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City of Victorville

Annual Report on Development Impact Fees & Capacity Charges (Government Code Sections 66006 and 66013)

Fiscal Year 2016-2017

Fiscal Year 2017-2018

Fiscal Year 2018-2019

Fiscal Year 2019-2020

Fiscal Year 2020-2021*

(*Includes 5-Year Report per Government Code Section 66001)

Rev. 5/31/22

Background

The Mitigation Fee Act, Government Code Section 66000 et seq., (the “Act”) governs the establishment and administration of development impact fees and capacity charges paid by new development projects for public facilities needed to serve new development. Fees/charges must be separately accounted for and used for the specific purpose for which the fee/charge was imposed. The City’s adopted development impact fees and capacity charges are listed in the attached exhibits. Expenditures are authorized through the annual Operating Budget and the City’s Capital Improvement Program.

Sections 66001 and 66006 of the Government Code provide that the City of Victorville ("City") shall make available to the public certain information and adopt described findings relative to development impact fees ("Impact Fees") collected pursuant to Section 66000 et seq. of the Government Code. The described information and findings relate to Impact Fees received, expended or to be expended in connection with public facilities to accommodate new development. Section 66013 of the Government Code provides that the City make available to the public certain information relative to capacity charges.

Annual Development Fee Reporting

The Act requires that the City prepare an annual review of all development impact fees and capacity fees as defined in the Act and make a public report on the fees available to the public after the end of each fiscal year. Section 66006(b) of the Government Code requires that for each Impact Fee the City shall, within 180 days after the last day of each Fiscal Year, make available to the public the following information for the Fiscal Year:

• A brief description of the type of fee in the account or fund;
• The amount of the fee;
• The beginning and ending fund balance of the account or fund;
• The amount of the fees collected, and interest earned;
• An identification of each public improvement on which fees were expended and the amount of expenditures on each improvement, including the total percentage of the cost of the public improvement that was funded with fees;
• An identification of an approximate date by which the construction of the public improvement will commence if the local agency determines that sufficient funds have been collected to complete financing on an incomplete public improvement;
• A description of each interfund transfer or loan made from the account or fund, including the public improvement on which the transferred or loaned fees will be expended, and, in the case of an interfund loan, the date on which the loan will be repaid and the rate of interest that the account or fund will receive on the loan; and
• The amount of refunds made due to sufficient funds being collected to complete financing on incomplete public improvements and volume of reallocation of funds made due to administrative costs of refunding unexpended revenues exceeding the amount to be refunded.

Sections 66013(d) has very similar requirements in that, within 180 days after the last day of each Fiscal Year, the City must make available to the public the following information for the Fiscal Year:

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• A description of the charges deposited in the fund;
• The beginning and ending balance of the fund and the interest earned from investment of moneys in the fund;
• The amount of charges collected in that fiscal year;
• An identification of:
• oEach public improvement on which charges were expended and the amount of expenditure for each improvement, including the percentage of the total cost of the public improvement that was funded with those charges if more than one source of funding was used;
• oEach public improvement on which chares were expended that was completed during that

Each public improvement on which chaos were expended that was completed during that fiscal year;

• oEach public improvement that is anticipated to be undertaken I the following fiscal year;
• A description of each interfund transfer or loan made from the capital facilities fund, including the public improvement on which the transferred or loaned charges are or will be expended, and, in the case of an interfund loan, the date on which the loan will be repaid and the rate of interest that the fund will receive on the loan.

Government Code Section 66013(e) allows for the required information on capacity charges to be included in the local agency's annual financial report. However, Government Code Section 66006(b)(2) requires that the Impact Fee report be placed on an agenda for review at a public meeting not less than 15 days after the report is made available to the public. Additionally, Section 66001(d) of the Government Code requires that for each Impact Fee, the City shall make all of the following findings every fifth year with respect to that portion of the account remaining unexpended, whether committed or uncommitted:

• Identify the purpose to which the fee is to be put;
• Demonstrate a reasonable relationship between the fee and purpose for which it is charged;
• Identify all sources and amounts of funding anticipated to complete financing in incomplete improvements; and
• Designate the approximate dates on which the funding is expected to be deposited into the appropriate account or fund.

