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CLAY COUNTY

DEVELOPMENT IMPACT FEE STUDY

ADMINISTRATIVE DRAFT

NOVEMBER 23, 2022

Oakland Office Corporate Office Other Regional Offices


66 Franklin Street 27368 Via Industria Aurora, CO
Suite 300 Suite 200 Orlando, FL
Oakland, CA 94607 Temecula, CA 92590 Phoenix, AZ
Tel: (510) 832-0899 Tel: (800) 755-6864 Plano, TX
Fax: (888) 326-6864 Seattle, WA
Washington, DC
www.willdan.com
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TABLE OF CONTENTS
EXECUTIVE SUMMARY .......................................................................... 4
Background and Study Objectives 4
Development Impact Fee Schedule Summary 4
Other Funding Needed 6
1. INTRODUCTION ........................................................................... 7
Study Objectives 7
Impact Fee Framework in Florida 7
Fee Program Maintenance 8
Study Methodology 8
Types of Facility Standards 8
New Development Facility Needs and Costs 9
Organization of the Report 10
2. DEVELOPMENT FORECAST ......................................................... 11
Land Use Types 11
Existing and Future Development 12
Occupant Densities 13
Land Use Category Consolidation 14
3. GOVERNMENT, JAILS, AND CONSTITUTIONAL FACILITIES ............... 16
Service Population 16
Facility Inventories and Standards 17
Existing Inventory 17
Existing Facility Standards 18
Existing Capacity 19
Potential Planned Facilities 19
Credit Component 19
Cost Allocation 20
Projected Fee Revenue 21
Fee Schedule 22
4. FIRE AND RESCUE FACILITIES .................................................... 23
Service Population 23
Facility Inventories and Standards 24
Existing Inventory 24
Existing Facility Standards 26
Planned Facilities 26
Credit Component 28
Cost Allocation 28
Projected Fee Revenue 29
Fee Schedule 30
5. LAW ENFORCEMENT FACILITIES ................................................. 31

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Clay County Development Impact Fee Study

Service Population 31
Facility Inventories and Standards 32
Existing Inventory 32
Existing Facility Standards 33
Planned Facilities 34
Credit Component 34
Cost Allocation 35
Projected Fee Revenue 36
Fee Schedule 37
6. NEIGHBORHOOD AND COMMUNITY PARKS ................................... 38
Service Population 38
Facility Inventories 38
Existing Parkland Inventory 38
Neighborhood and Community Park Standards 40
Comprehensive Plan Standards 40
Existing Facility Standards 40
Fee Benefit Districts 41
Parkland Unit Costs 43
Cost Allocation 44
Existing Deficiencies 44
Facilities Needed to Accommodate New Development 45
Credit Component 46
Net Cost per Resident 47
Fee Schedule 48
7. REGIONAL PARKS ..................................................................... 50
Service Population 50
Facility Inventories 50
Existing Parkland Inventory 50
Regional Park Standards 51
Planned Facilities 51
Credit Component 52
Parks Cost per Resident 53
Projected Fee Revenue 53
Fee Schedule 54
8. LIBRARY AND CULTURAL FACILITIES ............................................ 55
Service Population 55
Facility Inventories and Standards 55
Existing Inventory 55
Existing Facility Standards 57
Potential Planned Facilities 57
Credit Component 58
Cost Allocation 59
Projected Fee Revenue 59
Fee Schedule 60

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Clay County Development Impact Fee Study

9. IMPLEMENTATION ...................................................................... 61
Programming Revenues and Projects with the CIP 62
10. APPENDIX ................................................................................ 63

iii
Executive Summary
This report summarizes an analysis of development impact fees needed to support future
development in the Clay County through 2045. It is the County’s intent that the costs representing
future development’s share of public facilities and capital improvements be imposed on that
development in the form of a development impact fee, also known as a public facilities fee. The
public facilities and improvements included in this analysis are divided into the fee categories
listed below:
• Government, Jails, and • Neighborhood and
Constitutional Facilities Community Parks
• Fire and Rescue Facilities • Regional Parks
• Law Enforcement Facilities • Library and Cultural
Facilities

Background and Study Objectives


The primary policy objective of a development impact fee program is to ensure that new
development pays the capital costs associated with development. Although development also
imposes operating costs, there is not a similar system to generate revenue from new
development for services. The primary purpose of this report is to calculate and present fees that
will enable the County to expand its inventory of public facilities, as new development creates
increases in service demands.
All development impact fee-funded capital projects should be programmed through the County’s
five-year Capital Improvement Program (CIP). Using a CIP can help the County identify and
direct its fee revenue to public facilities projects that will accommodate future development. By
programming fee revenues to specific capital projects, the County can help ensure a reasonable
relationship between new development and the use of fee revenues.

Development Impact Fee Schedule Summary


Table E.1 summarizes the maximum justified development impact fee schedule that would meet
the County’s identified needs and does not unfairly overburden new development. The County
can adopt fees up to, but not exceeding these amounts.

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Clay County Development Impact Fee Study

E.1: Maximum Justified Development Impact Fees


Government, Neighborhood Library
Jails and Fire and Law and Regional and
Constitutional Rescue Enforcement Community Park Cultural
Land Use Demand Unit Facilities1 Facilities2 Facilities3 Parks4 Facilities1 Facilities1 Total

Residential (per Dwelling Unit)


Single Family (up to 1,500 sq. ft.) Dwelling Unit $ 527 $ 790 $ 781 $ 1,071 $ 234 $ 263 $ 3,666
Single Family (1,501 to 2,499 sq. ft.) Dwelling Unit 701 1,051 1,039 1,425 311 350 4,877
Single Family (2,500 sq. ft. and up) Dwelling Unit 877 1,315 1,300 1,784 389 438 6,103
Multifamily Dwelling Unit 464 696 688 944 206 232 3,230
Mobile Home Dwelling Unit 587 880 870 1,194 261 293 4,085
Senior Unit Dwelling Unit 392 588 581 798 174 196 2,729

Nonresidential (per 1,000 Sq. Ft., Hotel Room or Car Wash Tunnel)
Commercial: Retail and Services 1,000 Sq. Ft. $ 153 $ 1,011 $ 227 $ - $ - $ - $ 1,391
Car Wash Lane 126 835 187 - - - 1,148
Hotel/Lodging Room 40 267 60 - - - 367
Office 1,000 Sq. Ft. 235 1,555 349 - - - 2,139
Industrial 1,000 Sq. Ft. 84 553 124 - - - 761
Institutional 1,000 Sq. Ft. 190 1,258 282 - - - 1,730
Nursing Home 1,000 Sq. Ft. 147 973 218 - - - 1,338

1
Applicable Countyw ide.
2
Applicable in unincorporated areas and all cities except for the City of Orange Park.
3
Applicable in unincorporated areas plus the Cities of Keystone Heights and Penney Farms.
4
Applicable in unincorporated areas.

Sources: Tables 3.8, 4.8, 5.8, 6.11, 7.8 and 8.8.

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Other Funding Needed


Impact fees can only fund the share of public facilities attributable to new development in Clay
County. They cannot be used to fund the share of facility needs generated by existing
development. Table E.2 summarizes the net project costs, impact fee revenue projections and
non-fee funding required to fully fund the planned facilities identified in this report.
Note that the fire and rescue, law enforcement, neighborhood and community parks fees and
regional parks fees are driven by the cost of the planned facilities, which must be fully funded
otherwise new development has been overcharged. The project costs for the other fee categories
are equal to the projected impact fee revenue

Table E.2: Non-Impact Fee Funding Required


Additional
Fee Calculation Net Project Development Funding
Fee Category Methodology Cost Fee Revenue Required

Government, Jail, and Constitutional


Facilities 1 Existing Facility Standard $ 20,503,000 $ 20,503,000 $ -
Fire and Rescue Facilities System Standard 152,741,382 62,248,500 90,492,882
Law Enforcement Facilities System Standard 104,455,000 25,339,728 79,115,272
Neighborhood and Community Parks System Standard 47,864,483 24,249,000 23,615,483
Regional Parks System Standard 39,699,783 5,856,580 33,843,203
Library and Cultural Facilities 1 Existing Facility Standard 6,595,760 6,595,760 -
Total $ 371,859,408 $ 144,792,568 $ 227,066,840

1
Impact fees are calculated to fund facilities at the current facility standards, and are not driven by the cost of the planned facilities.
Additional funding is not required to collect impact fees, so long as the fee revenue is spent on capacity expanding facilities. Potential
project lists are provided for these facility categories to demonstrate the potential facilities that fee revenue may be spent on.

Sources: Tables 3.4, 3.7, 4.4, 4.7, 5.4, 5.7, 6.7, 6.8, 6.10, 7.4, 7.7, 8.4 and 8.7.

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1. Introduction
This report presents an analysis of the need for public facilities to accommodate new
development in the Clay County. This chapter provides background for the study and explains the
study approach under the following sections:
• Study Objectives;
• Impact Fee Framework in Florida;
• Fee Program Maintenance;
• Study Methodology; and
• Organization of the Report.

Study Objectives
Clay County is forecasted to experience significant growth through 2045. This development will
create an increase in demand for public services and the facilities required to deliver them. Given
the revenue challenges faced by local governments, Clay County has decided to use a
development impact fee program to ensure that new development funds the share of facility costs
associated with development. This report makes use of the most current available development
forecasts and facility plans to add six new impact fees to the County’s existing fee program to
ensure that the fee program accurately represents the facility needs resulting from new
development.

Impact Fee Framework in Florida


Impact fees are charged in many states throughout the Country. The fees are one-time charges,
typically paid at the time of building permit issuance. By paying impact fees, each new
development project will pay its proportional fair share of the cost of new capital facilities required
to serve that development.
Through case law, courts in Florida have developed guidelines for constitutionally-valid impact
fees, based on “rational nexus” standards. The standards essentially require that the fees must
be proportional to the need for additional infrastructure created by the new development and must
be spent in such a way as to provide that same type of infrastructure to benefit new development.
Beyond the case law, guidelines for the calculation and implementation of impact fees by local
jurisdictions are codified in Florida Statue 163.31801.1 The Act requires the calculation of impact
fees to be based on most recent and localized data. Administrative charges for the collection of
impact fees are limited to actual costs. The chief financial officer of the jurisdiction has specific
responsibilities for accounting and reporting collections and expenditures of impact fees.
As demonstrated in this report, Clay County has complied with the Florida Impact Fee Act and
applicable legal precedents. The impact fees are proportionate and reasonably related to the cost
of facilities needed to meet the demands of new development. Specific costs have been identified
using the most recent and local data available. With input from County staff, Willdan Financial
Services has estimated demand for each facility fee category included in the study, and
proportionately allocated responsibility for future facilities by the anticipated demand generated by
different types of development. Each fee category included in this report also identifies the extent

1 See Chapter 9 for key excerpts from Florida Statue 163.31801.

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Clay County Development Impact Fee Study

to which new development is entitled to various types of credits to avoid potential double payment
of growth-related capital costs.

Fee Program Maintenance


Once a fee program has been adopted it must be properly maintained to ensure that (1) the
revenue collected adequately funds the facilities needed by new development, and (2) the impact
fees do not exceed the reasonably anticipated costs associated with the improvements and
additions necessary to offset the demand generated by the new development on County facilities.
To avoid collecting inadequate revenue, the County must update inventories of existing facilities
and the costs for planned facilities, and then recalculate the fees to reflect the revised costs.
It is recommended to conduct periodic updates of the fee documentation and calculation (such as
this study) including when significant new data on development forecasts and/or facility plans
become available, though the Florida Impact Fee Act limits impact fee increases to not more than
once every four years.

Study Methodology
Development impact fees are calculated to fund the cost of facilities required to accommodate
development. The six steps followed in this development impact fee study include:
1. Estimate existing development and future development: Identify a base year for
existing development and a development forecast that reflects increased demand for
public facilities;
2. Identify facility standards: Determine the facility standards used to plan for new
and expanded facilities;
3. Determine facilities required to serve new development: Estimate the total
amount of planned facilities, and identify the share required to accommodate new
development;
4. Determine the cost of facilities required to serve new development: Estimate the
total amount and the share of the cost of planned facilities required to accommodate
new development;
5. Calculate fee schedule: Allocate facilities costs per unit of new development to
calculate the development impact fee schedule; and
6. Identify alternative funding requirements: Determine if any non-fee funding is
required to complete projects.
The key public policy issue in development impact fee studies is the identification of facility
standards (step #2, above). Facility standards document a reasonable relationship between new
development and the need for new facilities. Standards ensure that new development does not
fund deficiencies associated with existing development. An example of a facility standard is park
acres per 1,000 residents. Using such a standard, the analysis can estimate the amount of
parkland needed to serve the increase in population. Facility standards are identified for each
facility category included in this analysis. An in-depth discussion of facility standards is included
below.

Types of Facility Standards


There are three separate components of facility standards:
 Demand standards determine the amount of facilities required to accommodate
development, for example, park acres per thousand residents, square feet of library
space per resident, or gallons of water per day. Demand standards may also reflect a

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level of service such as the vehicle volume-to-capacity (V/C) ratio used in traffic
planning.
 Design standards determine how a facility should be designed to meet expected
demand, for example, park improvement requirements and technology infrastructure
for County office space. Design standards are typically not explicitly evaluated as part
of an impact fee analysis but can have a significant impact on the cost of facilities.
Our approach incorporates the cost of planned facilities built to satisfy the County’s
facility design standards.
 Cost standards are an alternate method for determining the amount of facilities
required to accommodate development based on facility costs per unit of demand.
Cost standards are useful when demand standards were not explicitly developed for
the facility planning process. Cost standards also enable different types of facilities to
be analyzed based on a single measure (cost or value). Examples include facility
costs per resident, cost per vehicle trip, or cost per gallon of water per day.

New Development Facility Needs and Costs


A number of approaches are used to identify facility needs and costs to serve new development.
This is often a two-step process: (1) identify total facility needs, and (2) allocate to new
development its fair share of those needs.
There are three common methods for determining new development’s fair share of planned
facilities costs: the existing inventory method, the system plan method and the planned
facilities method. Often the method selected depends on the degree to which the community
has engaged in comprehensive facility master planning to identify facility needs.
The formula used by each approach and the advantages and disadvantages of each method are
summarized below:

Existing Inventory Method


The existing inventory method allocates costs based on the ratio of existing facilities to demand
from existing development as follows:
Current Value of Existing Facilities
= $/unit of demand
Existing Development Demand
Under this method new development funds the expansion of facilities at the same standard
currently serving existing development. By definition, the existing inventory method results in no
facility deficiencies attributable to existing development. This method is often used when a long-
range plan for new facilities is not available. Future facilities to serve development are identified
through an annual capital improvement program and budget process, possibly after completion of
a new facility master plan. This approach is used to calculate the government, jails, and
constitutional facilities, and library and cultural facilities fees in this report.

