HomeMy WebLinkAboutAGENDA REPORT 2025 1105 CC REG ITEM 09CCITY OF MOORPARK, CALIFORNIA
City Council Meeting
of November 5, 2025
ACTION ADOPTED RESOLUTION NO.
2025-4360. (ROLL CALL VOTE:
UNANIMOUS)
BY A. Hurtado.
C. Consider Resolution Adopting Inclusionary Housing In-Lieu Fees. Staff
Recommendation: Adopt Resolution No. 2025-4360 implementing inclusionary
housing in-lieu fees. (Staff: Gene Burse, Deputy Community Development
Director) (ROLL CALL VOTE REQUIRED)
Item: 9.C.
MOORPARK CITY COUNCIL
AGENDA REPORT
TO: Honorable City Council
FROM: Doug Spondello, Community Development Director
BY: Gene Burse, Deputy Community Development Director
DATE: 11/05/2025 Regular Meeting
SUBJECT: Consider Resolution Adopting Inclusionary Housing In-Lieu Fees
BACKGROUND
The 2021-2029 General Plan Housing Element and 2023 Zoning Code Update
implemented standard requirements for the reservation of affordable housing with new
development projects constructed in the City of Moorpark.
The purpose of this item is to present the findings and recommendations from the Nexus
Study for the Affordable Housing In-Lieu Fee completed in 2024. The Study was
commissioned to develop a citywide Affordable Housing In-Lieu Fee Program that aligns
with the City’s housing policies and the recently adopted Inclusionary Housing Ordinance
(Ordinance No. 515). The Fees will provide additional flexibility to the City and
development community in meeting affordable housing needs generated by new market-
rate units in the City. The Nexus Study commenced in Fiscal Year (FY) 2023/24 and was
prepared by Harris & Associates, Inc. (Harris).
As the City continues to experience growth, the need and demand for affordable housing
has become increasingly pressing. New developments in the City must include affordable
housing units to offset the increased demand created by the construction of new market-
rate residential units. The Inclusionary Housing Ordinance was originally established by
Ordinance No. 515 in October 2023 and now appears in Section 16.24.065 of the
Municipal Code. This Ordinance requires that residential developments with 10 or more
units reserve 15% of the developed units as affordable housing. The Code also defines
specific criteria for the levels of affordability. Developers have the option to meet these
requirements by constructing the affordable units on-site as part of the project, or by
paying an in-lieu fee.
Item: 9.C.
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The Nexus Study establishes the reasonable relationship between new residential
development and the resulting demand for additional affordable housing consistent with
the City’s Inclusionary Housing Ordinance. It determines the maximum justifiable in-lieu
fees that can be levied by calculating the affordability gap—the difference between
development costs and what low- to moderate-income households can afford. This gap
is used to establish the maximum supported fee levels, ensuring new developments
contribute their fair share toward addressing affordable housing needs.
The fees are defined in the Nexus Study and would be paid on a per-unit basis multiplied
by the total number of all residential units proposed within a given project. The proposed
in-lieu fee would be paid only when a Developer elects not to provide affordable housing
on-site for the following types of housing units:
• Single-Family For-Sale Units
• Multifamily For-Sale Units
• Multifamily For-Rent Units
The goal of the City is to develop a fee program that helps bridge the housing affordability
gap and balances fee levels with desired economic growth and complies with the legal
requirements. The Nexus Study provides the necessary technical analysis to support the
adoption of the in-lieu fees. The fees will be effective immediately after the City’s final
action establishing and authorizing the collection of the fees.
DISCUSSION
In 2017, AB 1505, known as the "Palmer Fix," was enacted to allow jurisdictions to impose
inclusionary housing requirements on rental housing developments, effectively
overturning the 2009 court decision (Costa-Hawkins Act), which limited the ability of
jurisdictions to impose affordable rental housing requirements and led to challenges in
enforcing inclusionary housing policies. AB 1505 permits cities to adopt ordinances
requiring a percentage of residential rental units to be affordable for low- and moderate-
income households. It also mandates that cities provide alternative compliance options,
such as in-lieu fees, off-site construction, or land dedication.
Staff contracted with Harris to prepare a Nexus Study (Exhibit A to the Resolution) that
summarizes the assumptions, methodologies, facility standards, costs, and cost
allocation factors that were used to establish the relationship between the fees and the
development on which the fees will be charged using the Inclusionary Equivalent Fee
methodology. The Nexus Study outlines the calculation of fees that developers can pay
instead of building affordable housing units as part of new residential developments. The
Nexus Study calculates the “affordability gap,” which is the difference between the cost
of developing a housing unit and what lower-income households can afford to pay. This
gap is calculated separately for different types of housing (e.g., single-family homes,
multifamily for-sale, and multifamily for-rent units) and income levels (e.g., low-income,
moderate-income). The total development cost of affordable housing units is estimated
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based on recent trends in construction and land acquisition costs. This includes hard
costs (e.g., building costs), soft costs (e.g., design and permits), and financing costs. The
Nexus Study identifies the income levels required to afford market-rate housing in the
City. This includes calculating the maximum mortgage or rent that households at different
income levels can support, based on federal guidelines. The fee is based on the
affordability gap multiplied by the percentage of affordable units required under the City's
Inclusionary Housing Ordinance.
This calculation process ensures that the fees reflect the actual costs of developing
affordable housing and are aligned with the City's housing policies and goals. The City
may choose to adopt in-lieu fees that are lower than the maximum justifiable amounts to
encourage development and mitigate potential impacts on housing development within
city limits. The schedule of established fees may be amended from time to time by
resolution of the City Council. Fees can also be updated administratively by an annual
inflation factor that is included as part of the adopting resolution.
The proposed fees are consistent with the City’s 2021-2029 Housing Element, which
outlines the need to provide housing opportunities for all income levels. By adopting
these fees, the City can ensure that new development projects contribute appropriately
to the City's affordable housing stock without unduly burdening developers.
City staff reviewed the options provided in this Nexus Study and recommend the following
fees be adopted. These fees equal the maximum supportable fees calculated in the
Nexus Study and are less than the averages of other local agencies. This methodology
supports the City's goal of using the in-lieu fee funds to help finance affordable housing
development. The goal of the City is to develop a fee schedule that helps bridge the
housing affordability gap and balances fee levels with desired economic development
growth.
Based on the findings presented in the Nexus Study, City staff recommends the City
Council adopt an Enabling Resolution implementing the in-lieu fees. The recommended
fee levels for all land uses are set at the maximum justifiable fee amount calculated in
the Nexus Study.