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Annual Reports

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Brief Description and Amount of Fees Government Code Sections 66006(b)(1)(A) and (B); 66013(d)(1)

Fund # Fund Description Fee Description Last Updated Residential Fees per Dwelling Unit Non-Residential Fees per Building SF

Single Family Multi-Family Commercial Industrial Industrial High Cube

350 Public Buildings Construction of Public Buildings, Facilities 06-151 1,334.35 716.95 1.34 0.44 0.25

351 Fire Construction of Fire Service Buildings, Equipment 06-151 328.81 232.13 0.17 0.01 0.02

352 Road Construction of Public Roads 08-064 4,469.90 2,744.62 7.60 2.98 1.58

353 Public Safety Construction of Public Safety Buildings, Facilities 06-151 139.07 98.18 0.17 0.01 0.02

354 Recreation Construction of Parks, Recreational Amenities 06-151 5,045.87 3,847.12 0.00 0.00 0.00

357 Storm Drain Construction of Drainage Facilities 90-158 * * * * *

410 Water Capacity Charge Connection to Water District Pipelines/Capacity and Infrastructure 13-003 5,1421 Fee Varies2 Fee Varies2 Fee Varies2 Fee Varies2

425 Sewer Capacity Charge Connection to Victorville Sewer Infrastructure 91-219 350.003 350.003 350.003 350.003 350.003

* Collected at a rate of 2,585 per acre on all new development types.

1 Meter Size 3/4. Fee will increase based on meter size.

2 Fees can be located on City of Victorville Engineering Fee schedule

3 The local connection fee is three hundred fifty dollars (350.00) per house, habitation or structure, or number of equivalent dwelling units (“EDUs”)

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Fund Balances, Fees Collected, Interest Earned, and Project Expenditures - Five Year History Government Code Section 66006(b)(1)(C)(D) and (G); Government Code Section 66013(d)(2) and (3)

*Fund balances reflected are listed on a cash basis

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Fund Balances, Fees Collected, Interest Earned, and Project Expenditures - Five Year History Government Code Section 66006(b)(1)(C)(D) and (G); Government Code Section 66013(d)(2) and (3) "(continued)"

• Other Revenue Interest 9,476 0 26,967 0 72,093 0 77,137 0 12,619
• Capital Other Revenue -6,000 0 -27,453 0 -54,567 0 -305,598 0 -1,621,014
• Interfund Loan Payment Capital 47,312 -6,000 -27,453 43,370 -54,567 78,854 -305,598 128,137 -1,621,014
• Interfund Loan Payment Ending Balance 2,751,583 47,312 3,796,444 43,370 5,366,217 78,854 7,286,107 128,137 8,737,465
• Other Revenue Interest 1,091 0 3,434 0 9,575 0 10,412 0 2,159
• Other Revenue Capital -5,064 0 -2,688 0 0 0 -1,959 0 -304
• Capital Interfund Loan Payment 39,742 -5,064 36,430 -2,688 66,237 0 107,635 -1,959 -304
• Interfund Loan Payment Ending Balance 334,576 39,742 490,939 36,430 752,393 66,237 1,079,365 107,635 1,385,996
• Interfund Loan Payment Capital and Operating Expenditures -31,533,125 0 -38,129,959 0 -34,422,579 0 -26,830,016 0 -34,590,454
• Ending Balance Interfund Loan Payment 54,279,678 0 44,616,190 0 39,678,327 0 39,589,393 0 41,268,272
• Interfund Loan Payment Capital and Operating Expenditures -12,518,127 0 -17,629,574 0 -15,897,418 0 -17,313,754 0 -16,551,589
• Ending Balance Interfund Loan Payment 23,585,819 0 16,887,417 0 14,759,360 0 12,265,973 0 13,076,574

*Fund balances reflected are listed on a cash basis

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City of Victorville Annual Report Development Impact Fees Fiscal Year Ended June 30, 2017

Projects by Fund FY17 Government Code Section 66006(b)(1)(E); Government Code Section 66013(d)(4)(A)

* Project Expenditures and Budgets are listed on a budgetary basis whereas fund balances on prior pages are listed on a cash basis.