System Plan Method


This method calculates the fee based on the value of existing facilities plus the cost of planned
facilities, divided by demand from existing plus new development:
Value of Existing Facilities + Cost of Planned Facilities
= $/unit of demand
Existing + New Development Demand
This method is useful when planned facilities need to be analyzed as part of a system that
benefits both existing and new development. It is difficult, for example, to allocate a new fire
station solely to new development when that station will operate as part of an integrated system
of fire stations that together achieve the desired level of service.

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Clay County Development Impact Fee Study

The system plan method ensures that new development does not pay for existing deficiencies.
Often facility standards based on policies such as those found in General Plans are higher than
the existing facility standards. This method enables the calculation of the existing deficiency
required to bring existing development up to the policy-based standard. The local agency must
secure non-fee funding for that portion of planned facilities required to correct the deficiency to
ensure that new development receives the level of service funded by the impact fee. This
approach is used to calculate the fire and rescue facilities, law enforcement facilities,
neighborhood and community parks and regional parks fees in this report.

Planned Facilities Method


The planned facilities method allocates costs based on the ratio of planned facility costs to
demand from new development as follows:
Cost of Planned Facilities
= $/unit of demand
New Development Demand
This method is appropriate when planned facilities will entirely serve new development, or when a
fair share allocation of the cost of planned facilities to new development can be estimated. An
example of the former is a wastewater trunk line extension to a previously undeveloped area. An
example of the latter is expansion of an existing library building and book collection, which will be
needed only if new development occurs, but which, if built, will in part benefit existing
development, as well. Under this method new development funds the expansion of facilities at the
standards used in the applicable planning documents. This method is not used in this study.

Organization of the Report


The determination of a public facilities fee begins with the selection of a planning horizon and
identification of development projections for population and employment. These projections are
used throughout the analysis of different facility categories and are summarized in Chapter 2.
Chapters 3 through 8 identify facility standards and planned facilities, allocate the cost of planned
facilities between new development and other development, and identify the appropriate
development impact fee for each of the following facility categories:
• Government, Jails and • Neighborhood and
Constitutional Facilities Community Parks
• Fire and Rescue Facilities • Regional Parks
• Law Enforcement Facilities • Library and Cultural
Facilities

Chapter 9 highlights key portions of the Florida Impact Fee Act and details the procedures that
the County must follow when implementing a development impact fee program.

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2. Development Forecast
Development projections are used as indicators of demand to determine facility needs and
allocate those needs between existing and new development. This chapter explains the source
for the development projections used in this study based on a 2021 base year and a planning
horizon of 2045.
Estimates of existing development and projections of future development are critical assumptions
used throughout this report. These estimates are used as follows:
▪ The estimate of existing development in 2021 is used as an indicator of existing
facility demand and to determine existing facility standards.
▪ The estimate of total development in 2045 is used as an indicator of future
demand to determine total facilities needed to accommodate development and
remedy existing facility deficiencies, if any.
▪ Estimates of development from 2021 through 2045 are used to (1) allocate
facility costs between new development and existing development, and (2)
estimate total fee revenues.
The demand for public facilities is based on the service population, dwelling units or
nonresidential development creating the need for the facilities. The service populations for all
facilities included in this study include a varying weighted number of workers, to reflect varying
levels of demand for facilities.

Land Use Types


To ensure a reasonable relationship between each fee and the type of development paying the
fee, development projections distinguish between different land use types. The land use types
that impact fees have been calculated for are defined below.
▪ Single Family: Detached and attached single-family dwellings, including
townhomes. Detached single family homes are one-unit structures detached from
any other houses. Attached single family homes (also known as townhomes or
row houses) are one-unit structures that have one or more walls extending from
ground to roof separating them from adjoining structures. Fees for this land use
are charged on the square footage of each dwelling unit, in three categories: up
to 1,500 square feet, 1,501 to 2,499 square feet, and 2,500 square feet and
greater.
▪ Multifamily: All attached multifamily dwellings such as duplexes, condominiums,
plus mobile homes, apartments, and dormitories. These are units in structures
containing two or more housing units. Second dwelling units on single family lots
are also included in the other multifamily land use category.
▪ Mobile home: Includes manufactured mobile homes.
▪ Senior Unit: All age restricted housing units.
▪ Commercial- Retail and Services: Uses for which the floor area is primarily
devoted to retail sale of goods or services (or the adjacent storage of goods for
retail sale) to the general public or to small businesses. Examples of retail uses
include, but are not limited to: restaurants, automobile dealerships, automobile
care and body repair centers, movie theaters, specialty retail centers containing a
variety of retail shops specializing in quality apparel, hard goods, and services
such as travel agencies, dance studios, tutoring services and florists.

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Clay County Development Impact Fee Study

▪ Car Wash: Uses that allow for the manual or automatic cleaning of automobiles.
Fees assessed per car wash tunnel.
▪ Hotel/Lodging - Lodging including hotel, motel and resort development. Fees
charged per lodging room
▪ Office: Uses for which the floor area is primarily devoted to office and meeting
spaces. Examples of office uses are: Professional services (legal, engineering,
accounting), investment broker, real estate office, advertising agency, social
services, insurance, bank, or savings and loan institutions.
▪ Industrial: All manufacturing and warehouse development.
▪ Institutional: The institutional use category includes non-commercial uses such
as hospitals, schools, social or religious institutions, and public institutions.
▪ Nursing Home: Nursing homes and similar facilities that provide a combination
of residential care with nursing and/or personal care as required by the residents
are included in this category.
Some developments may include more than one land use type, such as a mixed-use
development with both multifamily and commercial uses. In those cases, the facilities fee would
be calculated separately for each land use type.
The County has the discretion to determine which land use type best reflects a development
project’s characteristics for purposes of imposing an impact fee and may adjust fees for special or
unique uses to reflect the impact characteristics of the use.

Existing and Future Development


Table 2.1 shows the estimated number of permanent residents, seasonal residents, employment
(jobs within the County boundaries), in Clay County, both in 2021 and in 2045. These estimates
factor into the calculation of the fees for all fee categories.
The estimate of existing residents comes from University of Florida Bureau of Economic and
Business Research (BEBR) data. The projection of residents in 2045 was estimated by BEBR
and is the “medium” growth scenario provided by the Bureau.
The estimate of 54,412 employees in 2021 is based on an estimate of 53,710 workers in 2019
from OnTheMap.ces.census.gov, which was adjusted to 2021 using the historical compound
annual growth rate from 2009 to 2019 from OnTheMap data. OnTheMap data was also used to
identify the estimates of employees in each incorporated city within the County. The projection of
156,073 jobs in 2045 is from the County's 2020 Mobility Fee Study. Jobs are allocated to each
jurisdiction proportionally to current employment estimates in each city.

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Clay County Development Impact Fee Study

Table 2.1: Existing and New Development


2021 2045 Increase

Residents 1
Green Cove Springs 9,959 12,516 2,557
Keystone Heights 1,454 1,827 373
Orange Park 9,126 11,469 2,343
Penney Farms 826 1,038 212
Unincorporated 200,075 251,450 51,375
Total 221,440 278,300 56,860

Employment 2
Green Cove Springs 9,377 26,897 17,520
Keystone Heights 537 1,540 1,003
Orange Park 5,828 16,717 10,889
Penney Farms 191 548 357
Unincorporated 38,479 110,371 71,892
Total 54,412 156,073 101,661

1
Existing residents from University of Florida Bureau of Economic and
Business Research (BEBR) data. Projection of Countyw ide residents in
2045 estimated by BEBR, medium scenario.
2
Estimate of 2021 employment based on data from
OnTheMap.ces.census.gov for 2019 adjusted to 2021 using 10-year
Countyw ide compound annual employment grow th rate from 2010 to
2019. Projection of 156,073 jobs in 2045 from the County's 2020 Mobility
Fee Study allocated to each jurisdiction proportionally to current
estimates.

Sources: University of Florida, Bureau of Economic and Business


Research, 2021; U.S. Census Bureau LEHD Origin-Destination
Employment Statistics (2009-2019) accessed at
https://onthemap.ces.census.gov; Clay County Mobility Fee Report, 2020;
Willdan Financial Services.

Occupant Densities
All fees in this report are calculated based on dwelling units or building square feet. Because
service demand is based on population, it is necessary to use occupant density assumptions to
calculate per-unit and per-square-foot fees. Occupant density assumptions ensure a reasonable
relationship between the size of a development project, the increase in service population
associated with the project, and the amount of the fee.
Occupant densities (residents per dwelling unit or workers per building square foot) are the most
appropriate characteristics to use for most impact fees. The fee imposed should be based on the
land use type that most closely represents the probable occupant of the development.
The average occupant density factors used in this report are shown in Table 2.2. The residential
occupant density factors for both the various types of dwelling units were calculated using the
most recently available data from US Census’ American Community Survey specific to the Clay
County. Table B25033 identifies the estimated population, by type of dwelling unit. Table B25024
identifies the total amount of dwelling units, by type. The estimates for single family units were
further adjusted with data from the 2013 American Housing Survey (AHS) specific to the

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Clay County Development Impact Fee Study

Jacksonville MSA. The 2013 AHS data is the most recent and local data available from that
source for the Jacksonville MSA. Refer to Appendix Table A.1 for further detail.
The nonresidential occupancy factors are calculated based on data from the most recent Institute
of Transportation Engineers (ITE) Trip Generation Manual, 11th Edition. The transportation survey
data reported in this resource per 1,000 building square foot or per employee can be cross
referenced for each land use to calculate the number of employees per 1,000 square feet for
building space for each land use included in the survey.

Table 2.2: Occupant Density

Residential
Single Family (up to 1,500 sq. ft.)1 2.27 Residents per dwelling unit
Single Family (1,501 to 2,499 sq. ft.)1 3.02 Residents per dwelling unit
Single Family (2,500 sq. ft. and up)1 3.78 Residents per dwelling unit
Multifamily 2.00 Residents per dwelling unit
Mobile Home 2.53 Residents per dwelling unit
Senior Unit 2 1.69 Residents per dwelling unit

Nonresidential
Commercial: Retail and Services 2.12 Employees per 1,000 square feet
Car Wash3 1.75 Employees per Lane
Hotel/Lodging 0.56 Employees per Room
Office 3.26 Employees per 1,000 square feet
Industrial 1.16 Employees per 1,000 square feet
Institutional4 2.64 Employees per 1,000 square feet
Nursing Home 2.04 Employees per 1,000 square feet

1
See Appendix Table A.1.
2
Derived from American Housing Survey and American Community Survey data for Jacksonville MSA.
3
Data unavailable by employee in ITE trip generation manual. Assumption consistent w ith other recent
Florida impact fee studies.
4
Average employees per 1,000 square feet across institutional uses.

Sources: U.S. Census Bureau, 2020 American Community Survey 5-Year Estimates Table B25033 and 1-
Year Estimates Table B25024; 2013 American Community Survey 1-Year Estimates Table S101 for
Jacksonville MSA; 2013 American Housing Survey for Jacksonville MSA; ITE Trip Generation Manual,
11th Edition, 2021; Appendix Table A.1, Willdan Financial Services.

Land Use Category Consolidation


The County currently charges a mobility fee to fund transportation improvements. That fee
program charges impact fees for a variety of land uses based on the expected trip generation of
each land use. While this approach is appropriate for transportation-related fees, the fees
included in this study are not based on transportation trip demand, rather they are based on
residential and nonresidential occupant density. As such the land use categories in this fee study
can be consolidated based on similar occupant densities and several categories from the mobility
fee study can nestle into the categories presented in this study. Further, commercial development
has the potential to change over time. Developers often build shell buildings and then tenants
make improvements and a building make house several related uses over time as tenants
change. Using generalized employment densities to allocate impact fees reasonably allows for

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Clay County Development Impact Fee Study

changes in commercial building use. Table 2.3 summarizes how the mobility fee land use
categories relate to the land use categories used in this study.

Table 2.3: Land Use Category Crosswalk


Mobility Fee Land Use Category Development Impact Fee Study Category

Single Family (less than 1,500 sqft) Single Family (less than 1,500 sqft)
Single Family (1,500 sqft to 2,499 sqft) Single Family (1,500 sqft to 2,499 sqft)
Single Family ( > 2,499 sqft) Single Family ( > 2,499 sqft)
Multiple Family (apartment) Multifamily
Multiple Family (mid-rise) Multifamily
Mobile Home Mobile Home
Continuing Care Retirement Community Senior Unit
Recreational Home/Vehicle Mobile Home
Hotel Hotel/Lodging
Motel Hotel/Lodging
Warehouse Industrial
Mini-Warehouse Industrial
Manufacturing Industrial
Marina Commercial: Retail and Services 1
Carwash Carwash
Nursery (Garden Center) Commercial: Retail and Services
Nursery (Wholesale) Commercial: Retail and Services
Hardware Store Commercial: Retail and Services
Retail Shopping Center Commercial: Retail and Services
Discount Club Commercial: Retail and Services
Electronics Superstore Commercial: Retail and Services
Pharmacy/Drugstore Commercial: Retail and Services
Tire Superstore Commercial: Retail and Services
Furniture Store Commercial: Retail and Services
General Office Building Office
Research & Development Center Office
University / College / Jr College Institutional
Private School, K-12 Institutional
Hospital Institutional
Nursing Home Nursing Home
Place of worship Institutional

1
Fees to be assessed based on square footage of buildings on site, not berths.

Sources: Clay County Mobility Fee Report, October 27, 2020; Willdan Financial Services.

15
3. Government, Jails, and
Constitutional Facilities
The purpose of the government, jails, and constitutional facilities impact fee is to fund the
government, jails, and constitutional facilities needed to serve new development.

