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Regular Governing Body Meeting - Second Wednesday — Wed, Aug 12, 2026

Fee-in-lieu Proposed Change - Examples and Comparisons 7.21.26

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Santa Fe Minutes document ID
10702
Government source ID
10702
Original filename
Fee-in-lieu Proposed Change - Examples and Comparisons 7.21.26
Meeting ID
922
Agenda item ID
20843
SHA-256
bad75308b6d1b029d1cdd47e20e1342bd70f3b948dba12a5f49de00ffe398e69
Revision
1
First discovered
2026-09-14T22:35:38.290Z
Last checked
2026-09-14T22:58:31.576Z

Extracted text

Fee-in-lieu Proposed Changes
Below is a 139-unit project example, demonstrating a comparison of the current and proposed
fee structure. Based on this example the fee went from 15k to 48k per unit. Please note that the
cost per unit may vary depending on the project size and unit composition.
Current Fee-in-Lieu
65% AMI: basis for the gap calculation that establishes the per unit fee.
Proposed Fee-in-Lieu
30% AMI: basis for the gap calculation that establishes the per unit fee.
Fee per Unit (based on example above)
Current: $15,822 per affordable unit
Proposed: $48,167 per affordable unit

National Program Comparison
Even with this increase in the fee per unit, the cost per unit is still substantially below the other
national program fee amounts. See data below related to inclusionary fee structures across the
US.
City Fee Structure Rental Rate Amount
Boston, MA Per Affordable Unit $200,000 – $380,000
Larkspur, CA Per Affordable Unit $298,784
Broomfield, CO Per Affordable Unit $106,635
Denver, CO Per Affordable Unit $250,000 - $478,000
Littleton, CO Per Affordable Unit $277,890
Boulder, CO Per Affordable Unit $106,000 - $165,000
Two examples from our neighboring state Colorado (Broomfield and Boulder) are closest to the
proposed fee in lieu. These examples are still approximately 120% higher than the proposed fee
structure.
Fee Approach
Santa Fe’s current calculation is unique and results in a substantially lower per unit fee structure
than most cities across the US. This is because most cities utilize the subsidy replacement model
approach when identifying their per unit fee amount. The subsidy replacement model uses the
average cost to develop a rental housing unit and the subsidy needed to build a similar
affordable unit in their community. Below is an example of what a subsidy replacement model
approach would equate to in Santa Fe.
Santa Fe Example
Approximate Average Cost Per Unit: $350,000
Average Subsidy Percentage: 50%
Subsidy Cost Per Unit: $350,000 x 50% = $175,000
This explains the discrepancy between Santa Fe’s per unit fee amount and the amounts we see
nationally. The proposed increase is not only be well below other national programs, but it is

also well below the general amount Santa Fe would request if they were to use the popular
subsidy replacement model calculation.
Additionally, if the general subsidy needed to build new affordable housing units is
approximately $175,000 per unit, a fee of approximately $38,000 falls substantially short of
what is needed to build a replacement unit. Therefore, slowing Santa Fe’s affordable housing
development impact.
Payment Timing
Although most programs require developers to pay the fee at permit issuance or application.
There are some jurisdictions that allow developers to defer payment until the issuance of a
Temporary Certificate of Occupancy (TCO) or Final Certificate of Occupancy (COO).