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City of Victorville Annual Report Development Impact Fees Fiscal Year Ended June 30, 2018

Projects by Fund FY18 Government Code Section 66006(b)(1)(E); Government Code Section 66013(d)(4)(A)

Sewer Capacity Charge (425)

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City of Victorville Annual Report Development Impact Fees Fiscal Year Ended June 30, 2019

Projects by Fund FY19 Government Code Section 66006(b)(1)(E); Government Code Section 66013(d)(4)(A)

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City of Victorville Annual Report Development Impact Fees Fiscal Year Ended June 30, 2020

Projects by Fund FY20 Government Code Section 66006(b)(1)(E); Government Code Section 66013(d)(4)(A)

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City of Victorville Annual Report Development Impact Fees Fiscal Year Ended June 30, 2021

Projects by Fund FY21 Government Code Section 66006(b)(1)(E); Government Code Section 66013(d)(4)(A)

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Government Code Section 66006(b)(1)(F), (G) and (H) Government Code Section 66013(d)(1), (4)(B) and (C) Annual Reporting for FYE 2017 through 2021

Public Buildings – Fund 350

Funding collected is to be used for new facilities, capital equipment, or improvements of existing city facilities to aid in the services of future population. Due to an existing interfund loan payable and minimal fund balance, the construction of eligible improvements for City buildings is not expected to begin until sufficient funds are accumulated.

Funds previously collected were used to expand City Hall facilities. Due to a population growth spurt in the early 2000's, more room was needed to expand services and to house additional staffing. Additional funding was needed for this project, so an interfund loan payable was established on November 15, 2011 in the amount of $20,290,000. The interest rate for the loan was established at the annualized (averaged) Local Agency Investment Fund "LAIF" rate and originally had a term ending on June 30, 2016. The loan term was subsequently extended to June 30, 2021. Such loan had a balance of $18,840,197 as of June 30, 2021, which is payable from Fund 350 to various other DIF funds. The annual payments made from Fund 350 in connection with the interfund loan are included on the five-year history chart earlier in this report. Subsequent to this reporting period, a request for an additional extension of the loan term is begin made prior to FYE 22.

Additionally, a loan payable in the original amount of $1,903,000 was established from Fund 350 payable to the Southern California Logistics Airport Authority, with an annualized (averaged) and compounded LAIF interest rate, in connection with the acquisition of land for a City library. Such loan had a balance of $1,940,094.54 as of June 30, 2021. The annual payments made from Fund 350 in connection with the interfund loan are included on the five-year history chart earlier in this report. Subsequent to this reporting period, on May 17, 2022, the City Council approved the termination of the loan agreement which was payable from the Public Buildings DIF to the Southern California Logistics Airport Authority.

During each reporting annual period listed above, no refunds were made from this fund pursuant to Government Code Section 6600.1

Fire – Fund 351

Funding collected is to be used for building and equipping of new fire stations to aid in the service of future population. Due to an existing interfund loan payable and minimal fund balance, the construction of eligible improvements for City building is not expected to begin until sufficient funds are accumulated.

Funds collected were used to build two new fire stations – Station 312 at 15182 El Evado Road and Station 315 at 12820 Eucalyptus Street. Due to a population growth spurt in the early 2000's, more stations were needed to support the additional growth. Additional funding was needed for this project so an interfund loan payable from Fund 351 to the Roads DIF fund 352 was established at the annualized (averaged) LAIF rate as simple interest. Such loan had a term ending June 30, 2021 and had a balance of $2,286,536 as of June 30, 2021. The payments made from Fund 351 in connection with the interfund loan are detailed annually on the five-year history chart earlier in this report. Subsequent to this reporting period, on May 17, 2022, repayment to the Road DIF in the amount of $2,286,536 by the General Fund, on behalf of the Fire DIF, was approved by the City Council.

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During each reporting annual period listed above, no refunds were made from this fund pursuant to Government Code Section 6600.1

Roads – Fund 352

Funding collected is to be used for building new roads to expand the city as new development occurs in previously undeveloped areas. This funding is currently supporting the projects for the Green Tree Extension to connect to Yucca Loma and the Bear Valley Bridge Widening project over the BNSF Railroad Bridge west of Industrial Blvd. The City of Victorville has established an agreement with San Bernardino County Transportation Authority to borrow funding to complete the Green Tree Extension in exchange for repayment from future DIF funding received by the City. Future financing will continue the use of this funding for the above listed projects.