Service Population
Government, jails, and constitutional facilities serve both residents and businesses. Therefore,
demand for services and associated facilities are based on the County’s service population
including residents and workers weighted to account for varying levels of demand for facilities.
The resulting service population is expressed in terms of resident equivalents.
Table 3.1 shows the existing and future projected service population for government, jails, and
constitutional facilities. While specific data is not available to estimate the actual ratio of demand
per resident to demand by businesses (per worker) for this service, Willdan believes it is
reasonable to assume that demand for these services is less for one worker compared to one
resident, because nonresidential buildings are typically occupied less intensively than dwelling
units and the demand for services is liked more closely to the workday or business hours. The
0.31-weighting factor for workers approximates relative demand for facilities for people who work
in the County relative to residents. This worker weighting factor is based on a 40-hour workweek
divided by the total number of non-work hours in a week (128) and therefore reflects the degree
to which nonresidential development yields a lesser demand for government, jails, and
constitutional facilities.
This approach assumes the following:
1. People generate demand for these types of facilities when they are physically within the
County. People who work in the County but do not live in the County only generate
demand for these facilities for the 40 hours that they are physically in the County.
2. People who live in the County may or may not also work in the County. Demand for those
who both live and work in the County is captured partially in the residential weighting
factor (128 nonwork hours per week / 168 total hours per week), and partially in the
worker weighting factor (40 work hours per week / 168 total hours per week), to account
for all 168 hours in a week.
3. Demand for one worker is compared to demand from one resident, which results in the
worker weighting factor of 0.3125 (rounded to 0.31 in this analysis). (40/168) / (128/168)
= 0.3125.

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Clay County Development Impact Fee Study

Table 3.1: Government, Jails, and Constitutional


Facilities Service Population
A B Ax B=C
Weighting Service
Persons Factor Population

Countywide
Residents
Existing (2021) 221,440 1.00 221,440
New Development 56,860 1.00 56,860
Total (2045) 278,300 278,300

Work ers 1
Existing (2021) 54,412 0.31 16,868
New Development 101,661 0.31 31,515
Total (2045) 156,073 48,383

Combined Weighted Service Population (Resident Equivalents)


Existing (2021) 238,308
New Development 88,375
Total (2045) 326,683

1
Workers are w eighted at 0.31 of residents based on a 40 hour w ork w eek out of
a possible 128 non-w ork hours in a w eek (40/128 = 0.31)

Sources: Table 2.1; Willdan Financial Services.

Facility Inventories and Standards


This section describes the County’s government, jails and constitutional facility inventory and
facility standards.

Existing Inventory
Table 3.2 shows the existing government, jails, and constitutional facility inventory. The
replacement cost for the buildings is based on the insured replacement cost for each building in
the County’s insurance property schedule. The assumed value of County owned land is
consistent with the current appraised market value of each parcel identified by the Clay County
Property Appraiser. The table also includes the replacement value of the County’s government,
jails, and constitutional vehicle fleet. In total, the County owns approximately $101.8 million worth
of government, jails, and constitutional facilities.

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Clay County Development Impact Fee Study

Table 3.2: Existing Government, Jails, and Constitutional Facilities


Inventory
Inventory Units Unit Cost Total Value

Land (acres) 1
Administration Building2 2.53 acres $ 427,297 $ 1,081,060
Animal Care and Control 10.58 acres 1,040 11,000
County Maintenance Yard 21.46 acres 6,666 143,063
Fleming Island Office Building3 1.49 acres 284,901 424,503
Sheriff's and Jail Complex 2.43 acres 429,593 1,043,910
Judge William A. Wilkes Judicial Complex 3.65 acres 389,812 1,422,812
Subtotal - Land 42.14 acres $ 4,126,348

Buildings 1
Administration Building 71,724 sq. ft. $ 216 $ 15,505,800
Animal Care and Control 12,745 sq. ft. 23 290,240
County Maintenance Yard 22,198 sq. ft. 22 482,990
Fleming Island Office Building 34 17,130 sq. ft. 111 1,900,000
Judge William A. Wilkes Judicial Complex 109,436 sq. ft. 327 35,815,280
Sheriff's and Jail Complex 56,640 sq. ft. 642 36,344,400
Subtotal - Buildings 218,149 $ 90,338,710

Vehicles 306 vehicles $ 23,920 $ 7,319,635

Total Value - Existing Facilities $ 101,784,693

1
Land and building values consistent w ith 2022 certified taxable values from Clay County Property Assessor.
2
Total parcel valued at $1,469,900. Only 2.53 of 3.44 acres are used for government uses, so value has been
adjusted proportionally.
3
Only 1 out of 3 buildings is used for County purposes. Consequently only one third of assessed value is included
for this property.
4
Only 1 out of 3 buildings is used for County purposes. Consequently only one third of the insured replacement
cost is included for this building.

Sources: Clay County; Clay County Property Assessor; Preferred Government Insurance Trust Property Schedule,
10/01/2022 through 10/01/2023; Willdan Financial Services.

Existing Facility Standards


Table 3.3 displays the County’s current government, jails, and constitutional facility infrastructure
standards expressed in terms of units per 1,000 resident equivalents. Impact fees calculated
using the existing standard methodology can provide a funding source from new development to
ensure that these standards are maintained as new development creates additional demand for
facilities.

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Clay County Development Impact Fee Study

Table 3.3: Existing Facility Standards


Achieved
Facility
Existing Standard per
Service 1,000 Resident
Component Quantity Units Population Equivalents

Land 42.14 Acres 238,308 0.18


Buildings 218,149 Sq. Ft. 238,308 915.41
Vehicles 306 Vehicles 238,308 1.28

Sources: Tables 3.1 and 3.2.

Existing Capacity
The facilities included in this impact fee category are at capacity and need to be expanded to
maintain the existing facility standards expressed above. The County is pursing leases to expand
its administrative government functions because it no longer has adequate space at County
owned facilities.
The jail is also out of capacity. The 2021 average inmate population was 479 inmates. Per the
Clay County Sheriff’s Office, 80% jail occupancy is considered to be at full capacity. The jail holds
492 inmates in total, 80% of which is 394, which compared to the 2021 average inmate
population indicates that the current jail should be expanded going forward.

Potential Planned Facilities


Clay County’s capital improvement program includes three new unfunded capacity expanding
facilities within the government, jails and constitutional facility fee category. Table 3.4 presents
the cost estimates of these facilities. These facility costs represent a standard greater than the
existing facility standard, and the impact fees will not fully fund them. The costs do not drive the
fee calculation and are listed here to demonstrate the potential uses of fee revenue.

Table 3.4: Potential Government/Jail/Constitutional Facilities


Cost

Fleet Maintenance Facility 1 $ 12,000,000


New Jail / P-Farm 50,000,000
New Judicial Services Building 25,000,000
Total $ 87,000,000

1
Cost show n is government/jail/constitutional facilities fee share of these facilities. One third
of the costs are allocated to the public safety facilities fee, and one third is allocated to the
law enforcement facilities fee.

Source: Clay County Capital Improvement Program, FY 21-22.

Credit Component
To avoid overcharging new development for the capital cost of facilities and infrastructure, a
review of the capital financing program for government, jails, and constitutional facilities was

19
Clay County Development Impact Fee Study

completed. The purpose of this review was to identify any potential revenues generated by new
development, other than impact fees, that are programmed to fund expansion of capital facilities,
land, and equipment over the next five years.
Capital expenditure credits per resident equivalent were calculated based on the non-impact fee
revenue expenditures planned for capital expansion projects from FY2022 to FY2026 identified in
the County’s FY2022 Capital Improvement Program. The average annual capital expansion
expenditures are divided by the average service population over the next five years to determine
the capital expenditure per resident equivalent for the five-year period.
The present value of the resulting average annual capacity expansion expenditures per resident
equivalent is then calculated using a discount period of 20 years, and a 3.90% discount rate.2 The
result is the revenue credit per resident equivalent which represents new development’s
contribution to capital facilities from sources other than impact fees. Table 3.5 details these
calculations.

Table 3.5: Government, Jails, and Constitutional Facilities Capital


Expansion Expenditures Credit
Fully Funded Capital FY 2022 FY 2023 FY 2024 FY 2025 FY 2026 Five Year
Projects Current Proposed Proposed Proposed Proposed Total

Animal Services Building $ 972,408 $ 4,200,000 $ 10,800,000 $ - $ - $ 15,972,408


Multi-Agency Storage
Warehouse Share - - 150,000 150,000 - 300,000
Public Works Building 687,404 650,000 - - - 1,337,404
Total Capital Funding1 $ 1,659,812 $ 4,850,000 $ 10,950,000 $ 150,000 $ - $ 17,609,812

Service Population2 241,461 244,655 247,892 251,171 254,494

Average Annual Capacity Expansion Expenditures $ 3,521,962


Average Service Population (2022 to 2026) 247,935
Average Annual Capacity Expansion Expenditures per Resident Equivalent $ 14.21

Discount Period (in years) 20


Discount Rate3 3.90%
Total Revenue Credit per Resident Equivalent $ (195)

1
Clay County CIP.
2
Based on 1.32% compound annual grow th rate from 2021 to 2045 calculated from service population projections.
3
Average 20-year interest rate as of November 19, 2022 for AAA municipal bonds at w w w .fmsbonds.com/market-yields/

Sources: Clay County Capital Improvement Program; w w w .fmsbonds.com/market-yields/; Willdan Financial

Cost Allocation
Table 3.6 calculates the County’s existing investment in government, jails, and constitutional
facilities per resident equivalent. This facility standard is calculated by dividing value of the
County’s existing facility inventory by the existing service population. The revenue credit per
resident equivalent is subtracted from the existing cost per resident equivalent. The resulting net
cost per resident equivalent is multiplied by the worker weighting factor of 0.31 to determine the

2 Average 20-year interest rate as of November 19, 2022 for AAA municipal bonds at
www.fmsbonds.com/market-yields/

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Clay County Development Impact Fee Study

net cost per worker. Note that the value of the existing inventory of government, jails, and
constitutional facilities drives this facility standard and subsequent fee calculation, not the cost of
the planned facilities.

Table 3.6: Government, Jails, and Constitutional


Facilities Existing Cost Standard

Value of Existing Facilities $ 101,784,693


Existing Service Population 238,308

Cost per Resident Equivalent $ 427


Less Revenue Credit (195)
Net Cost per Resident Equivalent $ 232

Facility Standard per Resident $ 232


Facility Standard per Worker1 72

1
Based on a w eighing factor of 0.31.

Sources: Tables 3.1, 3.3 and 3.5.

Projected Fee Revenue


The County plans to use government, jails, and constitutional facilities fee revenue to construct
improvements to add to the system of government, jails, and constitutional facilities to serve new
development. Table 3.7 details a projection of fee revenue based on the increase in service
population calculated in Table 3.1. Fee revenue projections are identified for the unincorporated
areas of the County, and for the incorporated cities. Impact fee revenue will not be sufficient to
fully fund all the potential project costs identified above. However, so long as the County spends
the collected fee revenue on capacity expanding government, jails, and constitutional facilities,
then new development will have contributed its fair share towards these facilities.

Table 3.7: Revenue Projection - Existing Standard


Unincorporated Incorporated
Areas Cities Total

Cost per Resident Equivalent $ 232 $ 232 $ 232


Growth in Service Population (2022 - 2045) 73,662 14,713 88,375
Fee Revenue $ 17,089,584 $ 3,413,416 $ 20,503,000

Net Cost of Potential Facilities $ 87,000,000


Unfunded Costs $ (66,497,000)

Sources: Tables 3.1, 3.4 and 3.6.

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Clay County Development Impact Fee Study

Fee Schedule
Table 3.8 shows the maximum justified government, jails, and constitutional facilities fee
schedule. The facility standard cost per costs per resident and worker are converted to a fee per
unit of new development based on dwelling unit and employment densities per demand unit
identified in Table 2.2.

Table 3.8: Maximum Justified Government, Jails, and Constitutional


Facilities Fee Schedule
A B C=Ax B D = C / 1,000
Cost Per
Resident Fee per
Land Use Demand Unit Equivalent Density Fee 1 Sq. Ft.

Residential - per Dwelling Unit


Single Family (up to 1,500 sq. ft.) Dwelling Unit $ 232 2.27 $ 527
Single Family (1,501 to 2,499 sq. ft.) Dwelling Unit 232 3.02 701
Single Family (2,500 sq. ft. and up) Dwelling Unit 232 3.78 877
Multifamily Dwelling Unit 232 2.00 464
Mobile Home Dwelling Unit 232 2.53 587
Senior Unit Dwelling Unit 232 1.69 392

Nonresidential
Commercial: Retail and Services 1,000 Sq. Ft. $ 72 2.12 $ 153 $ 0.15
Car Wash Lane 72 1.75 126 n/a
Hotel/Lodging Room 72 0.56 40 n/a
Office 1,000 Sq. Ft. 72 3.26 235 0.24
Industrial 1,000 Sq. Ft. 72 1.16 84 0.08
Institutional 1,000 Sq. Ft. 72 2.64 190 0.19
Nursing Home 1,000 Sq. Ft. 72 2.04 147 0.15

1
Fee per demand unit.

Sources: Tables 2.2 and 3.6.

22
4. Fire and Rescue Facilities
The purpose of the fire and rescue facilities impact fee is to fund the fire and rescue facilities
needed to serve new development.

Service Population
Fire and rescue facilities serve both residents and businesses Countywide, except for the Town
of Orange Park. Therefore, demand for services and associated facilities are based on the
County’s service population in the fire and rescue service area including residents and workers
weighted to account for varying levels of demand for facilities. The resulting service population is
expressed in terms of resident equivalents.
Table 4.1 shows the existing and future projected service population for fire and rescue facilities.
It is reasonable to assume that residential and nonresidential locations have varying amounts of
demand for these services. Consequently, to calculate service population for fire and rescue
facilities, residents are weighted at 1.00.
The use of a worker demand factor of 1.37 for workers in Clay County is based on an analysis of
calls for service, categorized by land use, in the County from November 2021 to November 2022.
Total calls to residential land uses were divided by the residential population to yield an annual
calls-per-capita factor. Dividing total calls to nonresidential areas by total employment in the City
yielded a comparable per-capita factor. The ratio of the worker per capita factor to the resident
per capita factor is the worker demand factor used in the analysis. See Appendix Tables A.2
and A.3 for a detailed worker weighting analysis.

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Clay County Development Impact Fee Study

Table 4.1: Fire and Rescue Facilities Service


Population
A B Ax B=C
Weighting Service
Persons Factor Population

All Jurisdictions Except for Orange Park


Residents
Existing (2021) 212,314 1.00 212,314
New Development 54,517 1.00 54,517
Total (2045) 266,831 266,831

Work ers 1
Existing (2021) 48,584 1.37 66,560
New Development 90,772 1.37 124,358
Total (2045) 139,356 190,918

Combined Weighted Service Population (Resident Equivalents)


Existing (2021) 278,874
New Development 178,875
Total (2045) 457,749

1
Workers are w eighted at 1.37 relative to residents based on an analysis of
Clay County Fire and Rescue call data. See Appendix Tables A.2 and A.3 for
more detail.

Sources: Tables 2.1, A.2 and A.3, Willdan Financial Services.

Facility Inventories and Standards


This section describes the County’s fire and rescue facility inventory and facility standards.

