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be attributed to new residential development during the planning period within <br />the county.. Some state legislatures and courts have authorized school impact <br />fees to be imposed on forms of commercial and industrial development? The <br />more common methodology, and the one chosen by Orange County, predicts <br />the number of public school students from growth in the housing stock. (The <br />choice was also influenced by the fact that Orange County has somewhat less <br />commercial and industrial development than a county with its population would <br />suggest.) <br /> <br /> One issue was the expected growth of the housing stock in the two <br /> school districts. The average annual growth rate of the housing stock during the <br /> period 1980-90 (3.08 percent in the Orange County district and 3.70 percent in <br /> <br />the Chapel HilI-Carrboro district) was projected to continue through 1998.43In <br /> <br />addition, the average number of children generated by a new dwelling unit <br />during the 1993-98 period was assumed to be the same as that dudng the <br />period 1980-90. These student generation rates we~'e then calculated .for <br />elementary, middle, and high schools in both districts. <br /> Another issue concerned whether the expected growth in the housing <br />stock and student generation rates should be projected by housing type and <br /> <br />the number of bedrooms. According to one variation of the proportionality logic, <br />a house with more bedrooms means a house with more children. Residents of <br />houses with more children thus could justifiably be expected to pay <br />proportionally more. Such an approach also appealed to those concerned with <br />the regressive nature of a flat fee on all housing units: if dwelling units with more <br /> <br />42. CAL. GOVERNMENT CODE § 65995 (West 1983); Shapell Industries, I.nc. v. Governing Bd. of <br /> <br />Milpitas Unified School District, I Cal. App. 4th 218 (Cal. App. 1991). <br /> <br />43. Revised Report on School Impact Fee Calculation, supra note 9, p. 16.1, Table 14. <br /> <br /> .,47 <br /> <br /> <br />