Fair Fees, Not False Claims | Flagler Home Builders Association

Fair Fees. Real Growth. Honest Accountability.
The Flagler Home Builders Association supports lawful impact fee increases—but opposes unjustified claims of “extraordinary circumstances.”

The Flagler HBA supports increasing impact fees up to the legal 50% limit to fund parks, fire, and transportation—but challenges the City’s unsupported claim of "extraordinary circumstances" used to exceed that cap. Learn the facts.

It now costs tens of thousands more just to start a home.

These stacked fees make it harder for working families to buy, builders to build, and the next generation to afford a future in our community. They affect not only new homeowners, but also renters, employers, and the local economy as a whole.

We support funding infrastructure responsibly.
We support legal, data-driven fee increases.
What we don’t support is overreach disguised as planning—and cumulative costs that make it nearly impossible to deliver housing people can actually afford.

Palm Coast Impact Fees for New Single-Family Homes Have More Than Doubled in Some Categories
This chart compares 2024 vs. 2025 impact fees for a standard 2,000 sq ft single-family residence. The largest increase is in transportation, jumping over $4,000 per home.

Category	Old Fee ($)	New Fee ($)	Dollar Increase	% Increase
Parks & Recreation	1,828	3,164	+1,136	+73%
Fire	435	942	+507	+117%
Transportation	3,502	7,540	+4,038	+115%

Parks & Recreation rose from $1,828 to $3,164 – a 73% increase
Fire jumped from $435 to $942 – a 117% increase
Transportation soared from $3,502 to $7,540 – a 115% increase

These jumps represent an added cost of $5,681 per home, significantly burdening future homebuyers, without meeting the statutory threshold for “extraordinary circumstances.”

As other cities manage growth responsibly within legal limits, Palm Coast is choosing to outpace both its peers and its legal obligations.

When Everything Goes Up, So Does the Price of Housing

In addition to rising impact fees, the City of Palm Coast has implemented sweeping increases in utility-related charges since May 1, 2024. Fees for meter installation, inspections, irrigation, and more have jumped by hundreds or even thousands of dollars per home.

While these increases may be final, they matter. Because when you add them to rising transportation, parks, and fire fees, the cumulative cost to build a home skyrockets—well beyond what’s reasonable for working families or first-time buyers.

Even modest percentage increases stack up fast. The result? New housing becomes more expensive, fewer homes get built, and affordability suffers.

We've reviewed the data. We've read the reports. And what we've found is a familiar trend: shifting justifications, outdated assumptions, and numbers that simply don't add up.

From population forecasts that were too high in 2020 to new projections that are lower today…
From construction cost spikes that have since stabilized…
To comparisons with other Florida cities that manage growth without breaking the rules…

The evidence doesn’t support an extraordinary claim.
It supports a very ordinary truth: Palm Coast is growing, yes—but not in a way that warrants a legal exception.

Below, we break down the data—and why the City’s claim doesn’t hold water.

No Extraordinary Circumstances Exist:
Extraordinary circumstances, by legislative intent, must involve unforeseen and urgent conditions requiring immediate infrastructure investment. A reduction in projected growth is neither extraordinary nor urgent—it reflects moderated demand and reduced strain on infrastructure.

Weakened Nexus:
Impact fees must be proportionate to the infrastructure demand created by new development. If the City's anticipated population has decreased, then the burden on the transportation system is less, not more—making a fee increase unjustified.

Inconsistent with Proportionality Requirements:
The decrease in growth projections indicates that prior assumptions were overstated. Adjusting fees upward despite downward population revisions violates the constitutional principle of rough proportionality.

Signals Overcollection for Capital Improvements:
Doubling fees when demand is softening may result in the overcollection of revenue for capital improvements that are no longer needed or scaled appropriately—this risks transforming the fee into an impermissible revenue-generating tax.

Do Permits Track with Population? Not Exactly.

One of the common assumptions behind rising impact fees is that they’re justified by rapid population growth. But the numbers tell a different story in Palm Coast.

Over the past two decades, the relationship between population and single-family residential (SFR) permits has been anything but consistent. In fact, the data shows that housing permits and population growth often move independently of one another:

During the early 2000s, Palm Coast saw explosive growth — both in people and in housing. Between 2001 and 2005, the population increased by more than 50%, and annual permits soared from 1,524 to 3,951. That period showed a clear correlation.
But by 2008, things changed. While the population continued to grow, permits dropped off sharply — hitting a low of just 80 in 2011. From 2006 to 2011, Palm Coast added over 19,000 residents, yet SFR permit activity fell by more than 90%.
In the years that followed, permits slowly recovered. But the trend wasn’t smooth — and it certainly didn’t follow population growth year by year. For example, between 2016 and 2019, the population grew by over 6,000, but annual permits bounced unpredictably between 537 and 956.
In recent years, permit activity has once again surged — reaching over 2,000 permits annually from 2021 to 2024. But the population during this same time grew at a far more moderate pace, averaging fewer than 3,000 new residents per year.