The proposed in-lieu fee would be paid only when a developer elects not to provide
affordable housing on-site. The proposed fees in Table 1 below are found in the Nexus
Study and would be paid on a per unit basis multiplied by the total number of all market-
rate residential units proposed within a given project that has single-family for sale-units,
multifamily for-sale units or multifamily for-rent units. For example, if the adopted fee for
a single-family detached for-sale unit is $111,000, a project consisting of 100 new single-
family homes would result in an in-lieu fee payment of $11,100,000 (100 units x
$111,000/unit). Another example, if a developer proposes a new building containing 150
market-rate multifamily for-rent units and elects to pay the in-lieu fee rather than provide
affordable units onsite would result in an in-lieu fee payment of $8,250,000 (150 units x
$55,000/unit).
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11/05/2025 Regular Meeting
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Table 1: Proposed In-Lieu Fees From Nexus Study
The land use types referenced in Table 1 are defined by the Moorpark Municipal Code
as follows:
• Single-Family Dwelling: A detached building constructed in conformance with the
Uniform Building Code, or a mobile home constructed on or after June 15, 1976,
containing one dwelling unit.
• Multifamily Dwelling: A building, or portion of a building, containing three or more
dwelling units.
The Nexus Study provides the necessary technical analysis to support the adoption of
the proposed in-lieu fees identified in Table 1. The fees will be effective immediately after
adoption of the Enabling Resolution.
ENVIRONMENTAL DETERMINATION
Adoption of the proposed inclusionary housing in-lieu fees was reviewed in accordance
with the criteria contained in the California Environmental Quality Act (“CEQA”) and the
State CEQA Guidelines. The Community Development Director finds that adoption of the
in-lieu fees will not have a significant impact on the environment and are exempt from
CEQA pursuant to Section 15061(b)(3) of State CEQA Guidelines because no specific
development is authorized by the adoption of new fees.
Land Use Inclusionary
Requirement1
Affordability
Level
Affordability Gap
per Unit2 Fee per Unit Total Fee
per Unit
Average of
Other Cities 3
Proposed
Fee 4
7%80% AMI or
below $862,569 $60,380
8%120% AMI or
below $641,120 $51,290
7%80% AMI or
below $554,659 $38,826
8%120% AMI or
below $333,392 $26,671
7%30% AMI or
below $410,054 $28,704
8%50% AMI or
below $331,224 $26,498
1) City of Moorpark Inclusionary Housing Requirements, Municipal Code 17.24.065.
2) Table 10 and Table 11.
3) Table 13.
4) Proposed fees are rounded to the nearest 1,000.
Multifamily
For-Rent 55,202 $73,849 $55,000
Single Family
Detached For-
S ale
Multifamily
For-Sale 65,497 $86,442 $65,000
111,670 $153,427 $111,000
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FISCAL IMPACT
Direct fiscal impacts to the City's operating budget are not expected as a result of this
recommended action. Rather, Affordable Housing In-Lieu fees may be paid by new
development which would provide funding that will be used by the Housing Division within
Fund 2121. Specifically, this revenue will be used to finance the development, acquisition,
and/or preservation of affordable housing units within the City as well as related staffing
costs. The fees are structured to cover the full cost of mitigating the affordable housing
impacts of new development.
To ensure the in-lieu fees remain consistent with the rising cost of construction, staff
recommends that the fees be adjusted annually on July 1, beginning in 2027, based on
the annual percentage change in the Engineering News-Record (ENR) Construction Cost
Index (commonly known as the Construction Cost Index or CCI) for the Los Angeles
region for the 12-month period ending in February. This index is a widely recognized
industry standard used to track and estimate construction cost inflation over time. It is
used as a benchmark for measuring cost trends in the U.S. construction market.
COUNCIL GOAL COMPLIANCE
This action accomplishes Goal 1, Objective 1.3 (Inclusionary Housing Policy) of the 2023-
2025 City Council Goals. It is also consistent with Goal 3, Objective 3.5 (Financial
Sustainability).
STAFF RECOMMENDATION (ROLL CALL VOTE REQUIRED)
Adopt Resolution No. 2025-____ implementing inclusionary housing in-lieu fees.
Attachment: Draft Resolution No. 2025-____
49
RESOLUTION NO. 2025-____
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
MOORPARK, CALIFORNIA, APPROVING THE
AFFORDABLE HOUSING IN-LIEU FEE NEXUS STUDY
FOR NEW RESIDENTIAL DEVELOPMENT AND ENABLING
THE IMPLEMENTATION OF THE AFFORDABLE HOUSING
IN-LIEU FEES
WHEREAS, the City of Moorpark is committed to addressing the affordable
housing needs of its residents and ensuring that housing is available for households of
all income levels; and
WHEREAS, the City desires to introduce Affordable Housing In-Lieu Fees for new
residential development that provides developers with the opportunity to meet the
affordable housing requirements pursuant to the City’s Inclusionary Housing Ordinance
(Ordinance No. 515). The establishment of the in-lieu fees offers developers the option
to pay an in-lieu fee rather than providing deed-restricted affordable units as part of their
development projects; and
WHEREAS, the City retained Harris & Associates, Inc. to prepare an Affordable
Housing In-Lieu Fee Nexus Study (the “Nexus Study”, Exhibit A) dated April 2024 to
analyze the relationship between new residential development and the need for additional
affordable housing and to determine the maximum justifiable in-lieu fees; and
WHEREAS, the Nexus Study identifies the purpose of the in-lieu fees, the use to
which the fees will be put, demonstrates a reasonable relationship between the
development of new residential units and the impact on affordable housing demand. The
Study also describes the relationship between new residential development and the fee
amounts under assumptions that are consistent with the City’s Inclusionary Housing
Ordinance; and
WHEREAS, the Nexus Study provides the documentation, detail, and other
information required by AB 1505 as the basis for the adoption and imposition of the in-
lieu fees; and
WHEREAS, the proposed in-lieu fees are consistent with the goals and policies
outlined in the City’s 2021-2029 Housing Element, which was adopted in February 2023,
to provide opportunities for the development of adequate housing for all income levels;
and
WHEREAS, the City Council has reviewed and considered the in-lieu fees
established herein, and finds that the fees will mitigate the impact of an increase in
affordable housing needed from the development of market-rate residential units.
ATTACHMENT
50
Resolution No. 2025-____
Page 2
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF MOORPARK DOES
HEREBY RESOLVE AS FOLLOWS:
SECTION 1. RECITALS. The findings and recitals set forth in this Resolution are
true and correct, and are incorporated herein.
SECTION 2. CEQA. The approval of the Nexus Study and the adoption of the in-
lieu fees specified in this Resolution, was reviewed in accordance with the criteria
contained in the California Environmental Quality Act (“CEQA”) and the State CEQA
Guidelines. The City Council finds that approval of the Nexus Study and the adoption of
the in-lieu fees specified in this Resolution will not have a significant impact on the
environment and are exempt from CEQA pursuant to Section 15061(b)(3) of State CEQA
Guidelines because these actions involve the adoption of in-lieu fees and no specific
development is authorized by the adoption of the Nexus Study or the adoption of new
fees. No physical activity will occur until all required environmental review is conducted
at the time the physical improvements are undertaken at a future unspecified date.
