HomeMy WebLinkAbout2016-03-28 PACKET 06.1.STAFF REPORT CASE: CP2016-032
ITEM: 6.1
PUBLIC MEETING DATE: 3/28/16 TENTATIVE COUNCIL REVIEW DATE: 4/6/16
APPLICATION
APPLICANT: City of Cottage Grove and Economic Development Authority
REQUEST: TIF District No. 1-17 is proposed for the construction of a senior housing
development.
SITE DATA
LOCATION:
7003-7007 East Point Douglas Road South
ZONING:
B-2, Retail Business
GUIDED LAND USE:
Commercial
LAND USE OF ADJACENT PROPERTIES:
CURRENT
GUIDED
NORTH:
Parks/Open Space
Parks/Open Space
EAST:
Commercial
Commercial
SOUTH:
Highway 61
Highway 61
WEST:
Vacant Commercial
Commercial
SIZE:
N/A
DENSITY:
N/A
RECOMMENDATION
Approval.
Cottage COTTAGE GROVE PLANNING DIVISION
Grove
114e1e vdde an�PosPedW Meet
Planning Staff Contact: Robin Roland, Finance Director; 651-458-2832; rroland(aDcottage-grove.org
Application Accepted:. N/A 60 -Day Review Deadline: N/A
City of Cottage Grove Planning Division • 12800 Ravine Parkway South • Cottage Grove, MN 56016
Planning Staff Report
TIF District 1-17 (Dominium)
Case CP2016-032
March 28, 2016
Proposal
The City of Cottage Grove and the Economic Development Authority (EDA) are considering the
creation of a new Tax Increment Financing (TIF) District. The EDA approved creation of the district
on March 8; the City Council will hold the public hearing on April 6, 2016.
Minnesota Statutes require that the Planning Commission review the new district for conformance
to the City's Comprehensive Plan. If the Commission finds the changes to the TIF district are
consistent with the plan, the attached resolution should be adopted and forwarded to the City
Council.
TIF District 1-17 (Dominium) is proposed to facilitate the construction of 184 affordable apartment
units for seniors in the City. The project is a housing district under Minnesota State Statutes
469.174 and 469.1761; affordable rental housing units with income requirements defined in sec-
tion 172(d) of the Internal Revenue Code. A map of the proposed district and the TIF plan are
included with this item.
The proposed district would capture tax capacity resulting from the development of the property
for a period of 15 years. The proceeds (tax increment) would be used to subsidize the market
value rents, which would be paid by occupants of the facility.
Analysis
Cottage Grove Future Vision 2030 (Comprehensive Plan) includes the following elements which
directly impact the creation of this housing TIF district:
Community Vision
• Guiding principle: Maintain small town character. The Comprehensive Plan identifies the
aim of "encouraging life cycle housing opportunities."
Land Use
• Previous plans (Comprehensive Plan 2020) addressed "Additional high density residential
areas were designated to provide more senior housing."
Housing
Goal: Meet future needs with a variety of housing products: Policy 3.4. Encourage life-
cycle housing opportunities in Cottage Grove that allow residents to remain in the community
throughout their lives including the construction of various types of senior housing, including
senior ownership units, senior rental units and assisted living units.
Planning Staff Report
TIF District 1-17 (Dominium)
March 28, 2016
Page 2 of 2
Recommendation
Given the information provided above, TIF District 1-17 (Dominium) would conform to the Com-
prehensive Plan by providing another housing option for seniors (market rate rental housing
development for ages 55+) within the community. Staff therefore recommends the Planning Com-
mission approve the attached resolution finding that the district is in conformance with the Future
Vision 2030 Comprehensive Plan.
CITY OF COTTAGE GROVE
COUNTY OF WASHINGTON
STATE OF MINNESOTA
RESOLUTION NO. PC2016-001
RESOLUTION OF THE CITY OF COTTAGE GROVE
PLANNING COMMISSION FINDING THAT A MODIFICATION TO THE
DEVELOPMENT PROGRAM FOR DEVELOPMENT DISTRICT NO. 1 AND
A TAX INCREMENT FINANCING PLAN FOR TAX INCREMENT FINANCING
DISTRICT NO. 1-17 (DOMINIUM) CONFORM TO THE GENERAL PLANS
FOR THE DEVELOPMENT AND REDEVELOPMENT OF THE CITY
WHEREAS, the Cottage Grove Economic Development Authority (the "EDA") and
the City of Cottage Grove (the "City") have proposed to adopt a Modification to the
Development Program for Development District No. 1 (the "Development Program
Modification") and a Tax Increment Financing Plan for Tax Increment Financing District
No. 1-17 (Dominium) (the "TIF Plan") therefor (the Development Program Modification
and the TIF Plan are referred to collectively herein as the "Program and Plan") and have
submitted the Program and Plan to the City Planning Commission (the "Commission")
pursuant to Minnesota Statutes, Section 469.175, Subd. 3; and
WHEREAS, the Commission has reviewed the Program and Plan to determine
their conformity with the general plans for the development and redevelopment of the City
as described in the comprehensive plan for the City.
NOW, THEREFORE, BE IT RESOLVED by the Commission that the Program and
Plan conform to the general plans for the development and redevelopment of the City as
a whole.
Passed this 28th day of March 2016.
Chair
ATTEST:
Secretary
As of March 16, 2016
Draft for Planning Commission
Modification to the Development Program
for Development District No. 1
and the
Tax Increment Financing Plan
for the establishment of
Tax Increment Financing District No. 1-17 (Dominium)
(a housing district)
within
Development District No. 1
Cottage Grove Economic Development Authority
City of Cottage Grove
Washington County
State of Minnesota
Public Hearing: April 6, 2016
Adopted:
4by: EHLERS & IC. 0 EHLERS 3060 Centre Pointe Drriii e, Roseville, Minnesota
5113-11 5
651-697-8500 fax: 651-697-8555 www.ehlers-inc.com
Table of Contents
(for reference purposes only)
Section 1 - Modification to the Development Program
for Development District No. 1 ............................................. 1-1
Foreword............................................................. 1-1
Section 2 - Tax Increment Financing Plan
for Tax Increment Financing District No. 1-17 .................................
2-1
Subsection 2-1.
