2001 $4,407 2007 2008 Impact
detached (217 closed Impact Fee (74 closed Fee if at same
dwelling sales) % of Price sales) % as 2001
Average $393,445 1.12 $805,707 $9,024
Sales Price
Median $364,900 1.21 $764,394 $9,249
Sales Price
Source of data: MLS closed sale date for Average; proprietary appraisal
software for Median, using MLS data. It should be noted that all sales are not
entered into the MLS.
Orange County Schools District
New SF 2001 $3,000 2007 2008 Impact
detached (95 closed Impact Fee (110 closed Fee if at same
dwelling sales) % of Price sales) % as 2001
Average $233,626 1.28 $337,775 $4,324
Sales Price
Median $228,000 1.32 $284,968 $3,762
Sales Price
Source of data: MLS closed sale date for Average; proprietary appraisal
software for Median, using MLS data. It should be noted that all sales are not
entered into the MLS.
Attachment 4C
4131
Example of Cost Recovery
Example for 1,000 new single family detached dwellings in the
Chapel Hill — Carrboro City Schools District
PLEASE NOTE: Numbers are rounded to the nearest whole number for example
100% MSIF Example
Number of students Generated (at all levels)
[0.603 x 1000 = 603] 600
Maximum Supportable Impact Fee per Dwelling
[actual is $19,039] $19,000
Impact Fee Collected on 1,000 new dwellings if
MSIF imposed $19,000,000
Approximate cost of school for 600 students
(not including land costs) $24,600,000
Deficit if impact fee is increased to MSIF
(other fund sources would be necessary to ($5,600,000)
compensate for this amount)
60% MSIF Example
Impact Fee Collected on 1,000 new dwellings if
impact fee is set at 60% of the MSIF [$11,400] $11,400,000
Deficit if impact fee is increased to 60% of MSIF
(other fund sources would be necessary to ($13,200,000)
compensate for this amount)
27% MSIF Example
Impact Fee Collected on 1,000 new dwellings if
impact fee is set at 27% of the MSIF [$5,000] $5,000,000
Deficit if impact fee is increased to 27% of MSIF
(other fund sources would be necessary to ($19,600,000)
compensate for this amount)
Attachment 5
C
Adopted Student Generation Rates and Results of 2007 Study and Relationship
to SAPFO (Schools Adequate Public Facilities Ordinance)
Student generation rates have increased in both school districts from the rates
calculated in 2001. The Adopted (2001) student generation rates are as follows:
Adopted Student Generation Rates (2001)
Chapel Hill-Carrboro Schools Orange County Schools
Elem. Middle High All Elem. Middle High All
Grades Grades
Single- 0.168 0.095 0.123 0.386 0.150 0.075 0.084 0.309
Family
Other 0.094 0.042 0.043 0.179 0.084 0.033 0.030 0.147
All
Housing 0.134 0.070 0.086 0.290 0.140 0.068 0.076 0.284
Types
The analysis for the 2007 draft report found the student generation rates in the
following table. Some data was aggregated slightly differently for the school districts
since the housing types found in each district vary (i.e., Single Family Attached /
Multifamily was combined for OCS since there is minimal single family attached
housing in the OCS district).
2007 Study Student Generation Rates
Chapel Hill-Carrboro Schools Orange County Schools
Elem. Middle High All Elem. Middle High All
Grades Grades
Single-Family 0.263 0.143 0.197 0.603 0.168 0.090 0.126 0.384
Detached
Single-Family 0.158 0.077 0.115 0.350 - - - -
Attached
Multifamily 0.038 0.015 0.017 0.070 - - - -
Single-Family
Attached / - - - - 0.066 0.022 0.034 0.122
Multifamily
Manufactured 0.141 0.066 0.061 0.268 0.096 0.041 0.049 0.186
Homes
All Housing 0.149 0.078 0.105 0.332 0.145 0.074 0.102 0.321
Types
The contract with TischlerBise, Inc. includes an update to student generation rates
because student generation rates are a factor, along with school construction costs,
in the Maximum Supportable Impact Fee calculation.