Therefore, the approval of the Nexus Study and adoption of the in-lieu fees does not have
the potential for causing a significant effect on the environment.
SECTION 3. Approval of the Nexus Study. The City Council hereby approves the
City of Moorpark Affordable Housing In-Lieu Fee Nexus Study prepared by Harris &
Associates, Inc. and dated April 2024, and the findings contained therein, attached hereto
as Exhibit A. A copy of the Nexus Study shall be on-file with the City Clerk and available
during regular City business hours for public inspection.
SECTION 4. Establishing the amount of the Inclusionary Housing In-Lieu Fees for
new residential development projects subject to the City’s Inclusionary Housing
Ordinance. The City Council hereby adopts the in-lieu fees for (1) Single Family For-Sale
Units, (2) Multifamily For-Sale Units, and (3) Multifamily For-Rent Units, in accordance
with the Schedule of Inclusionary Housing In-Lieu Fees identified in Table A below and
incorporated by this reference.
Table A: Schedule of Inclusionary Housing In-Lieu Fees
Land Use Fee Per Unit*
Single-Family Detached For-Sale $111,000
Multifamily For-Sale $65,000
Multifamily For-Rent $55,000
*Fee is to be paid on a per unit basis multiplied by the total number of all market-rate
residential units proposed within a given project.
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Resolution No. 2025-____
Page 3
SECTION 5. Adoption of Methodology for Calculation, Adjustment, and Collection
of Inclusionary Housing In-Lieu Fees. The City Council adopts the methodology set forth
in the Nexus Study, for calculating the in-lieu fees adopted herein. The in-lieu fees
established in Table A (Schedule of Inclusionary Housing In-Lieu Fees) shall be collected
in accordance Chapter 3.36 of the Moorpark Municipal Code and automatically adjusted
annually on July 1 each year, beginning in 2027, using the annual percentage change in
the Engineering News-Record Construction Cost Index (CCI) for Los Angeles region for
the 12-month period ending in February each year.
SECTION 6. Effective Date of Inclusionary Housing In-Lieu Fees. The in-lieu fees
shall be effective immediately following the adoption of this Resolution.
SECTION 7. No Changes to Other City Fees. Nothing in this Resolution shall
repeal, amend or supersede any other City-imposed fees except for the amount of
specific type and category of fees addressed in the Nexus Study and expressly
established by this Resolution.
SECTION 8. Certification. The City Clerk shall certify to the adoption of this
resolution and shall cause a certified resolution to be filed in the book of original
resolutions.
PASSED AND ADOPTED this 5th day of November, 2025.
________________________________
Chris R. Enegren, Mayor
ATTEST:
___________________________________
Ky Spangler, City Clerk
Exhibit A: Affordable Housing In-Lieu Fee Nexus Study dated April 2024
52
Affordable Housing In-Lieu Fee Nexus Study April 2024
City of Moorpark
FINAL
Affordable Housing In-Lieu Fee
Nexus Study
City of Moorpark
April 2024
Prepared for:
Prepared by:
101 Progress, Suite 250
Irvine, California 92618
(949) 655-3900
EXHIBIT A
Resolution No. 2025-____
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Affordable Housing In-Lieu Fee Nexus Study April 2024
City of Moorpark
Table of Contents
EXECUTIVE SUMMARY .............................................................................................................. i
Section 1 INTRODUCTION AND METHODOLOGY ............................................................. 1
INTRODUCTION ...................................................................................................... 1
METHODOLOGY ..................................................................................................... 3
Section 2 AFFORDABILITY GAP ANALYSIS ........................................................................ 8
METHODOLOGY ..................................................................................................... 8
DEVELOPMENT COSTS ........................................................................................... 8
AFFORDABLE HOUSING RATES .......................................................................... 11
AFFORDABILITY GAP RESULTS .......................................................................... 13
Section 3 FINDINGS AND NEXUS REQUIREMENTS .......................................................... 15
MAXIMUM FEE CALCULATION ........................................................................... 15
Section 4 POLICY CONSIDERATIONS ................................................................................ 17
HOUSING POLICY CONSISTENCY ........................................................................ 17
COMPARISON TO OTHER JURISDICTIONS .......................................................... 18
CONCLUSION ........................................................................................................ 18
Resolution No. 2025-____
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Affordable Housing In-Lieu Fee Nexus Study i April 2024
City of Moorpark
EXECUTIVE SUMMARY
INTRODUCTION
The City of Moorpark (City) retained Harris & Associates (Harris) to prepare an Affordable
Housing In-Lieu Fee Nexus Study (Study) in order to develop a citywide Affordable Housing In-
Lieu Fee (Fee) Program. The Fees will provide additional flexibility to the City and development
community in meeting affordable housing needs generated by new market-rate units in the City.
This Study provides a nexus analysis of the linkages between the new development of residential
units and the need/demand for additional affordable housing for informational purposes. This
Study also analyzes the reasonable relationship between new residential development and the Fee
amounts under assumptions that are consistent with the City’s recently adopted Inclusionary
Housing Ordinance. The Fees in this Study represent the maximum fees supported but do not
represent specific Fee recommendations. The City has the latitude to adopt the Fees deemed
appropriate.
FINDINGS AND METHODOLOGY
Table ES. 1 compares the maximum supportable fees calculated using the inclusionary equivalent
methodology and the averages of in-lieu fees in other local cities for comparison purposes.
Table ES. 1: Maximum Supported Fee Comparison
The Inclusionary Equivalent Supportable Fee is the gap in affordability under the affordable unit
production requirement in the existing Inclusionary Housing Ordinance. These amounts
approximate the actual costs to build the affordable units required by the City’s Inclusionary
Ordinance and represent the maximum supportable in-lieu fees. The Local City Survey numbers
represent the average in-lieu fees required by surrounding cities. Harris staff completed the
analysis using the Inclusionary Equivalent Supportable methodology to determine the maximum
supportable Fee for the City.
Inclusionary Equivalent
Supportable Fee1
Local City
Survey2
Single-Family For-Sale $111,670 $153,427
Multifamily For-Sale $65,497 $86,442
Multifamily For-Rent $55,203 $73,849
1) Tables 10 and 11.
2) Table 13.
Resolution No. 2025-____
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Affordable Housing In-Lieu Fee Nexus Study ii April 2024
City of Moorpark
The Inclusionary Equivalent Fee Methodology involves applying the affordability gap calculations
per unit to the established affordable unit requirements from the existing Inclusionary Housing
Ordinance. This methodology has the advantage of using existing inclusionary requirements,
which may reflect additional considerations beyond demand created by new development, such as
the City’s Regional Housing Needs Allocation. The Study uses this methodology, illustrated by
the figure below.