Foreword ...............................................
2-1
Subsection 2-2.
Statutory Authority ........................................
2-1
Subsection 2-3.
Statement of Objectives ...................................
2-1
Subsection 2-4.
Development Program Overview ............................
2-1
Subsection 2-5.
Description of Property in the District and Property To Be Acquired
. 2-2
Subsection 2-6.
Classification of the District.................................2-2
Subsection 2-7.
Duration and First Year of Tax Increment of the District ...........
2-3
Subsection 2-8.
Original Tax Capacity, Tax Rate and Estimated Captured Net Tax Capacity
Value/Increment
and Notification of Prior Planned Improvements ................
2-4
Subsection 2-9.
Sources of Revenue/Bonds to be Issued ......................
2-5
Subsection 2-10.
Uses of Funds ...........................................
2-5
Subsection 2-11.
Fiscal Disparities Election ..................................
2-6
Subsection 2-12.
Business Subsidies .......................................
2-7
Subsection 2-13.
County Road Costs .......................................
2-8
Subsection 2-14.
Estimated Impact on Other Taxing Jurisdictions .................
2-8
Subsection 2-15.
Supporting Documentation ................................
2-10
Subsection 2-16.
Definition of Tax Increment Revenues .......................
2-10
Subsection 2-17.
Modifications to the District ................................
2-10
Subsection 2-18.
Administrative Expenses ..................................
2-11
Subsection 2-19.
Limitation of Increment ...................................
2-12
Subsection 2-20.
Use of Tax Increment ....................................
2-12
Subsection 2-21.
Excess Increments ......................................
2-13
Subsection 2-22.
Requirements for Agreements with the Developer ..............
2-13
Subsection 2-23.
Assessment Agreements .................................
2-14
Subsection 2-24.
Administration of the District ...............................
2-14
Subsection 2-25.
Annual Disclosure Requirements ...........................
2-14
Subsection 2-26.
Reasonable Expectations .................................
2-14
Subsection 2-27.
Other Limitations on the Use of Tax Increment .................
2-14
Subsection 2-28.
Summary ..............................................
2-15
Appendix A
Project Description...................................................... A-1
Appendix B
Map of Development District No. 1 and the District ............................. B-1
Appendix C
Description of Property to be Included in the District ............................ C-1
Appendix D
Estimated Cash Flow for the District ........................................ D-1
Appendix E
Housing Qualifications for the District ........................................ E-1
Appendix F
Findings for the District ................................................... F-1
Section 1 - Modification to the Development Program
for Development District No. 1
Foreword
The following text represents a Modification to the Development Program for Development District No. 1.
This modification represents a continuation of the goals and objectives set forth in the Development Program
for Development District No. 1. Generally, the substantive changes include the establishment of Tax
Increment Financing District No. 1-17.
For further information, a review of the Development Program for Development District No. 1, adopted
January 7, 1985, is recommended. It is available from the City Administrator at the City of Cottage Grove.
Other relevant information is contained in the Tax Increment Financing Plans for the Tax Increment
Financing Districts located within Development District No. 1.
Cottage Grove Economic Development Authority
Modification to the Development Program for Development District No. 1 1-1
Section 2 - Tax Increment Financing Plan
for Tax Increment Financing District No. 1-17 (Dominium)
Subsection 2-1. Foreword
The Cottage Grove Economic Development Authority (the "EDA"), the City of Cottage Grove (the "City"),
staff and consultants have prepared the following information to expedite the establishment of Tax Increment
Financing District No. 1-17 (Dominium) (the "District"), a housing tax increment financing district, located
in Development District No. 1.
Subsection 2-2. Statutory Authority
Within the City, there exist areas where public involvement is necessary to cause development or
redevelopment to occur. To this end, the EDA and City have certain statutory powers pursuant to Minnesota
Statutes ('M.S.'), Sections 469.090 to 469.1082, inclusive, as amended, and M.S., Sections 469.174 to
469.1794, inclusive, as amended (the "Tax Increment Financing Act" or "TIF Act"), to assist in financing
public costs related to this project.
This section contains the Tax Increment Financing Plan (the "TIF Plan") for the District. Other relevant
information is contained in the Modification to the Development Program for Development District No. 1.
Subsection 2-3. Statement of Objectives
The District currently consists of three parcels of land and adjacent and internal rights-of-way. The District
is being created to facilitate the construction ofl84 affordable apartment units for seniors in the City. Please
see Appendix A for further District information. The City/EDA will be entering into an agreement with
Dominium for the construction of the facility and development is likely to occur in 2016. This TIF Plan is
expected to achieve many of the objectives outlined in the Development Program for Development District
No. 1.
The activities contemplated in the Modification to the Development Program and the TIF Plan do not
preclude the undertaking of other qualified development or redevelopment activities. These activities are
anticipated to occur over the life of Development District No. 1 and the District.
Subsection 2-4. Development Program Overview
1. Property to be Acquired - Selected property located within the District may be acquired by
the EDA or City and is further described in this TIF Plan.
Relocation - Relocation services, to the extent required by law, are available pursuant to
M.S., Chapter 117 and other relevant state and federal laws.
3. Upon approval of a developer's plan relating to the project and completion of the necessary
legal requirements, the EDA or City may sell to a developer selected properties that it may
acquire within the District or may lease land or facilities to a developer.
4. The EDA or City may perform or provide for some or all necessary acquisition, construction,
relocation, demolition, and required utilities and public street work within the District.
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17 2-1
Subsection 2-5. Description of Property in the District and Property To Be Acquired
The District encompasses all property and adjacent rights-of-way and abutting roadways identified by the
parcels listed in Appendix C of this TIF Plan. Please also see the map in Appendix B for further information
on the location of the District.
The EDA or City may acquire any parcel within the District including interior and adjacent street rights of
way. Any properties identified for acquisition will be acquired by the EDA or City only in order to
accomplish one or more of the following: storm sewer improvements; provide land for needed public streets,
utilities and facilities; carry out land acquisition, site improvements, clearance and/or development to
accomplish the uses and objectives set forth in this plan. The EDA or City may acquire property by gift,
dedication, condemnation or direct purchase from willing sellers in order to achieve the objectives of this TIF
Plan. Such acquisitions will be undertaken only when there is assurance of funding to finance the acquisition
and related costs.