Existing Inventory
Table 4.2 shows the existing fire and rescue facility inventory. The replacement cost for the
buildings is based on the insured replacement cost for each building in the County’s insurance
property schedule. The assumed value of County owned land is consistent with the current
appraised market value of each parcel identified by the Clay County Property Appraiser. In total,
the County owns approximately $26.4 million worth of fire and rescue facilities, including land,
buildings, vehicles and apparatus.

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Clay County Development Impact Fee Study

Table 4.2: Existing Fire and Rescue Facilities Inventory


Inventory Unit Unit Cost Total Value

Land (acres)
Clay County Emergency Services Complex 9.77 acres $ 13,252 $ 129,469
Clay Hill Fire Station 13 1.32 acres 23,674 31,250
Doctors Inlet Fire Station 17 0.52 acres 19,231 10,000
Fire Station 11 0.93 acres 9,871 9,180
Fleming Island Fire Station 22 0.98 acres 81,633 80,000
Lake Asbury Fire Station 15 1.12 acres 6,696 7,500
McRae Fire Station 23 1.02 acres 10,098 10,300
Middleburg Fire Station 14 1.73 acres 66,080 114,318
Oakleaf Plantation Fire Station 26 1.23 acres 126,607 155,727
Oakridge Fire Station 20 0.60 acres 54,288 32,573
Orange Park Fire Station 18 0.65 acres 537,097 349,113
Subtotal 19.87 $ 929,430

Buildings (square feet)


Clay County Emergency Services Complex 26,557 sq. ft. $ 215 $ 5,717,200
Clay Hill Fire Station 13 4,160 sq. ft. 89 369,440
Doctors Inlet Fire Station 17 3,860 sq. ft. 110 423,650
Fire Station 11 10,165 sq. ft. 246 2,500,000
Fleming Island Fire Station 22 4,449 sq. ft. 102 452,430
Lake Asbury Fire Station 15 4,776 sq. ft. 16 76,000
McRae Fire Station 23 5,380 sq. ft. 10 52,800
Middleburg Fire Station 14 9,226 sq. ft. 87 800,630
Oakleaf Plantation Fire Station 26 7,203 sq. ft. 162 1,168,910
Oakridge Fire Station 20 3,813 sq. ft. 25 97,000
Orange Park Fire Station 18 2,585 sq. ft. 235 607,380
Subtotal 82,174 $ 12,265,440

Vehicles and Apparatus


Aerial Ladder Truck 1 $ 841,510 $ 841,503
Ambulance 18 159,616 2,873,089
Brush Truck 4X4 2 - -
Contender Pumper 3 306,400 919,176
Expedition 2 28,450 56,890
F550 4x4 Brush Truck 1 42,320 42,320
Fire Truck 12 253,220 3,038,589
Fire Truck - Typhoon 1 502,720 502,714
Fire Truck - V234 1 226,660 226,659
Fire Truck / Tanker 1 146,820 146,818
Firefighting Unit 2 - -
Freighliner Pumper 2 420,880 841,754
Ladder / 85 1 566,410 566,401
M2 1 103,880 103,879
M2-106 2 101,660 203,317
Pumper 6 331,290 1,987,713
Tanker 4 210,120 840,479
Subtotal 60 $ 13,191,301

Total Value - Existing Facilities $ 26,386,171

Sources: Clay County; Clay County Property Assessor; Preferred Government Insurance Trust Property Schedule,
10/01/2022 through 10/01/2023; Willdan Financial Services.

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Clay County Development Impact Fee Study

Existing Facility Standards


Table 4.3 displays the County’s current fire and rescue facility infrastructure standards expressed
in terms of units per 1,000 resident equivalents (calculated in Table 4.1). The County’s current
Countywide level of service in terms of response time is an average response time of 7:42 per
911 call.

Table 4.3: Existing Facility Standards


Achieved
Facility
Existing Standard per
Service 1,000 Resident
Component Quantity Units Population Equivalents

Land 19.87 Acres 278,874 0.07


Buildings 82,174 Sq. Ft. 278,874 294.66
Vehicles 60 Vehicles 278,874 0.22

Sources: Tables 4.1 and 4.2.

Planned Facilities
The County plans to construct a joint use public safety/sheriff facility, a fleet maintenance facility,
eight new fire stations (including equipment), to relocate and make capacity expanding
improvements at four existing stations, and to rebuild an existing station with greater capacity to
serve both existing and new development within the County. The cost of these facilities is shown
in Table 4.4.
The cost estimates for new stations are based on the average cost of construction bids for three
stations in Clay County in 2022. The average station size for these future stations is 14,167
square feet and represents the type of stations that the County will continue to build. The cost of
land acquisition to site the future stations assumes four acres of land per station, and an average
cost of $72,793 per acre. This cost per acre assumption is based on sales comparisons of land in
Clay County over the past three years of parcels greater than five acres in size, as reported by
CoStar. Also shown in the table is a listing of where future apparatus will be located. Further
detail regarding cost apparatus costs is contained in Appendix Table A.4.
The need for future fire stations was estimated by the County using a call volume land use model.
Existing calls by land use type were used to project future calls for service based on undeveloped
land in the County. The model conservatively assumed the smallest amount of development
possible on currently undeveloped parcels to identify the minimum number of facilities needed to
serve the County meet its response time goals. The resulting future call volume was compared to
the goal of 2,681 calls per station per year to estimate the number of stations needed to serve the
County by the planning horizon.3 Based on the call volume model and the future planned
facilities, the County estimates it will respond to 2,809 calls per station per year across 19
stations at the planning horizon.

3 2,681 calls per station per year is the average calls per station per year across four comparable
jurisdictions: City of Jacksonville, St. John’s County, Hillsborough, and Indian River.

26
Clay County Development Impact Fee Study

Table 4.4: Planned Fire and Rescue Facilities


Fire Station Type Land1 Design Building2 Pumper Ladder Rescue Tender Total

Station 11 Apparatus $ - $ - $ - $ - $ - $ - $ 544,000 $ 544,000


Station 13 Apparatus - - - - - - 544,000 544,000
Station 14 Apparatus - - - - - 443,265 - 443,265
Station 14 A (Station 5) Addition 291,172 300,000 6,771,155 830,649 1,357,728 443,265 - 9,993,969
Station 14 B (Station 1) Addition 291,172 300,000 6,771,155 830,649 1,357,728 443,265 - 9,993,969
Station 15 A (Station 3) Addition 291,172 300,000 6,771,155 830,649 - 443,265 - 8,636,241
Station 15 R3 Relocate 291,172 300,000 6,771,155 - 1,357,728 - - 2,830,193
Station 17 A (Station 6) Addition 291,172 300,000 6,771,155 830,649 - 443,265 - 8,636,241
Station 17 R3 Relocate 291,172 300,000 6,771,155 - 1,357,728 - - 2,830,193
Station 18 Apparatus - - - - 1,357,728 - - 1,357,728
Station 18 A (Station 2) Addition 291,172 300,000 6,771,155 830,649 - 443,265 - 8,636,241
Station 20 A (Station 16) Addition 291,172 300,000 6,771,155 830,649 - 443,265 544,000 9,180,241
Station 20 R3 Relocate - 300,000 6,771,155 - - 443,265 - 1,857,496
Station 22 A (Station 21) Addition - 300,000 6,771,155 830,649 1,357,728 443,265 - 9,702,797
Station 22 R3 Relocate - 300,000 6,771,155 - 1,357,728 - - 2,771,959
Station 24 A (Station 4) Addition 291,172 300,000 6,771,155 830,649 1,357,728 443,265 - 9,993,969
Station 24 R3 Rebuild - 300,000 6,771,155 - - - 544,000 1,414,231
Station 25 Apparatus - - - - - - 544,000 544,000
Station 26 Apparatus - - - 830,649 - - - 830,649
Subtotal $ 2,620,548 $ 3,900,000 $ 88,025,013 $ 7,475,841 $ 10,861,824 $ 4,432,650 $ 2,720,000 $ 90,741,382

Shared Facilities
Public Safety/Sheriff Facility 3 $ 50,000,000
Fleet Maintenance Facility 4 12,000,000
Subtotal $ 62,000,000

Total $ 152,741,382

1
Assumes 4 acres of land acquisition per station, and average land acquisition cost of $72,793 per acre. Cost per acre assumption based on sales comparison of land in Clay County
over the past three years of parcels greater than five acres in size, as reported by CoStar.
2
Building cost based on average cost of construction bids for three stations in Clay County in 2022. Average station size is 14,167 square feet.
3
Assumes 20% of land, design, and building costs increase capacity for station relocation and rebuild projects.
3
Cost show n is fire and rescue facilities fee share of these facilities. The other half of the project costs are allocated to the law enforcement facilities fee category.
4
Cost show n is fire and rescue facilities fee share of these facilities. One third of the costs are allocated to the government/jail/constitutional facilities fee, and one third is allocated to the
law enforcement facilities fee.

Sources: Clay County Capital Improvement Program, FY 21-22; Clay County Fire Department; CoStar; Table A.4, Willdan Financial Services

27
Clay County Development Impact Fee Study

Credit Component
To avoid overcharging new development for the capital cost of facilities and infrastructure, a
review of the capital financing program for fire protection and rescue facilities was completed. The
purpose of this review was to identify any potential revenues generated by new development,
other than impact fees, that are programmed to fund expansion of capital facilities, land, and
equipment over the next five years.
Capital expenditure credits per resident equivalent were calculated based on the non-impact fee
revenue expenditures planned for capital expansion projects from FY2022 to FY2026 identified in
the County’s FY2022 Capital Improvement Program. The average annual capital expansion
expenditures are divided by the average service population over the next five years to determine
the capital expenditure per resident equivalent for the five-year period.
The present value of the resulting average annual capacity expansion expenditures per resident
equivalent is then calculated using a discount period of 20 years, and a 3.90% discount rate.4 The
result is the revenue credit per resident equivalent which represents new development’s
contribution to capital facilities from sources other than impact fees. Table 4.5 details these
calculations.

Table 4.5: Fire and Rescue Capital Expansion Expenditures Credit


Fully Funded Capital FY 2022 FY 2023 FY 2024 FY 2025 FY 2026 Five Year
Projects Current Proposed Proposed Proposed Proposed Total

Burn Building $ 1,500,000 $ 1,500,000 $ - $ - $ - $ 3,000,000


Multi-Agency Storage
Warehouse Share - - 825,000 825,000 - 1,650,000
Capital Funds 1 $ 1,500,000 $ 1,500,000 $ 825,000 $ 825,000 $ - $ 4,650,000

Service Population2 284,692 290,632 296,695 302,885 309,204

Average Annual Capacity Expansion Expenditures $ 930,000


Average Service Population (2022 to 2026) 296,822
Average Annual Capacity Expansion Expenditures per Resident Equivalent $ 3.13

Discount Period (in years) 20


Discount Rate3 3.90%
Total Revenue Credit per Resident Equivalent $ (43)

1
Clay County CIP. Excludes funding for vehicle and equipment replacement.
2
Based on 2.09% compound annual grow th rate from 2021 to 2045 calculated from service population projections.
3
Average 20-year interest rate as of November 19, 2022 for AAA municipal bonds at w w w .fmsbonds.com/market-yields/

Sources: Clay County Capital Improvement Program; w w w .fmsbonds.com/market-yields/; Willdan Financial Services.

Cost Allocation
Table 4.6 calculates the County’s system standard per resident equivalent investment in fire and
rescue facilities in 2045. This facility standard is calculated by dividing the total future value of the
system of fire and rescue facilities in 2045 by the future service population in 2045. The revenue

4Average 20-year interest rate as of November 19, 2022 for AAA municipal bonds at
www.fmsbonds.com/market-yields/

28
Clay County Development Impact Fee Study

credit per resident equivalent is subtracted from the resulting cost per resident equivalent. The
resulting net cost per resident equivalent is multiplied by the worker weighting factor of 1.37 to
determine the net cost per worker. The resulting cost per resident equivalent standard is the
facility standard that will be achieved once projected development has occurred and once the
planned facilities have been built. This standard is higher than the existing cost standard. It is
legitimate to charge new development at this higher standard so long as the County can fund
existing development’s share with funding sources other than impact fees.

Table 4.6: Fire and Rescue Facilities System


Standard

Value of Existing Facilities $ 26,386,171


Value of Planned Facilities 152,741,382
Total System Value (2045) $ 179,127,553

Future Service Population (2045) 457,749

Cost per Resident Equivalent $ 391

Less Revenue Credit $ (43)


Net Cost per Resident Equivalent $ 348

Cost Allocation per Resident $ 348


Cost Allocation per Worker1 477

1
Based on a w eighing factor of 1.37.

Sources: Tables 4.1, 4.2 and 4.5.

Projected Fee Revenue


Table 4.7 details a projection of fee revenue based on the increase in service population
calculated in Table 4.1. Fee revenue projections are identified for the unincorporated areas of the
County, and for the incorporated cities within the fire and rescue service area. The County must
identify approximately $90.5 million in additional funding by 2045 to fully fund the identified
projects, or else new development will have paid too high a fee.

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Clay County Development Impact Fee Study

Table 4.7: Revenue Projection - System Standard


Incorporated
Unincorporated Cities in Service
Areas Area Total

Cost per Resident Equivalent $ 348 $ 348 $ 348


Growth in Service Population (2021- 2045) 149,867 29,008 178,875
Fee Revenue $ 52,154,000 $ 10,095,000 $ 62,248,500

Net Cost of Planned Facilities $ 152,741,382


Non-fee Revenue Required $ (90,492,882)

Sources: Tables 4.1, 4.4 and 4.6.

Fee Schedule
Table 4.8 shows the maximum justified fire and rescue facilities fee schedule. The County can
adopt any fee up to these amounts. The facility standard costs per resident and worker are
converted to a fee per unit of new development based on dwelling unit and employment densities
per demand unit identified in Table 2.2.

Table 4.8: Maximum Justified Fire and Rescue Facilities Impact Fee
A B C=Ax B D = C / 1,000
Cost Per
Resident Fee per
Land Use Demand Unit Equivalent Density Fee 1 Sq. Ft.

Residential - per Dwelling Unit


Single Family (up to 1,500 sq. ft.) Dwelling Unit $ 348 2.27 $ 790
Single Family (1,501 to 2,499 sq. ft.) Dwelling Unit 348 3.02 1,051
Single Family (2,500 sq. ft. and up) Dwelling Unit 348 3.78 1,315
Multifamily Dwelling Unit 348 2.00 696
Mobile Home Dwelling Unit 348 2.53 880
Senior Unit Dwelling Unit 348 1.69 588

Nonresidential
Commercial: Retail and Services 1,000 Sq. Ft. $ 477 2.12 $ 1,011 $ 1.01
Car Wash Lane 477 1.75 835 n/a
Hotel/Lodging Room 477 0.56 267 n/a
Office 1,000 Sq. Ft. 477 3.26 1,555 1.56
Industrial 1,000 Sq. Ft. 477 1.16 553 0.55
Institutional 1,000 Sq. Ft. 477 2.64 1,258 1.26
Nursing Home 1,000 Sq. Ft. 477 2.04 973 0.97

1
Fee per demand unit.

Sources: Tables 2.2 and 4.6.