Inclusionary Equivalent Fee Methodology
The in-lieu fee estimates were based on three general development types, which were identified in
the City’s General Plan 2050:
· Single-family detached (SFR for-sale)
· Multifamily condominiums (MFR for-sale)
· Multifamily apartments (MFR for-rent)
In order to estimate future market-rate housing development in the City, Harris staff researched
and reviewed Zillow and LoopNet data showing recently constructed units for-sale, and
information from City staff to identify recent market trends related to home prices. The Fees
calculated in this Study reflect the estimated cost of future residential development.
The household income limits as a percentage of Area Median Income (AMI) for Ventura County
are shown in Table ES. 2. These threshold incomes are a key input to the economic impact analysis
described in Section 1. Prior to determining the affordability gap, the total amount that households
can afford to allocate to their housing must be determined.
Determine types of new market-
rate units to be developed
Calculate Cost to Develop For-
Sale and For-Rent units in the City
Determine HH income levels and
maximum amount to be spent on
housing
Calculate Affordability Gap: difference
between development cost and sales
price (for-sale)
and development cost and maximum
supportable debt (for-rent)
Affordability Gap x Inclusionary
Housing Requirement
Resolution No. 2025-____
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Affordable Housing In-Lieu Fee Nexus Study iii April 2024
City of Moorpark
Table ES. 2: Threshold Incomes and percent of Area Median Income (AMI)
POLICY CONSIDERATIONS
The City should evaluate several policy considerations and implications related to the in-lieu fees.
Harris reviewed the maximum supportable Fees for consistency with the Housing Policy outlined
in the City’s Housing Element and has prepared a comparison of fees with other jurisdictions.
Housing Policy Consistency
The 2021-2029 Housing Element, adopted in 2023, discusses the current affordable housing issues
that exist within the City and details the City’s existing Inclusionary Housing Program. The
proposed Fees are consistent with the Housing Element’s goal of providing opportunities for the
development of adequate housing for households of all income levels and are directly based on the
Inclusionary Housing Program requirements.
The City’s current Housing Program is managed by the Community Development Department.
The Housing Program implements goals and policies of the City’s General Plan and Housing
Element. The Housing Program manages market rate and affordable housing projects and
initiatives. A primary goal of the Housing Program is to expand the variety of housing availability
in the community to meet the current and future needs of the City’s community members. Housing
Program staff coordinates with local housing developers, non-profit housing organizations, and
the Area Housing Authority of County of Ventura to monitor and help develop new and preserve
existing housing in the City. The proposed Fees are consistent with the goals of the Housing
Element and the City’s Housing Program.
Comparison to Other Jurisdictions
An analysis of comparable cities that require affordable housing in-lieu fees is provided below as
a comparison to the maximum supported Fees as determined by this Study. Table ES. 3 shows the
average amount of affordable housing in-lieu fees collected per residential type in comparable
communities in the region. See Table 13 for an in-depth review of surrounding cities.
1 2 3 4 5 6
Extremely Low Income 30%27,900$ $31,900 $35,900 $39,850 $43,050 $46,250
Very Low Income 50%46,500$ $53,150 $59,800 $66,400 $71,750 $77,050
Low Income 80%74,400$ $85,000 $95,650 $106,250 $114,750 $123,250
Moderate Income 120% 111,600$ $127,600 $143,600 $159,400 $172,200 $185,000
Source: Area Housing Authority of County of Ventura I n come Limits effective May 15, 2023.
Percent
of AMI
Family Size
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Affordable Housing In-Lieu Fee Nexus Study iv April 2024
City of Moorpark
Table ES. 3: Average Fee of Comparable Municipalities
Policymakers may choose to adopt a fee less than the maximum supported amount in order to
lessen the burden on new development while still mitigating a portion of the affordable housing
needs created from new development.
Proposed Fees
City staff reviewed the options provided in this analysis and recommend the following fees be
adopted. These fees equal the maximum supportable fees calculated in this report and are less than
the averages of other local agencies. This methodology supports the City's goal of using the in-
lieu fee funds to help finance affordable housing development. See Table ES. 4 for a summary of
the recommended fees.
Table ES. 4: Proposed Fees
Land Use Fee
Single Family (Detached)$153,427
Multifamily - For-Sale (Attached)$86,442
Multifamily - For-Rent (Attached)$73,849
Source: See Table 13 for detailed local city survey.
Land Use
Inclusionary
Requirement1
Affordability
Level
Affordability Gap
per Unit2 Fee per Unit Total Fee
per Unit
Average of
Other Cities 3
Proposed
Fee4
7%80% AMI or
below $862,569 $60,380
8%120% AMI or
below $641,120 $51,290
7%80% AMI or
below $554,659 $38,826
8%120% AMI or
below $333,392 $26,671
7%30% AMI or
below $410,054 $28,704
8%50% AMI or
below $331,224 $26,498
1) City of Moorpark Inclusionary Housing Requirements, Municipal Code 17.24.065.
2) Table 10 and Table 11.
3) Table 13.
4) Proposed fees are rounded to the nearest 1,000.
Multifamily
For-Rent 55,203 $73,849 $55,000
Single Family
Detached For-
Sale
Multifamily
For-Sale 65,497 $86,442 $65,000
111,670 $153,427 $111,000
Resolution No. 2025-____
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58
Section 1 INTRODUCTION AND METHODOLOGY
INTRODUCTION
The City desires to introduce an Affordable Housing In-Lieu Fee for new residential development
to offer developers the option to pay an in-lieu fee rather than producing deed-restricted, affordable
units pursuant to the City’s Inclusionary Housing Ordinance (Ordinance No. 515) as part of any
new residential development project of 10 units or more. The Fee is designed to mitigate the impact
of an increase in affordable housing needed from the development of new market-rate residential
units.
This Study establishes the maximum supported Fee levels related to residential development. The
methodology establishes a reasonable relationship between the associated impact of new
development and the amount of the Fee and details the data sources and associated findings. The
first portion of the analysis determines the demand created by the development of market-rate
residential units for affordable housing units. The demand for affordable housing units at various
income levels is then used to calculate the “affordability gap”. For ownership housing units, the
sales price needed for units to be affordable to low-income households is compared to the cost to
develop these units to calculate the “affordability gap.” For rental units, the development cost is
compared with income sources available for housing to determine the “affordability gap”.
The second portion of the analysis involves applying the affordability gap calculations per unit to
both the estimated affordable housing demand determined in the first portion of the analysis and
the affordable unit requirements from the existing Inclusionary Housing Ordinance.
Background
This section discusses the City’s historical Inclusionary Housing Policy and the results of recent
legislation and judicial rulings.