Subsection 2-6. Classification of the District
The EDA and City, in determining the need to create a tax increment financing district in accordance with
M.S., Sections 469.174 to 469.1799, as amended, inclusive, find that the District, to be established, is a
housing district pursuant to M.S, Section 469.174, Subd. 11 and M.S., Section 469.1761 as defined below:
M.S., Section 469.174, Subd.11:
"Housing district" means a type of tax increment financing district which consists of a project, or a
portion of a project, intended for occupancy, in part, by persons or families of low and moderate
income, as defined in chapter 462A, Title H of the National Housing Act of 1934, the National
Housing Act of 1959, the United States Housing Act of 1937, as amended, Title V of the Housing Act
of 1949, as amended, any other similar present or future federal, state, or municipal legislation, or
the regulations promulgated under any of those acts, and that satisfies the requirements of M.S.,
Section 469.1761. Housing project means a project, or portion of a project, that meets all the
qualifications of a housing district under this subdivision, whether or not actually established as a
housing district.
M.S, Section 469.1761:
Subd. 1. Requirement imposed.
(a) In order for a tax increment financing district to qualify as a housing district:
(1) the income limitations provided in this section must be satisfied; and
(2) no more than 20 percent of the square footage of buildings that receive assistance from tax
increments may consist of commercial, retail, or other nonresidential uses.
(b) The requirements imposed by this section apply to property receiving assistance financed with
tax increments, including interest reduction, land transfers at less than the authority's cost of
acquisition, utility service or connections, roads, parking facilities, or other subsidies. The
provisions of this section do not apply to districts located within a targeted area as defined in
Section 462C. 02 Subd 9, clause (e).
(c) For purposes of the requirements of paragraph (a), the authority may elect to treat an addition
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17 2-2
to an existing structure as a separate building if. -
(1)
(1) construction of the addition begins more than three years after construction of the
existing structure was completed, and
(2) for an addition that does not meet the requirements of paragraph (a), clause (2), if it is
treated as a separate building, the addition was not contemplated by the tax increment
financing plan which includes the existing structure.
Subd. 2. Owner occupied housing.
For owner occupied residential property, 95 percent of the housing units must be initially
purchased and occupied by individuals whose family income is less than or equal to the
income requirements for qualified mortgage bond projects under section 1430 of the
Internal Revenue Code.
Subd. 3. Rental property.
For residential rental property, the property must satisfy the income requirements for a
qualified residential rental project as defined in section 142(d) of the Internal Revenue
Code. The requirements of this subdivision apply for the duration of the tax increment
financing district.
Subd. 4. Noncompliance; enforcement.
Failure to comply with the requirements of this section is subject to M.S., Section 469.1771.
In meeting the statutory criteria the EDA and City rely on the following facts and findings:
• The District consists of 3 parcels
• The development will consist of 184 units of affordable rental housing for seniors
• 40% of the units will be occupied by person with incomes less than 60% of median income
Pursuant to M.S, Section 469.176, Subd. 7, the District does not contain any parcel or part of a parcel that
qualified under the provisions of M.S., Sections 273.111, 273.112, or 273.114 or Chapter 473H for taxes
payable in any of the five calendar years before the filing of the request for certification of the District.
Subsection 2-7. Duration and First Year of Tax Increment of the District
Pursuant to M. S , Section 469.175, Subd. 1, and Section 469.176, Subd. 1, the duration and first year of tax
increment of the District must be indicated within the TIF Plan. Pursuant to M. S., Section 469.176, Subd. 1 b.,
the duration of the District will be 25 years after receipt of the first increment by the EDA or City (a total of
26 years of tax increment). The EDA or City elects to receive the first tax increment in 2018, which is no
later than four years following the year of approval of the District. Thus, it is estimated that the District,
including any modifications of the TIF Plan for subsequent phases or other changes, would terminate after
2043, or when the TIF Plan is satisfied. The EDA or City reserves the right to decertify the District prior to
the legally required date.
Subsection 2-8. Original Tax Capacity, Tax Rate and Estimated Captured Net Tax Capacity
Value/Increment and Notification of Prior Planned Improvements
Pursuant to M.S., Section 469.174, Subd. 7 andM. S., Section 469.177, Subd. 1, the Original Net Tax Capacity
(ONTC) as certified for the District will be based on the market values placed on the property by the assessor
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17 2-3
in 2015 for taxes payable 2016.
Pursuant to M.S., Section 469.177, Subds. 1 and 2, the County Auditor shall certify in each year (beginning
in the payment year 2018) the amount by which the original value has increased or decreased as a result of:
1. Change in tax exempt status of property;
2. Reduction or enlargement of the geographic boundaries of the district;
3. Change due to adjustments, negotiated or court-ordered abatements;
4. Change in the use of the property and classification;
5. Change in state law governing class rates; or
6. Change in previously issued building permits.
In any year in which the current Net Tax Capacity (NTC) value of the District declines below the ONTO, no
value will be captured and no tax increment will be payable to the EDA or City.
The original local tax rate for the District will be the local tax rate for taxes payable 2016, assuming the
request for certification is made before June 30, 2016. The ONTC and the Original Local Tax Rate for the
District appear in the table below.
Pursuant to M.S., Section 469.174 Subd. 4 and M.S., Section 469.177, Subd. 1, 2, and 4, the estimated
Captured Net Tax Capacity (CTC) of the District, within Development District No. 1, upon completion of
the projects within the District, will annually approximate tax increment revenues as shown in the table
below. The EDA and City request 100 percent of the available increase in tax capacity for repayment of its
obligations and current expenditures, beginning in the tax year payable 2018. The Project Tax Capacity (PTC)
listed is an estimate of values when the projects within the District are completed.
Project Estimated Tax Capacity upon Completion (PTC) $295,952
Original Estimated Net Tax Capacity (ONTO) $7,019
Estimated Captured Tax Capacity (CTC) $288,933
Original Local Tax Rate 1.12869 Estimated
Pay 2016
Estimated Annual Tax Increment (CTC x Local Tax Rate) $326,116
Percent Retained by the EDA 100%
Tax capacity includes a 3% inflation factor for the duration of the District. The tax capacity included in this
chart is the estimated tax capacity of the District in year 25. The tax capacity of the District in year one is
estimated to be $72,795.