As mentioned previously, and interfund loan in the amount of $7,725,000 was made from Roads Fund 352 to the Public Building Fund 350 as described above. The interest rate for the loan was established at the annualized (averaged) Local Agency Investment Fund “LAIF” rate and originally had a term ending on June 30, 2016. The loan term was subsequently extended to June 30, 2021 and a request to extend the term is being made prior to FYE 22.

Additionally, an interfund loan was made from Road Fund 352 to the Fire Fund 351 as described above. The loan in the original amount of $2,658,525 was established at the annualized (averaged) LAIF rate as simple interest. Such loan had a term ending June 30, 2021. Subsequent to this reporting period, on May 17, 2022, repayment to the Road DIF in the amount of $2,286,536 by the General Fund, on behalf of the Fire DIF, was approved by the City Council.

During each reporting annual period listed above, no refunds were made from this fund pursuant to Government Code Section 6600.1

Public Safety – Fund 353

Funding collected is to be used for facilities and equipment in connection with the expansion of police services as new development occurs. The majority of the funds are currently tied into an interfund loan receivable, and the focus of this fund is toward a new larger police facility. That project is not expected to commence until sufficient funds have been collected.

An interfund loan in the amount of $1,150,000 was made from the Public Safety Fund 353 to the Public Building Fund 350 as described above. The interest rate for the loan was established at the annualized (averaged) Local Agency Investment Fund “LAIF” rate and originally had a term ending on June 30, 2016. The loan term was subsequently extended to June 30, 2021 and a request to extend the term is being made prior to FYE 22.

During each reporting annual period listed above, no refunds were made from this fund pursuant to Government Code Section 6600.1

Recreation – Fund 354

Funding collected is to be used for new or expanded parks, park amenities, recreational facilities, or expansions of services as new development occurs in the area. Certain City parks and community centers were pledged as security for a 2007 bond, so the city must seek approval prior to modifying or taking any action on these properties outside of routine maintenance. The encumbrance on these City facilities has made it difficult and cost prohibitive to utilize much of

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the existing fund balance for park and recreational amenities. However, subsequent to this reporting period, on May 19, 2022, such bonds were refinanced, and the encumbrance of such properties will be lifted. This will facilitate the ability to spend the existing fund balance.

Recent expenditures include the completion of a skate park, new restrooms, and additional park amenities at Doris Davies Park as well as the completion of a new Parks and Recreation Master Plan.

An interfund loan in the amount of $4,375,000 was made from the Recreation Fund 354 to the Public Building Fund 350 as described above. The interest rate for the loan was established at the annualized (averaged) Local Agency Investment Fund "LAIF" rate and originally had a term ending on June 30, 2016. The loan term was subsequently extended to June 30, 2021 and a request to extend the term is being made prior to FYE 22.

During each reporting annual period listed above, no refunds were made from this fund pursuant to Government Code Section 6600.1

Storm Drain – Fund 357

Funding collected is to be used for the building of storm drain infrastructure as new development occurs in previously undeveloped areas or in areas with deficiencies as a result of new growth.

An interfund loan in the amount of $3,675,000 was made from the Storm Drain Fund 357 to the Public Building Fund 350 as described above. The interest rate for the loan was established at the annualized (averaged) Local Agency Investment Fund “LAIF” rate and originally had a term ending on June 30, 2016. The loan term was subsequently extended to June 30, 2021 and a request to extend the term is being made prior to FYE 22.

During each reporting annual period listed above, no refunds were made from this fund pursuant to Government Code Section 6600.1

Water Capacity Charge – Fund 410

Water Capacity Fees are one-time charges to new development connecting to the City of Victorville/Victorville Water District's water system. Listed projects include the expansion of the water line connections for the extension of Green Tree Boulevard to Yucca Loma as well as the building of a one-million-gallon underground water storage tank at SCLA.

Sewer Capacity Charge – Fund 425

Sewer Capacity fees are one-time charges to new development or existing development first connecting to the City of Victorville's sewer system. Listed projects in FY22 include continuing work on the expansion of the sewer line connections for the extension of the Green Tree Boulevard to Yucca Loma.

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Five-Year Report

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This Five-Year Report provides information and findings on unexpended funds in the various DIF accounts as of June 30, 2021, pursuant to Government Code Section 66001(d). It also provides supplemental information for Government Code Section 66013(d)(4) and information specific to Government Code Section 66013(d)(5), if applicable.