City’s Inclusionary Housing Ordinance
The City uses an Inclusionary Housing Policy originally established by Ordinance No. 515
(adopted in October 2023) to generate affordable housing in proportion with the overall increase
in market-rate residential units and is described in the Housing Element of the City’s General Plan.
The Policy requires the following for housing projects with 10 or more units:
· For-Sale: For-sale residential development projects of fifteen (15) or more dwelling units
shall provide fifteen percent (15%) of the total units of a residential development and
satisfied by designating seven percent (7%) for low-income household and eight percent
(8%) for moderate income household. For residential developments of between ten (10)
Resolution No. 2025-____
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Affordable Housing In-Lieu Fee Nexus Study 2 April 2024
City of Moorpark
and fifteen (15) units, a single inclusionary unit shall be required and can be either very
low or low income.
· For-Rent: Rental residential development projects of fifteen (15) or more dwelling units
shall provide fifteen percent (15%) of the total units available at affordable rent and
satisfied by designated seven percent (7%) for extremely low-income households and eight
percent (8%) for very low-income households.
However, the Ordinance (and therefore the in-lieu fees) do not apply to the following:
· Projects that are not residential development.
· Residential developments of nine (9) or less residential units. Adjacent projects that are on
separate parcels but collectively equal ten (10) or more dwellings and are held by the same
owner are not exempt, unless permitted more than one (1) year apart.
· A one hundred percent (100%) affordable housing project.
· Units approved as accessory dwelling units or junior accessory dwelling units.
· Residential development projects using density bonus which meet or exceed the
affordability of fifteen percent (15%) of units.
The current Policy (as described in Ordinance 515) allows developers to pay an in-lieu Affordable
Housing Payment instead of developing affordable units as part of a project or as part of an offsite
project. The purpose of this Nexus Study is to determine the maximum justifiable fee for different
types of residential development. The City Council may choose to establish the fees at the
maximum justifiable amounts or at lower amounts to reduce the potential impact on new
residential development.
Legal Framework
In 2009, the Court of Appeals struck down a City of Los Angeles ordinance imposing inclusionary
housing requirements on rental housing projects with a density of more than 10 dwelling units per
lot. The Courts’ decision that regulating the rent levels to ensure the units were affordable in nature
directly violated the provisions of the Costa-Hawkins Act. Jurisdictions were unable to require
affordable housing units at affordable rental rates as a condition of project approval because of this
decision.
In 2015, the California Supreme Court ruled in favor of the City of San Jose in a court case
involving the California Building Industry Association (Association). The Association challenged
the legality of San Jose’s inclusionary program on the basis that it constituted an “exaction” that
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required a nexus study. The court deemed that San Jose’s inclusionary program was not an exaction
and it constituted a valid exercise of the City’s power to regulate land use.
Finally, in 2017, Governor Jerry Brown signed a package of housing related bills, which included
AB 1505, commonly referred to as the “Palmer Fix”. AB 1505 allows jurisdictions to adopt
ordinances that require a percentage of residential rental units to be affordable to individuals whose
income falls below the moderate-income limit, based on AMI, for the county. Additionally, AB
1505 requires jurisdictions to provide alternative methods for developers to satisfy their affordable
housing requirements, which may include in-lieu fees, off-site construction, land dedication, or
acquisition and rehabilitation of existing units.
METHODOLOGY
Nexus Analysis
Residential development projects contribute to population growth. As the population grows,
additional services and facilities are needed to accommodate the residential population influx. In
order to meet the increased demands of population growth, new non-residential development will
occur, correlating to an increase in the worker population. A portion of the new worker population
will earn a wage that is not sufficient to rent or purchase market-rate housing. The Study analyzes
the maximum supported Fee to address the affordable housing need created by new residential
development. The Fee will be used to build affordable housing to address the demand generated.
One approach to calculating a supportable in-lieu fee uses the demand created by the development
of market-rate residential units for affordable housing units. The demand for affordable housing
units at various income levels is then used to calculate the “affordability gap”. For ownership
housing units, the sales price needed for units to be affordable to low-income households is
compared to the cost to develop these units to calculate the “affordability gap.” For rental units,
the development cost is compared with supportable debt to determine the “affordability gap”. The
figure on the following page illustrates this methodology.
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Demand-Based Fee Methodology
An alternative approach is the Inclusionary Equivalent Fee Methodology, which involves applying
the affordability gap calculations per unit to the established affordable unit requirements from the
existing Inclusionary Housing Ordinance. This methodology has the advantage of using existing
inclusionary requirements, which may reflect additional considerations beyond demand created by
new development, such as the City’s Regional Housing Needs Allocation. The Study uses this
methodology, illustrated by the figure on the following page.
Determine types of new market-
rate units to be developed
Determine gross HH income
necessary to buy or rent
Determine discretionary HH
income levels spent on goods &
services for new HH
Determine jobs generated by
discretionary income spending
Determine amount of housing
units needed for workers
generated
Calculate Affordability Gap:
difference between development
cost and sales price (for-sale)
and development cost and
maximum supportable debt (for-
rent)
Affordabilty Gap x Estimated
Demand
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Inclusionary Equivalent Fee Methodology
Harris staff determined that the best methodology for calculating the City’s Affordable Housing
In-Lieu fee is the Inclusionary Equivalent Fee methodology. The Demand-Based Fee methodology
is not used in this nexus analysis.
The methodology utilized in this nexus analysis for the Inclusionary Equivalent maximum
supportable Fees complies with general best practices related to nexus studies and follows the
following order, specific data points are explained in the following sections of this study:
This nexus analysis begins with an analysis of the types of market rate residential units to be
developed. Harris coordinated with City staff, local real estate professionals, and a sampling of
planned and current recently developed housing types to determine the likely characteristics of
new residential units developed in the City and categorized the development into three land use
types based on the City’s General Plan 2050:
· Single-family detached (SFR for-sale)
· Multifamily condominiums (MFR for-sale)
· Multifamily apartments (MFR for-rent)
Using separate housing types ensures the presentation of an accurate representation of similar
market-rate units.
Harris staff estimated the income levels of buyers and tenants of market-rate units to serve as a
reference; this information is not directly used in the Inclusionary Equivalent Fee methodology.
The sales price and rent costs for market-rate units, as well as the income levels of potential buyers
and tenants were determined using several data sources. For rental units, the income level required
Determine types of new market-
rate units to be developed
Calculate Cost to Develop For-
Sale and For-Rent units in the City
Determine HH income levels and
maximum amount to be spent on
housing
Calculate Affordability Gap: difference
between development cost and sales
price (for-sale)
and development cost and maximum
supportable debt (for-rent)
Affordability Gap x Inclusionary
Housing Requirement
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to occupy market-rate units is determined by taking the average annual rent for a variety of rental
housing apartment sizes (studio to three bedroom) and adding the annual utility amounts, as
recommended by the US Department of Housing and Urban Development (HUD), to determine
the total annual cost. The annual housing cost is divided by 30%, the recommended maximum
percentage of gross income to be spent on housing costs, to determine the amount of household
income that would be required in order to rent a unit of that size. Table 1 details the calculations
for the income levels necessary to occupy market-rate rental units. The average household income
needed to rent a two- or three-bedroom MFR unit is currently estimated at $122,710.