30
5. Law Enforcement Facilities
The purpose of the law enforcement facilities impact fee is to fund the law enforcement facilities
needed to serve new development.

Service Population
Law enforcement facilities serve both residents and businesses within the Sheriff’s service area,
which includes the unincorporated areas of the County, plus the cities of Keystone Heights and
Penney Farms. Therefore, demand for services and associated facilities are based on the
Sheriff’s service area service population including residents and workers weighted to account for
varying levels of demand for facilities. The resulting service population is expressed in terms of
resident equivalents.
Table 5.1 shows the existing and future projected service population for law enforcement
facilities. While specific data is not available to estimate the actual ratio of demand per resident to
demand by businesses (per worker) for this service, Willdan believes it is reasonable to assume
that demand for these services is less for one worker compared to one resident, because
nonresidential buildings are typically occupied less intensively than dwelling units and the
demand for services is liked more closely to the workday or business hours. The 0.31-weighting
factor for workers approximates relative demand for facilities for people who work in the County
relative to residents. This worker weighting factor is based on a 40-hour workweek divided by the
total number of non-work hours in a week (128) and therefore reflects the degree to which
nonresidential development yields a lesser demand for law enforcement facilities.
This approach assumes the following:
1. People generate demand for these types of facilities when they are physically within the
County. People who work in the County but do not live in the County only generate
demand for these facilities for the 40 hours that they are physically in the County.
2. People who live in the County may or may not also work in the County. Demand for those
who both live and work in the County is captured partially in the residential weighting
factor (128 nonwork hours per week / 168 total hours per week), and partially in the
worker weighting factor (40 work hours per week / 168 total hours per week), to account
for all 168 hours in a week.
3. Demand for one worker is compared to demand from one resident, which results in the
worker weighting factor of 0.3125 (rounded to 0.31 in this analysis). (40/168) / (128/168)
= 0.3125.

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Clay County Development Impact Fee Study

Table 5.1: Law Enforcement Facilities Service


Population
A B Ax B=C
Weighting Service
Persons Factor1 Population

Sheriff's Service Area 2


Residents
Existing (2021) 202,355 1.00 202,355
New Development 51,960 1.00 51,960
Total (2045) 254,315 254,315

Work ers
Existing (2021) 39,207 0.31 12,154
New Development 73,252 0.31 22,708
Total (2045) 112,459 34,862

Combined Weighted Service Population (Resident Equivalents)


Existing (2021) 214,509
New Development 74,668
Total (2045) 289,177

1
Workers are w eighted at 0.31 of residents based on a 40 hour w ork w eek
out of a possible 128 non-w ork hours in a w eek (40/128 = 0.31)
2
Includes unincorporated areas plus the Cities of Keystone Heights and
Penney Farms.

Sources: Table 2.1, Willdan Financial Services.

Facility Inventories and Standards


This section describes the County’s law enforcement facility inventory and facility standards.

Existing Inventory
Table 5.2 shows the existing law enforcement facility inventory. The replacement cost for the
buildings is based on the insured replacement cost for each building in the County’s insurance
property schedule. The assumed value of County owned land is consistent with the current
appraised market value of each parcel identified by the Clay County Property Appraiser. In total,
the County owns nearly $5 million worth of law enforcement facilities used to provide service to
the Sheriff service area, including land and buildings.

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Clay County Development Impact Fee Study

Table 5.2: Existing Law Enforcement Facilities Inventory


Inventory Unit Unit Cost Total Value

Land
Sheriff's Fleet Maintenance 0.88 acres $ 32,386 $ 28,500
Sheriff Substation Middleburg 1.08 acres 209,067 225,792
Sheriffs O.P. Operations 3.01 acres 381,918 1,149,574
Gun Range1 5.00 acres 3,444 17,220
Clay County Sheriff's / Old EOC Building 1.10 acres 35,002 38,502
Subtotal 11.07 acres $ 1,459,588

Buildings
Sheriff's Fleet Maintenance 10,425 sq. ft. $ 48 $ 503,910
Sheriff Substation Middleburg 9,701 sq. ft. 58 558,890
Sheriffs O.P. Operations 17,966 sq. ft. 101 1,819,990
Clay County Sheriff's / Old EOC Building 7,220 sq. ft. 87 629,070
Subtotal 45,312 sq. ft. $ 3,511,860

Total Value - Existing Facilities $ 4,971,448

1
Total parcel valued at $534,278. Approximately 5 of 155.13 acres are used for the gun range, so value has
been adjusted proportionally.

Sources: Clay County; Clay County Property Assessor; Preferred Government Insurance Trust Property
Schedule, 10/01/2022 through 10/01/2023; Willdan Financial Services.

Existing Facility Standards


Table 5.3 displays the County’s current law enforcement facility infrastructure standards
expressed in terms of units per 1,000 resident equivalents. In this case the County’s existing
facility standards are not sufficient. The County’s current response time goal is six minutes per
call. The current average response time is 9.56 minutes per call. The County needs to add more
officers and the facilities to house those officers to reduce response times.
The County’s current law enforcement facilities are at capacity and the County must expand
facilities to be able to continue to provide services to a growing service population. The future
planned facilities will increase the County’s facility standards. New development can fund a
higher standard than current exists, but existing development must fund its share of the higher
standard through funding sources other than impact fees.

Table 5.3: Existing Facility Standards


Achieved
Existing Facility
Service Standard per
Component Quantity Units Population 1,000 Capita

Land 11.07 Acres 214,509 0.05


Buildings 45,312 Sq. Ft. 214,509 211.24

Sources: Tables 5.1 and 5.2.

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Clay County Development Impact Fee Study

Planned Facilities
The County plans to construct a joint use public safety/sheriff facility, a fleet maintenance facility,
and to acquire a variety of vehicles to serve both existing and new development within its service
area. The cost of these facilities is shown in Table 5.4. The quantity of vehicles and equipment,
and costs of these items was provided by the Clay County Sheriff’s Office. The planned facilities
were identified by projecting the increase in the number of future officers needed to serve the
County and the corresponding facilities that those officers needed to provide law enforcement
services. The Sheriff’s Office projects the addition of 25 officers per year to continue to improve
its Citizen to Deputy ratio and to ensure to reduce response times.

Table 5.4: Planned Law Enforcement Facilities


Service Area
Only
Allocation

Public Safety/Sheriff Facility 1 $ 50,000,000


Fleet Maintenance Facility 2 12,000,000
Sheriff Vehicles 3 30,000,000
SWAT Vehicles 700,000
Emergency Management Vehicles and Equipment 150,000
Dive/Swift Water Vehicles and Equipment 75,000
Additional Fugitive/ Warrants Equipment 10,000
Additional Internet Crimes Against Children (ICAC) & Cyber Forensic Equipment 100,000
Real Time Crime Center Equipment (trailers, cameras, etc.) 10,000,000
Additional Traffic Vehicles and Equipment (motorcycles/radars) 450,000
Additional K9s and Specialty Equipment 570,000
Additional Marine Boat and Associated Equipment 380,000
Additional Community Affairs Equipment 20,000
Total $ 104,455,000

1
Cost show n is law enforcement facilities fee share of these facilities. The other half of the project costs are
allocated to the public safety facilities fee category.
2
Cost show n is law enforcement facilities fee share of these facilities. One third of the costs are allocated to the
government/jail/constitutional facilities fee, and one third is allocated to the fire and rescue facilities fee.
3
Only includes capacity expanding vehicles. Assumes $75,000 per vehicle, 20 vehicles per year for 20 years.

Source: Clay County Capital Improvement Program, FY 21-22; Clay County Sherrif's Office.

Credit Component
To avoid overcharging new development for the capital cost of facilities and infrastructure, a
review of the capital financing program for law enforcement facilities was completed. The purpose
of this review was to identify any potential revenues generated by new development, other than
impact fees, that are programmed to fund expansion of capital facilities, land, and equipment over
the next five years.
Capital expenditure credits per resident equivalent were calculated based on the non-impact fee
revenue expenditures planned for capital expansion projects from FY2022 to FY2026 identified in
the County’s FY2022 Capital Improvement Program. The average annual capital expansion
expenditures are divided by the average service population over the next five years to determine
the capital expenditure per resident equivalent for the five-year period.

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Clay County Development Impact Fee Study

The present value of the resulting average annual capacity expansion expenditures per resident
equivalent is then calculated using a discount period of 20 years, and a 3.90% discount rate.5 The
result is the revenue credit per resident equivalent which represents new development’s
contribution to capital facilities from sources other than impact fees. Table 5.5 details these
calculations.

Table 5.5: Law Enforcement Facilities Capital Expansion Expenditures


Credit
Fully Funded Capital FY 2022 FY 2023 FY 2024 FY 2025 FY 2026 Five Year
Projects Current Proposed Proposed Proposed Proposed Total

Gun Range $ 1,750,000 $ - $ - $ - $ - $ 1,750,000


Multi-Agency Storage
Warehouse Share - - 525,000 525,000 - 1,050,000
Total Capital Funds 1 $ 1,750,000 $ - $525,000 $ 525,000 $ - $ 2,800,000

Service Population2 217,195 219,915 222,669 225,457 228,280

Average Annual Capacity Expansion Expenditures $ 560,000


Average Service Population (2022 to 2026) 222,703
Average Annual Capacity Expansion Expenditures per Resident Equivalent $ 2.51

Discount Period (in years) 20


Discount Rate3 3.90%
Total Revenue Credit per Resident Equivalent $ (34)

1
Clay County CIP. Excludes funding for vehicle and equipment replacement.
2
Based on 1.25% compound annual grow th rate from 2021 to 2045 calculated from service population projections.
3
Average 20-year interest rate as of November 19, 2022 for AAA municipal bonds at w w w .fmsbonds.com/market-yields/

Sources: Clay County Capital Improvement Program; w w w .fmsbonds.com/market-yields/; Willdan Financial Services.

Cost Allocation
Table 5.6 shows the calculation of the system standard of law enforcement facilities. The system
standard represents new development’s projected per resident equivalent investment in law
enforcement facilities at the planning horizon. This value is calculated by dividing the total value
of the system of law enforcement facilities by the projected service population in 2045. The
revenue credit per resident equivalent from Table 5.5 is then subtracted from the cost per
resident equivalent, to determine the net cost per resident equivalent, which drives the fee
calculation. It is legitimate to charge new development at this higher standard so long as the
County can fund existing development’s share with funding sources other than impact fees. The
net cost per resident equivalent is multiplied by the worker weighting factor to determine the net
cost per worker.

5Average 20-year interest rate as of November 19, 2022 for AAA municipal bonds at
www.fmsbonds.com/market-yields/

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Clay County Development Impact Fee Study

Table 5.6: Law Enforcement Facilities System


Standard
Sheriff's
Service Area

Value of Existing Facilities $ 4,971,448


Value of Planned Facilities 104,455,000
Total System Value (2045) $ 109,426,448

Future Service Population (2045) 289,177

Cost per Resident Equivalent $ 378

Less Revenue Credit $ (34)


Net Cost per Resident Equivalent $ 344

Cost Allocation per Resident $ 344


Cost Allocation per Worker1 107

1
Based on a w eighing factor of 0.31.

Sources: Tables 5.1, 5.2 and 5.3.

Projected Fee Revenue


Table 5.7 details a projection of fee revenue based on the increase in service population
calculated in Table 5.1. Fee revenue projections are identified for the unincorporated areas of the
County, and for the incorporated cities within the sheriff’s service area. The County must spend
the projected fee revenue on new or expanded law enforcement facilities to serve new
development to achieve the system facility standard at the planning horizon. The County plans to
construct the facilities listed in Table 5.4. The County will need to fund an additional $78.8 million
with funding sources other than impact fees by 2045, or else new development will have paid too
high of a fee.

Table 5.7: Revenue Projection - System Standard


Incorporated
Unincorporated Cities in
Areas Service Area Total

Cost per Resident Equivalent $ 344 $ 344 $ 344


Growth in Service Population (2021- 2045) 73,662 1,006 74,668
Fee Revenue $ 25,339,728 $ 346,064 $ 25,685,792

Net Cost of Planned Facilities 104,455,000


Non-fee Revenue Required $ (78,769,208)

Sources: Tables 5.1, 5.4 and 5.6.

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Clay County Development Impact Fee Study

Fee Schedule
Table 5.8 shows the maximum justified law enforcement facilities fee schedule. The County can
adopt any fee up to these amounts. The facility standard costs per resident and worker are
converted to a fee per unit of new development based on dwelling unit and employment densities
per demand unit identified in Table 2.2.

Table 5.8: Maximum Justified Law Enforcement Facilities Fee


A B C = A x B D = C / 1,000
Cost Per
Resident Fee per
Land Use Demand Unit Equivalent Density Fee 1 Sq. Ft.

Sheriff Service Area


Residential - per Dwelling Unit
Single Family (up to 1,500 sq. ft.) Dwelling Unit $ 344 2.27 $ 781
Single Family (1,501 to 2,499 sq. ft.) Dwelling Unit 344 3.02 1,039
Single Family (2,500 sq. ft. and up) Dwelling Unit 344 3.78 1,300
Multifamily Dwelling Unit 344 2.00 688
Mobile Home Dwelling Unit 344 2.53 870
Senior Unit Dwelling Unit 344 1.69 581

Nonresidential
Commercial: Retail and Services 1,000 Sq. Ft. $ 107 2.12 $ 227 $ 0.23
Car Wash Lane 107 1.75 187 n/a
Hotel/Lodging Room 107 0.56 60 n/a
Office 1,000 Sq. Ft. 107 3.26 349 0.35
Industrial 1,000 Sq. Ft. 107 1.16 124 0.12
Institutional 1,000 Sq. Ft. 107 2.64 282 0.28
Nursing Home 1,000 Sq. Ft. 107 2.04 218 0.22

1
Fee per demand unit.

Sources: Tables 2.2 and 5.6.

37
6. Neighborhood and Community
Parks
The purpose of this fee is to generate revenue to fund the neighborhood and community parks
needed to serve new development. The impact fee is based on ensuring that new development
meets the County’s Comprehensive Plan neighborhood and community park standards.