The Educational Facilities Impact Fee Ordinance is independent of and preceded the
Schools Adequate Public Facilities Ordinance (SAPFO) effective date. Student
generation rates are also a part of SAPFO and the Certificate of Adequate Public
Schools (CAPS) system that is component of SAPFO. Although it is logical to update
SAPFO processes with the most up-to-date data available, there is not a requirement
that SAPFO student generation rates be updated prior to or concurrent with changes
to the Educational Facilities Impact Fee Ordinance. For example, the 2001 impact
fee study included student generation rates which were adopted into SAPFO in 2003
because they were readily available.
The SAPFO MOU contains a process for updating student generation rates (and
other statistical methods). The process is as follows:
1. The Board may change the projected student membership growth rate, the
methodology used to determine this rate, or the student generation rate if the
Board concludes that such a change is necessary to predict growth more
accurately.
2. Before making any such change, the Board shall receive and consider the
recommendation of a staff committee consisting of the planning directors of
the Town(s) and the County and a representative of the School District
appointed by the Superintendent.
3. The committee shall provide, in a timely manner, a copy of its
recommendation to the governing boards at the time it provides such
recommendation to the BOCC and the BOCC shall provide an opportunity for
the governing boards to comment on the recommendation.
4. If a change is made, the BOCC shall inform the governing boards prior to
February 1st in any year in which such change is intended to become effective
what change was made and why it was necessary.
$
CHAPEL HILL- rEcF i':_TED
ARRBORO BY0 9 zaos:s
CITY SCHOOLS
September 8, 2008
Barry Jacobs, Chair
Board of County Commissioners
PO Box 8181
Hillsborough, NC 27278
Dear Commissioner Jacobs:
At its meeting on September 3, 2008, the Chapel Hill-Carrboro Board of
Education approved the following resolution:
Be it, therefore, resolved that the Board of Education urges the Orange
County Board of Commissioners to increase the school impact fees in
order to provide a source of funding to construct new schools to keep
pace with the district's growing student population and the escalating cost
of construction.
Be it further resolved that the Board of Education urges the Orange
County Board of Commissioners to continue to reimburse the impact fee
for newly constructed affordable housing.
We look forward to further discussion on this important topic at our joint meeting
on September 25, 2008.
Sincerely,
Pamela S. Hemminger, Chair
Board of Education
C: Laura Blackmon
Neil Pedersen
Lincoln Center,750 S. Merritt Mill Road • Chapel Hill, NC 27516-2878 • (919)967-8211 •www.chccs.k12.nc.us
iq
Orange County Schools
1f L
c 200 East King Street
Hillsborough NC 27278
G.Patrick Rhodes (919)732-8126 Telephone
Superintendent (919)732-8120 Fax
www.orange.k12.nc.us
September 19,2008
•
Mr.Craig Benedict,Director
Orange County Planning and Inspections Department
306 F Revere Road,PO Box 8181
Hillsborough,NC 27278
Dear Mr.Benedict:
RE: School Impact Fees
The Orange County Board of Education held a discussion at their September 2,2008 Board meeting regarding the
Draft School Impact Fees Report completed by TischlerBise. In response to the request for our Board to provide
comments pertaining to the report,I am providing the following excerpt from the approved minutes of the
September 2 meeting:
Board members agreed by consensus to reply to the County Commissioners stating the Board of
Education supports the County Commissioners in all their efforts to fully fund our school district
Administration recommends the percentage of the maximum supportable impact fee remain at 56%
The Orange County Board of Education fully supports the Board of County Commissioners'efforts to fund the
Orange County Schools and supports the current impact fee levels. Please let me know if you need any additional
infulmation.
Sincerely,
,/"Cl Pc,kketc ardA4.--
G.Patrick Rhodes
Superintendent
/pmc
cc: Orange County Board of Education SAP Z�QQB
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