Table 1: Housing Income Requirements – For-Rent Market-rate Units
With for-sale units, the calculation for the income level requirement to purchase a market-rate unit
accounts for a five percent (5%) down payment to determine the mortgage amount and then
applying the current mortgage insurance rates, homeowner’s insurance, estimated property tax
payments, and homeowner’s association (HOA) fees to determine the total monthly housing costs.
Finally, dividing the total monthly obligation by the maximum 35 percent (35%) of gross income,
as recommended by HUD.
Table 2 details the calculations of the income levels required to purchase for-sale market-rate
units.
Studio 1 Bedroom 2 Bedroom 3 Bedroom
Average Monthly Rent1 $1,665 $2,384 $2,840 $3,296
Annual Rent $19,980 $28,612 $34,076 $39,550
Percent of Income Spent on Rent 30% 30% 30% 30%
Annual Household Income Required $66,600 $95,373 $113,586 $131,833
1) Area Housing Authority of County of Ventura Income Limits effective May 15, 2023.
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Table 2: Housing Income Requirements – For-Sale Market-rate Units
For-Sale SFR For-Sale MFR
Market Sales Price1 $1,161,300 $779,800
Down Payment (5.0%)$232,260 $155,960
Amount Borrowed $929,040 $623,840
Estimated Mortgage Payment 2 $5,101 $3,426
Mortgage Insurance (0.55%)3 $426 $286
Homeowners Insurance (1.0%)1 $968 $650
Property Tax (1.20%)4 $1,161 $780
HOA $76 $315
Total Monthly Housing Cost $7,732 $5,457
Share of Income Spent on Mortgage 3 35%35%
Annual Household Income Required $265,097 $187,097
1) City of Moorpark General Plan Housing Element 2021-2029.
2) Assumes 5.2% interest rate and a 30-year amortization.
3) U.S. Department of Housing and Urban Development, 2023.
4) Keyser Marston Associates, Fuschia & Verbena Financial Analyses, April 2023.
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Section 2 AFFORDABILITY GAP ANALYSIS
A key input required in the calculation of the maximum supported in-lieu Fees is the affordability
gap. The affordability gap provides information on the difference between what lower-income
buyers and renters can afford to pay versus the total cost of developing the units. This section
summarizes the methodology used to calculate the affordability gap and presents the results of this
analysis for the respective unit type.
METHODOLOGY
The following section details total development costs of units in the City, the findings for
affordable housing rates, and a summary of the affordability gap by unit type.
DEVELOPMENT COSTS
The estimated cost of developing affordable housing units was determined by examining current
development trends related to unit type and size. As the development, sale, and operations
associated with for-rent and for-sale units vary, an analysis of each housing type was required.
For the purposes of this Study, the development costs for rental housing were based on recently
completed market-rate and affordable multifamily projects in the City and neighboring cities as
well as surveys performed by Keyser Marston Associates in their Fuchsia & Verbena Financial
Analyses (April 2023).
The costs associated with the cost for acquisition of land are based on research conducted by Harris
& Associates on recently sold land in the City and neighboring jurisdictions and are representative
of multifamily units recently completed within the City.
Table 3 shows the total development cost of multifamily for-rent two and three-bedroom units,
pursuant to the requirements in the City’s Inclusionary Housing Ordinance. Two-bedroom
multifamily units are assumed to be 922 square feet and three-bedroom units are assumed to be
1,214 square feet.
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Table 3: Development Costs – Affordable Multifamily For-Rent
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Table 4 shows the total development cost of multifamily for-sale two and three-bedroom units.
Two-bedroom units are assumed to be 1,772 square feet and three-bedroom units are assumed to
be 2,289 square feet.
Table 4: Development Costs – Affordable Multifamily For-Sale
Assumption Amount
Assumed Density A 24 Units/Acre
Land Acquisition Cost ($/Acre)1 B 883,962$
Land Price per Unit B ÷ A = C 36,832
Land Price per Unit SF C ÷ Average Unit Size2 18.14
Development Costs
Direct Development Costs
Land Cost ($/Rentable SF)$18.14
Building Hard Costs ($/SF)D 215.00
Prevailing Wage Cost Increase (25%)D x 0.25 = E 53.75
Market Sales Price (Owned MFR)3 F 779,800.00
Indirect Development Costs
Soft Costs (15%)4 (D +E) x 0.15 40.31
Developer Fees (12%)5 (F x 0.12)/Average Unit Size2 46.09
Financing Costs (10%)(D + E) x 0.10 26.88
Total Development Costs per SF $400.16
For-Sale Unit Development Cost Average Unit Sizes 6
2 Bedroom Unit 1,772 $709,088
3 Bedroom Unit 2,289 $915,972
Average Development Cost of 2 and 3 Bedroom Unit $812,530
1) Harris & Associates City of Moorpark Development Impact Fee Nexus Study, 2023.
2) Average square footage is 2,031 square feet.
4) Includes design, engineering, city permits and fees, and contingencies.
5) Percentage of Gross Sales Revenue for average 2,031 SF condominium unit.
6) Keyser Marston Associates survey in Fuchsia & Verbena Financial Analyses, April 2023, Appendix E.
3) Keyser Marston Associates survey completed April 2023 of townhome sales in the Fuchsia & Verbena at Pacific
Arroyo community.
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Table 5 shows the total development cost per for-sale unit. For-sale units are assumed to be 2,572
square foot, single-family homes, consisting of thee (3) bedrooms and two (2) bathrooms. The
costs associated with the development of these units were obtained from surveys performed by
Keyser Marston Associates in their Beltramo Ranch Analysis (May 2022).
Table 5: Development Costs – Affordable Single-Family For-Sale
AFFORDABLE HOUSING RATES
Prior to determining the affordability gap, the total amount that households can afford to allocate
to their housing must be determined. For the purposes of this report, the income levels included in
the City’s Inclusionary Housing Ordinance have been included in the analysis and are defined as:
1. Extremely Low Income (Between 0 and 30% of AMI)
2. Very Low Income (Between 30% and 50% of AMI)
3. Moderate Income (Between 80-120% of AMI)
Amount
Land Costs
Land Acquisition Cost per Acre1 $883,962
Land Cost per Unit (8 Units/Acre)$110,495
Site Improvement (15%)$16,574
Finished Lot Cost $127,070
Construction Costs Total Building Costs 2
Building Hard Costs $215.00 $552,980
Prevailing Wage Cost Increase (35%)$53.75 $138,245
Total Construction Hard Costs $691,225
Total Direct Development Costs $818,295
Soft Costs (10%)3 $26.88 $69,123
Developer Fees (12%)4 $54.18 $139,356
Financing Costs (10%)$31.82 $81,829
Total Indirect Development Costs $112.88 $290,308
Total Building Cost for 2,572 Square Foot Affordable Unit $1,108,603
4) Percentage of Gross Sales Revenue for a single family 2,572 SF, 3 bedroom, 2 bathroom detached home.
