Members of the Albemarle Board of Supervisors,
This Wednesday (4/8) you will be holding a work session to discuss the proposed increase in Albemarle County’s subdivision fees. The Free Enterprise Forum has three areas of concern with the current proposal: the study, the fairness of cost burden share, and the cost of complexity. Despite our general agreement that applicants should share in the cost burden of applications, we are unable to fully support staff’s recommendation regarding the proposed fees.
The Free Enterprise Forum has significant concerns regarding the timing and methodology of the consultant time study of Albemarle County’s Community Development Department.
ü Timing – The study took place in 2007 at a time of significant rezoning activity and a high level (50%?) of employee turnover.
ü Self Reporting – the study relied on staff reporting regarding the time spent on a particular task. Parkinson’s law dictates work will always expand to fill the time allotted.
ü Staff year – The staff work year in the study is 1,750 hours rather than a standard 2,080 hours.
The Applicant’s Cost Burden
In addition to our concerns regarding the study, The Free Enterprise Forum believes the Community Development Department activities benefit a multiplicity of population cohorts. If the goal of the new fees is to place the cost burden on the beneficiaries and examination of all those involved in the process is instructive.
The primary beneficiaries are the public and the applicant. Enforcement of codes provides the applicant (and any subsequent ownership) with the security that neighboring parcels will be held to the same high development standards. Such enforcement also provides the public with assurances that their vision as enumerated in the Comprehensive Plan and supported by ordinance will come to fruition.
In recent years, the Albemarle County Planning Commission has significantly expanded the level of detail and amount of information required for any given approval. Each time an administrative approval is called up by the commission, the costs for Albemarle County (staff reporting, presentation time) and the applicant (consultant fees, attendance at public meetings, etc.) increase exponentially. Who is being served by this process? If the Planning Commission’s hands are tied by law regarding the approval if it meets the prescribed criteria, are the citizens being served by taking this to the commission?
Two different engineering firms have indicated to the Free Enterprise Forum that the proposed increase in fees for County review may exceed the professional fees these firms would charge for surveying and preparation of a subdivision plat. This does not seem fair or right.
Cost of Complexity
Recently, a rural church wanted to build a shed for their lawn mower and other yard equipment. By the time they received their building permit, the church had spent over six months working with Community Development. Mark Graham estimated over $6,000 of county costs were sunk into that application. This too does not seem right or fair.
The cumulative impact of Albemarle County’s regulatory environment can not be ignored in this discussion. In this time of reduced application volume, the Board of Supervisors could direct staff to dig deeper into the Development Review Task Force recommendations and reduce the onerous regulatory burden on County staff and applicants.
The Free Enterprise Forum recognizes the need to increase subdivision fees to more effectively capture a portion of application approval costs. We believe significant inefficiencies exist in the current system. We call on the Albemarle County Board of Supervisors to reject the results of the flawed time work study. Further, we encourage Community Development to examine the current regulations and propose streamlining of the process.
Finally, considering the current economic environment and the questions that have been raised by the Free Enterprise Forum and others, we call on the Board of Supervisors to delay this vote (or at least implementation) for at least 12 months.
Thank you for your service to our community,
Free Enterprise Forum