Pursuant to M.S., Section 469.177, Subd. 4, the EDA shall, after a due and diligent search, accompany its
request for certification to the County Auditor or its notice of the District enlargement pursuant to M.S.,
Section 469.175, Subd. 4, with a listing of all properties within the District or area of enlargement for which
building permits have been issued during the eighteen (18) months immediately preceding approval of the
TIF Plan by the municipality pursuant to M.S., Section 469.175, Subd. 3. The County Auditor shall increase
the original net tax capacity of the District by the net tax capacity of improvements for which a building
permit was issued.
The City has reviewed the area to be included in the District and found no parcels for which building
permits have been issued during the 18 months immediately preceding approval of the TIF Plan by the
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17 2-4
City.
Subsection 2-9. Sources of Revenue/Bonds to be Issued
The costs outlined in the Uses of Funds will be financed primarily through the annual collection of tax
increments. The EDA or City reserves the right to incur bonds or other indebtedness as a result of the TIF
Plan. As presently proposed, the projects within the District will be financed by a pay-as-you-go
note/interfund loan/transfer. Any refunding amounts will be deemed a budgeted cost without a formal TIF
Plan Modification. This provision does not obligate the EDA or City to incur debt. The EDA or City will
issue bonds or incur other debt only upon the determination that such action is in the best interest of the City.
The total estimated tax increment revenues for the District are shown in the table below:
SOURCES OF FUNDS TOTAL
Tax Increment $5,846,258
Interest $584.626
TOTAL $6,430,884
The EDA or City may issue bonds (as defined in the TIF Act) secured in whole or in part with tax increments
from the District in a maximum principal amount of $3,742,552. Such bonds may be in the form of pay-as-
you-go notes, revenue bonds or notes, general obligation bonds, or interfund loans. This estimate of total
bonded indebtedness is a cumulative statement of authority under this TIF Plan as of the date of approval.
Subsection 2-10. Uses of Funds
Currently under consideration for the District is a proposal to facilitate the construction of 184 affordable
apartment units for seniors. The EDA and City have determined that it will be necessary to provide assistance
to the project(s) for certain District costs, as described. The EDA has studied the feasibility of the
development or redevelopment of property in and around the District. To facilitate the establishment and
development or redevelopment of the District, this TIF Plan authorizes the use of tax increment financing to
pay for the cost of certain eligible expenses. The estimate of public costs and uses of funds associated with
the District is outlined in the table on the following page.
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17 2-5
USES OF TAX INCREMENT FUNDS TOTAL
Land/Building Acquisition $950,000
Site Improvements/Preparation $200,000
Utilities $150,000
Other Qualifying Improvements $200,000
Affordable Housing $1,657,926
Administrative Costs (up to 10%) $584.626
PROJECT COST TOTAL $3,742,552
Interest $2,688,332
PROJECT AND INTEREST COSTS TOTAL $6,430,884
The total project cost, including financing costs (interest) listed in the table above does not exceed the total
projected tax increments for the District as shown in Subsection 2-9.
Estimated costs associated with the District are subject to change among categories without a modification
to this TIF Plan. The cost of all activities to be considered for tax increment financing will not exceed,
without formal modification, the budget above pursuant to the applicable statutory requirements. The EDA
may expend funds for qualified housing activities outside of the District boundaries.
Subsection 2-11. Fiscal Disparities Election
Pursuant to M.S., Section 469.177, Subd. 3, the City may elect one of two methods to calculate fiscal
disparities. If the calculations pursuant to M.S, Section 469.177, Subd. 3, clause b, (within the District) are
followed, the following method of computation shall apply:
(1) The original net tax capacity shall be determined before the application of the fiscal disparity
provisions of Chapter 276A or 473F. The current net tax capacity shall exclude any fiscal
disparity commercial -industrial net tax capacity increase between the original year and the
current year multiplied by the fiscal disparity ratio determined pursuant to M.S., Section
276A.06, subdivision 7 or M.S., Section 473F.08, subdivision 6. Where the original net tax
capacity is equal to orgreater than the current net tax capacity, there is no captured tax capacity
and no tax increment determination. Where the original tax capacity is less than the current tax
capacity, the difference between the original net tax capacity and the current net tax capacity
is the captured net tax capacity. This amount less any portion thereof which the authority has
designated, in its tax increment financing plan, to share with the local taxing districts is the
retained captured net tax capacity of the authority.
(2) The county auditor shall exclude the retained captured net tax capacity of the authority from the
net tax capacity of the local taxing districts in determining local taxing district tax rates. The
local tax rates so determined are to be extended against the retained captured net tax capacity
of the authority as well as the net tax capacity of the local taxing districts. The tax generated by
the extension of the less of (A) the local taxing district tax rates or (B) the original local tax rate
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17 2-6
to the retained captured net tax capacity of the authority is the tax increment of the authority.
The City will choose to calculate fiscal disparities by clause b. It is not anticipated that the District will
contain commercial/industrial property. As a result, there should be no impact due to the fiscal
disparities provision on the District.
According to M.S., Section 469.177, Subd. 3:
(c) The method of computation of tax increment applied to a district pursuant to paragraph (a) or
(b) shall remain the same for the duration of the district, except that the governing body may
elect to change its election from the method of computation in paragraph (a) to the method in
paragraph (b).