Public Buildings – Fund 350

Purpose: Funding collected is to be used for new facilities, capital equipment, or improvements of existing city facilities to aid in the services of future population. As outlined in the Development Impact Fee & Capacity Fee Capital Improvement Plan FY 2023, the Central Facilities Yard and Central Household Hazardous Waste/Consolidated Recycling Facility will help to serve a future population. The City Hall facility, which houses the majority of the city's workforce, has existing capacity to serve new development, but may be further expanded, or otherwise improved in the future.

Unexpended Fees: This Fund has a balance of $39,740 of unexpended fees as of June 30, 2021.

Relationship between fee and purpose: There is a reasonable relationship between the unexpended fee and the purpose for which it was charged because it will continue to fund the expansion of city facilities or equipment as the population grows.

Sources and Amounts of funding anticipated: A Potential funding sources other than DIF for the Central Facilities Yard is the City's general fund at 50%. The solid waste fund and landfill mitigation funds may provide funding for the Central Household Hazardous Waste/Consolidated Recycling Facility at 50%. The exact amounts potentially needed from these sources is undetermined.

Approximate dates funding expected: The fees will be collected from developers prior to final inspection of the project. The exact dates for which future fees are collected is unknown.

Fire – Fund 351

Purpose: Funding collected is to be used for building and equipping of new fire stations to aid in the service of future population. As outlined in the Development Impact Fee & Capacity Fee Capital Improvement Plan FY 2023, the construction of Fire Station 316 will help to serve a future population. The unexpended fees could also be used to help fund facility improvements as outlined in the City's Public Safety Plan.

Unexpended Fees: This Fund has a balance of $19,394 of unexpended fees as of June 30, 2021.

Relationship between fee and purpose: There is a reasonable relationship between the unexpended fee and the purpose for which it was charged because it will continue to fund the expansion of fire services as the population grows.

Sources and Amounts of funding anticipated: Potential funding sources other than DIF for the fire station include Measure P and the City's general fund at 50%. The exact amounts potentially needed from these sources is undetermined.

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Approximate dates funding expected: The fees will be collected from developers prior to final inspection of the project. The exact dates for which future fees are collected is unknown.

Roads – Fund 352

Purpose: Funding collected is to be used for building new roads to expand the city as new development occurs in previously undeveloped areas. This funding is currently supporting the projects for the Green Tree Extension to connect to Yucca Loma and the Bear Valley Bridge Widening project over the BNSF Railroad Bridge west of Industrial Boulevard. As outlined in the Development Impact Fee & Capacity Fee Capital Improvement Plan FY 2023, the unexpended fees may be used for numerous projects throughout the City. Please see the 2023 Plan for details of the projects.

Unexpended Fees: This Fund has a balance of $10,463,600 in unexpended fees as of June 30, 2021.

Relationship between fee and purpose: There is a reasonable relationship between the unexpended fee and the purpose for which it was charged because it will continue to fund the expansion of roadway and related projects as the population grows.

Sources and Amounts of funding anticipated: Potential funding sources other than DIF for the roadway and related projects include Measure I and the City's general fund at varying percentages per project. The exact amounts potentially needed from these sources is undetermined. The City of Victorville has established an agreement with San Bernardino County Transportation Authority to borrow funding to complete the Green Tree Extension in exchange for repayment from future DIF funding received by the City.

Approximate dates funding expected: The fees will be collected from developers prior to final inspection of the project. The exact dates for which future fees are collected is unknown.

Public Safety – Fund 353

Purpose: Funding collected is to be used for the expansion of police services to the area as new development occurs. As outlined in the Development Impact Fee & Capacity Fee Capital Improvement Plan FY 2023, the construction of a Central Police Department Building will help to serve a future population. The unexpended fees could be used to help fund this police station.

Unexpended Fees: This Fund has a balance of $597,579 of unexpended fees as of June 30, 2021.

Relationship between fee and purpose: There is a reasonable relationship between the unexpended fee and the purpose for which it was charged because it will continue to fund the expansion of police services as the population grows.

Sources and Amounts of funding anticipated: Potential funding sources other than DIF for the police station include American Rescue Plan Act funding (ARPA) at 78%. The exact amounts potentially needed from alternate sources is undetermined.

Approximate dates funding expected: The fees will be collected from developers prior to final inspection of the project. The exact dates for which future fees are collected is unknown.

