• Following the 2013 dissoluiton of the City of Vancouver’s Interlocal Parks Agreement with Clark County, the City’s Park Impact Fee (PIF) service area districts were consolidated and redefined in 2016 from ten original, numbered districts, to three larger lettered districts (Districts A, B, and C) (see attached 2016 Staff Report No. 143-16 for reference (“2016 Staff Report”).
• The 2016 realignment and consolidation of the PIF districts did not include a corresponding realignment of the PIF district accounts. At the time, there were ongoing projects and considerable funds in many of the original district accounts, much of which was already committed for expenditure.
• Currently the original district accounts contain only residual funds or, because the district service area realignment involved a separation from Clark County, only isolated original service areas remaining in the City.
• During the 2016 realignment of the County and City park service area districts, collected funds were proportionately allocated between the County and the City. The most effective way for the City to use the residual PIF funds in the service areas for which they were collected is consolidation of the original district accounts with the current park service area districts.
• The current 2020 PIF Technical Document includes a management policy to retroactively retain the original district allocations for funds collected prior to January 1, 2017; however, there is no prohibition in statute, code, or administrative rule requiring this. Further, the PIF district realignment presumes that the original districts in which PIFs were collected are served by and benefit from public improvements made in the new, realigned districts.
• Under the City’s PIF program and state law governing impact fees, the Parks, Recreation & Cultural Services Department has the authority to direct funds remaining in the original district accounts to be merged with the realigned district accounts, provided it is done in compliance with all other account and fund expenditure standards, including tracking concurrency based on when PIF funds were received by the City.
• Accordingly, all remaining funds in original district accounts could be consolidated into the respective New District account that covers the substantially same service area as that original. 

Goal 3, Objective 3.2: Improve services available to underserved or vulnerable residents

Goal 4: Ensure that Vancouver's parks and trails system is the highest quality and most complete in the region

The restrictions on the City’s use and allocation of PIF funds is addressed by the “reasonableness” requirements of RCW 82.02.060(8). For example, the new District C service area encompasses the City’s portion of the old District 6. Provided that any PIF funds accrued in accounts assigned to the old, numbered districts are expended proportionately in the respective new District A, B, or C covering the area of the original district where PIF was assessed, this approach is fully permissible, so long as the City adopts such a policy.

The 2016 PIF Technical Document indicated as a procedural matter that PIF funds collected prior to the 2017 Ordinance would be restricted retroactively to the original district, except when a site serves more than one district (see “Fund Management” on page 16 of the 2016 Staff Report).

In 2017, in accordance with the 2016 Resolution, the acquisition and development accounts of the former PIF service districts were merged retroactively into single accounts and a single consolidated acquisition and development account was created for each of the three realigned PIF service districts. The reasoning provided in the 2016 PIF Technical Document, and continued in as stated in the 2020 PIF Technical Document for the merger and consolidation of the acquisition and development component of the PIF District accounts, is:

“The park impact fee calculation formula includes an acquisition and development component. Prior to 2016 there were separate acquisition and development accounts for each of the park districts, although this was not required by either state law or city code. Acquisition and development accounts were merged in 2016 into a single account retrospectively for each of the original ten districts, and each of the realigned park districts (A, B and C) have a single account prospectively.”

When the realignment of the service districts occurred in 2017, retaining separate accounts for the old and new districts made sense, especially because there was a period of time when the realignment was subject to challenge and could have been reversed. Now, however, the bulk of such retained funds have been expended (or appropriated) and the realignment is well established. Therefore, the revised approach to fund management in the proposed resolution and amendment to the PIF Technical Document provides the City improved flexibility and responsiveness to meet community needs and adopted standards.

1. Achieving the purpose intended by the 2016 PIF district realignment and more effectively delivering the intended benefits of the PIF program to the appropriate service areas;
2. Acknowledgement that the old district accounts are now essentially residual accounts and the current policy does not allow for or provide a plan to close out these accounts;
3. Giving the City the ability to actually expend PIF funds for the purpose intended in appropriate, designated service areas by pooling residual funds with larger, current district accounts; and
4. Creating administrative efficiency and accuracy – while this policy shift will require an initial upfront investment of staff time, the account consolidation will result in long-term efficiencies and accuracy in delivering services and managing funds.