Service Population
Facility standards for parks are typically expressed as a ratio of park acres per 1,000 residents.
As residents are the primary users of parks in unincorporated Clay County, demand for
neighborhood and community parks and associated amenities is based on the County’s
unincorporated residential population, rather than a combined resident-worker service population.
Table 6.1 provides estimates of the County’s current and projected residential population.

Table 6.1: Neighborhood and Community


Parks Service Population
Residents

Unincorporated Only
Existing (2021) 200,075
New Development 51,375
Total (2045) 251,450

Source: Table 2.1, Willdan Financial Services.

Facility Inventories
This section describes the County’s neighborhood and community park inventory, facility
standards, and park facility costs.

Existing Parkland Inventory


The Clay County owns and maintains many neighborhood and community parks throughout the
County. Table 6.2 summarizes the County’s existing neighborhood and community parkland
inventory. All facilities are located within the County. The inventory makes a distinction between
fully improved parkland, and unimproved/open space land. The park inventory data was provided
by the County for use in this analysis.

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Clay County Development Impact Fee Study

Table 6.2: Existing Parkland Inventory


Unimproved
Improved Park/Open Space
Park Acres Acres Total

Community Park s
Little Rain Lake Park 34.35 - 34.35
Twin Lakes Park 57.61 - 57.61
Omega Park 23.50 - 23.50
Carl Pugh Park 7.69 0.92 8.61
Paul Armstrong Park 17.03 - 17.03
Oakleaf Community Park 24.57 55.97 80.54
Walter Odum Park 13.83 - 13.83
Tanglewood Park 13.16 - 13.16
Plantation Sports Complex 11.87 14.16 26.03
Eagle Harbor Soccer Complex 29.79 - 29.79
Ronnie Van Zant Park 45.45 42.54 87.99
Future Saratoga Springs Park - 19.00 19.00
Subtotal 278.85 132.59 411.44

Neighborhood Park s
Foxmeadow Recreational Park 12.12 6.34 18.46
Master Sgt. John E Haynes 2.91 3.70 6.61
Hunter Douglas 9.76 - 9.76
Pier Station 1.53 - 1.53
Lake Geneva Park 0.88 - 0.88
Deerfield Point Park 1.81 - 1.81
Foxridge Park 2.88 - 2.88
Moody Ave Park 14.90 0.04 14.94
W.E Varnes Park 2.37 - 2.37
Greenwood Park 1.05 - 1.05
Doctors Lake Park 0.67 - 0.67
Eagle Harbor Park 7.44 - 7.44
Oak Creek Park 0.59 - 0.59
Neptune Park 2.94 21.87 24.81
Thunderbolt Park 7.30 - 7.30
Island Forest Park 2.70 - 2.70
Ridaught Landing Park 0.84 - 0.84
Future Antler’s Run Park - 6.02 6.02
Williams Park 1.53 - 1.53
Four Silos Park 6.41 - 6.41
Subtotal 80.63 37.97 118.60

Boat Ramps
Lake Geneva Boat Ramp 0.22 - 0.22
Lake Brooklyn Boat Ramp 1.56 - 1.56
Lakeshore Boat Ramp 5.31 - 5.31
Knights Boat Ramp 4.78 - 4.78
Williams Boat Ramp 1.50 - 1.50
Old Ferry Boat Ramp 0.65 - 0.65
Subtotal 14.02 - 14.02

Misc
Dupont Fleming Island - 73.15 73.15
Boyd Park - 25.00 25.00
Subtotal - 98.15 98.15

Total 373.50 268.71 642.21

Source: Clay County.

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Clay County Development Impact Fee Study

Neighborhood and Community Park Standards


Comprehensive Plan Standards
Clay County’s Comprehensive Plan has identified standards for neighborhood and community
parks and a variety of park amenities. Those Comprehensive Plan standards are shown in Table
6.3. The standards are also expressed in terms of facilities per 1,000 residents in the table.

Table 6.3: Comprehensive Plan Standards


Comprehensive
Plan Standard
per 1,000
Residents

Neighborhood Parks - Land 1 acre per 2,100 residents 0.48


Neighborhood Parks - Improvements 1 acre per 2,100 residents 0.48
Community Park - Land 1 acre per 700 residents 1.43
Community Park - Improvements 1 acre per 700 residents 1.43
Boat Ramp Lanes 1 lane per 25,000 residents 0.04
Baseball Field 1 field per 7,500 residents 0.13
Softball Field 1 field per 5,500 residents 0.18
Football Field 1 field per 24,000 residents 0.04
Soccer Field 1 field per 5,500 residents 0.18
Basketball Court 1 court per 5,500 residents 0.18
Tennis Court 1 court per 4,500 residents 0.22

Source: Clay County Comprehensive Plan.

Existing Facility Standards


Table 6.4 quantifies the County’s existing neighborhood and community park standards, based
on the facility inventory in Table 6.2 and the County’s count of current existing amenities at those
parks.

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Clay County Development Impact Fee Study

Table 6.4: Existing Facility Standards


Achieved
Facility
Standard
Existing Existing per 1,000
Inventory Units Residents Residents

Neighborhood Parks - Land 118.60 acres 200,075 0.59


Neighborhood Parks - Improvements 80.63 acres 200,075 0.40
Community Park - Land 411.44 acres 200,075 2.06
Community Park - Improvements 278.85 acres 200,075 1.39
Boat Ramp Lanes 10 lanes 200,075 0.05
Baseball Field 39 fields 200,075 0.19
Softball Field 11 fields 200,075 0.05
Football Field 17 fields 200,075 0.08
Soccer Field 17 fields 200,075 0.08
Basketball Court 15 courts 200,075 0.07
Tennis Court 24 courts 200,075 0.12

Sources: Clay County; Table 6.2.

Fee Benefit Districts


While the County’s Comprehensive Plan park standards are Countywide standards, to ensure
that those paying the fees receive benefit from the use of the fee revenue, the County will restrict
neighborhood and community park fee revenue spending to the fee benefit district in which the
fee revenue was collected. Since the County has already established benefit districts for its
mobility impact fee, those same districts will be used as neighborhood and community park fee
districts. A map of these districts is included below.

41
Clay County Development Impact Fee Study

42
Clay County Development Impact Fee Study

Parkland Unit Costs


Table 6.5 shows the estimated cost per acre for acquiring and developing neighborhood and
community parkland, and the amenities included in the County’s Comprehensive Plan standards.
The cost estimates for improvements and amenities are based on cost estimates the County
obtained for recent park projects. The assumed cost per acre of land acquisition is based on the
weighted average cost per acre of the market value of County owned neighborhood and
community parkland, respectively, as reported by the County Property Appraiser. The general
improvement costs listed under the neighborhood and community parks are exclusive of the
amenity costs, which may be co-located at those parks, to avoid double counting.

Table 6.5: Parkland Unit Costs

Neighborhood Park (5 Acres)


Playgrounds $ 131,386
Concession Stands/restrooms 750,000
General Improvements 350,000
Total Cost (5 Acre Park) $ 1,231,386
Cost per Acre - Improvements $ 246,277

Neighborhood Park - Acquisition per Acre $ 50,376

Community Park (10 Acres)


Playgrounds $ 131,386
Concession Stands/restrooms 1,000,000
General Improvements 750,000
Total Cost (10 Acre Park) $ 1,881,386
Cost per Acre $ 188,139

Community Park - Acquisition per Acre $ 19,699

Amenities
Boat Ramp Lanes $ 100,000
Baseball Field 250,000
Softball Field 250,000
Football Field 150,000
Soccer Field 150,000
Basketball Court 75,000
Tennis Court 75,000

1
Average value per acre of County ow ned neighborhood and community
parks, respectively, based on County Property Assessor data.

Source: Clay County; Clay County Property Assessor; Willdan Financial


Services.

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Clay County Development Impact Fee Study

Cost Allocation
Table 6.6 calculates the cost to serve one resident at the Comprehensive Plan standards using
the unit costs from Table 6.5.

Table 6.6: Cost per Resident


Comprehensive
Plan Standard Cost per
per 1,000 Cost per 1,000 Cost per
Residents Unit Residents Resident

Neighborhood Parks - Land 0.48 $ 50,376 $ 23,989 $ 24


Neighborhood Parks - Improvements 0.48 246,277 117,275 117
Community Park - Land 1.43 19,699 23,989 24
Community Park - Improvements 1.43 188,139 268,769 269
Boat Ramp Lanes 0.04 100,000 4,000 4
Baseball Field 0.13 250,000 33,333 33
Softball Field 0.18 250,000 45,455 45
Football Field 0.04 150,000 6,250 6
Soccer Field 0.18 150,000 27,273 27
Basketball Court 0.18 75,000 13,636 14
Tennis Court 0.22 75,000 16,667 17

Sources: Tables 6.3 and 6.5.

Existing Deficiencies
When comparing the existing standards quantified in Table 6.4 to the Comprehensive Plan
standards in Table 6.3, there are several facility and amenity categories where the County’s
existing standards do not meet the Comprehensive Plan standards. New development cannot
correct existing deficiencies through impact fees, so these deficiencies must be funded through
other funding sources. For facilities and amenities where the existing standard is less than the
Comprehensive Plan standard Table 6.7 calculates the deficiencies that must be funded by the
County by other means, in order to charge impact fees at the Comprehensive Plan standard.

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Clay County Development Impact Fee Study

Table 6.7: Existing Deficiencies


Existing Comp. Plan
Standard Standard Existing Deficiency Cost of
per 1,000 per 1,000 Existing Service (Acres/Fields Existing
Residents Residents1 Deficiency2 Population Courts)2 Unit Cost Deficiencies2

Neighborhood Parks - Land 0.59 0.48 - 200,075 - $ 50,376 $ -


Neighborhood Parks - Improvements 0.40 0.48 0.08 200,075 15.24 246,277 3,754,203
Community Park - Land 2.06 1.43 - 200,075 - 19,699 -
Community Park - Improvements 1.39 1.43 0.04 200,075 7.72 188,139 1,451,899
Boat Ramp Lanes 0.05 0.04 - 200,075 - 100,000 -
Baseball Field 0.19 0.13 - 200,075 - 250,000 -
Softball Field 0.05 0.18 0.13 200,075 26.37 250,000 6,593,381
Football Field 0.08 0.04 - 200,075 - 150,000 -
Soccer Field 0.08 0.18 0.10 200,075 20.37 150,000 3,055,691
Basketball Court 0.07 0.18 0.11 200,075 22.37 75,000 1,677,902
Tennis Court 0.12 0.22 0.10 200,075 20.45 75,000 1,533,908
Total $ 18,066,983

1
Fees are calculated at the policy standard.
2
For facilities w here the existing standard is less than the policy standard, the County must fund the deficiency w ith non-impact fee funding in order to
bring exsting development up to the policy standard.

Sources: Tables 6.1, 6.3, 6.4, and 6.6.

Facilities Needed to Accommodate New Development


Table 6.8 calculates the cost of neighborhood and community parks needed to accommodate
new development at the Comprehensive Plan standards. The costs per resident from Table 6.6
are multiplied by the projected increase in unincorporated residents to calculate the total cost of
facilities to accommodate new development at the Comprehensive Plan standards.

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Clay County Development Impact Fee Study

Table 6.8: Cost of Facilities to Accommodate New


Development
Cost per
Facility Type Resident

Cost per Resident


Neighborhood Parks - Land $ 24
Neighborhood Parks - Improvements 117
Community Park - Land 24
Community Park - Improvements 269
Boat Ramp Lanes 4
Baseball Field 33
Softball Field 45
Football Field 6
Soccer Field 27
Basketball Court 14
Tennis Court 17
Total $ 580

Projected Growth in Residents 51,375

Cost of Facilities to Serve New Development $ 29,797,500

Sources: Tables 6.1 and 6.6.

Credit Component
To avoid overcharging new development for the capital cost of facilities and infrastructure, a
review of the capital financing program for neighborhood and community parks was completed.
The purpose of this review was to identify any potential revenues generated by new development,
other than impact fees, that are programmed to fund expansion of capital facilities, land, and
equipment over the next five years.
Capital expenditure credits per resident were calculated based on the non-impact fee revenue
expenditures planned for capital expansion projects from FY2022 to FY2026 identified in the
County’s FY2022 Capital Improvement Program. The average annual capital expansion
expenditures are divided by the average service population over the next five years to determine
the capital expenditure per resident, for the five-year period.
The present value of the resulting average annual capacity expansion expenditures per resident
is then calculated using a discount period of 20 years, and a 3.90% discount rate.6 The result is
the revenue credit per resident equivalent which represents new development’s contribution to
capital facilities from sources other than impact fees. Table 6.9 details these calculations.

6 Average 20-year interest rate as of November 19, 2022 for AAA municipal bonds at
www.fmsbonds.com/market-yields/

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Clay County Development Impact Fee Study

Table 6.9: Neighborhood and Community Parks Capital Expansion


Expenditures Credit
FY 2022 FY 2023 FY 2024 FY 2025 FY 2026 Five Year
Fully Funded Capital Projects Current Proposed Proposed Proposed Proposed Total

Moccasin Slough-Tower, classroom,


boardwalk $ 260,050 $ 439,950 $ - $ - $ - $ 700,000
Oakleaf Community Park Phase II - - - 200,000 2,000,000 2,200,000
Multipurpose Field - Thunderbolt Park 185,400 - - - - 185,400
Twin Lakes Park - Lighting - 1,244,000 - - - 1,244,000
Walter Odum Park - Lighting - - - - 1,632,300 1,632,300
Omega Park - Lighting - - - 1,538,000 - 1,538,000
Neptune Park Phase II 240,000 - - - - 240,000
Additional Pickleball Courts 138,500 - - - - 138,500
Main St. Park Expansion & Boat Ramp
Improve - - - 250,000 - 250,000
1
Capital Funds $ 823,950 $ 1,683,950 $ - $ 1,988,000 $ 3,632,300 $ 8,128,200

Service Population2 201,989 203,922 205,873 207,843 209,832

Average Annual Capacity Expansion Expenditures $ 1,625,640


Average Service Population (2022 to 2026) 205,892
Average Annual Capacity Expansion Expenditures per Capita $ 7.90

Discount Period (in years) 20


Discount Rate3 3.90%
Total Revenue Credit per Resident $ (108)

1
Clay County CIP.
2
Based on 0.96% compound annual grow th rate from 2021 to 2045 calculated from service population projections.
3
Average 20-year interest rate as of November 19, 2022 for AAA municipal bonds at w w w .fmsbonds.com/market-yields/

Sources: Clay County Capital Improvement Program; w w w .fmsbonds.com/market-yields/; Willdan Financial Services.