Subsection 2-12. Business Subsidies
Pursuant to M.S., Section 116J.993, Subd. 3, the following forms of financial assistance are not considered
a business subsidy:
(1) A business subsidy of less than $150,000;
(2) Assistance that is generally available to all businesses or to a general class of similar businesses,
such as a line of business, size, location, or similar general criteria;
(3) Public improvements to buildings or lands owned by the state or local government that serve a
public purpose and do not principally benefit a single business or defined group of businesses at
the time the improvements are made;
(4) Redevelopment property polluted by contaminants as defined in M.S., Section 116J.552, Subd. 3;
(5) Assistance provided for the sole purpose of renovating old or decaying building stock or bringing
it up to code and assistance provided for designated historic preservation districts, provided that
the assistance is equal to or less than 50% of the total cost;
(6) Assistance to provide job readiness and training services if the sole purpose of the assistance is to
provide those services;
(7) Assistance for housing;
(8) Assistance for pollution control or abatement, including assistance for a tax increment financing
hazardous substance subdistrict as defined under M.S., Section 469.174, Subd. 23;
(9) Assistance for energy conservation;
(10) Tax reductions resulting from conformity with federal tax law;
(11) Workers' compensation and unemployment compensation;
(12) Benefits derived from regulation;
(13) Indirect benefits derived from assistance to educational institutions;
(14) Funds from bonds allocated under chapter 474A, bonds issued to refund outstanding bonds, and
bonds issued for the benefit of an organization described in section 501 (c) (3) of the Internal
Revenue Code of 1986, as amended through December 31, 1999;
(15) Assistance for a collaboration between a Minnesota higher education institution and a business;
(16) Assistance for a tax increment financing soils condition district as defined under M.S., Section
469.174, Subd. 19;
(17) Redevelopment when the recipient's investment in the purchase of the site and in site preparation
is 70 percent or more of the assessor's current year's estimated market value;
(18) General changes in tax increment financing law and other general tax law changes of a principally
technical nature;
(19) Federal assistance until the assistance has been repaid to, and reinvested by, the state or local
government agency;
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17 2-7
(20) Funds from dock and wharf bonds issued by a seaway port authority;
(21) Business loans and loan guarantees of $150,000 or less;
(22) Federal loan funds provided through the United States Department of Commerce, Economic
Development Administration; and
(23) Property tax abatements granted under M.S., Section 469.1813 to property that is subject to
valuation under Minnesota Rules, chapter 8100.
The EDA will comply with M.S., Sections 116J.993 to 116J.995 to the extent the tax increment assistance
under this TIF Plan does not fall under any of the above exemptions.
Subsection 2-13. County Road Costs
Pursuant to M.S., Section 469.175, Subd. ]a, the county board may require the EDA or City to pay for all or
part of the cost of county road improvements if the proposed development to be assisted by tax increment
will, in the judgment of the county, substantially increase the use of county roads requiring construction of
road improvements or other road costs and if the road improvements are not scheduled within the next five
years under a capital improvement plan or within five years under another county plan.
If the county elects to use increments to improve county roads, it must notify the EDA or City within forty-
five days of receipt of this TIF Plan. In the opinion of the EDA and City and consultants, the proposed
development outlined in this TIF Plan will have little or no impact upon county roads, therefore the TIF Plan
was not forwarded to the county 45 days prior to the public hearing. The EDA and City are aware that the
county could claim that tax increment should be used for county roads, even after the public hearing.
Subsection 2-14. Estimated Impact on Other Taxing Jurisdictions
The estimated impact on other taxing jurisdictions assumes that the redevelopment contemplated by the TIF
Plan would occur without the creation of the District. However, the EDA or City has determined that such
development or redevelopment would not occur "but for" tax increment financing and that, therefore, the
fiscal impact on other taxing jurisdictions is $0. The estimated fiscal impact of the District would be as
follows if the "but for" test was not met:
IMPACT ON TAX BASE
Estimated
Estimated Captured
2015/Pay 2016
Tax Capacity (CTC)
Percent of CTC
Total Net
Upon Completion
to Enti , Total
Tax Capacity
Washington County 279,157,332
288,933
0.1035%
City of Cottage Grove 28,000,985
288,933
1.0319%
ISD No. 833 93,984,883
288,933
0.3074%
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17 2-8
IMPACT ON TAX RATES
The estimates listed above display the captured tax capacity when all construction is completed. The tax rate
used for calculations is the estimated Pay 2016 rate. The total net capacity for the entities listed above are
based on estimated Pay 2016 figures. The District will be certified under the actual Pay 2016 rates, which
were unavailable at the time this TIF Plan was prepared.
Pursuant to M.S. Section 469.175 Subd. 2(b):
(1) Estimate of total tax increment. It is estimated that the total amount of tax increment that will be
generated over the life of the District is $5,846,258;
(2) Probable impact of the District on cily provided services and ability to issue debt. An impact of the
District on police protection is not expected. The City does track all calls for service including
property -type calls and crimes. With any addition of new residents or businesses, police calls for
service will be increased. New developments add an increase in traffic, and additional overall
demands to the call load. The City does not expect that the proposed development, in and of itself,
will necessitate new capital investment.
The probable impact of the District on fire protection is not expected to be significant. Typically new
buildings generate few calls, if any, and are of superior construction.
The impact of the District on public infrastructure is expected to be minimal. The development is
not expected to significantly impact any traffic movements in the area. The current infrastructure for
sanitary sewer, storm sewer and water will be able to handle the additional volume generated from
the proposed development. Based on the development plans, there are no additional costs associated
with street maintenance, sweeping, plowing, lighting and sidewalks. The development in the District
is expected to contribute an as yet undetermined amount in sanitary sewer (SAC) and water (WAC)
connection fees.
The probable impact of any District general obligation tax increment bonds on the ability to issue
debt for general fund purposes is expected to be minimal. It is not anticipated that there will be any
general obligation debt issued in relation to this project, therefore there will be no impact on the
City's ability to issue future debt or on the City's debt limit.
(3) Estimated amount of tax increment attributable to school district levies. It is estimated that the
amount of tax increments over the life of the District that would be attributable to school district
levies, assuming the school district's share of the total local tax rate for all taxing jurisdictions
remained the same, is $1,754,462;
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17 2-9
Estimated
Percent
Potential
Pay 2016
of Total
CTC
Taxes
Extension Rates
Washington County
0.305536
27.07%
288,933
88,279
City of Cottage Grove
0.431276
38.21%
288,933
124,610
ISD No. 833
0.338681
30.01%
288,933
97,856
Other
0.053197
4.71%
288,933
15,370
Total
1.128690
100.00%
326,116
The estimates listed above display the captured tax capacity when all construction is completed. The tax rate
used for calculations is the estimated Pay 2016 rate. The total net capacity for the entities listed above are
based on estimated Pay 2016 figures. The District will be certified under the actual Pay 2016 rates, which
were unavailable at the time this TIF Plan was prepared.