Direct Development Costs
Indirect Development Costs
1) Harris & Associates City of Moorpark Development Impact Fee Nexus Study, 2023.
3 ) Includes design, engineering, city permits and fees, and contingencies.
Estimated Cost
per SF
2) Construction assumed to be a single family 2,572 SF, 3 bedroom, 2 bathroom detached home per KMA Survey completed
Ma y 2022 for home sales occurring between May 2021 and May 2022 of homes constructed after 2010.
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Housing affordability for rental units is defined by HUD as 30% of gross income. Table 6 shows
the maximum affordable rent attributed to each income level.
Table 6: Maximum Affordable Rent by Income Level
The recommended household gross income expenditure for ownership housing units pursuant to
HUD is 35% of gross income minus a deduction for typical homeownership costs, such as
insurances, taxes, utilities, and fees.
Table 7 shows the maximum affordable mortgage for a low-income household of four persons.
It is important to note that only low-income and moderate-income households are included in this
portion of the analysis due to several factors including the affordability requirements in the City’s
existing Inclusionary Housing Ordinance, the tightening of lending requirements and the
elimination of redevelopment agencies in 2011. Under current programs and very limited funding
sources, it is generally not financially feasible to develop for-sale housing units for very low-
income households. Prior to 2011, redevelopment provided a significant funding source to cities
to assist homebuyers with loan qualification and down payment assistant at lower income levels.
Additionally, lending practices after the housing crash in 2008 have been reformed, making it more
difficult for individuals to obtain loans. These events have affected lower-income households
significantly, making ownership very challenging. The following analysis includes a deduction for
utilities to follow HUD guidelines.
Extremely Low
Income
Very Low
Income
Moderate
Income
(30% AMI) (50% AMI) (80-120% AMI)
Maximum Annual Household Income1 $35,900 $59,800 $143,600
Maximum Monthly Housing Cost2 $898 $1,495 $3,590
1) Household AMI is shown for a family of three. See Table ES.2.
2 ) 30% of gross monthly income per U.S. Department of Housing and Urban Development guidelines.
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Table 7: Maximum Affordable Mortgage by Income Level
AFFORDABILITY GAP RESULTS
The differences between the total cost of developing new units (Table 3, Table 4, Table 5) and
the total amount that each targeted income level can afford to allocate for housing (Table 6, Table
7) determines the Affordability Gap. This difference represents the fee amount that is necessary to
cover the costs of developing housing at each of the respective income levels analyzed. While
other funding sources may be available to assist in mitigating this difference between affordability
and development costs, these sources are very difficult to predict with accuracy moving forward.
In the case of for-sale housing, there are very few funding sources for subsidy on this unit type in
the wake of redevelopment dissolution in 2011 which eliminated approximately $1 billion of low
and moderate-income housing revenue Statewide. Lending practices have become stricter in the
years following the 2008 recession and qualifying households below 80% AMI for a mortgage is
extremely challenging, even with the City’s current down payment assistance program.
The City’s current Ordinance calls for 15% of all newly developed for-sale units to be affordable
to very low and low-income households (i.e., below 80% of AMI). Therefore, the inclusionary
equivalent gap analysis for ownership units has been limited to the low-income category for the
Low Income Low Income Moderate Income Moderate Income
SFR MFR SFR MFR
(80% AMI)(80% AMI)(120% AMI)(120% AMI)
Household Income1 $106,250 $106,250 $159,400 $159,400
Maximum Monthly Housing Cost2 $3,099 $3,099 $4,649 $4,649
Less:
Utility Deduction $376 $302 $376 $302
Mortgage Insurance (0.55%)3 $113 $118 $214 $220
Homeowner's Insurance (1.0%)4 $924 $677 $924 $677
Property Tax (1.20%)5 $259 $271 $492 $504
HOA 5 $76 $315 $76 $315
Maximum Monthly Mortgage $1,351 $1,416 $2,567 $2,631
Maximum Mortgage Amount 6 $246,034 $257,871 $467,483 $479,138
1) Household AMI is shown for a family of four. See Table ES.2.
2) 35% of gross income per U.S. Department of Housing and Urban Development guidelines.
3) U.S. Department of Housing and Urban Development, 2023, applied to Loan Amount.
4) City of Moorpark General Plan Housing Element 2021-2029, based on total direct development costs for replacement.
5) Keyser Marston Associates, Fuschia & Verbena Financial Analyses (April 2023) and Beltramo Ranch CBA (May 2022).
6) Determined by iterative process, where the Purchase Price and Loan Amounts are used to estimate Mortgage Insurance, and Property Taxes.
These in turn impact the maximum monthly mortgage amount available, which is used to establish revised Purchase Price (rounded to the
nearest $1,000) and Loan Amounts (95% Loan-to-Value). Iterations continue until the Maximum Mortgage amount is equal to or higher than
the Loan Amount.
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purposes of this analysis. Table 8 shows the for-sale affordability gap calculation for low- and
moderate-income households.
Table 8: Affordability Gap –For-Sale Units
The affordability gap for rental units is the difference between the development and the
maximum supported debt for each income level, shown in Table 9.
Table 9: Affordability Gap – For-Rent Units
Development Costs 1
Maximum Mortgage
Amount2 Affordability Gap
Low Income Single Family (80% AMI)$1,108,603 $246,034 $862,569
Low Income Multifamily (80% AMI)812,530 257,871 554,659
Moderate Income Single Family (120% AMI) 1,108,603 467,483 641,120
Moderate Income Multifamily (120% AMI)812,530 479,138 333,392
1) Tables 4 and 5.
2) Table 7.
Extremely Low Income Very Low Income Moderate Income
(30% AMI) (50% AMI) (80-120% AMI)
Maximum Potential Rent 1 $898 $1,495 $3,590
Utility Allowance2 240 240 240
An nual Gross Rental Income3 7,896 15,060 40,200
Vacancy Loss 4 395 753 2,010
Es timated Annual Expenses 5 7,500 7,500 7,500
Net Operating Income 1 6,807 30,690
Available for Debt Service6 1 5,673 25,575
Supportable Debt7 14 78,844 355,475
Development Costs 8 410,068 410,068 410,068
Affordability Gap $410,054 $331,224 $54,594
1) Table 6.