Net Cost per Resident


Table 6.10 calculates the cost per resident of providing new parks at the Comprehensive Plan
standards, net of the capital contribution credits. The revenue credit calculated in Table 6.9 is
subtracted from the total cost per resident from Table 6.6 to determine the net cost per resident.

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Clay County Development Impact Fee Study

Table 6.10: Net Cost per Resident

Neighborhood Parks - Land $ 24


Neighborhood Parks - Improvements 117
Community Park - Land 24
Community Park - Improvements 269
Boat Ramp Lanes 4
Baseball Field 33
Softball Field 45
Football Field 6
Soccer Field 27
Basketball Court 14
Tennis Court 17
Total $ 580

Revenue Credit per Resident (108)

Net Cost per Resident $ 472

Service Population Growth (2021 to 2045) 51,375


Net Impact Fee Revenue $ 24,249,000

Sources: Tables 6.1, 6.8 and 6.9.

Fee Schedule
Table 6.11 shows the maximum justified neighborhood and community parks impact fee
schedule. The facility standard cost per resident is converted to a fee per unit of new
development based on the residential dwelling unit densities (persons per dwelling unit) identified
in Table 2.2.

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Clay County Development Impact Fee Study

Table 6.11: Maximum Justified Neighborhood and Community


Parks Fee
A B C=Ax B
Cost Per
Land Use Resident Density1 Fee 2

Residential - per Dwelling Unit


Single Family (up to 1,500 sq. ft.) $ 472 2.27 $ 1,071
Single Family (1,501 to 2,499 sq. ft.) 472 3.02 1,425
Single Family (2,500 sq. ft. and up) 472 3.78 1,784
Multifamily 472 2.00 944
Mobile Home 472 2.53 1,194
Senior Unit 472 1.69 798

1
Residential occupancy density assumptions from Table 2.2.
2
Fee per dw elling unit.

Sources: Tables 2.2 and 6.10.

49
7. Regional Parks
The purpose of this fee is to generate revenue to fund the planned regional park improvements
needed to serve new development. The impact fee is based on the system standard approach.

Service Population
The County is planning to construct a regional sports park on a site that it already owns. This
facility will be unique compared to the neighborhood and community park facilities described in
the prior chapter. The future facility will serve all residents of the County, including those in
incorporated cities. Consequently, the service population for the regional park impact fee includes
residents Countywide. Table 7.1 provides estimates of the County’s current and projected
residential population.

Table 7.1: Regional Parks Service Population


Residents

Countywide
Existing (2021) 221,440
New Development 56,860
Total (2045) 278,300

Source: Table 2.1, Willdan Financial Services.

Facility Inventories
This section describes the County’s regional park facility inventory, facility standards, and park
facility costs.

Existing Parkland Inventory


The Clay County owns and several regional parks throughout the County. Table 7.2 summarizes
the County’s existing regional parkland inventory. All facilities are located within the County. The
inventory makes a distinction between fully improved parkland, and unimproved/open space land.
The park inventory data was provided by the County for use in this analysis.

50
Clay County Development Impact Fee Study

Table 7.2: Existing Parkland Inventory


Unimproved
Improved Park/Open Space
Park Acres Acres Total

Regional Park s
Veterans Park - 635.04 635.04
Moccasin Slough 5.85 255.48 261.33
Camp Chowenwaw 27.50 120.10 147.60
Black Creek Park and Trail 1.96 67.12 69.08
Regional Sports Complex - 252.13 252.13
Total 35.31 1,329.87 1,365.18

Source: Clay County.

Regional Park Standards


Table 7.3 quantifies the County’s existing regional park demand standards, in terms of acres of
parks per 1,000 residents.

Table 7.3: Existing Facility Standards


Achieved
Facility
Standard
Existing Existing per 1,000
Inventory Units Residents Residents

Regional Parks - Land 1,365.18 acres 200,075 6.82


Regional Parks - Improvements 35.31 acres 200,075 0.18

Sources: Clay County; Table 7.2.

Planned Facilities
Table 7.4 displays the cost of the future regional sports complex. The costs shown in this table
are based on the recent cost estimates for this project obtained by the County in November,
2022. The regional sports complex will include the following amenities:
- Six tennis courts - Three shade structures
- 10 sand volleyball courts - Restrooms
- 16 pickleball courts - Concession stands for each quad
- Quad baseball fields - Outdoor fitness stations
- Quad Softball eilds - Indoor gymnasium
- Playground - General park infrastructure
- Five multipurpose fields
This regional sports complex will provide these amenities in addition to the amenities provided at
the Comprehensive Plan standards at neighborhood and community parks.

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Clay County Development Impact Fee Study

Table 7.4: Regional Sports Complex - Future


Facility Cost

Regional Sports Complex Cost Estimate


Phase 1A + 1B1 $ 4,300,000
Phase 2 7,499,988
Phase 3 5,422,248
Phase 4 10,228,870
Phase 5 4,001,572
Phase 6 8,447,105
Total $ 39,899,783

1
Net of current CIP funding. Total cost of Phase 1A and 1B is $7.1 million.

Source: Clay County Regional Park - ROM Budget 11.17.22.

Credit Component
To avoid overcharging new development for the capital cost of facilities and infrastructure, a
review of the capital financing program for regional parks was completed. The purpose of this
review was to identify any potential revenues generated by new development, other than impact
fees, that are programmed to fund expansion of capital facilities, land, and equipment over the
next five years.
Capital expenditure credits per resident were calculated based on the non-impact fee revenue
expenditures planned for capital expansion projects from FY2022 to FY2026 identified in the
County’s FY2022 Capital Improvement Program. The average annual capital expansion
expenditures are divided by the average service population over the next five years to determine
the capital expenditure per resident, for the five-year period.
The present value of the resulting average annual capacity expansion expenditures per resident
is then calculated using a discount period of 20 years, and a 3.90% discount rate.7 The result is
the revenue credit per resident which represents new development’s contribution to capital
facilities from sources other than impact fees. Table 7.5 details these calculations.

7 Average 20-year interest rate as of November 19, 2022 for AAA municipal bonds at
www.fmsbonds.com/market-yields/

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Clay County Development Impact Fee Study

Table 7.5: Regional Parks Capital Expansion Expenditures Credit


FY 2022 FY 2023 FY 2024 FY 2025 FY 2026 Five Year
Fully Funded Capital Projects Current Proposed Proposed Proposed Proposed Total

DEO Grant - NE Sports Complex $ 2,250,000 $ 750,000 $ - $ - $ - $ 3,000,000


1
Capital Funds $ 2,250,000 $ 750,000 $ - $ - $ - $ 3,000,000

Service Population2 201,989 203,922 205,873 207,843 209,832

Average Annual Capacity Expansion Expenditures $ 600,000


Average Service Population (2022 to 2026) 205,892
Average Annual Capacity Expansion Expenditures per Capita $ 2.91

Discount Period (in years) 20


Discount Rate3 3.90%
Total Revenue Credit per Resident $ (40)

1
Clay County CIP.
2
Based on 0.96% compound annual grow th rate from 2021 to 2045 calculated from service population projections.
3
Average 20-year interest rate as of November 19, 2022 for AAA municipal bonds at w w w .fmsbonds.com/market-yields/

Sources: Clay County Capital Improvement Program; w w w .fmsbonds.com/market-yields/; Willdan Financial Services.

Parks Cost per Resident


Table 7.6 calculates the cost per resident of providing new parks at the existing facility standards.
First, the per acre unit costs are multiplied by the acreage standards to determine the total
amount of costs needed to serve 1,000 residents. Then, those costs are divided by 1,000 to
determine the cost needed to serve one person. Finally, the revenue credit calculated in Table
7.5 is subtracted from the cost per resident to determine the net cost per resident.

Table 7.6: System Standard Cost per


Resident

Net Regional Sports Park Costs $ 39,699,783


Future Service Population (2045) 278,300
Cost per Resident $ 143

Revenue Credit per Resident (40)


Net Cost per Resident $ 103

Sources: Tables 7.1, 7.4 and 7.5.

Projected Fee Revenue


Table 7.7 details a projection of fee revenue based on the increase in service population
calculated in Table 7.1. Fee revenue projections are identified for the unincorporated areas of the
County, and for the incorporated cities. The County must spend the projected fee revenue on new
or capacity expanding regional parks to serve new development to achieve the system facility
standard at the planning horizon. The County plans to construct the facilities listed in Table 7.4.

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Clay County Development Impact Fee Study

The County will need to fund an additional $33.8 million with funding sources other than impact
fees by 2045, or else new development will have paid too high of a fee.

Table 7.7: Projected Fee Revenue


Unincorporated Incorporated
Areas Cities Total

Cost per Resident $ 103 $ 103 $ 103


Growth in Residents (2021- 2045) 51,375 5,485 56,860
Fee Revenue $ 5,291,625 $ 564,955 $ 5,856,580

Net Cost of Planned Facilities $ 39,699,783


Non-fee Funding Required $ 33,843,203

Sources: Tables 2.1, 7.4 and 7.6.

Fee Schedule
Table 7.8 shows the maximum justified regional park facilities fee schedule. The facility standard
cost per resident is converted to a fee per unit of new development based on the residential
dwelling unit densities (persons per dwelling unit) identified in Table 2.2.

Table 7.8: Maximum Justified Regional Parks Fee Schedule


A B C=Ax B
Cost Per
Land Use Resident Density1 Fee 2

Residential - per Dwelling Unit


Single Family (up to 1,500 sq. ft.) $ 103 2.27 $ 234
Single Family (1,501 to 2,499 sq. ft.) 103 3.02 311
Single Family (2,500 sq. ft. and up) 103 3.78 389
Multifamily 103 2.00 206
Mobile Home 103 2.53 261
Senior Unit 103 1.69 174

1
Residential occupancy density assumptions from Table 2.2.
2
Fee per dw elling unit.

Sources: Tables 2.2 and 7.6.

54
8. Library and Cultural Facilities
The purpose of the library and cultural impact fee is to fund the library and cultural facilities
needed to serve new development.

Service Population
Library and cultural facilities primarily residents Countywide. Therefore, demand for services and
associated facilities are based on the County’s residential population. Table 8.1 shows the
existing and future projected service population for library and cultural facilities.

Table 8.1: Library and Cultural Facilities


Service Population
Residents

Countywide
Existing (2021) 221,440
New Development (2021-2045) 56,860
Total (2045) 278,300

Source: Table 2.1, Willdan Financial Services.

Facility Inventories and Standards


This section describes the County’s library and cultural facilities inventory and facility standards.

Existing Inventory
Table 8.2 shows the existing library and cultural facilities inventory. The replacement cost for the
buildings is based on the insured replacement cost for each building in the County’s insurance
property schedule. The assumed value of County owned land is consistent with the current
appraised market value of each parcel identified by the Clay County Property Appraiser. The
County provided the inventory and replacement cost estimates of the items in the library’s
collections. In total, the County owns approximately $28.4 million worth of library and cultural
facilities.

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Clay County Development Impact Fee Study

Table 8.2: Existing Library and Cultural Facilities Inventory


Existing Facilities Amount Units Unit Cost Total Value

Land
Archives and Museum 2.24 acres $ 135,596 $ 303,395
Middleburg Community Center 1.17 acres 65,427 76,839
Council on Aging 1.32 acres 35,206 46,603
Fleming Island Library 5.07 acres 214,802 1,089,000
Green Cove Springs Library 0.56 acres 241,749 136,070
Middleburg Senior Center 0.50 acres 63,649 31,820
Middleburg Library 2.35 acres 31,966 75,177
Orange Park Library 2.73 acres 63,511 173,200
Orange Park Senior Citizens 1.74 acres 54,267 94,500
Senior Citizen Center 0.69 acres 156,815 108,000
Subtotal 18.38 acres $ 2,134,604

Buildings
Archives and Museum 22,488 sq. ft. $ 92 $ 2,065,020
Middleburg Community Center 3,584 sq. ft. 86 306,980
Council on Aging 30,837 sq. ft. 149 4,607,710
Fleming Island Library 30,357 sq. ft. 158 4,808,300
Green Cove Springs Library 9,425 sq. ft. 124 1,166,960
Middleburg Senior Center 6,089 sq. ft. 119 722,880
Middleburg Library 6,885 sq. ft. 130 895,110
Orange Park Library 29,855 sq. ft. 160 4,791,550
Orange Park Senior Citizens 7,274 sq. ft. 99 722,820
Senior Citizen Center 4,363 sq. ft. 125 544,890
Subtotal 151,157 $ 20,632,220

Library Collections and Equipment


Books 222,459 $ 20 $ 4,444,817
Electronic Books 5,124 28 141,909
Downloadable Audio Books 2,673 57 151,678
Audio Books 13,456 32 429,117
Compact Discs 1,411 9 13,023
Adult Kits 33 125 4,125
Juvenile Kits 217 68 14,856
DVDs 23,496 17 395,764
Public Computers 72 350 25,200
Laptops 25 335 8,367
Hotspots 40 94 3,760
Subtotal $ 5,632,614

Total Value - Existing Facilities $ 28,399,438

Note: Clay County also operates the Keystone Library, but it is excluded from this inventory
because it is not County ow ned.

Sources: Clay County; Clay County Property Assessor; Preferred Government Insurance Trust
Property Schedule, 10/01/2022 through 10/01/2023; Willdan Financial Services.

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Clay County Development Impact Fee Study

Existing Facility Standards


Table 8.3 displays the County’s current library and cultural facilities infrastructure standards
expressed in terms of units per 1,000 residents. Impact fees calculated using the existing
standard methodology can provide a funding source from new development to ensure that these
standards are maintained as new development creates additional demand for facilities.
For the purpose of comparison, when isolating just the existing library square footage, the County
has a library building space standard of 0.35 square feet per resident, and 1.21 collection items
per person. The State “essential level” is 0.60 square feet per resident and 2.0 items per resident.
This demonstrates that the County’s library facilities are not meeting State standards. However,
the impact fees are calculated such that new development funds the expansion of facilities at the
existing level of service.

Table 8.3: Existing Facility Standards


Achieved
Facility
Existing Service Standard per
Component Quantity Units Population 1,000 Residents

Land 18.38 Acres 221,440 0.08


Buildings 151,157 Sq. Ft. 221,440 682.61
Collections 268,869 Items 221,440 1,214.18
Technology (Computers/Laptops/Hotspots) 137 Items 221,440 0.62

Sources: Tables 8.1 and 8.2.

Potential Planned Facilities


The Clay County’s capital improvement program identifies the design of a new library building
within the library and cultural facilities fee category. The design of this facility is fully funded within
the five-year time period of the CIP, and the construction of the new library building, while not in
the CIP, is anticipated to occur after that five-year window. That said, the library and cultural
facilities are calculated at the existing facility standard, and are not driven by the cost of the
planned facilities. Table 8.4 presents the potential facilities cost estimates.