Pursuant to M.S. Section 469.175 Subd. 2(b):
(1) Estimate of total tax increment. It is estimated that the total amount of tax increment that will be
generated over the life of the District is $5,846,258;
(2) Probable impact of the District on cily provided services and ability to issue debt. An impact of the
District on police protection is not expected. The City does track all calls for service including
property -type calls and crimes. With any addition of new residents or businesses, police calls for
service will be increased. New developments add an increase in traffic, and additional overall
demands to the call load. The City does not expect that the proposed development, in and of itself,
will necessitate new capital investment.
The probable impact of the District on fire protection is not expected to be significant. Typically new
buildings generate few calls, if any, and are of superior construction.
The impact of the District on public infrastructure is expected to be minimal. The development is
not expected to significantly impact any traffic movements in the area. The current infrastructure for
sanitary sewer, storm sewer and water will be able to handle the additional volume generated from
the proposed development. Based on the development plans, there are no additional costs associated
with street maintenance, sweeping, plowing, lighting and sidewalks. The development in the District
is expected to contribute an as yet undetermined amount in sanitary sewer (SAC) and water (WAC)
connection fees.
The probable impact of any District general obligation tax increment bonds on the ability to issue
debt for general fund purposes is expected to be minimal. It is not anticipated that there will be any
general obligation debt issued in relation to this project, therefore there will be no impact on the
City's ability to issue future debt or on the City's debt limit.
(3) Estimated amount of tax increment attributable to school district levies. It is estimated that the
amount of tax increments over the life of the District that would be attributable to school district
levies, assuming the school district's share of the total local tax rate for all taxing jurisdictions
remained the same, is $1,754,462;
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17 2-9
(4) Estimated amount of tax increment attributable to coun , levies. It is estimated that the amount of
tax increments over the life of the District that would be attributable to county levies, assuming the
county's share of the total local tax rate for all taxing jurisdictions remained the same, is $1,582,582;
(5) Additional information requested by the county or school district. The City is not aware of any
standard questions in a county or school district written policy regarding tax increment districts and
impact on county or school district services. The county or school district must request additional
information pursuant to M.S. Section 469.175 Subd. 2(b) within 15 days after receipt of the tax
increment financing plan.
No requests for additional information from the county or school district regarding the proposed
development for the District have been received.
Subsection 2-15. Supporting Documentation
Pursuant to M.S. Section 469.175, Subd. 1 (a), clause 7 the TIF Plan must contain identification and
description of studies and analyses used to make the findings are required in the resolution approving the
District. Following is a list of reports and studies on file at the City that support the EDA and City's findings:
• A list of applicable studies will be listed here prior to the public hearing.
Subsection 2-16. Definition of Tax Increment Revenues
Pursuant to M.S, Section 469.174, Subd. 25, tax increment revenues derived from a tax increment financing
district include all of the following potential revenue sources:
1. Taxes paid by the captured net tax capacity, but excluding any excess taxes, as computed under M. S.,
Section 469.177;
2. The proceeds from the sale or lease of property, tangible or intangible, to the extent the property was
purchased by the authority with tax increments;
3. Principal and interest received on loans or other advances made by the authority with tax increments;
4. Interest or other investment earnings on or from tax increments;
5. Repayments or return of tax increments made to the Authority under agreements for districts for
which the request for certification was made after August 1, 1993; and
6. The market value homestead credit paid to the Authority under M.S., Section 273.1384.
Subsection 2-17. Modifications to the District
In accordance with M.S., Section 469.175, Subd. 4, any:
1. Reduction or enlargement of the geographic area of the District, if the reduction does not meet the
requirements of M.S., Section 469.175, Subd. 4(e);
2. Increase in amount of bonded indebtedness to be incurred;
3. A determination to capitalize interest on debt if that determination was not a part of the original TIF
Plan;
4. Increase in the portion of the captured net tax capacity to be retained by the EDA or City;
5. Increase in the estimate ofthe cost of the District, including administrative expenses, that will be paid
or financed with tax increment from the District; or
6. Designation of additional property to be acquired by the EDA or City,
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17 2-10
shall be approved upon the notice and after the discussion, public hearing and findings required for approval
of the original TIF Plan.
Pursuant to M.S. Section 469.175 Subd. 4(1), the geographic area of the District may be reduced, but shall not
be enlarged after five years following the date of certification of the original net tax capacity by the county
auditor. If a housing district is enlarged, the reasons and supporting facts for the determination that the
addition to the district meets the criteria of M.S., Section 469.174, Subd. 11 must be documented. The
requirements of this paragraph do not apply if (1) the only modification is elimination of parcel(s) from the
District and (2) (A) the current net tax capacity of the parcel(s) eliminated from the District equals or exceeds
the net tax capacity of those parcel(s) in the District's original net tax capacity or (B) the EDA agrees that,
notwithstanding M. S., Section 469.177, Subd. 1, the original net tax capacity will be reduced by no more than
the current net tax capacity of the parcel(s) eliminated from the District.
The EDA or City must notify the County Auditor of any modification to the District. Modifications to the
District in the form of a budget modification or an expansion of the boundaries will be recorded in the TIF
Plan.
Subsection 2-18. Administrative Expenses
In accordance with M.S., Section 469.174, Subd. 14, administrative expenses means all expenditures of the
EDA or City, other than:
1. Amounts paid for the purchase of land;
2. Amounts paid to contractors or others providing materials and services, including architectural and
engineering services, directly connected with the physical development of the real property in the
District;
3. Relocation benefits paid to or services provided for persons residing or businesses located in the
District;
4. Amounts used to pay principal or interest on, fund a reserve for, or sell at a discount bonds issued
pursuant to M.S., Section 469.178; or
5. Amounts used to pay other financial obligations to the extent those obligations were used to finance
costs described in clauses (1) to (3).
For districts for which the request for certification were made before August 1, 1979, or after June 30, 1982,
and before August 1, 2001, administrative expenses also include amounts paid for services provided by bond
counsel, fiscal consultants, and planning or economic development consultants. Pursuant to M.S., Section
469.176, Subd. 3, tax increment may be used to pay any authorized and documented administrative
expenses for the District up to but not to exceed 10 percent of the total estimated tax increment expenditures
authorized by the TIF Plan or the total tax increments, as defined by M.S., Section 469.174, Subd. 25, clause
(1), from the District, whichever is less.