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Recreation – Fund 354

Purpose: Funding collected is to be used for new or expanded parks, park amenities, recreational facilities, or expansions of services as new development occurs in the area. As outlined in the Development Impact Fee & Capacity Fee Capital Improvement Plan FY 2023, the unexpended fees may be used for numerous projects throughout the City. The projects include a sports complex, dog parks, shade structures, track lighting, a pool complex and splash pad, recreational walking paths or loops, and developing a Trails Master Plan to address the need for additional trails and connectivity throughout the City. Please see the 2023 Plan for more details of the projects.

Unexpended Fees: This Fund has a balance of $8,737,465 in unexpended fees as of June 30, 2021.

Relationship between fee and purpose: There is a reasonable relationship between the unexpended fee and the purpose for which it was charged because it will fund new park and recreation amenities for the future population.

Sources and Amounts of funding anticipated: Potential funding sources other than DIF for the parks and recreation projects include Measure P, the City's general fund, and state and federal grants at varying percentages per project. The exact amounts potentially needed from these sources is undetermined.

Approximate dates funding expected: The fees will be collected from developers prior to final inspection of the project. The exact dates for which future fees are collected is unknown.

Storm Drain – Fund 357

Purpose: Funding collected is to be used for the building of storm drain infrastructure as new development occurs in previously undeveloped areas or in areas with deficiencies as a result of new growth. As outlined in the Development Impact Fee & Capacity Fee Capital Improvement Plan FY 2023, the unexpended fees may be used for numerous projects throughout the City. Please see the 2023 Plan for details of the projects.

Unexpended Fees: This Fund has a balance of $1,385,996 in unexpended fees as of June 30, 2021.

Relationship between fee and purpose: There is a reasonable relationship between the unexpended fee and the purpose for which it was charged because it will continue to fund the expansion of regional drainage projects and storm drain infrastructure as the population grows.

Sources and Amounts of funding anticipated: A potential funding source other than DIF for the storm drain projects is the City's general fund at varying percentages per project. The exact amount potentially needed from other sources is undetermined.

Approximate dates funding expected: The fees will be collected from developers prior to final inspection of the project. The exact dates for which future fees are collected is unknown.

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Water Capacity Charge – Fund 410

Purpose: Water Capacity Fees are one-time charges to new development connecting to the City of Victorville/Victorville Water District's water system. FY22 projects include the expansion of the water line connections for the extension of Green Tree Boulevard to Yucca Loma as well as the building of a one-million-gallon underground water storage tank at SCLA. As outlined in the Development Impact Fee & Capacity Fee Capital Improvement Plan FY 2023, the unexpended fees may be used for numerous projects throughout the City. Please see the 2023 Plan for details of the projects.

Unexpended Fees: This Fund has a balance of $41,268,272 in unexpended fees as of June 30, 2021.

Relationship between fee and purpose: There is a reasonable relationship between the unexpended fee and the purpose for which it was charged because it will continue to fund the expansion of water infrastructure projects that improve the water system as the population grows.

Sources and Amounts of funding anticipated: Funding sources other than DIF for the water system improvements listed in the 2023 Capital Plan are not anticipated.

Approximate dates funding expected: The fees will be collected from developers prior to final inspection of the project. The exact dates for which future fees are collected is unknown.

Sewer Capacity Charge – Fund 425

Purpose: Sewer Capacity fees are one-time charges to new development or existing development first connecting to the City of Victorville's sewer system. FY22 projects included continuing work on the expansion of the sewer line connections for the extension of the Green Tree Boulevard to Yucca Loma. As outlined in the Development Impact Fee & Capacity Fee Capital Improvement Plan FY 2023, the unexpended fees may be used for numerous projects throughout the City. Please see the 2023 Plan for details of the projects.

Unexpended Fees: This Fund has a balance of $13,076,574 in unexpended fees as of June 30, 2021.

Relationship between fee and purpose: There is a reasonable relationship between the unexpended fee and the purpose for which it was charged because it will continue to fund the expansion of sewer projects and infrastructure as the population grows.

Sources and Amounts of funding anticipated: A potential funding source other than DIF for the storm drain projects is the City's general fund at varying percentages per project. The exact amount potentially needed from other sources is undetermined.

Approximate dates funding expected: The fees will be collected from developers prior to final inspection of the project. The exact dates for which future fees are collected is unknown.

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