EXECUTIVE SUMMARY

MAYOR AND BOARD OF ALDERMEN

DEPARTMENT OF PLANNING & COMMUnity DEVELOPMENT

Date SUBMITTED:                         July 13, 2006          

DATE OF WORKSHOP SESSION:  July 19, 2006

date of public MEETING:        N/A

 

To:                 MAYOR & Board of ALDERMEN

From:           Chuck Boyd, Deputy Director of Planning & Community Development

RE:                  Adequate Public Facilities Ordinance (APFO)

 

 

PURPOSE:     To present to the Mayor & Board of Aldermen information on an APFO. 

 

HISTORY:  With recent election, there has been a renewed push for the City of Frederick to adopt an Adequate Public Facilities Ordinance (APFO).  Frederick County adopted an APFO for roads, schools, sewer and water on December 1, 1991.  Since that time, the County ordinance has had several revisions. 

 

There are several exemptions in the County’s APFO.  They include:  minor residential subdivisions (5 or fewer lots), private or public schools and public safety facilities.  In addition several residential and non-residential developments were exempt for 3-10 years depending on the size of the development.

 

The capacity for each facility is spelled out in the County’s Ordinance.  Roads in a designated agricultural / rural or conservation category will be considered adequate if a level of service (LOS) of “C” or better is maintained.  For roads outside of designated agricultural / rural or conservation category will be considered adequate if a level of service (LOS) of “D” or better is maintained. 

 

In the County’s system, water & sewer are considered adequate factoring in existing connections, future connection from buildings under construction, recorded lots for which allocations have been made and multi-year tap agreements.  For water source facilities, storage tanks and local pumping station have sufficient capacity to provide maximum day demand and peak hour demand in addition to fire flow and the distribution system is capable of providing normal required pressure.

 

The capacity of elementary and secondary schools shall be considered adequate if enrollment is less than 100 percent of the state-rated capacity.  There are provisions for requesting that the BOE to redistrict if there is additional capacity is in an adjacent school district.

 

 

 

 

 

 

 

 

 

 

In 1997 & 1998, the City of Frederick established a committee to develop an APFO for only schools. This committee produced a draft plan that was never adopted.  In creating an APFO for schools, the committee found three major problems:

 

1)      Decision about school construction and redistricting essentially became decision as to where developments can be approved.  These decisions are made by the County and the Board of Education and not the City of Frederick.

2)      The APFO often passes small projects and fails larger project (unless the phasing option is used).  To pass there must be enough seats available today for all students who would come from a development when totally built out.

3)      The County APFO is very strict and would not allow for exceptions that promote other City goals and objectives like affordable housing or downtown redevelopment.     

 

Copies of the 1998 Draft is include in your packet for your review. 

 

There are other municipalities in the County that currently have an APFO.  These include: Brunswick, Emmitsburg, Mt Airy, and Walkersville.  These ordinances vary with the issues facing each jurisdiction.  For instance, Walkersville only reviews the adequacies of schools & water and Brunswick reviews water, sewer, roads & schools. 

 

Other jurisdictions within the state that have APFO’s include:

 

Counties with Adequate Public Facilities Ordinances

Anne Arundel Carroll Harford Prince George’s Washington, Baltimore, Charles, Howard, Queen Anne’s, Calvert, Frederick, Montgomery, St. Mary’s

 

Municipalities with Adequate Public Facilities Ordinances

Boonsboro, Emmitsburg, Laurel, New Windsor, Walkersville, Brunswick, Hagerstown, Manchester, Sykesville, Cumberland, Hampstead, Mount Airy, Taneytown

(Source: HB 1205)

 

 

DISCUSSION:  First we must understand what an APFO can accomplish and what it cannot do.

An APFO is a form of land use regulation that controls the timing of property development and population growth with the purpose of ensuring that the public facilities needed to serve new residents are constructed and made available contemporaneously with the impact of the new development

 

Said another way, the purpose of an APFO is to ensure that, to the maximum extent practicable, approval of new residential development will become effective only when it can reasonably be expected that adequate public facilities will be available to accommodate such new development.

 

An APFO is a planning tool that attempts to coordinate the local CIP and growth.  An APFO can be applied to public facilities such as schools, jails, transportation, utilities, parks and recreation, etc…The most common uses for an APFO is for schools, roads, water and sewer. 

 

An APFO is not intended to stop growth, but to manage it in a responsible manner.  An APFO is also not a financing mechanism, but can work to regulate development to mirror pubic and private investments in infrastructure.

The staff has reviewed local and other jurisdictions APFO to determine the list of facilities that could be considered in an APFO.  Again, the most common use for an APFO is for schools, roads, water and sewer.  However, almost any facility could be included.

 

  • Roads
  • Schools
  • Water
  • Sewer
  • Government Buildings
  • Fleet Services
  • Emergency Services Fire/ Rescue (Office & Equipment – not personnel)
  • Emergency Services Police (Office & Equipment – not personnel)
  • Parks
  • Libraries
  • Storm Water Management
  • Affordable Housing
  • Jails

 

There are some facilities that would be difficult to manage in an APFO.  For example, Fire & Rescue is a County facility.  Fire & Rescue is also typically determined to be adequate by their response time or by the percentage of late and no responses to a call.  In the past the City has had little success in securing a new fire station.  At this time the only means by which the City can enhance Fire & Rescue service is through improved roads, enhanced fire codes and adequate water pressure.