2) Area Housing Authority of County of Ventura Apartment Utility Allowance Schedule effective June 1, 2023.
3) Available rent multiplied by 12.
4) Assumes 5% for vacancy/collection loss.
5) Assumes $7,500 annual maintenance/capital improvement costs.
6) Assumes 1.2 Debt Coverage Ratio
7) Assumes a 6% interest rate and 30-year loan term.
8) Table 3.
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Section 3 FINDINGS AND NEXUS REQUIREMENTS
This section presents the maximum supported fee per market-rate unit, which is calculated by
following the methodology outlined in Section 1 and using the results from the affordability gap
analysis detailed in Section 2.
MAXIMUM FEE CALCULATION
Table 10 and Table 11 provide estimated maximum supported Fees using the requirements on the
total percentage of affordable units (both for-sale and rental) that must be developed as part of
market rate housing projects as stated in the City’s Inclusionary Housing Ordinance.
Table 10: Maximum Supported Inclusionary Equivalent Fee, For-Sale Units
Table 11: Maximum Supported Inclusionary Equivalent Fee, For-Rent Units
Low Income Moderate Income Low Income Moderate Income
(80% AMI) (120% AMI) (80% AMI) (120% AMI)
Single Family For-Sale Single Family For-Sale Multifamily For-Sale Multifamily For-Sale
Maximum Affordable Price1 $246,034 $467,483 $257,871 $479,138
Development Cost2 1,108,603 1,108,603 812,530 812,530
Affordable Gap $862,569 $641,120 $554,659 $333,392
Inclusionary Requirement3 $60,380 $51,290 $38,826 $26,671
Total For-Sale Fee
1) Table 8, rounded.
2) Tables 4 and 5, rounded.
3) 7% requirement for Low Income housing and 8% requirement for Moderate Income housing.
$111,670 $65,497
Extremely Low Income Very Low Income
(30% AMI)(50% AMI)
Multifamily For-Rent Multifamily For-Rent
Maximum Supportable Debt1 $0 $78,844
Development Costs 2 410,068 410,068
Affordable Gap $410,068 $331,224
Inclusionary Requirement 3 $28,705 $26,498
Total For-Rent Fee
1) Table 9, rounded.
2 ) Table 3, rounded.
3) 7% requirement for Extremely Low Income housing and 8% requirement for Very Low Income housing.
$55,203
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Table 12 summarizes the maximum justifiable fee for each land use.
Table 12: Maximum Justifiable Fee
Justifiable Fee
Single-Family For-Sale $111,670
Multifamily For-Sale 65,497
Multifamily For-Rent 55,203
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Section 4 POLICY CONSIDERATIONS
Adopting a fee to be collected from new development should be consistent with other City policies
and should not have measurable impacts on the development community. Harris and City staff
evaluated multiple scenarios and present the following for consideration.
HOUSING POLICY CONSISTENCY
The City adopted its 2021-2029 Housing Element (housing element) in February 2023. The
Housing Element identified that approximately one of every four households in the City is a lower-
income household (These groups consist of minimum-wage workers, seniors on fixed incomes,
disabled persons, and college students, all of whom have difficulty finding affordable housing).
Adopting an affordable housing impact fee enables the City to mitigate these issues for future
development by providing lower-income households the ability to afford adequate housing.
The City uses an Inclusionary Housing Policy originally established by Ordinance No. 515
(adopted in October 2023) to generate affordable housing in proportion with the overall increase
in market-rate residential units and is described in the Housing Element of the City’s General Plan.
The Policy requires the following for housing projects with 10 or more units:
· For-Sale: For-sale residential development projects of fifteen (15) or more dwelling units
shall provide fifteen percent (15%) of the total units of a residential development and
satisfied by designating seven percent (7%) for low-income household and eight percent
(8%) for moderate income household. For residential developments of between ten (10)
and fifteen (15) units, a single inclusionary unit shall be required and can be either very
low or low income.
· For-Rent: Rental residential development projects of fifteen (15) or more dwelling units
shall provide fifteen percent (15%) of the total units available at affordable rent and
satisfied by designated seven percent (7%) for extremely low-income households and eight
percent (8%) for very low-income households.
However, the Ordinance (and therefore the in-lieu fees) does not apply to the following:
· Projects that are not residential development.
· Residential developments of nine (9) or less residential units. Adjacent projects that are on
separate parcels but collectively equal ten (10) or more dwellings and are held by the same
owner are not exempt, unless permitted more than one (1) year apart.
· A one hundred percent (100%) affordable housing project.
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· Units approved as accessory dwelling units or junior accessory dwelling units.
· Residential development projects using density bonus which meet or exceed the
affordability of fifteen percent (15%) of units.
The current Policy (as described in Ordinance 515) allows developers to pay an in-lieu Affordable
Housing Payment instead of developing affordable units as part of a project or as part of an offsite
project. The purpose of this Nexus Study is to determine the maximum justifiable fee for each land
use. The City will then determine and establish by City Council resolution the amounts of the fee.
COMPARISON TO OTHER JURISDICTIONS
Jurisdictions throughout the State of California have adopted an affordable housing fee program
as a method of bridging the housing affordability gap. Harris has compiled a list of fees from
nearby cities that have adopted comparable affordable housing fees. Table 13 summarizes the
aggregated fees of the jurisdictions. An average excluding the City of Agoura Hills has also been
included as the fees charged in that jurisdiction are significantly higher than the fees adopted in
the other surrounding jurisdictions included in the comparison. The fee shown for Agoura Hills is
for every low income unit not built.
Table 13: Affordable Housing Fee Market Survey
CONCLUSION
The City has the discretion to adopt fees that are lower than the maximum supported fees under
the Inclusionary Equivalent level. High development costs have resulted in significantly higher
costs to develop affordable housing. Due to the housing legislation and mandates from the State
to cities to encourage the development of housing at all income levels, it is important to note
residential development could potentially decrease and occur in other jurisdictions with lower fees.
This would potentially result in decreased housing development in the City. One option available
to the City is to adopt Fees that are consistent with the average of the fees collected in other
jurisdictions in order to ensure that housing development continues at its current pace.
Municipality Year Fees Adopted
Single Family
For-Sale
Multifamily
For-Sale
Multifamily
For-Rent
Moorpark (Proposed) - $111,000 $65,000 $55,000
Oxnard 2020 36,000 35,000 28,000
Agoura Hills 2018 487,953 262,541 260,196
Calabasas 2021 66,900 48,100 19,000
Ventura 2023 133,070 53,150 30,850
Thousand Oaks 2023 43,210 33,419 31,200
Comparable City Average $153,427 $86,442 $73,849
Comparable City Average (excl. Agoura Hills)$69,795 $42,417 $27,262
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