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<br /> <br /> <br /> <br />5. Return metrics are not fair and reasonable. <br /> <br />Ώ 4.6% - this does not <br />. <br /> <br />Ώ Yield on cost of at least 5.25% represents a more reasonable market rate of return. <br /> <br />Ώ Driving to a below-market rate of return inflates the supportable in-lieu fee. <br /> <br />6. Lower market--lieu fees. <br /> <br />Ώ Santa Ana historically has some of the lowest rents in the County and is less capable of <br />supporting an in-lieu fee when compared to Irvine, Newport Beach, etc. <br /> <br />o Market rate developers incorporate the costs of such fees into their capitalized budgets. <br />supportable by the rents in the area. <br /> <br />o Construction costs, design costs, insurance, marketing and financing costs do not change <br />by city. These costs remain the same whether you are building in Santa Ana, Irvine or <br />Newport Beach. <br /> <br />o Consequently, cities with higher rents are able to afford higher in-lieu fees. Cities with <br />lower rents are able to afford less. <br /> <br />o Historically, Santa Ana has had the lowest rents in the County. Santa Ana should have <br />the lowest in- <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br />