Why This Matters

This inconsistent relationship shows there’s no fixed nexus between population growth and residential development activity. Permits often surge or stall based on broader economic forces — not because the population grew by a certain percentage.

Impact fees that assume a one-to-one link between population projections and building activity risk overstating demand — and overcharging those pulling permits. Growth may be steady, but building is cyclical. Fair fees recognize that difference.

Construction Cost Trends: Spike and Stabilization
This chart shows the annual percentage change in U.S. construction costs from 2018 to 2024. After sharp increases in 2021 and 2022 (highlighted in red), cost growth has significantly stabilized in 2023 and 2024 (highlighted in green)—undermining claims of ongoing “extraordinary” inflation.

Why Rising Construction Costs Don’t Qualify as Extraordinary Circumstances

Florida law only allows impact fees to rise beyond 50% in the presence of extraordinary circumstances. Rising construction costs—especially national trends—do not meet that threshold.

✅ Cost spikes were temporary

Costs surged in 2021–2022 due to supply chain disruptions—but have since stabilized.

✅ Costs have returned to normal growth

By 2024, construction cost increases have slowed dramatically. These are not ongoing, unforeseen, or locally specific.

✅ Florida law requires more

State statute demands that extraordinary circumstances be severe, unforeseen, and local.
General inflation is expected, and already accounted for in normal fee increases.

✅ The City's own data contradicts its position

Palm Coast is now projecting less growth than in 2020, yet using outdated cost spikes to double impact fees. That’s not planning. That’s overreach.

Why Rising Construction Costs Don’t Qualify as Extraordinary Circumstances

Florida law only allows impact fees to rise beyond 50% in the presence of extraordinary circumstances. Rising construction costs—especially national trends—do not meet that threshold.

✅ Cost spikes were temporary

Costs surged in 2021–2022 due to supply chain disruptions—but have since stabilized.

✅ Costs have returned to normal growth

By 2024, construction cost increases have slowed dramatically. These are not ongoing, unforeseen, or locally specific.

✅ Florida law requires more

State statute demands that extraordinary circumstances be severe, unforeseen, and local.
General inflation is expected, and already accounted for in normal fee increases.

✅ The City's own data contradicts its position

Palm Coast is now projecting less growth than in 2020, yet using outdated cost spikes to double impact fees. That’s not planning. That’s overreach.

Our Position on Impact Fee Increases

The Flagler Home Builders Association (FHBA) supports the City of Palm Coast in its efforts to responsibly plan for future growth and maintain essential public services. We recognize the need for updated infrastructure and agree that increasing impact fees—within the limits established by state law—is a reasonable and appropriate course of action.

Specifically, FHBA supports raising impact fees for parks, transportation, and fire services up to the legally allowed maximum of 50% over a four-year period, as outlined in Florida Statutes. These increases can help the City address legitimate infrastructure needs while preserving economic stability and housing affordability for our residents.

However, we strongly oppose any increase beyond the 50% cap based on the claim of "extraordinary circumstances." This legal threshold was designed by the Florida Legislature to prevent excessive, unjustified burdens on new development and must be supported by clear, compelling, and extraordinary evidence—which we believe the current circumstances do not provide.

This page outlines our concerns in detail, including data inconsistencies, legal standards, and the broader implications for housing, jobs, and the local economy.

Comparable Cities to Palm Coast

It is common in the course of impact fee studies for other municipalities impact fee rates to be compared. Instead of only selecting the closest municipalities, we found the most similar municipalities across the state:

Some additional information on the comparable municipalities fees:

Update Timing Matters

Impact fees must be based on current data—but they must also be justified within the framework of state law. Palm Coast’s update is one of the most recent in the region, yet it proposes to double fees beyond the legal 50% cap.

Other cities with similar growth and infrastructure demands—like Port Orange, Ocala, and Palm Bay—have recently updated their fees too, without claiming extraordinary circumstances to exceed statutory limits.

This reinforces our position: Palm Coast can address infrastructure needs within the same legal framework followed by its peers.

No available records or public meeting documents indicate that any of the listed cities have exceeded the 50% statutory limit on impact fees by claiming ‘extraordinary circumstances,’ even during recent updates.