Table 8.4: Potential Planned Facilities


Project Name Total

Library - Challenger Ctr - Design $ 750,000


Library Building1 15,000,000
Total $ 15,750,000

1
This project is not in the five year CIP. These costs do not drive the fee,
and are displayed here to demonstrate how the County intends to spend
the fee revenue.

Source: Clay County Capital Improvement Program, FY 21-22.

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Clay County Development Impact Fee Study

Credit Component
The County does not have any library and cultural capital facilities on its five-year CIP. However,
the County has historically received grant revenue that has partially been used to expand its
capital facilities within this impact fee category. Unlike the other facilities fees calculated in this
report, rather than using the forward-looking CIP to estimate the capital credit component, this fee
category uses five years of historical spending to estimate the credit.
The average annual capital expansion expenditures from 2017 through 2021 are divided by the
average service population during that time period to determine the capital expenditure per
resident, for the five-year period.
The present value of the resulting average annual capacity expansion expenditures per resident
is then calculated using a discount period of 20 years, and a 3.90% discount rate.8 The result is
the revenue credit per resident which represents new development’s contribution to capital
facilities from sources other than impact fees. Table 8.5 details these calculations.

Table 8.5: Library and Cultural Facilities Capital Expansion Expenditures


Credit
Five Year
2021 2020 2019 2018 2017 Total

Library Free Fund $ 64,744 $ 19,639 $ 88,779 $ 104,131 $ 80,072 $ 357,365


Senior Kitchen 600,274 - - - - 600,274
Capital Funds 1 $ 665,018 $ 19,639 $ 88,779 $ 104,131 $ 80,072 $ 957,639

Service Population2 221,440 219,575 215,246 212,034 208,549

Average Annual Capacity Expansion Expenditures (2017 to 2021) $ 191,528


Average Service Population (2017 to 2021) 215,369
Average Annual Capacity Expansion Expenditures per Capita $ 0.89

Discount Period (in years) 20


Discount Rate3 3.90%
Total Revenue Credit per Resident $ (12)

1
Historical spending from Clay County Budget.
2
Annual countyw ide population as reported by UF BEBR.
3
Average 20-year interest rate as of November 19, 2022 for AAA municipal bonds at w w w .fmsbonds.com/market-yields/

Sources: Clay County Budget; Bureau of Economic and Business Research, University of Florida Estimates of Population,
2017 through 2021; w w w .fmsbonds.com/market-yields/; Willdan Financial Services.

8 Average 20-year interest rate as of November 19, 2022 for AAA municipal bonds at
www.fmsbonds.com/market-yields/

58
Clay County Development Impact Fee Study

Cost Allocation
Table 8.6 calculates the County’s existing investment in library and cultural facilities per resident.
This facility standard is calculated by dividing value of the County’s existing facility inventory by
the existing service population. The revenue credit per resident is subtracted from the existing
cost per resident. Note that the value of the existing inventory of library and cultural facilities
drives this facility standard and subsequent fee calculation, not the cost of the planned facilities.

Table 8.6: Library and Cultural Facilities


Existing Cost Standard

Existing Library and Cultural Facilities $ 28,399,438


Existing Service Population 221,440

Facility Standard per Resident $ 128

Less Revenue Credit $ (12)

Cost Allocation per Resident $ 116

Sources: Tables 8.1, 8.2 and 8.5.

Projected Fee Revenue


The County plans to use library and cultural facilities fee revenue to construct improvements to
add to the system of library and cultural facilities to serve new development. Table 8.7 details a
projection of fee revenue based on the increase in service population calculated in Table 8.1. Fee
revenue projections are identified for the unincorporated areas of the County, and for the
incorporated cities. The County must spend the projected fee revenue on new or capacity
expanding libraries and cultural facilities to serve new development. Impact fee revenue will not
be sufficient to fully fund the project costs identified above. However, so long as the County
spends the collected fee revenue on capacity expanding library and cultural facilities, then new
development will have contributed its fair share towards these facilities.

Table 8.7: Revenue Projection - Existing Standard


Unincorporated Incorporated
Areas Cities Total

Facility Standard per Resident $ 116 $ 116 $ 116


Growth in Service Population (2021-2045) 51,375 5,485 56,860
Projected Impact Fee Revenue $ 5,959,500 $ 636,300 $ 6,595,760

Cost of Planned Facilities $ 15,750,000

Unfunded Costs $ 9,154,240

Sources: Tables 8.1, 8.4 and 8.6.

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Clay County Development Impact Fee Study

Fee Schedule
Table 8.8 shows the maximum justified library and cultural facilities fee schedule. The facility
standard cost per resident is converted to a fee per unit of new development based on dwelling
unit densities per demand unit identified in Table 2.2.

Table 8.8: Maximum Justified Library and Cultural


Facilities Fee Schedule
A B C=Ax B
Cost Per
Land Use Resident Density Fee 1

Residential
Single Family (up to 1,500 sq. ft.) $ 116 2.27 $ 263
Single Family (1,501 to 2,499 sq. ft.) 116 3.02 350
Single Family (2,500 sq. ft. and up) 116 3.78 438
Multifamily 116 2.00 232
Mobile Home 116 2.53 293
Senior Unit 116 1.69 196

1
Fee per dw elling unit.

Sources: Tables 2.2 and 8.6.

60
9. Implementation
The County imposes impact fees under authority granted by the Florida Impact Fee Act (the Act),
contained in Section 163.31801 of the Florida Statutes. The analysis contained in the preceding
chapters of this report meets the requirements of Act for imposition of impact fees.
Key portions of Section 163.31801 are reproduced below:
(4) At a minimum, each local government that adopts and collects an impact fee by ordinance
and each special district that adopts, collects, and administers an impact fee by resolution
must:
(a) Ensure that the calculation of the impact fee is based on the most recent and
localized data.
(b) Provide for accounting and reporting of impact fee collections and expenditures and
account for the revenues and expenditures of such impact fee in a separate accounting
fund.
(c) Limit administrative charges for the collection of impact fees to actual costs.
(d) Provide notice at least 90 days before the effective date of an ordinance or
resolution imposing a new or increased impact fee. A local government is not required to
wait 90 days to decrease, suspend, or eliminate an impact fee. Unless the result is to
reduce the total mitigation costs or impact fees imposed on an applicant, new or
increased impact fees may not apply to current or pending permit applications submitted
before the effective date of a new or increased impact fee.
(e) Ensure that collection of the impact fee may not be required to occur earlier than the
date of issuance of the building permit for the property that is subject to the fee.
(f) Ensure that the impact fee is proportional and reasonably connected to, or has a
rational nexus with, the need for additional capital facilities and the increased impact
generated by the new residential or commercial construction.
(g) Ensure that the impact fee is proportional and reasonably connected to, or has a
rational nexus with, the expenditures of the funds collected and the benefits accruing to
the new residential or nonresidential construction.
(h) Specifically earmark funds collected under the impact fee for use in acquiring,
constructing, or improving capital facilities to benefit new users.
(i) Ensure that revenues generated by the impact fee are not used, in whole or in part,
to pay existing debt or for previously approved projects unless the expenditure is
reasonably connected to, or has a rational nexus with, the increased impact generated by
the new residential or nonresidential construction.
(6) A local government, school district, or special district may increase an impact fee only as
provided in this subsection.
(a) An impact fee may be increased only pursuant to a plan for the imposition,
collection, and use of the increased impact fees which complies with this section.
(b) An increase to a current impact fee rate of not more than 25 percent of the current
rate must be implemented in two equal annual increments beginning with the date on
which the increased fee is adopted.
(c) An increase to a current impact fee rate which exceeds 25 percent but is not more
than 50 percent of the current rate must be implemented in four equal installments
beginning with the date the increased fee is adopted.
(d) An impact fee increase may not exceed 50 percent of the current impact fee rate.

61
Clay County Development Impact Fee Study

(e) An impact fee may not be increased more than once every 4 years.
(f) An impact fee may not be increased retroactively for a previous or current fiscal or
calendar year.
(g) A local government, school district, or special district may increase an impact fee
rate beyond the phase-in limitations established under paragraph (b), paragraph (c),
paragraph (d), or paragraph (e) by establishing the need for such increase in full
compliance with the requirements of subsection (4), provided the following criteria are
met:
1. A demonstrated-need study justifying any increase in excess of those authorized
in paragraph (b), paragraph (c), paragraph (d), or paragraph (e) has been completed
within the 12 months before the adoption of the impact fee increase and expressly
demonstrates the extraordinary circumstances necessitating the need to exceed the
phase-in limitations.
2. The local government jurisdiction has held not less than two publicly noticed
workshops dedicated to the extraordinary circumstances necessitating the need to
exceed the phase-in limitations set forth in paragraph (b), paragraph (c), paragraph (d),
or paragraph (e).
3. The impact fee increase ordinance is approved by at least a two-thirds vote of
the governing body.
163.31801(8) also states:
A local government, school district, or special district must submit with its annual financial
report required under s. 218.32 or its financial audit report required under s. 218.39 a
separate affidavit signed by its chief financial officer or, if there is no chief financial officer, its
executive officer attesting, to the best of his or her knowledge, that all impact fees were
collected and expended by the local government, school district, or special district, or were
collected and expended on its behalf, in full compliance with the spending period provision in
the local ordinance or resolution, and that funds expended from each impact fee account
were used only to acquire, construct, or improve specific infrastructure needs.

Programming Revenues and Projects with the CIP


The County maintains a five-year Capital Improvement Program (CIP) to plan for future
infrastructure needs. The CIP identifies costs and phasing for specific capital projects. The use of
the CIP in this manner documents a reasonable relationship between new development and the
use of those revenues.
The County may decide to alter the scope of the planned projects or to substitute new projects as
long as those new projects continue to represent an expansion of the County’s facilities. If the
total cost of facilities varies from the total cost used as a basis for the fees, the County should
consider revising the fees accordingly.

62
10. Appendix
Appendix Table A.1: Single Family Resident Density

Residents per Single Family Unit 1 A 2.72


Median Square Feet per Single Family Unit 2 B 1,800
Square Feet per Resident C=B/A 662
Residents per 1,500 Square Feet D = 1,500 / C 2.27
Residents per 2,000 Square Feet 3 E = 2,000 / C 3.02
Residents per 2,500 Square Feet F = 2,500 / C 3.78

1
Derived from Clay County data from Tables B24025 and B24033 of the 2020 American
Community Survey
2
For Jacksonville MSA, 2013 American Housing Survey.
3
2,000 square feet is used because it is at the midpoint of the 1,500 to 2,500 square foot
range.

Sources: 2013 American Housing Survey; 2020 American Community Survey, Tables B25024
and B25033; Willdan Financial Services.

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Clay County Development Impact Fee Study

Appendix Table A.2: Fire and Rescue Calls for Service (November 1,
2022 YTD)
Residential Nonresidential
Land Use Total Calls Class1 Allocation Allocation
AG 497 Residential 100% 0%
AR 1,015 Residential 100% 0%
BF AC 701 Split 15% 85%
BF CC 52 Nonresidential 25% 75%
BF INST 1 Nonresidential 0% 100%
BF MPC 288 Split 50% 50%
BF MU 5 Nonresidential 90% 10%
BF PCN 13 Residential 100% 0%
BF RAC 6 Nonresidential 0% 100%
BF RNC - Nonresidential 0% 100%
BF RS 357 Residential 100% 0%
BP 2 Nonresidential 0% 100%
CO - Residential 100% 0%
COM 2,857 Nonresidential 0% 100%
IND 94 Nonresidential 0% 100%
IP - Nonresidential 0% 100%
LA AC 1 Split 25% 75%
LA COM 47 Nonresidential 0% 100%
LA GW 5 Residential 0% 100%
LA IVC - Split 50% 50%
LA MPC 123 Residential 100% 0%
LA RC 455 Residential 100% 0%
LA RF 727 Residential 100% 0%
LA RRSV 141 Residential 100% 0%
LA SOL - Nonresidential 0% 100%
LA VC 11 Split 65% 35%
MIL 94 Nonresidential 0% 100%
MIN 36 Nonresidential 0% 100%
MIX 145 Split 75% 25%
MUNI 4,496 Muni 0% 0%
PC 3,546 Split 75% 25%
RF 2,259 Residential 100% 0%
RP 82 Residential 100% 0%
RR 3,690 Residential 100% 0%
RRSV 20 Residential 100% 0%
UC-10 5,941 Residential 100% 0%
UF 105 Residential 100% 0%
Total Calls 27,812

1
Calls are assigned to either a primarily residential land use or a primarily nonresidential land use. Categories
that contain both residential and nonresidential land uses are classified as split and area allocated to
residential or nonresidential uses based on an estimate of the share of reatlive uses in a land use
classificaiton. Calls classified as MUNI are those responding to incidents w ithin the incorporated cities of
Penney Farms, Keyston Heights and Green Cove Springs and cannot be further classified. MUNI also includes
mutual aid calls to Orange Park.

Source: Clay County Department of Public Safety.

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Clay County Development Impact Fee Study

Appendix Table A.3: Fire And Rescue


Worker Weighting Factor - Calls for
Service

Annual Calls for Service


Residential 18,467
Nonresidential 4,849

Residents 1 200,075
Calls per Resident 0.092

Employees 1 38,479
Calls per Employee 0.126

Employee Weighting Factor2 1.37

1
Uses unicorporated residential and employment estimates
to calculate, because calls w ithin incorporated cities cannot
be classified to residential or nonresidential land uses and
are excluded from the calculation.
2
Calls per employee / calls per resident.

Sources: Tables A.1 and 2.2.

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Clay County Development Impact Fee Study

Appendix Table A.4: Fire and Rescue


Apparatus and Equipment Costs
Item Cost

Rescue
Apparatus $ 291,265
Lifepak 30,000
Stretcher\Chair Lift 50,000
Ventlator 15,000
Sierra\Laptop 13,000
Radios 27,000
Misc items 10,000
Lucas 7,000
Total $ 443,265

Pumper
Apparatus $ 702,649
Lifepak 30,000
Radios 43,000
Sierra\Laptop 10,000
Misc items 45,000
Total $ 830,649

Ladder
Apparatus $ 1,224,728
Lifepak 30,000
Radios 43,000
Sierra\Laptop 10,000
Misc items 50,000
Total $ 1,357,728

Tender
Apparatus $ 500,000
Radios 19,000
Sierra\Laptop 10,000
Misc items 15,000
Total $ 544,000

Source: Clay County Department of Public Safety.

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