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Letter: An Open Letter to Manatee BOCC on Impact Fees


Dear Commissioners,

As you know I am very concerned about impact fees in Manatee County. Specifically I am concerned that the county is missing revenue collecting opportunities. That failure will have serious future consequences. I do not believe that it is fair to make county taxpayers pay for expansion of infrastructure or services that are necessitated because of new construction.  County taxpayers should only be responsible to sustain the present level of services, to maintenance of present infrastructure, and to replace or update old or inefficient infrastructure.

Any expansion of services and infrastructure costs should be offset by impact fees. Impact fees should also cover any costs associated with bond issues including interest that results from a need for services and infrastructure required because of new construction and required by the resulting increase in population.

It has been suggested that impact fees damage the local economy and reduce jobs. Many studies indicate otherwise. For example, a Brookings Institute study maintains that at a minimum, “impact fees are not a drag on local economies. At most, impact fees are the grease that helps sustain job growth in the local economy.”

The study also found that, “While impact fees will continue to draw detractors, this paper shows that impact fees are a practical and valuable tool for financing local infrastructure needs. Without them, growing communities may not be able to sustain growth. In short, impact fees can directly fund vital infrastructure improvements, while increasing the supply of buildable land, improving predictability in the development process, and indirectly promoting local employment at the same time. Faced with the growing demand for investment and the public resistance to tax increases, localities in growing regions that institute impact fees may become more prosperous in the long run than communities in such regions that do not have them.” (www.brookings.edu/research/reports/2003/06/metropolitanpolicy-nelson_

Do impact fees harm or benefit developers? Impact fees should have no negative effect on developers since those fees may be passed on to buyers.  And that would be justified since the buyers are those who would benefit from expansion of infrastructure and services. Present property owners have already paid for or are paying for existing infrastructure and services.

An example of how a developer might benefit from low or no impact fees would be the disparity of impact fees between Manatee and Sarasota Counties.  If a builder constructed two identical houses, three-bedroom and two-bath, one in Manatee County and one in Sarasota County in similar subdivisions he could sell both houses for the same price.  However, the total impact fee in Manatee is $6,249 while in Sarasota it is $12,035 (2012 data, most recent available.) (impactfees.com/publications%20pdf/2012_survey.pdf)

The developer would thus pocket an extra $5,786 that might have otherwise been collected by Manatee County. Multiply that by the tens of thousands of homes that are planned to be built in Manatee County and you will see that we are missing out on tens of millions of dollars of desperately needed revenue: (www.mymanatee.org/dms/departments/financial-management/impact-fees/A_County_Impact_Fees_Effective_October_1_2011.pdf)

In May of 2011 the Florida legislature passed two bills that repealed the Growth Management Act of 1985 and dismantled the Department of Community Affairs. The bills banned cities and counties form imposing any impact fees for nonresidential development for two years and automatically extended all permits for large-scale developments for seven years. This action was one of seven steps intended to increase job production by 700,000 in seven years in addition to the increase of 1.05M jobs projection if nothing was done. So far jobs are being created at 40% below that 700K level. In addition the environment has suffered and county & city coffers are dwindling: (www.tampabay.com/news/environment/florida-lawmakers-wipe-out-30-years-of-growth-management-law/1168328)

At the Land Use Meeting on August 7th it was mentioned that the Manatee County School Board had requested that a school impact fee not be collected. No explanation was made. I request more information since that appears to be contrary to the needs of the school system which is deeply in debt.

There was also talk of a “facilities” fee that was charged developers in lieu of an impact fee. I searched the county website but could find not mention of that fee. Please provide details about that fee.

A review of the Duncan Associates survey cited previously clearly shows that Manatee County is not collecting impact fees in many areas authorized by Florida statutes and the fees that are collected fall below those collected by many other counties in Florida. I urge that the studies being done now (mentioned at the Aug. 7th meeting) be completed as soon as possible and that rates be adjusted soon thereafter in order to help stop Manatee County from sliding into deeper debt and to prevent property tax increases. Please inform me of the present status of those studies and when completion is anticipated.


Edward Goff


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