 

Police is a City wide service that maybe difficult to include in an APFO.  If the desired threshold is 2.0 officers per 1,000, then once that threshold is not met the entire City would be shut down until the Mayor & Board fund the additional needed officers to meet that threshold.  If the Mayor & Board of Aldermen want to develop a policy that the City needs 2.0 officers per 1,000, then this issue could be monitored and addressed during the budget cycle. 

 

If it is the desire of the Mayor & Board of Aldermen, the City could be subdivide into areas for police service.  The most logical sub area would be the 5 existing beats. Then a methodology would need to be developed to ensure that adequacy is met in each of the beats.  This would prevent the entire City from being shut down from an inadequacy of sworn officers. 

 

The third way to address police is to establish an impact fee for police service.  A calculation could be made on the cost to outfit a new officer.  This impact can only be established for office space, training and equipment (not salary).  Then this fee would be asset on each dwelling unit. 

 

 

 

 

 

 

 

 

 

At the direction of the Mayor, staff quickly changed the Brunswick APFO for schools, water, sewer and roads to accommodate the City of Frederick.  Even with this quick turn around, each ordinance requires policy to be developed by the elected officials.  If the Mayor & Board of Aldermen decided to use Brunswick APFO as a model, the following decision need to be made:

 

  • Types of exemptions (page 5 Section 1.7 B)
  • Road Thresholds (page 10 & 11 Section 2.1 A & B)
  • Determine extent of road test (page 11 Section 2.2 A)
  • Water: maximum percentage of plant capacity for adequacy (page 13 Section 3.2)
  • Sewer: maximum percentage of plant capacity for adequacy (page 13 Section 4.2)
  • Schools maximum percentage for adequacies (page 14 Section 5.2 C)
  • Phasing adequacies for schools (page 16 Section 5.2 H)

 

These same policy decisions will need to be made with any type of growth management tool. 

 

The big problem implementing the Brunswick APFO model is dealing with the issue of existing approved – yet unbuilt developments.  The City has over 3,000 units in the development pipeline that have some type of approval.  It is difficult interjecting an APFO requirement on the entire residential project when it is half completed.  The issue becomes more complicated when there are several residential projects all moving forward at the time and an APFO requirement is imposed.  Which of the projects would proceed forward (if any) and which ones get placed on hold. 

 

Another way of looking at this problem is at the time of adoption of an APFO, there are three developments that are all grandfathered in because of approval of a preliminary plan.  Combined these three developments make an elementary school capacity reach 121% when they are completely built.  Which developments are allowed to move forward?  Can all three developments move forward without regard to school capacity? 

 

The staff believes that there may be several advantages to developing a combination of an Allocation and APFO.  Those advantages would include:

 

  • A system could be established that would require minimal grandfathering of development projects. 
  • A yearly policy decision by the Mayor & Board of Aldermen on the number of units to allocate based on City wide services and policy decisions.
  • The system could be developed into regions to target growth to areas of the City that can support growth or to areas of the City that are planned for growth.
  • The Water Allocation System is in place and has been working effectively.  The allocation system for dwelling units could mirror, with some modifications, the Water Allocation System.
  • After the allocation process, each development would need to pass the APFO test for the facilities that are included in the APFO.
  • If an allocation system is established, then a provision (allocation) could be made for MPDU, affordable housing and infill projects.
  • Other jurisdictions that have a similar process:  Howard County and Carroll County

 

 

 

 

 

The following issues are generic and staff believes that these should be included in any growth management tool. 

 

1)      Staff believes that for schools, if a project is held up by an APFO Test (in whatever form it takes) there should be a number of years that the project can be held up before allowing to proceed.  The 1998 School APFO draft staff suggested that 4 years be used as the sunset set provision.  This was include in the 1998 Draft as well as suggested today to deal with the issue that the City does not control the Board of Education’s CIP.  Howard County has a similar approach to avoid property owners challenging the APFO claiming that their development rights have been taken indefinitely.   This is another policy decision that will need to be made by the Mayor & Board of Aldermen.

2)      Staff would also recommend that a development only needs to pass each test once in an AFPO (in whatever form it takes).  For example if there are 5 tests and a development passes three the first year, in the second year this development would only need to be tested for the remaining two facilities.  This is another policy decision that will need to be made by the Mayor & Board of Aldermen.

3)      Staff would also recommend that a yearly report be issued to the Mayor & Board of Aldermen on a yearly basis indicating the status of the current facilities, number and status of projects in the system, and recommend CIP projects for the upcoming fiscal year.  

 

Staff has attached a flow chart that shows how both systems could work within our current system.  The attached flow chart is conceptual and is not the only way the process could work within our current system. 

 

 

RECOMMENDATION:  Staff would like direction on how to proceed with the APFO issue.

 

 

BACKUP INCLUDED:          1998 Staff Draft of the APFO for schools

                                                Staff Draft APFO modeled on Brunswick’s APFO

                                                Flowcharts

           

           

REVIEWED BY DEPARTMENT HEAD:    Charles W. Boyd 

 

CONCURRENCE BY:

                                                               Date                                                                       Date

FINANCE                          ________ _______        LEGAL       ________       ________

 

CITIZEN SERVICES                   ________ _______        FPD             ________       ________

 

DEPT. PUBLIC WORKS   ________           _______        PLANNING  ________       ________

 

ENGINEERING                 ________            _______        CIP              ________       ________