For districts for which certification was requested after July 31, 2001, no tax increment may be used to pay
any administrative expenses for District costs which exceed ten percent of total estimated tax increment
expenditures authorized by the TIF Plan or the total tax increments, as defined in M. S., Section 469.174, Subd.
25, clause (1), from the District, whichever is less.
Pursuant to M.S, Section 469.176, Subd. 4h, tax increments may be used to pay for the County's actual
administrative expenses incurred in connection with the District and are not subject to the percentage limits
ofM.S., Section 469.176, Subd. 3. The county may require payment of those expenses by February 15 of the
year following the year the expenses were incurred.
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17
2-11
Pursuant to M.S., Section 469. 177, Subd. 11, the County Treasurer shall deduct an amount (currently .36
percent) of any increment distributed to the EDA or City and the County Treasurer shall pay the amount
deducted to the State Commissioner of Management and Budget for deposit in the state general fund to be
appropriated to the State Auditor for the cost of financial reporting of tax increment financing information
and the cost of examining and auditing authorities' use of tax increment financing. This amount may be
adjusted annually by the Commissioner of Revenue.
Subsection 2-19. Limitation of Increment
The tax increment pledged to the payment of bonds and interest thereon may be discharged and the District
may be terminated if sufficient funds have been irrevocably deposited in the debt service fund or other escrow
account held in trust for all outstanding bonds to provide for the payment of the bonds at maturity or
redemption date.
Pursuant to M.S., Section 469.176, Subd. 6:
if, after four years from the date of certification of the original net tax capacity of the tax
incrementfinancingdistrictpursuant to M.S., Section 469.177, no demolition, rehabilitation
or renovation of property or other site preparation, including qualified improvement of a
street adjacent to a parcel but not installation of utility service including sewer or water
systems, has been commenced on a parcel located within a tax increment financing district
by the authority or by the owner of the parcel in accordance with the tax increment financing
plan, no additional tax increment may be taken from that parcel, and the original net tax
capacity of that parcel shall be excluded from the original net tax capacity of the tax
increment financing district. If the authority or the owner of the parcel subsequently
commences demolition, rehabilitation or renovation or other site preparation on that parcel
including qualified improvement of a street adjacent to that parcel, in accordance with the
tax incrementfinancingplan, the authority shall certify to the county auditor that the activity
has commenced and the county auditor shall certify the net tax capacity thereof as most
recently certified by the commissioner of revenue and add it to the original net tax capacity
of the tax incrementfinancing district. The county auditor must enforce the provisions of this
subdivision. The authority must submit to the county auditor evidence that the required
activity has taken place for each parcel in the district. The evidence for a parcel must be
submitted by February 1 of the fifth year following the year in which the parcel was certified
as included in the district. For purposes of this subdivision, qualified improvements of a
street are limited to (1) construction or opening of a new street, (2) relocation of a street,
and (3) substantial reconstruction or rebuilding of an existing street.
The EDA or City or a property owner must improve parcels within the District by approximately April 2020
and report such actions to the County Auditor.
Subsection 2-20. Use of Tax Increment
The EDA or City hereby determines that it will use 100 percent of the captured net tax capacity of taxable
property located in the District for the following purposes:
1. To pay the principal of and interest on bonds issued to finance a project;
2. To finance, or otherwise pay the cost of redevelopment of the Development District No. 1 pursuant
to M.S., Sections 469.090 to 469.1082;
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17 2-12
To pay for project costs as identified in the budget set forth in the TIF Plan;
To finance, or otherwise pay for other purposes as provided in M.S., Section 469.176, Subd. 4;
To pay principal and interest on any loans, advances or other payments made to or on behalf of the
EDA or City or for the benefit of Development District No. 1 by a developer;
To finance or otherwise pay premiums and other costs for insurance or other security guaranteeing
the payment when due of principal of and interest on bonds pursuant to the TIF Plan or pursuant to
M.S, Chapter 462C. M.S., Sections 469.152 through 469.165, and/or M.S, Sections 469.178; and
To accumulate or maintain a reserve securing the payment when due of the principal and interest on
the tax increment bonds or bonds issued pursuant to M.S., Chapter 462C, M.S., Sections 469.152
through 469.165, and/or M.S., Sections 469.178.
Revenues derived from tax increment from a housing district must be used solely to finance the cost
of housing projects as defined in M.S., Sections 469.174, Subd. 11 and 469.1761. The cost of public
improvements directly related to the housing projects and the allocated administrative expenses of the
EDA or City may be included in the cost of a housing project.
These revenues shall not be used to circumvent any levy limitations applicable to the City nor for other
purposes prohibited by M.S., Section 469.176, Subd. 4.
Tax increments generated in the District will be paid by Washington County to the EDA for the Tax
Increment Fund of said District. The EDA or City will pay to the developer(s) annually an amount not to
exceed an amount as specified in a developer's agreement to reimburse the costs of land acquisition, public
improvements, demolition and relocation, site preparation, and administration. Remaining increment funds
will be used for EDA or City administration (up to 10 percent) and for the costs of public improvement
activities outside the District.
Subsection 2-21. Excess Increments
Excess increments, as defined in M.S., Section 469.176, Subd. 2, shall be used only to do one or more of the
following:
1. Prepay any outstanding bonds;
2. Discharge the pledge of tax increment for any outstanding bonds;
3. Pay into an escrow account dedicated to the payment of any outstanding bonds; or
4. Return the excess to the County Auditor for redistribution to the respective taxing jurisdictions in
proportion to their local tax rates.
The EDA or City must spend or return the excess increments under paragraph (c) within nine months after
the end of the year. In addition, the EDA or City may, subject to the limitations set forth herein, choose to
modify the TIF Plan in order to finance additional public costs in Development District No. 1 or the District.
Subsection 2-22. Requirements for Agreements with the Developer
The EDA or City will review any proposal for private development to determine its conformance with the
Development Program and with applicable municipal ordinances and codes. To facilitate this effort, the
following documents may be requested for review and approval: site plan, construction, mechanical, and
electrical system drawings, landscaping plan, grading and storm drainage plan, signage system plan, and any
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17 2-13
other drawings or narrative deemed necessary by the EDA or City to demonstrate the conformance of the
development with City plans and ordinances. The EDA or City may also use the Agreements to address other
issues related to the development.
Pursuant to M.S., Section 469.176, Subd. 5, no more than 10 percent, by acreage, of the property to be
acquired in the District as set forth in the TIF Plan shall at any time be owned by the EDA or City as a result
of acquisition with the proceeds of bonds issued pursuant to M.S., Section 469.178 to which tax increments
from property acquired is pledged, unless prior to acquisition in excess of 10 percent of the acreage, the EDA
or City concluded an agreement for the development of the property acquired and which provides recourse
for the EDA or City should the development not be completed.
Subsection 2-23. Assessment Agreements
Pursuant to M.S., Section 469.177, Subd. 8, the EDA or City may enter into a written assessment agreement
in recordable form with the developer of property within the District which establishes a minimum market
value of the land and completed improvements for the duration of the District. The assessment agreement
shall be presented to the County Assessor who shall review the plans and specifications for the improvements
to be constructed, review the market value previously assigned to the land upon which the improvements are
to be constructed and, so long as the minimum market value contained in the assessment agreement appears,
in the judgment of the assessor, to be a reasonable estimate, the County Assessor shall also certify the
minimum market value agreement.
Subsection 2-24. Administration of the District
Administration of the District will be handled by the City Administrator
Subsection 2-25. Annual Disclosure Requirements
Pursuant to M.S., Section 469.175, Subds. 5, 6, and 6b the EDA or City must undertake financial reporting
for all tax increment financing districts to the Office of the State Auditor, County Board and County Auditor
on or before August 1 of each year. M.S, Section 469.175, Subd. 5 also provides that an annual statement
shall be published in a newspaper of general circulation in the City on or before August 15.
If the City fails to make a disclosure or submit a report containing the information required by M.S., Section
469.175 Subd. 5 and Subd. 6, the Office of the State Auditor will direct the County Auditor to withhold the
distribution of tax increment from the District.
Subsection 2-26. Reasonable Expectations
As required by the TIF Act, in establishing the District, the determination has been made that the anticipated
development would not reasonably be expected to occur solely through private investment within the
reasonably foreseeable future. In making said determination, reliance has been placed upon written
representation made by the developer to such effects and upon EDA and City staff awareness of the feasibility
of developing the project site(s) within the District.
Subsection 2-27. Other Limitations on the Use of Tax Increment
General Limitations. All revenue derived from tax increment shall be used in accordance with the TIF
Plan. The revenues shall be used to finance, or otherwise pay the cost of redevelopment of the
Development District No. 1 pursuant to M.S., Sections 469.090 to 469.1082. Tax increments may not be
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17 2-14
used to circumvent existing levy limit law. No tax increment may be used for the acquisition,
construction, renovation, operation, or maintenance of a building to be used primarily and regularly for
conducting the business of a municipality, county, school district, or any other local unit of government
or the state or federal government. This provision does not prohibit the use of revenues derived from tax
increments for the construction or renovation of a parking structure.
2. Housing District Exceptions to Restriction on Pooling, Five Year Limit. Pursuant to M.S., Section
469.1763, (1) At least 80% of the tax increment derived from the District must be expended on Public
Costs incurred within said district, and up to 20% of said tax increments may be spent on public costs
incurred outside of the District but within Development District No. 1; provided that in the case of a
housing district, a housing project, as defined in M.S., Section 469.174, Subd. 11, is deemed to be an
activity in the District, even if the expenditure occurred after five years.
Subsection 2-28. Summary
The Cottage Grove Economic Development Authority is establishing the District to provide an impetus for
residential development and provide safe and decent life cycle housing in the City. The TIF Plan for the
District was prepared by Ehlers & Associates, Inc., 3060 Centre Pointe Drive, Roseville, Minnesota 55113-
1105, telephone (651) 697-8500.
Cottage Grove Economic Development Authority
Tax Increment Financing Plan for Tax Increment Financing District No. 1-17 2-15
Appendix A
Project Description
Dominium is proposing to construct a 184 -unit affordable senior apartment complex within the City. It is
anticipated that 100% of the units will be affordable to persons at or below 60% of the Area Median Income
(AMI). The project will be comprised of approximately 73 one -bedroom units, 79 two-bedroom units and
32 three-bedroom units. The project will include residential amenities including a clubroom with full kitchen,
attached outdoor patio, beauty salon, craft room, library, exercise room and underground parking.
Appendix A-1
Appendix B
Map of Development District No. 1 and the District
Appendix B-1
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Appendix C
Description of Property to be Included in the District
The District encompasses all property and adjacent rights-of-way and abutting roadways identified by the
parcels listed below.
Parcel Numbers
Address
Owner
07.027.21.44.0027
N/A
Southpoint Ridge LLC
07.027.21.44.0028
N/A
Southpoint Ridge LLC
08.027.21.33.0043
7007 East Point Douglas Rd S
Anchor Bank
Appendix
C-1
Appendix D
Estimated Cash Flow for the District
Appendix D-1
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Appendix E
Housing Qualifications for the District
INCOME RESTRICTIONS - ADJUSTED FOR FAMILY SIZE
(HOUSING DISTRICT) - WASHINGTON COUNTY
WASHINGTON COUNTY MEDIAN INCOME: $86,600
No. of Persons
50% of Median Income
60% of Median
Income
1 -person
$30,350
$36,420
2 -person
$34,650
$41,580
3 -person
$39,000
$46,800
4 -person
$43,300
$51,960
Source: Department of Housing and Urban Development and Minnesota
Housing Finance Agency
The two options for income limits on a standard housing district are 20% of the units at 50% of median
income or 40% of the units at 60% of median income. There are no rent restrictions for a housing district.
***PLEASE NOTE: THESE NUMBERS ARE ADJUSTED ANNUALLY. ALL INCOME FIGURES
REPORTED ON THIS PAGE ARE FOR 2015. UPDATED NUMBERS FOR THE YEAR 2016 ARE NOT
YET AVAILABLE.
Appendix E-1
Appendix F
Findings for the District
To be added prior to the public hearing
Appendix F-1